Privacy Policy


IN GENERAL


We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are, how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.


We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as a “data processor” of that personal information for the purposes of those laws, unless you are a GrowSurf User, in which case you are our direct customer, and we have responsibility as a "Controller" of your data. 


Our users are "controllers" for the purposes of those laws if you are a GrowSurf participant, referred to our site and/or applications by them, and may have separate legal responsibilities to you with respect to your data. Our subprocessors are "data processors" for the purpose of use of your data, and GrowSurf is the "controller" of such data, except to the extent that GrowSurf users otherwise specify data use and retention. 


WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?


In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites. 


The Sites may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites. You should review the policies of such third parties and contact them directly to respond to your questions.


KEY TERMS


It would be helpful to start by explaining some key terms used in this policy:


We, us, our:

GrowSurf, Inc., located at 2035 Sunset Lake Road, Ste B2, Newark, DE 19702


Our representative:

Email contact for data system protection and privacy policy questions: legal@growsurf.com or by post to:

GrowSurf, Inc

1900 E. Golf Rd.

Ste 950A

Schaumburg, IL 60173


Our data protection officer:

Kevin Yun, GrowSurf


Personal Information:

Any information relating to an identified or identifiable individual


PERSONAL INFORMATION WE COLLECT ABOUT USERS AND PARTICIPANTS


We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:


GrowSurf Users:

  • First name
  • Last name
  • Email address
  • Company name
  • IP address
  • Password (hashed)
  • Tracking activity:
  • Google Analytics: Pageviews and behavior
  • Heap Analytics: Pageviews and behavior
  • DataDog: Error reporting and logging
  • Sentry.io: Error reporting and logging
  • HubSpot: Pageviews and form submissions
  • Mailerlite: Form submissions
  • SendGrid: Email open and click-tracking
  • Postmark: Email open and click-tracking
  • GrowSurf: Referral tracking and activity
  • Rewardful: Affiliate tracking and activity


GrowSurf Participants:

  • Browser fingerprint
  • IP address
  • Referrer URL (e.g, https://customersite.com?grsf=abc123)
  • Referral Source (Direct, Referral, Import)
  • First name
  • Last name
  • Email address
  • Metadata (any custom data)
  • GDPR opt-in approval
  • Tracking activity:
  • Sharing activity (clicking share on Twitter, Email, etc)
  • Impressions count (how many times referral link was viewed)
  • Referral count (how many people signed up using their referral link)
  • Email activity (opens and click-tracking)


This personal information is required to provide products AND/OR services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.


WE DO NOT COLLECT BIOMETRIC INFORMATION


The laws of the state of Illinois provide for protection of biometric information. The Biometric Information Privacy Act (BIPA) was passed by the Illinois General Assembly on October 3, 2008. Codified as 740 ILCS 14/1 ff. and Public Act 095-99. The BIPA guards against the unlawful collection and storing of biometric information. When Illinois passed the law in 2008, it became the first state to regulate the collection of biometric information. Washington and Texas have since passed similar laws. The Illinois law regulates collection, retention, and use of the following types of information: "Biometric identifier" means a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. GrowSurf does not collect or process or store any of these types of information, and does not provide data processing services for those types of information if collected by their users.


HOW YOUR PERSONAL INFORMATION IS COLLECTED


We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps. However, we may also collect information:


  • From publicly accessible sources (e.g., property records);
  • Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
  • From a third party with your consent (e.g., your bank);
  • From cookies on our website; and
  • Via our IT systems, including:
  • Door entry systems and reception logs at our physical locations, for users and possibly for others, including at times participants and vendors;
  • Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems


DO WE USE GOOGLE MAPS?


In Short: Yes, we may use Google Maps for the purpose of providing better service.

Our and our customer's websites, mobile applications, or Facebook applications may use Google Maps APIs. You may find the Google Maps APIs Terms of Service here. To better understand Google’s Privacy Policy, please refer to this link


By using our or our customer's Maps API Implementation, you agree to be bound by Google’s Terms of Service. By using our implementation of the Google Maps APIs, you agree to allow us to gain access to information about you including personally identifiable information (such as usernames) and non-personally identifiable information (such as location). 


The Maps APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Union, note that we require our customers to get your permission to use your data and to allow us to process same and to notify you in case of data breach in accordance with the data privacy regulations of the EU and of its member countries, as applicable. 


