This Privacy Policy (“Policy“) describes how Grow Wireless Inc. (“Grow Wireless”) collects and treats your personal information when you access and use products and services provided by Grow Wireless and its licensors (collectively the “Products”) using your mobile device or other electronic device (collectively a “Device”) or when you provide information to us via the Grow Wireless website located at http://growwireless.com.
By using our Products or by providing information to Grow Wireless through our website, you agree that you have read and agree with this Policy, together with any Grow Wireless Terms of Use” which are applicable to such Products (the “Terms of Use”) and moreover, you expressly consent to the collection and use of your personal information as described in this Policy and any amendments made to it by Grow Wireless from time to time as posted on our website.
Collection and Use of Personal Information
Privacy laws typically define personal information as information about an “identifiable individual”, such as name, age, home address and phone number (collectively described herein as the “personal data”).
Grow Wireless is committed to protecting your privacy and therefore collects and uses personal data which you provide to us solely in accordance with this Policy.
Accordingly, this Policy applies when you submit personal data: (1) as part of a registration process required to use our Products; (2) in the course of inquiring about our products and services or about Grow Wireless through our website; or (3) by logging onto our website in order to use our Products. Personal data may also be automatically collected from your Device when you access and use any of our Products.
Some examples of how we might collect and use your personal data include, but are not limited to, the following situations:
- When you launch an application related to one of our Products for the first time, you may be asked for personal data such as your phone number or your e-mail address in order to create a username and password for your account. This personal data is only used to generate your unique account identification for the Product, to allow for the retrieval and resetting of passwords for your account or to send you notices, updates or changes to our Products from time to time.
- We may also ask for your name in certain circumstances in order to provide you with technical assistance, for directed messaging, prize redemptions (depending on the nature of the Product) and for better understanding your needs and providing you with services that are valuable to you.
- Certain of our Products may automatically capture the make and model and your Device’s unique identifier as a required function of the product application and we use this information solely for the purpose of delivering the particular product or service to you.
- Certain applications for our Products may also automatically track and record a limited amount of location-based data from your Device which may be a required part of the functionality of a particular Product in order to tag and track user scores, but we will not use this data for any other purpose than to enable you to use the Product or store it longer than is reasonably necessary for us to provide the applicable product or service to you.
- You may voluntarily supply us with personal data when you make inquiries through our website. Revealing personal data in this fashion is voluntary and you have a choice about whether or not to disclose this personal data to Grow Wireless.
You have the option to “opt-out” of providing Grow Wireless with your e-mail address or phone number in these circumstances, but by doing so, you may experience reduced functionality for the Product and you will not be able to reset your password in the event that you forget it in the future.
Grow Wireless will never contact you directly by telephone, either by making a voice call to you, or by sending you an SMS text message, unless there is an urgent support matter to resolve or you have specifically requested that we telephone you. We also reserve the right to use SMS to notify you of any prizes you are entitled to collect from Grow Wireless.
Once Grow Wireless collects your personal data, it gets transmitted via the internet to a dedicated and secure server environment, which may be located outside of Canada and/or the United States, where it is managed, hosted and/or processed by Grow Wireless or its third party service providers (who may be located in the United States or other countries outside of Canada) in accordance with this Policy for the purposes of enabling your use of our Products as well as providing you with administrative notifications, forwarding software updates or responding to your inquiries.
Grow Wireless may also aggregate the personal data it collects on a non-personally identifiable basis in order to analyze our customer’s use patterns or other statistically relevant information. We reserve the right to use this anonymous aggregated data with advertisers and business partners and also for Grow Wireless to develop product enhancements that improve your user experience. However, no personal data which is specific to you is ever made available to these third parties, only the statistical data we compile that is not associated with any particular individual.
Your personal data is never viewed, analyzed or used by Grow Wireless for any other purpose or shared with any third party, except as specifically described in this Policy. Some of our Products may require the display of your username, which may be made visible to other users of our Products as part of their functionality; however, your personal data is never made visible to any other parties who use our Products.
Disclosure to Third Parties, Data Transfer, Security and Retention
Transmission of Data
Our Products use industry-standard encryption techniques with both wireless and connected communications. Any personal data being sent from your Device to the Grow Wireless server is as secure as any voice calling, text messaging or web-browsing activities in which you engage using your Device.
Due to the nature of the internet, and the fact that applications like our Products are managed on a global basis with system redundancies and failover built into them, your personal data may be transferred and maintained in a location outside your particular state, province, country or other jurisdiction where the privacy laws may not be as protective.
By using our Products, you expressly agree and acknowledge that your personal data may be transferred outside your country of residence and that it may be processed and stored in that location, which may include locations outside either Canada or the United States. You should also be aware that data protection laws vary from jurisdiction to jurisdiction, and that while Grow Wireless is committed to taking reasonable steps to protect your privacy, certain jurisdictions are less protective of personal data than others and certain jurisdictions may have laws which override the privacy laws of Canada.
Personal Data Provided to Third Party Retailers
As you will have accessed any one of our Products via a third party retail distribution outlet, store or online store front (“Distributor”), this Policy does not apply to any information that you submit during that sign-up and subscription process. You will need to refer to the privacy policies of your Distributor to find out about their practices regarding the collection, storage and use of any personal information that you submit during the sign-up and subscription process. Grow Wireless is not responsible for the privacy practices of any third party.
