This website www.flowle.com (hereinafter, “Site”)is owned and operated by Growithy AG, with its registered address at Tödistrasse 16, 8002 - Zurich) (hereinafter, “ Growithy “, “we”, “our”, and “us”).

At Growithy, we are committed to respecting your privacy.

This Privacy Policy explains how we collect, use and disclose personal information that we receive when you visit the Site and use our service “Flowle – Culture Data” hereinafter, “service”), or communicate with us offline as a business customer, prospective customer or general contact. This Privacy Policy applies to Growithy and covers our processing activities as a data controller.

We also process personal information as a data processor on behalf of our customers (please see “Growithy as Data Processor” below).

The Site is not intended for or directed at children under the age of 18 years, and we do not knowingly collect information relating to children under this age.

We are not required to appoint a formal data protection officer under data protection laws. However, we have appointed a Data Protection Contact who you can reach out to about any queries you may have in relation to this Privacy Policy. You can contact us about any data protection queries, using the contact details below.

CONTACTING US

If you have any questions about our Privacy Policy or your information, or to exercise any of your rights as described in this Privacy Policy or under data protection laws, you can contact us as follows:

by post: Growithy AG, with its registered address at Tödistrasse 16, 8002 - Zurich
by email: contact@growithy.com

DATA PROTECTION PRINCIPLES

Growithy adheres to the following principles when processing your personal information as data controller:

1. Lawfulness, fairness and transparency – data must be processed lawfully, fairly and in a transparent manner.

2. Purpose limitation – data must be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

3. Data minimization – data must be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed.

4. Accuracy – data must be accurate and, where necessary, kept up to date.

5. Storage limitation – data must be kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal information is processed.

6. Integrity and confidentiality – data must be processed in a manner that ensures appropriate security of the personal information, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage by using appropriate technical or organizational measures.

PERSONAL INFORMATION WE COLLECT

Information you give us

You may provide us with information about you browsing the Sites or by corresponding with us, by email or phone. This includes information you provide when you:

· request additional information about our service or ask us to contact you

· try the demo version of our service

. log in to access and use the service

The categories of personal information you provide may include:

· first and last name

· job title and company name

· email address

· phone number

. account details

· any other identifier that permits Growithy to make contact with you.

We do not generally seek to collect sensitive personal information through our Site. Sensitive personal information is information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; health or sex life, sexual orientation; genetic or biometric information. If we do collect sensitive personal information, we will ask for your explicit consent to our proposed use of that information at the time of collection.

Information we collect from you

Growithy collects, stores and uses information about your visits to the Site and about your computer, tablet, mobile or other device through which you access the Site. This includes the following information: technical information, including the Internet protocol (IP) address, browser type, internet service provider, device identifier, time zone setting, browser plug-in types and versions, operating system and platform, and geographical location; information about your visit and use of the Site, including the full Uniform Resource Locators (URL), clickstream to, through and from our Site, pages you viewed and searched for, page response times, length of visits to certain pages, referral source/exit pages, page interaction information (such as scrolling, clicks and mouse-overs),and Website navigation.

GROWITHY AS DATA PROCESSOR

We collect and process personal information on behalf of our customers in the provision of our service. In these circumstances, Growithy is acting as a data processor; our customers remain the data controllers in respect of personal information they provide to us. To the extent that we are acting as data processor, we will process such personal information in accordance with our customer’s instructions and any agreement in place with our customers. We will only use such personal information for the purposes of providing the service for which our customers have engaged us.

The customers of Growithy are responsible for ensuring that individual privacy is respected, including communicating to the individuals in their own privacy policies who their personal information is being shared with and processed by.

As a data processor, Growithy may share personal information when instructed by the customer (the data controller). Where authorized by the customer, personal information may also be shared with third party service providers who work for Growithy and who are subject to security and confidentiality obligations.

Where Growithy is acting as a data processor, any request from an individual for access to personal information held about them will be referred to the customer. Growithy will not respond directly to the request.

Growithy will retain personal information processed on behalf of customers only for as long as needed to provide services to the customer and in accordance with any agreements in place with the customer.