HOW WE HANDLE YOUR SOCIAL LOGINS:


In Short: If you choose to register or log in to our or our customer's websites using a social media account, we may have access to certain information about you.


Our or our customer's Sites offers you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we and our customers will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.


We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Sites. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.


HOW AND WHY WE USE YOUR PERSONAL INFORMATION. 


Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.,:


To comply with our legal and regulatory obligations;


For the performance of our contract with you or to take steps at your request before entering into a contract;


For our legitimate interests or those of a third party; or


Where you have given consent.


A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.


The table below explains what we use (process) your personal information for and our reasons for doing so:


What we use your personal information for (Our reasons)

  • To provide products and/or services to you
  • Reason: For the performance of our contract with you or to take steps at your request or that of our users before entering into a contract or as a user on our site or as a person who our site users contact through our site or otherwise and collect data from.
  • To prevent and detect fraud against you or our customers.
  • Reason: For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
  • Conducting checks to identify our customers and verify their identity. Screening for financial and other sanctions or embargoes. Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by any regulator with jurisdiction over us or our customers.
  • Reason: To comply with our legal and regulatory obligations
  • Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies
  • Reason: To comply with our legal and regulatory obligations
  • Ensuring business policies are adhered to, e.g. policies covering security and internet use
  • Reason: For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
  • Operational reasons, such as improving efficiency, training and quality control
  • Reason: For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
  • Ensuring the confidentiality of commercially sensitive information
  • Reason: For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations
  • Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures
  • Reason: For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
  • Preventing unauthorized access and modifications to systems
  • Reason: For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you. To comply with our legal and regulatory obligations.
  • Updating and enhancing customer records
  • Reason: For the performance of our contract with you or our users or vendors or to take steps at your request before entering into a contract, or to assist your use of your customer's data To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products
  • Statutory returns
  • Reason: To comply with our legal and regulatory obligations
  • Ensuring safe working practices, staff administration and assessments
  • Reason: To comply with our legal and regulatory obligations. For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
  • Marketing our services and those of selected third parties to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.
  • Reason: For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
  • Credit reference checks via external credit reference agencies
  • Reason: For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services
  • External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts
  • Reason: For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards. To comply with our legal and regulatory obligations


PROMOTIONAL COMMUNICATIONS 


We may use your personal information to send you updates (by email, text message, telephone or post) about our products and/or services, including exclusive offers, promotions or new products and/or services.


We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.


We will always treat your personal information with the utmost respect.


HOW LONG DO WE KEEP YOUR INFORMATION? 


In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law. 


We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:


To respond to any questions, complaints or claims made by you or on your behalf;


To show that we treated you fairly; or


To keep records required by law.


When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.


HOW DO WE KEEP YOUR INFORMATION SAFE? 


In Short: We aim to protect your personal information through a system of organizational and technical security measures.


We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment. 


DO WE COLLECT INFORMATION FROM MINORS? 


In Short: We do not knowingly collect data from or market to children under 18 years of age. 

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at legal@growsurf.com.


ACCESS AND DELETION (UNSUBSCRIBE) REQUESTS


Account Information:


You may at any time review or change the information in your account with us or our customer or terminate your account by:


Logging into your account settings and updating your account


Contacting us or our customer using the contact information provided below. If you are a GrowSurf participant, please direct any requests for access or deletion of your Personal Data to our Customers with whom you have a direct relationship.


Upon your request to terminate your account, we or our customer will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.


Cookies and similar technologies:


Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites.


Opting out of email marketing:


You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. You can also opt-out by: 


Noting your preferences at the time you register your account with the Sites.


Logging into your account settings and updating your preferences.


Contacting us using the contact information provided below.


IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY? 


In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in the states of California, Oregon, and Illinois, United States of America, unless our customer agreements specify otherwise. If you are accessing our Sites from outside those states, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information, in the United States of America and other countries where our customers and their site hosting and data processing services are located. 


If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law. 


Our customers are responsible for the processing of personal information they receive on their Sites or through their Apps, under the EU-US Privacy Shield Framework, and subsequently transfer to a third party acting as an agent and data processor on our customer's behalf. 


