Last updated: September 12th, 2022
- About GoGrow GoGrow
- Personal Data we collect from you. When do we collect your Personal Information?
Register, or complete or submit information or forms on our website;
Download content on our website;
Provide us with feedback and information via phone, email, social media, etc.;
Answer a survey;
Subscribe to our newsletters or other content-related material;
Use Live Chat;
Use forums or leave comments on our website; or
Purchase or use GoGrow products and/or services;
During in-person meetings or at GoGrow’s events, conferences, workshops or gatherings;
Use Live Chat;
Identifiers and registration contact information: such as name, e-mail address, postal address, telephone number, account name, online identifier, Internet Protocol (IP) address, or other similar identifiers.
Customer records information: such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, bank account number, credit or debit card number, other financial information.
Characteristics of protected classifications under California or federal law: such as age, gender.
Commercial information: such as delivery information and records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies and transactions made with us.
Internet or other electronic network activity information: device information and device identifiers, browsing type and language, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement, and data connection and use, such as information you download.
Geolocation data: such as city, state, zip code, etc. related to your IP address.
Inferences on your preferences and characteristics.
- How do we use your Personal Data
To fulfill the purpose for which the Personal Information is provided;
To provide you with information, products and/or services that you request from GoGrow;
To communicate and respond to your requests and inquiries to GoGrow;
To operate our business and provide you with our products and services: engage in transactions with clients, and process orders from our services;
To follow up with our products and/or services after delivering them (live chat, email, or phone inquiries).
To provide consumers with e-mail alerts, event registrations, and other notices concerning GoGrow’s products and/or services, or events or news that might be of interest to the consumer;
To administer and improve the functionality of our Site and its technical and functional management and present its content to our clients or others;
To analyze, develop and improve the use and performance of our Site;
To modify, enhance, or improve our services and/or provision of such services to our clients;
As necessary and appropriate to protect the rights, property of GoGrow,
To carry out obligations and enforce our rights arising from any agreement entered between GoGrow and GoGrow’s clients or other contractual third-party, including billing and collections;
For testing, research, analysis, and product and services development;
To manage the security of our Site; To comply with applicable law and regulations to operate our business;
To comply with applicable law, court order, or governmental request;
To respond to law enforcement requests as required by applicable law, court order, or governmental regulations;
As described to the consumer when collecting the consumer’s Personal Information, or as otherwise as set forth by the CCPA.
To market our products and/or services and/or related products and services, and to tailor our marketing and sales activities to our clients’ interests.
Technical information including, but not limited to, browser type, operating system, device information, online identifiers including cookie data and Internet Protocol address (IP), domain name, referral URL, time zone setting, and/or time-stamp for your visit, information about your devices.
Usage information including, but not limited to, geographic location information (such as your country and/or state), date and time you visited our Site, numbers and frequency visitors to our Site, page views and search queries, clickstream behaviors, amongst others. Also, it may include details of your use of third-party applications in connection with our service.
Data brokers from which we purchase data to complement the data we collect;
Partners: (i) authentication partners: if you register or log in into our services using third party credentials (e.g. Facebook) we will import your information from such third-party source to help you create an account on our website; (ii) technical services partners that helps us without technology, and may provide us with certain data (e.g. such as mapping IP address to location data) to help us to provide our services, (iii) advertising partners, that provide us with services on our website (analytics, marketing, etc.) providing with inferences about your preferences and interests to offer you a better service and customized offerings, (iv) payment partners,if you choose to pay for a service and/or product, we may receive data from our them, to enable us to send you invoices, process your payment, (v) resellers, distributors, that deliver the product and/or service you have contracted, and therefore may supply us with data to help us provide improve our services, amongst others.
- Legal Basis for processing your Personal Data
Consent: where you have provided your consent for the processing of your Personal Data for a specific purpose.
Performance of a contract: where processing is necessary for the performance of a contract with you, or taking steps prior to entering a contract with you.
Legal obligation: where we have a legal obligation to process your Personal Data for example when responding to a public or governmental authority, courts, or regulators, according to a legal obligation under applicable law-.
Legitimate interest: to satisfy a legitimate interest, for example when it is not required by law but it clearly benefits you.
Understand and save your preferences for future visits.
Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
In your device: In your mobile device, your operating system (OS) offers options for avoiding personalized advertising -both in IOS and Android- to limit the use of information with the use of apps to generate advertisements based on your interests and tastes. Please be aware that advertisers and our partners may also use their own cookies and beacons, and we do not hold control of the information they collect. You will need to refer to their Privacy Policies. These third parties may use the information collected to serve more relevant advertisements. To configure your cookie controls and reject advertising cookies, follow the instructions on your device.
- Your Rights
Right of access: you have the right to be informed and request access to the Personal Data we have collected and process about you.
Right to rectification: you have the right to request the rectification of inaccurate Personal Data concerning you, which must be duly amended or updated without undue delay.
