Privacy Shield Policy

This Privacy Shield Policy (“Policy”) describes how GROW Inc (“Grow”) in the United States (“US”) (“Company,” “we,” “our,” or “us”) collect, use, and disclose certain non-HR, personally identifiable information received from the European Economic Area (“EEA Personal Data”) and Switzerland (“CH PersonalData”) (collectively “EEA/CH Personal Data”).

Grow recognizes that the EEA and Switzerland have established strict protections regarding the handling of EEA/CH Personal Data, including requirements to provide adequate protection for EEA/CH Personal Data transferred outside of the EEA and Switzerland. To provide adequate protection for certain EEA/CH Personal Data about consumers/corporatecustomers/clients/suppliers/business partners transferred from the EEA andSwitzerland, and received in the US, Grow has elected to self-certify to theEU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the US Department of Commerce (collectively “Privacy Shield”).

Grow has certified to the Department ofCommerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/; our Privacy Shield certification can be viewed here. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. .  

For purposes of enforcing compliance with thePrivacy Shield, Grow is subject to the investigatory and enforcement authority of the US Federal Trade Commission.

Personal Data Collection and Use

Grow may collect the following categories ofEEA/CH Personal Data: information about customers, potential customers, prospects and partners like their first name, last name, email address, title, and phone number.  

We process EEA/CH Personal Data for the following purposes: provide requested services; send emails or other information or materials requested; understand needs and interests and tailor the Site and our services accordingly; respond to questions and comments and provide customer support; communicate about our services, offers, and promotions; operate, evaluate, and improve our business and the services we offer; enforce our Terms of Service and other agreements; and comply with applicable legal requirements and industry standards.

Grow only processes EEA/CH Personal Data in ways that are compatible with the purpose that we collected it for, or for purposes the individual later authorizes. Before we use your EEA/CH PersonalData for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Grow maintains reasonable procedures to help ensure that EEA/CHPersonal Data is reliable for its intended use, accurate, complete, and current.

Data Transfers to Third Parties

Third-Party Agents or Service Providers. We may transfer EEA/CH Personal Data to our third-party agents or service providers who perform functions on our behalf. Where required by the PrivacyShield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection thePrivacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process EEA/CH PersonalData in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of EEA/CH Personal Data that we transfer to them.

Disclosures for National Security or LawEnforcement. Under certain circumstances, we may be required to disclose your EEA/CH Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

Grow maintains reasonable and appropriate security measures to protect EEA/CH Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights

You may have the right to access the EEA/CHPersonal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield.These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EEA/CH Personal Data, you can submit a written request to privacy@grow.com. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.

Questions or Complaints

You can direct any questions or complaints about the use or disclosure of your EEA/CH Personal Data to us at privacy@grow.com[IS1] .

We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EEA/CH PersonalData within 45 days of receiving your complaint. If we have not been able to satisfactorily resolve the issue, GROW has further committed to cooperate with the International Centre for Dispute Resolution/ American ArbitrationAssociation (“ICDR/AAA”), which can be contacted here, and the Swiss Federal Data Protection and InformationCommissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland, respectively.

Binding Arbitration. You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with GROW and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the USDepartment of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department ofCommerce’s Privacy Shield Framework: Annex I (Binding Arbitration).