WHO ARE WE?
Growme is a registered trademark owned by SUPERB EQUATION, LDA.
Growme is committed to protecting the personal data of their customers, any personal data provided while using Growme products and services, as well as personal data provided in any situation in which it may be processed. This Policy has therefore been drawn up with this in mind, to demonstrate our commitment to respecting the applicable rules for the protection of personal data.
WHY DO WE NEED A PERSONAL DATA PROTECTION POLICY?
In this Policy, we inform our Customers of the general rules for the processing of personal data, which is collected and processed in strict compliance with the provisions of the applicable personal data protection legislation, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“RGPD”).
Growme respects best practices in the field of security and personal data protection by taking the necessary technical and organisational measures necessary to comply with the RGPD, ensuring that the company processes personal data in a way that is lawful, fair, transparent and limited to the purposes authorized by data owners.
Growme is committed protecting our customers’ personal data, as well as ensuring it is kept strictly confidential, and has taken the measures it deems appropriate to ensure the accuracy, integrity and confidentiality of personal data, as well as all other rights granted to the respective data holders.
The rules provided in this Data Protection Policy complement the provisions on the protection and processing of personal data, provided for in the agreements our Customers enter into with Growme, as well as the rules set forth in the terms and conditions that regulate the various products and services provided and duly advertised on the website.
WHAT IS THIS DATA PROTECTION POLICY ABOUT?
This Data Protection Policy applies exclusively to the collection and processing of personal data Growme is responsible for processing, within the scope of services and products made available to its Customers / Users and in all situations in which Growme processes this personal data.
Growme’s website may include links to other websites that are in no way connected to Growme. These links are provided in good faith, and Growme can not be held liable for the collection and processing of personal data made through these websites, nor does Growme take any responsibility for such websites, their accuracy, credibility or the functionalities available within them.
WHAT IS PERSONAL DATA?
Personal data is any information of any nature regardless of the manner in which it is stored, including sound and image, relating to an identified or identifiable natural person.
This relates to any identifiable person that can be directly or indirectly identified by their name, identification number, location data, electronic identifiers or one or more specific factors relating to their physical appearance, physiological, genetic, mental, economic, cultural or social status.
WHAT IS PERSONAL DATA PROCESSING?
The processing of personal data consists of an operation or set of operations carried out on personal data or personal data sets, which may be automated, specifically collection, registration, organisation, structuring, preservation, adaptation, retrieval, consultation, use, disclosure, dissemination, comparison, interconnection, limitation, erasure or destruction.
WHO IS RESPONSIBLE FOR DATA PROCESSING?
The entity responsible for the processing of personal data is Growme itself which determines the purposes and means of processing applied to this data.
As such, if a personal data holder wishes to contact the data controller, they may do so through the means and contact details indicated below:
Through the website Growme.pt
Or in a letter addressed to:
Growme – Business Accelerator Agency
CRIA Universidade do Algarve
Campus Gambelas – G12
WHO IS THE DATA PROTECTION SUPERVISOR?
The Data Protection Officer plays a relevant role in the processing of personal data, ensuring, among other aspects, that the data is processed in a manner that is consistent with the applicable legislation, verifying compliance with this Data Protection Policy and establishing the clear rules applicable to the processing of personal data, ensuring that all those entrusted with the processing of their personal data are aware of how Growme processes it and the rights they have to their data.
Therefore, personal data owners may, if they wish, address a letter to the Data Protection Officer regarding matters related to the processing of personal data, using the contact details provided at growme.pt/en/contacts to do so.
WHAT TYPES OF PERSONAL DATA ARE PROCESSED?
As part of its operations, Growme processes the personal data necessary in order to provide services and/or products, as well as processing data such as names, addresses, telephone numbers and e-mail addresses collected from social media sites, as per the most detailed information available to the holders of personal data at the time of collection.
