Privacy Policy
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.
WHAT WE DO WITH YOUR PERSONAL DATA
As a data controller, Growithy will only use your personal information where there is a legal basis to do so. The purpose for which we use and process your information and the legal basis on which we carry out each type of processing is explained in the table below.
Purposes for which we will process the information | Legal Basis for the processing |
To provide you with information and materials that you request from us. | It is in our legitimate interests to respond to your queries and provide any information and materials requested in order to generate and develop business. To ensure we offer an efficient service, we consider this use to be proportionate and will not be prejudicial or detrimental to you. |
To update you on service and benefits we offer. | It is in our legitimate interests to market our service. We consider this use to be proportionate and will not be prejudicial or detrimental to you. If you would prefer not to receive any direct marketing communications from us, you can opt-out at any time by contacting us as providing in “Contacting Us” above. For direct marketing sent by email to new contacts (i.e. individuals who we have not previously engaged with), we need your consent to send you unsolicited direct marketing. |
To personalize our service and the Site to you. | It is in our legitimate interests to enhance your experience on our Sites and to better our services. We consider this use to be proportionate and will not be prejudicial or detrimental to you. If you do not wish to receive tailored or personalized information from us based on personal information you have provided us, please contact us as provided in “ContactingUs” above. |
To send you information regarding changes to our policies, our terms and conditions and other administrative information. | It is in our legitimate interests to ensure that any changes to our policies and other terms are communicated to you. We consider this use to be necessary in your and our legitimate interests and not to be prejudicial or detrimental to you. |
· To administer our Site including troubleshooting, data analysis, testing, research, statistical and survey purposes; · To improve our Site to ensure that consent is presented in the most effective manner for you and your computer, mobile device or other item of hardware through which you access the Site; and · To keep our Site safe and secure. | For all these categories, it is in our legitimate interests to continually monitor and improve our services and your experience of the Sites and to ensure network security. We consider this use to be necessary for our legitimate interests and will not be prejudicial or detrimental to you. |
Growithy will only use your personal information for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you in a timely manner and we will explain the legal basis which allows us to do so.
DISCLOSURE OF YOUR PERSONAL DATA TO THIRD PARTIES
Growithy will not sell, rent, lease or otherwise share your personal information other than as outlined in this Privacy Policy or without obtaining your consent beforehand.
Personal information will be shared with our third parties service providers who assist with the running of the Site and our services including hosting providers. Our third parties service providers are subject to security and confidentiality obligations and are only permitted to process your personal information for specified purposes and in accordance with our instructions.
Personal information will be shared also with subjects authorized by Growithy to process the personal data necessary for carrying out activities strictly connected to the provision of service and who have assumed an appropriate legal and contractual obligation of confidentiality (e.g. employees and / or collaborators of Growithy).
In addition, we may disclose information about you:
· if we are under a duty to disclose or share your personal information in order to comply with any legal or regulatory obligation;
· if necessary to protect the vital interests of a person; and
· to enforce or apply our terms and conditions or to establish, exercise or defend the rights of Growithy, our staff, customers or others.
STORING OF YOUR PERSONAL INFORMATION
Your personal information will not be stored or transferred outside UE or to countries that do not provide adequate levels of personal protection.
In the event this is necessary to provide you with services, Growithy assures you that the transfer of your personal data outside UE or to countries that do not provide an adequate level of protection shall be performed only prior to the signing of specific contracts between Growithy and said parties in accordance with the applicable law and regulations.
SECURITY OF YOUR PERSONAL DATA
Growithy use appropriate technical and organizational security measures to protect personal information both online and offline from unauthorized use, loss, alteration or destruction. We use industry-standard physical and procedural security measures to protect information from the point of collection to the point of destruction. This includes access controls to our systems, policies and other procedures to protect information from unauthorized access.
Only authorized personnel and third parties service providers are permitted access to personal information, and such access is limited by need. Where data processing is carried out on our behalf by a third party, we take steps to ensure that appropriate security measures are in place to prevent unauthorized disclosure of personal information.
Despite these precautions, however, Growithy cannot guarantee the security of information transmitted over the Internet or that unauthorized persons will not obtain access to personal information. In the event of a data breach, Growithy has put in place procedures to deal with any suspected breach and will notify you and any applicable regulator of a breach where required to do so.
HOW LONG WE KEEP YOUR PERSONAL DATA
Your personal information will not be kept for longer than is necessary for the purposes for which it was collected and processed.
Growithy will retain your personal data only for as long as is necessary for the purposes set out in this privacy policy, in compliance with the storage limitation principle, article 6 of LPD and article 5 of GDPR.
YOUR RIGHTS
ACCESS TO AND UPDATING YOUR PERSONAL DATA
You have the right to access information which we hold about you (“data subject access request”).
You may also have the right to receive personal information which you have provided to us in a structured and commonly used format so that it can be transferred to another data controller (“data portability”). The right to data portability only applies where your personal data is processed by us with your consent or for the performance of a contract and when processing is carried out by automated means.
We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. Please keep us informed if your personal information changes during your relationship with us.
RIGHT TO OBJECT
Direct marketing
You have the right to object at any time to our processing of your personal information for direct marketing purposes.
Where we process your information based on our legitimate interests :
You also have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information which is based on our legitimate interests. Where you object on this ground, we shall no longer process your personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.
YOUR OTHER RIGHTS
You also have the following rights under data protection laws to request that we rectify your personal information which is inaccurate or incomplete.
In certain circumstances, you have the right to:
· request the erasure of your personal information (“right to be forgotten”);
· restrict the processing of your personal information in certain circumstances.
Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.
For example, we may refuse a request for erasure of personal information where the processing is necessary to comply with a legal obligation or necessary for the establishment, exercise or defense of legal claims. We may refuse to comply with a request for restriction if the request is manifestly unfounded or excessive.
EXERCISING YOUR RIGHTS
You can exercise any of your rights as described in this Privacy Policy and under data protection laws by contacting us as provided in “Contacting Us” above.
Save as described in this Privacy Policy or provided under data protection laws, there is no charge for the exercise of your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either: (a) charge a reasonable fee taking into account the administrative costs of providing the information or taking the action requested; or (b) refuse to act on the request.
Where we have reasonable doubts concerning the identity of the person making the request, we may request additional information necessary to confirm your identity.
LINKS
The Site may contain links to and from the websites of social media and advertisers. If you follow a link to any of these websites, please note that these websites have their own privacy policies and Growithy does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
COMPLAINTS
If you have any questions or complaints regarding our Privacy Policy or practices, please contact us as provided in “Contacting Us” above.
- If you are in located in the EEA, you also have the right to complain to the relevant supervisory authority in the EEA. In Switzerland this is the Federal Data Protection and Information Commissioner (www.edoeb.admin.ch).
CHANGES TO OUR PRIVACY POLICY
Growithy reserves the right to change this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date.
If we make any material changes to this Privacy Policy, we will notify you by means of a prominent notice on the Site prior to the change becoming effective.
Updated and Effective as of 27.10.2021