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Privacy Notice

Welcome to Growee, by Growee Technologies Ltd. (“Growee”, “we”, “us” or “our”, as applicable). We care about your Privacy and are committed to your right to privacy.

This Privacy Notice (“Privacy Notice”), is an integral part of our Terms of Use, which can be found at: https://www.getgrowee.com, and governs the processing and transfer of Personal Data collected in connection with the services provided on our mobile device App (“App”), our website, available at: getgrowee.com (“Website”), and any and all other services or products provided by us through the App, the Website or otherwise (“Services”), to any person using the App, Website or Services (“User”, or “you”).

If you choose to use, download the App, register to the App or provide Personal Data to us through the Services, you explicitly agree to the use of such data in accordance with this Privacy Notice. You may not use the App and the Services or submit any data through them if you do not agree to any of the terms hereunder. This Privacy Notice shall not be construed in any manner to derogate from the Terms of Use or any other agreement made between Growee and you.

THE HIGHLIGHTS:

You are not required by law to provide us with any Personal Data. Sharing Personal Data with us or other users on the App is entirely voluntary.

Our Services are intended for Users over the age of 18 or equivalent minimum age for providing consent to processing of Personal Data in the relevant jurisdiction. Children under such age are not permitted to register to or use the Services. If you are under such age you should cease to use the Services immediately, and uninstall the App from your device.

You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data. Please note that in case you request to erase or restrict the processing of your Personal Data, your use of the App and the Services may be restricted or disabled.

We do not sell, trade, or rent Users’ Personal Data to third parties. We only share Personal Data with third parties in connection with the provision of the Services to our Users, or other limited circumstances specified herein.

If you have any questions or requests regarding the processing of your Personal Data, or would otherwise like to contact us in connection with this Privacy Notice, please send us an email to: support@getgrowee.com].

What is Personal Data, and what data is collected about me by Growee?

“Personal Data”, means any information which identifies or can be used to identify a natural person, including, but not limited to, first and last name, phone number, email address, IP address, billing information, etc.

Non-Personal Data

We collect non-Personal Data regarding Users concerning their use of the App and Services, such as the scope, frequency, latency, pages accessed, what and when a User views or interacts with content and materials displayed through our Services, device identifiers, and other technical information regarding the device used to access the Services, such as model, operating system, etc.

Personal Data

In order to use certain Services through the App and the Website you will be asked to register to the App and create an account by providing certain Personal Data, such as your name, email address and a password of your choice (the “Account”).

We do not knowingly collect or Process any Personal Data included in Special Categories of Personal Data (as defined in the GDPR). In the event you become aware that such data has been posted to the App or collected by us, please inform us immediately.

Please note, that the App may contain links to other apps or websites maintained by third parties, which may not be governed by this Privacy Notice. This Privacy Notice does not apply to the practices of entities which are not controlled by Growee.

What will Growee do with my Personal Data?

Non-Personal Data. Non-Personal Data is used mainly for click stream analysis in order to constantly improve and maintain our App, Website or/and Services, including among others, in order to measure and understand the level of engagement to our services, for general business analytics and in order to provide a more personalized experience and tailored content, for ensuring the technical functioning of our network, to help prevent fraudulent use of our Services and for developing new services and features.

Personal Data. Personal Data is used only for the following limited purposes: To provide you with the Services.

To communicate with you regarding customer service issues, or to provide updates with respect to material changes to this Privacy Notice or our Terms of Use.

For the purposes of our legitimate interests, to the extent not overridden by the rights and freedoms of natural persons, and as permitted under applicable law.

To protect the security or integrity of our databases and the Services, and to take precautions against legal liability.

To improve the Services, and to develop new features, products and services.
To improve your experience on the App and customize our Services to your interests.

Does Growee use cookies?

Yes, we use cookies (small text files stored in a user’s device) or web beacons (electronic images that allow to count visitors who have accessed a particular page and to access certain cookies) and other

similar technologies to gather non-Personal Data. You may at any time program your device to block cookies, but please be aware that such blocking may prevent us from providing some or all of the Services to you. These cookies help us track how visitors use the App. These cookies provide us only with aggregate, which is used to assist us in improving your experience of using the Services through the App.

What can I do to control my Personal Data?