Notwithstanding Growme’s compliance with legal regulations regarding the preservation and transmission of data for the purposes of investigation, detection, prosecution of serious crimes, as well as any other practices the company is legally obliged to follow, traffic data, geographical location, profile and/or Client / Users consumption will also be processed by Growme to the extent necessary in order to provide the respective services. Based on their location, profile and/or consumption patterns, Clients will be provided with access to specific functionalities of services, suggestions of content and location-based information services.
Location information may also be legally recorded and transmitted to organisations that are entitled to receive emergency calls, for the purpose of responding to incoming calls.
Growme also processes personal, traffic, geographic location, profile and/or consumption data for the purpose of marketing and publicising the goods and services provided by the company, as long as the respective holder has authorised the company to do so.
Personal data will also be processed if the respective holder has authorised the company to do so for the purpose of sharing information about services and lists within the universal service provided by the company, including sharing this information with third parties for the publication of such lists and the provision of information services.
If a Client has given prior consent, it may be withdrawn at any time, though this does not affect the legality of the data processed previously, based on the prior consent provided.
WHEN AND HOW DO WE COLLECT YOUR PERSONAL DATA?
Growme collects your personal data, via telephone, in writing and via our website, securing, where necessary, the prior consent of the holder of the personal data.
Some personal data is indispensable in order to enter into contracts with us. In the event that a lack of, or insufficient data is provided by the Client, Growme can not make the product or service in question available to them.
If the data subject is not a Growme Customer, their personal data will only be processed when made available to Growme, which could take place when they subscribe to our newsletter, in which case the rules contained within this Data Protection Policy will apply.
The personal data collected can be processed using computerised, and automated, or non-automated means, though strict compliance with the legislation relating to the protection of personal data is always guaranteed, this data being stored in specific databases created specifically for this purpose. In any case, the data collected will not be used for any purpose other than that for which it was collected, or for which the data subject has given their consent.
WHO MAY PERSONAL DATA BE SHARED WITH?
Notwithstanding the addressees indicated throughout this Data Protection Policy, Growme may communicate a Client’s personal data to an entity for the purposes of complying with legal obligations, specifically to police, judicial, tax and regulatory entities.
WHAT ARE THE PURPOSES OF PROCESSING PERSONAL DATA?
In general, the personal data collected has a basis in managing a contractual relationship, the provision of contracted services and the adequacy of the services to the needs and interests of the Customer. Growme may also, if legally permissible, use the personal data provided by the holder for other purposes, such as sending suggestions, sharing brand information, publicising campaigns, promotions, advertising and news about the products and/or Growme services, as well as in order to carry out market research or evaluation surveys.
HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
The length of time for which personal data is stored varies according to the purpose for which the information is processed.
Certain legal requirements require us to retain the data for a minimum period of time. Therefore, and whenever there is no specific legal requirement, the data will be stored and kept for the minimum period necessary for the purposes for which it was collected or subsequently processed, as per the terms of the law.
WHAT ARE YOUR RIGHTS AS A DATA HOLDER?
As holders of personal data, Clients are guaranteed, at any time, the right to access, rectify, update, limit and erase their personal data (except the data that is indispensable for the provision of services by Growme, as duly identified in the Form as being mandatory, or data required to ensure compliance with legal obligations to which the controller is subject), the right to oppose the use of this data for commercial purposes by Growme and withdrawal of their consent, without compromising the lawfulness of the processing prior to the withdrawal of said consent, as well as the right to data portability.
HOW CAN I ACCESS, RECTIFY, UPDATE, LIMIT, ERASE, OPPOSE THE PROCESSING OF MY PERSONAL DATA, OR WITHDRAW CONSENT?
Notwithstanding the provisions of the RGPD, the holder of the personal data may carry out any of the aforementioned actions directly, or via a written request addressed to the person responsible for data processing, via the contact details available for the purpose in this document, as well as other contact detailss made available by Growme.