Right to erasure: you have the right to request we delete your Personal Data.
Right to restriction of processing: you have the right to request us to stop processing either all or some of your Personal Data, temporarily or permanently.
Right to data portability: you have the right to request a copy of your Personal Data in electronic format and the right to transmit your data to another controller.
Right to object: you have the right, at any time, to object to us processing your Personal Data on grounds relating to your particular situation, and the right to object to your Personal Data being processed for direct marketing purposes.
Right not to be subject to automated decision making: you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
The specific pieces of your Personal Information we collect or have collected.
The categories of Personal Information we have to collect or have collected about you;
The categories of sources from which we collect or have collected your Personal Information;
The categories of your Personal Information that we sell, or have sold, disclose, or have disclosed for a business purpose;
The categories of third parties to whom we sell or have sold, disclose, or have disclosed your Personal Information.
The business or commercial purpose for which we have to collect, sell, or have collected or sold your Personal Information;
GoGrow can be subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)
As an individual, under certain conditions, you can contact us to invoke binding arbitration.
GoGrow liability about information transfer to third parties is detailed here: Section 9
- How to exercise your Rights
- Sharing your Personal Data. Categories of third parties with whom we share your Personal Information.
Our affiliates: to provide our services and/or products;
Our service providers: that help us conduct our business and support infrastructure, payment processors when you purchase our products and/or services;
Vendors and Agents;
- Links to Third-Party Websites
- Data retention and deletion
- Keeping Your Personal Data Safe
- Data Breaches
- Sale of Personal Information/Right to Opt-out of the sale of your Personal Information
- Where do we store your Personal Information
- How to contact us
We may collect data, including your Personal Data, through our interactions with you, and when you:
Categories of Personal Information and Specific Pieces of Personal Information we collect from you.
We have collected within the last twelve (12) months, and may collect in the future the following categories of Personal Information listed below from consumers, for commercial and/or business purposes under the California Consumer Privacy Act of 2018 (“CCPA”):
Other information, such as any other information you choose to provide us directly in relation to the use of our services, surveys we send you, etc., customer information such as questions and other messages that you send us directly through online forms, chats, e-mail, phone, or post, summaries or voice recordings of your interactions with customer service.
Such business purposes may be:
Such commercial purposes (“Commercial Purposes”) may be:
4.1 Personal Data we collect automatically. Our website automatically collects certain data, through automatic data collection tools such as cookies, beacons, among others. These tools automatically collect the following information:
4.2 Sources of Personal Information. Personal Information we collect from third-parties We work closely with various third parties and may receive Personal Data from them. We protect the Personal Data obtained from them in accordance with the practices and policies described herein, plus any additional obligations imposed by the third-party source of your Personal Data. The third-party sources may vary due to context, but may include the following:
During the past 12 (twelve) months we have disclosed the categories of Personal Information about you listed above to our affiliates, group companies, and service providers for our business and commercial purposes. We have not, however, sold your Personal Information to third parties and shall not sell your Personal Information to third parties.
We rely on the following legal bases to collect and process your Personal Data under applicable EU data protection laws and regulations if you are a European Economic Area’s (EEA) resident:
- Strictly Necessary Cookies: are cookies that are fundamentally necessary for our website to work and allow you to use the functions of our services. Without this type of cookies, you couldn’t receive the requested services. In sum, these cookies enable services that you have specifically requested and allow you to use our services. E.g. logging in. We need these Cookies to provide you with our service.
- Performance Cookies: these cookies collect information about the use that visitors make of our services, such as the frequency of the visits and traffic, allowing us to improve the performance of our website. These cookies collect anonymous information about the visits on our webpages. They are used exclusively to improve the performance of our services.
- Functional Cookies: These Cookies allow our webpage to remember certain types of information, such as your username, language, etc. They provide functionality and personalization. This information is also anonymous. These cookies remember the options you have selected to improve your experience. These Cookies allow us to adapt our services based on the provided information.
- Targeting Cookies: may be set through our website to offer you relevant advertisements on other sites, based on your interests. These cookies collect information on your browsing habits with the purpose of adapting advertisement to your activities. In general, this information is shared with other advertisers and third parties. We may also use this information to record the number of times you have seen a particular ad and avoid showing you the same ads repeatedly.