Personal Data Provided to Grow Wireless Licensors
Grow Wireless provides certain of our Products and associated services on behalf of our third party licensors and third party strategic industry collaborators. As part of these relationships, Grow Wireless may provide your personal data to such third parties for the purposes of providing product support and for improving the quality and features of the Products and otherwise for purposes that are consistent with this Policy.
Third Party Service Providers
Grow Wireless may also retain the services of third party service providers to perform certain functions or store personal data on Grow Wireless’s behalf. These third party service providers may be located outside of Canada, including service providers in the United States and possibly other countries as well. These third party service providers are only provided with access to your personal data on a “need-to-know basis” as required to perform the services on behalf of Grow Wireless and otherwise in accordance with this Policy.
Legal Proceedings
Grow Wireless may also be required to share your personal data as necessary to respond to court orders or other legal processes or to establish Grow Wireless’s legal rights, defend against legal claims, or as otherwise required to comply with applicable laws and regulations.
We believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Grow Wireless Terms of Use, or as otherwise required by law or legal proceedings.
Support and Subscription Services
In order to continue to provide you with our Products, Grow Wireless and the Distributor may need to share certain information that identifies you solely for the purposes of maintaining your subscription and service account, including your name, e-mail address, mobile telephone number, and some unique identifier generated by either Grow Wireless or the Distributor.
In order to provide you with such support, and depending on how that support is provided, Grow Wireless and the Distributor may be required to provide each other with a minimal amount of your personal information as is necessary to register and respond to your support query.
Security of Personal Information
We have security policies and practices in place for the management, storage, processing and purging of your personal data. Grow Wireless has also implemented reasonable security measures, such as encryption technology, to help reasonably protect against the risk of loss, misuse and alteration of any information under Grow Wireless’s control.
Storage and Retention
Your personal information will not be stored for longer than is reasonably necessary for the purposes described in this Policy or to otherwise meet legal requirements.
“Opting out/Opting in”
Before you first start using any of our Products, you are required to accept the terms of this Policy and the Terms of Use. If you change your mind and decide that you want to discontinue using the Products, you can de-register or uninstall the software from your Device and you must notify Grow Wireless in writing that you wish to deactivate your subscription, at which point all of your registration information will removed from the Grow Wireless systems within a reasonable period of time following your request.
Access to your Personal Information
If you have any questions about the collection, use or disclosure of your personal information by Grow Wireless, or, if you simply want to know whether Grow Wireless has any of your personal information on file, you may contact us via the Grow Wireless website http://growwireless.com and we will put you in touch with our compliance officer.
Except in limited circumstances, as specifically set out in applicable privacy legislation, Grow Wireless can tell you what personal information has been collected and stored, allow you access to your personal information, and account for the use that has been made or is being made of the information and the third parties to whom it has been disclosed.
The Grow Wireless Website
Grow Wireless’s website is purely to provide you with access to information about our products and our organization. If you choose to contact Grow Wireless via the Grow Wireless website, you may be requested to provide personal information in order for us to respond to your inquiry. Once again, our policies that apply with respect to the personal data collected for any of our Products also apply to any personal information that you provide to us via our website.
Grow Wireless is not responsible for the practices of any third party website that may be linked to our website. If you visit a third party website via a link from Grow Wireless’s website, you will need to refer to the privacy policies of the third party website provider.
On our website, you may be given the option to subscribe to our newsletters and other communications regarding new products and services. If at any time you choose not to receive these communications, you can unsubscribe for them as directed on the applicable webpage or e-mail communication.
When you access our website or certain of our Products, Grow Wireless reserves the right to use “cookies” technology in the form of a small amount of data, which often includes an anonymous unique identifier that is sent to your internet browser from a web site’s computers and stored on your Device. This technology may be disabled using the auto logon feature on your Device.
We may use cookies for the following purposes:
- Accessing your information submitted during the sign-in process so we can provide you with customized content or remembering the last page you visited on our website or when using your Device.
- Keeping track of the preferences you specify while you are using Grow Wireless products or services;
- Delivering advertisements relevant to your interests when you visit our network of partner websites using a cookie that gathers anonymous information based on visits to those sites.
E-mail Communications from Grow Wireless
When we send e-mails to you at the e-mail account which you have the option to designate during the registration process, we use industry-standard techniques such as requesting delivery receipts and read receipts, and within those e-mails you have the option of downloading and viewing the images which are stored on a server and the option of clicking hypertext links to access further information on the internet. You should be aware that these techniques, which are used within almost all marketing e-mails that you receive from service providers, such as airlines, loyalty cards, newsletters and retailers, provide us with information about your e-mail viewing habits. Grow Wireless only uses this information in order to provide our Products to you, and does not share it with any third party.
Changes to our Policy
Grow Wireless may modify this Policy at any time by updating and posting an amended Policy in place of the old one. Grow Wireless will place the amendments on a prominent place on our website. In addition Grow Wireless will reasonably endeavour to notify all existing subscribers of our Products by sending an e-mail notification to the subscriber’s registered e-mail address. The amended Policy will automatically be effective upon posting on our website. Your continued use of the applicable Products, following the posting of the amended Policy, shall mean that you accept the terms of the Policy, as amended. If you do not agree with any of the terms in the amended document, then your sole remedy is to discontinue your use of such Products.
More information
If you have any questions about the laws respecting the collection, use of disclosure of personal information, we recommend that you contact your local privacy compliance officer.