HOW CAN YOU OPPOSE TO BEING CONTACTED FOR MARKETING PURPOSES?
Growme may contact its Customers in order to share information relating to new products or services by telephone, e-mail, SMS, MMS or any other electronic communications service, if the holder of the personal data has given their consent for Growme to do so.
If the holder of personal data does not intend to continue receiving such communications, they may withdraw their consent for the use of their data for marketing purposes at any time.
HOW CAN YOU FILE A COMPLAINT?
Notwithstanding complaints made directly to Growme via the contact details made available for the purpose, Customers can complain directly to the Control Authority, which is the National Data Protection Commission (CNPD), using the contacts made available by the entity for this purpose.
WHICH MEASURES HAVE BEEN ADOPTED BY GROWME TO ENSURE YOUR PERSONAL DATA IS KEPT SAFE?
Growme is committed to ensuring the protection the personal data it has access to, and has adopted and implemented strict rules in this regard. Every person who accesses them legally must comply with these rules.
With Growme’s concern and commitment to keeping personal data safe in mind, a number of technical and organisational security measures have been adopted in order to protect the personal data made available to the company from being shared, lost or misused, from any unauthorised access being granted, from the data being altered, processed or accessed, as well as against any from other form of illicit treatment.
Additionally, third-party service providers that process Growme clients’ personal data on behalf of Growme, are under written obligation to adopt adequate technical and security measures that comply with the requirements of current legislation and ensure that data subject rights are protected(in particular, their privacy and client personal data).
In this sense, personal data collected in forms on the Growme website require Browser sessions to be encrypted. All personal data transferred is then safely stored in Growme’s systems, which are, in turn, on Growme’s server, which is covered by all the physical and logical security measures that Growme considers to be indispensable for the protection of personal data.
In respect of the safety measures adopted by Growme, Growme warns all those who surf the Internet that they should take additional security measures, specifically ensuring that their PC and Browser are updated and properly configured in terms of security patches, that they have an active firewall, antivirus and antispyware, and that those surfing the web ensure the authenticity of the sites they visit, and avoid websites they do not trust.
UNDER WHICH CIRCUMSTANCES WILL GROWME COMMUNICATE MY PERSONAL DATA TO OTHER ENTITIES (WHETHER THIRD PARTIES OR SUBCONTRACTORS)?
As a part of its operations, Growme may use third parties to provide certain services. Sometimes the provision of these services requires that these entities be granted access to the personal data of Growme Customers. When this is the case, Growme takes all necessary measures to ensure that entities with access to the data are reputed and provide the highest guarantees that it will be kept strictly confidential, a fact that is duly enshrined in a contract entered into between Growme and any third party(ies).
Therefore, any entity subcontracted by Growme may process any Customer personal data on behalf of Growme, adopting any necessary technical and organisational measures in order to protect the personal data against destruction, whether accidental or illicit, accidental loss, alteration, dissemination or unauthorised access, as well as against any other form of illicit treatment.
In any case, Growme remains responsible for the personal data made available to it.
UNDER WHICH CIRCUMSTANCES DO WE TRANSFER YOUR PERSONAL DATA?
The provision of certain services by Growme may involve transferring your data outside of Portugal, including outside the European Union or to International Organisations.
In such a cases, Growme shall ensure strict compliance with the applicable legal provisions, in particular with regards to determining the suitability of the country(ies) to which it shall send this data, where the protection of the personal data is concerned, as well as the requirements applicable to such transfers, including, where appropriate, entering into the appropriate contractual instruments to guarantee and respect the applicable legal requirements.
“Cookies” are small software labels that are stored on computers through the browser. These only retain information related to preferences, not including personal data.
CHANGES TO THE GROWME PERSONAL DATA PROTECTION POLICY?
Growme reserves the right to make adjustments or changes to this Personal Data Protection Policy at any time. These changes will be duly publicised in the various communication channels used by Growme.
Last updated: 26th April 2018