Reviewing and amending your Personal Data. You may review the information included in your Account on the App. You may also send us a request in connection with your Personal Data to:support@growee.com In the event any Personal Data is incorrect or outdated, you may update and correct such data by providing us with appropriate notification or correcting the data directly on the App.

Right of erasure and restriction. You may also be entitled request the erasure or the restriction of your Personal Data, and we will comply with such requests, to the extent required under applicable law.

Portability of Personal Data. To the extent relevant to you and to the Services, you may be entitled to request the portability of your Personal Data, and we will comply with such requests, to the extent required under applicable law.

Retention of Data. We reserve the right to retain any Personal Data for as long as reasonably necessary in order to: (i) fulfill the purposes described herein; (ii) in the defense or assertion of legal claims and liability; (iii) for the analysis and development of the Services; and (iv) to comply with applicable law. Non-Personal Data and statistical anonymized data may be retained by us without limitation.

Will Growee Time Share my Personal Data?

Non-Personal Data, aggregate and statistical or otherwise anonymized data may be shared without limitation with third parties at our discretion. This information does not contain Personal Data and is used to develop content and services for our Users and partners.

We share Personal Data only under the following limited circumstances:

With trusted third parties who assist us in operating the Services, conducting our business, and for personalizing your experience of the App.

To comply with a legal requirement, for the administration of justice, to protect your vital interests or the vital interests of others, to protect the security or integrity of our databases or the Services, to take precautions against legal liability, or in the event of a corporate sale, merger, reorganization, dissolution or similar event.

What is the lawful basis under which Growee processes Personal Data?

Certain processing activities conducted by us are based on the necessity of such activities for the performance of the understandings between us and our Users.

Other processing activities are based on the grounds that they are necessary for the purposes of our legitimate interests or the legitimate interests of a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of natural persons which require protection of Personal Data.

There may be certain processing activities based on your consent to this Privacy Notice. In connection with such activities, you may rescind your consent, by sending us an email

to: support@getgrowee.com. Please note that in the event you rescind your consent to the processing of Personal Data, we may not be able to provide you with some or all of the Services.

Will Growee transfer my Personal Data internationally?

Our databases are currently located in Frankfort. We may transfer our databases from time to time to centers located in other jurisdictions, in accordance with applicable law. Some of our processing activities are made in Israel. The European Commission has decided that the State of Israel ensures an adequate level of privacy and data protection, therefore, in accordance with the GDPR, the transfer of Personal Data from the EU to Israel is lawful and does not require any specific authorization.

Any other transfer of Personal Data originating from the EU to a third country (other than Israel) shall be made in accordance with applicable law, including by providing adequate protections, or otherwise implementing appropriate safeguards to ensure the protection of our Users’ rights.

Will I receive SPAM from Growee?

We currently do not send Users any commercial or promotional information via direct mailing such as emails or SMS messaging. We will not send any User such promotional mailing without obtaining the User’s explicit prior consent. We may however send our Users notifications to their mobile devices (“push notifications”), containing offers which may be of interest to them. If you wish not to receive such notifications, you may change the settings of your device at any time to block such notifications.

Applicable Laws

The provisions included in this Notice relating to matters regulated under the GDPR will apply only to the processing of Personal Data which is subject to the GDPR in accordance with the applicability provisions contained therein. If the GDPR does not apply to the processing of your Personal Data, some of the provisions above may not apply to you.

Persons under 18

Our App is a general audience App, which is not directed to persons under 13 years old. If a parent or guardian becomes aware that his/her child has provided us with Personal Data without their consent, he/she should contact us immediately. We do not knowingly collect or solicit Personal Data from people under 13 years old. If you are under 13, please do not send any information about yourself to us, including your name, address, telephone number, or email address. If we become aware that a person under years 13 old has provided us with Personal Data, please contact us quickly as possible and we will delete such data from our databases.

Questions or concerns regarding privacy

If you have any questions or concerns regarding privacy issues, please send us a message to support@getgrowee.com, and we will make every effort to resolve your concerns without delay.

We may, at any time and from time to time, modify this Privacy Notice. Modifications to this Privacy Notice we will notify you by email (sent to the e-mail address specified in your account) or by posted on the App or our Website, and shall be effective as of the date in which they are posted on the App.

You are also entitled to file a complaint with the appropriate supervisory authority in connection with concerns you may have with regards to your privacy and Personal Data.

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