With respect to personal information received or transferred pursuant to the US-EU Privacy Shield Framework, GrowSurf, Inc. is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


WHO WE SHARE YOUR PERSONAL INFORMATION WITH


We routinely share personal information with third parties, including:


Our affiliates and vendors, including legal, accounting, and other general service providers

Service providers we use to help deliver our products and/or services to you, such as payment service providers, other subprocessors, and, if needed for customers who use our services for participants for services involving physical products, warehouses and delivery companies;


Other third parties we use to help us run our business, such as marketing agencies or website hosts;


Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;


Credit reporting agencies;


Our insurers and brokers;


Our bank(s);


We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO or Investors in People accreditation and the audit of our accounts.


We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.


We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.


PERSONAL INFORMATION WE SOLD OR DISCLOSED FOR A BUSINESS PURPOSE


As a general matter, we share a minimum of information needed on GrowSurf users or participants. We may, however, use such data for commercial purposes, particularly for communications for and analysis of data for our users. When participant data is shared with paying users, this is a "sale" of data.


Within this general policy of minimal disclosure, we have made some disclosures and commercial uses of data, possibly including the following specific items. 


In the preceding 12 months, we may have transferred or sold to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:


Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);


Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;


WHERE YOUR PERSONAL INFORMATION IS HELD 


Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above.


WHAT ARE YOUR PRIVACY RIGHTS?


In Short: In some regions, such as the European Economic Area, or individual states like California (for privacy matters) or Illinois (for biometric information), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. 


Types of Information Which May Be Protected:


Characteristics of protected classifications under California or federal law:


  • Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
  • Biometric information;
  • Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
  • Geolocation data;
  • Audio, electronic, visual, thermal, olfactory, or similar information;
  • Professional or employment-related information;
  • Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and
  • Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.


Possible Disclosures:


In the preceding 12 months, we may have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:


  • Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
  • Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;


EUROPEAN UNION GENERAL DATA PROTECTION REGULATIONS (GDPR)


In some world regions (like the European Economic Area), you have certain rights under applicable data protection laws. In the EU, these national and EU wide regulations are referred to as the GDPR. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws. 


If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.


If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm]


YOUR RIGHTS UNDER THE GDPR


  • Right to Access - The right to be provided with a copy of your personal information (the right of access)
  • Right to Rectification - The right to require us to correct any mistakes in your personal information
  • Right to be Forgotten - The right to require us to delete your personal information—in certain situations
  • Right to Restriction of Processing - The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
  • Right to Data Portability - The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
  • Right to Object - The right to object:
  • at any time to your personal information being processed for direct marketing (including profiling);
  • in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
  • Right Not to be Subject to Automated Individual Decision-Making - The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you


For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.


DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 


In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.


California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.


If you are under 18 years of age, reside in California, and have a registered account with the Sites or Apps, you have the right to request removal of unwanted data that you publicly post on the Sites or Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites or Apps, but please be aware that the data may not be completely or comprehensively removed from our or our customer's systems.


Disclosure of Personal Information We Collect About You


You have the right to know:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information, if any; and
  • The specific pieces of personal information we have collected about you.
  • Please note that we are not required to:
  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.
  • Personal Information Sold or Used for a Business Purpose
  • In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:
  • The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and
  • The categories of personal information that we disclosed about you for a business purpose.
  • You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale [or disclosure] of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. NOTE THAT YOUR CONSENT TO OUR TERMS OF SERVICE IS EXPLICIT AGREEMENT TO OUR USE OF YOUR DATA CONSISTENT WITH THIS PRIVACY POLICY.
  • To opt-out of the sale or disclosure of your personal information, please review the Opt-Out procedures listed above in an earlier section of this privacy policy, and use same as needed. 
  • Right to Deletion
  • Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.
  • Please note that we may not delete your personal information if it is necessary to:
  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
  • Protection Against Discrimination
  • You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
  • Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.


WE HAVE POLICIES AND PROCEDURES IN PLACE TO KEEP YOUR PERSONAL INFORMATION SECURE


We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.


DO WE MAKE UPDATES TO THIS POLICY?


In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.


HOW TO CONTACT US


If you have questions or comments about this policy, or want to make requests to us in connection with your privacy rights, email us at legal@growsurf.com or send requests or other contacts by mail or other physical delivery service to:


GrowSurf, Inc

1900 E. Golf Rd.

Ste 950A

Schaumburg, IL 60173

Last updated: March 27, 2020