Under current privacy laws and regulations, CCPA, the General Data Protection Regulation (GDPR), and the Privacy Shield Framework, you possess certain rights in relation to your Personal Data, as follows: Under the GDPR: If you are a resident from the European Economic Area (EEA) or the UK, you have the following rights regarding your Personal Data:
To make a verifiable consumer request for information about the Personal Information we have collected about you, please use our Contact Form or email us at email@example.com. B. RIGHT TO DELETE: You also have the right to request that we delete Personal Information, subject to certain exceptions according to applicable law. You may exercise your right by using our Contact Form (www.gogrow.dev/hire-talent) and typing in the message box “I want to permanently delete my data” or emailing us at firstname.lastname@example.org. C. RIGHT TO RECEIVE A COPY: You have the right to request a copy of the Personal Information we have collected about you. You may exercise your right by using our Contact Form (www.gogrow.dev/hire-talent) and typing in the message box “I want to receive a copy of my Personal Information” or emailing us at email@example.com. D. RIGHT TO NON-DISCRIMINATION: You have the right not to be discriminated against by us; namely, by is us denying you goods or services, charging you a different price or rate for our goods and services, amongst others, resulting form your exercise of any of your consumer rights under the CCPA. E. RIGHT TO OPT-OUT OF THE SALE OF YOUR PERSONAL INFORMATION: You have the right to opt-out of the sale of your Personal Information in accordance with Section 14 herein. Under the Privacy Shield Framework:
You might exercise any of your rights under the CCPA by submitting your request for information required to be disclosed and/or deleted by accessing our Contact Form at the following link (www.gogrow.dev/hire-talent), or by contacting us at the following e-mail address firstname.lastname@example.org: When receiving a verifiable consumer request, we will verify the person making a request to know or request to delete, is the consumer about whom we have collected the Personal Information. We will generally avoid requesting additional information for the consumer’s purpose of verification. However, if we cannot verify the identity of the consumer from the information already maintained by us, we may request certain additional information, that will be only used for the purposes of verifying the consumer’s identity. We will address your verifiable consumer request in an appropriate manner, according to provisions set forth on the CCPA. Provided you have a password-protected account with us, we may verify your identity, by authenticating you through that account. Requests made through authorized agents: Please note that under the CCPA, you also may designate in writing or through a power of attorney an authorized agent to make the request on your behalf, and exercise your privacy rights. Before accepting your agent’s request, we will take all steps necessary to verify you have duly authorized him to act on your behalf, for which they must provide us in writing a signed authorization or copy of a power of attorney.
Transfer of your Personal Data to other countries In some cases, our third-party service providers are located outside the EEA, meaning your Personal Information may be processed or stored in other countries. In certain circumstances, our service providers may be required to disclose information to government authorities, regulators, courts, or law enforcement in those countries. When your Personal Data is transferred internationally to third parties located in territories which may not offer an equivalent level of protection to privacy as that applicable within your country of residence (Personal Data collected within the European Economic Area (EEA), for example, may be transferred to be processed by third countries located outside the EEA), we ensure that the transfer of your Personal Data is carried out in accordance with applicable privacy laws and that appropriate technical and organizational security measures are taken. We will take all the necessary steps to verify that your Personal Data receives an adequate or substantially equal (where required by local law) level of protection. This, by entering into Data Transfer Agreements (“DTA’s”) pursuant to applicable law, such as the Model Clauses of EU Directive 87/2010, valid as set forth by Section 47 of the GDPR, or Corporate Binding Rules as an option to the referred DTA’s, when the international transfer of Personal Data is made amongst companies of the same economic group, to countries that do not count with an adequate level of protection in accordance to the terms of applicable law.
We will keep your Personal Data as long as necessary to fulfill the purposes described herein. Upon your request, we will delete your Personal Data, unless we are llegally permitted to or required to keep certain Personal Data, for example, to fulfill a legal obligation or to resolve a dispute, etc.
We are firmly committed to the security of your Personal Data. We will make our best efforts to protect your Personal Data, by implementing adequate technical, physical, administrative, and organizational measures, in order to guarantee the security of your information. We have implemented several measures such as (encryption, pseudonymization, amongst other measures to protect your information). However, please be advised that no system is ever a complete secured system, and you can decide not to use our products and/or services. We also encourage you to take all possible measures to secure your Personal Data by using a safe strong password, never sharing your password with others, logging out of the account, immediately after your session is done.
Despite our best efforts to secure your information if we suffer a data breach, we will do our best to reduce its effects and will follow the applicable notification provision of the CCPA and GDPR and any other applicable laws.
The CCPA gives California residents the right to opt-out from the sale of Personal Information. We do not sell information that directly identifies you. We do not exchange information about you to third parties in exchange for money or other consideration. We share information with third parties who work with us, as explained in previous sections, for the purposes described herein. However, due to the broad definition of “sale” of Personal Information under CCPA, including the provision of Personal Information to another business or third party for monetary and other valuable consideration, shall you prefer for us not to sell your Personal Information, please contact us to the following email@example.com in order to opt-out of the future sale of your Personal Information.
We protect our children. Our services are not directed to children under the age of 13 years, or from ages from 13 to 16, or equivalent minimum age in the relevant jurisdiction. If you are under the age limit of 13 years, or from 13 to 16 years old, please do not use our services and do not provide us with any Personal Data or information. We will not collect, process nor sell the Personal Information of users under 13 years of age, or from 13 to 16 years, if we have actual knowledge that the user is less than those years of age.
Your Personal Data will be stored in GoGrow’s databases.
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