Privacy Policy

Last updated September 2026

This Site is operated by Growly Inc. This Privacy Policy explains how we collect, use, disclose, and protect information about you when you visit this Site, contact us, or interact with us through the channels described below. We are committed to protecting your privacy and being transparent about our data practices.

At Growly, our mission is to harness technology to improve both the physical and emotional well-being of our users, while making mobile devices more efficient and user-friendly. We are passionate about the transformative power of technology to foster positive impacts, and we are committed to upholding strong privacy and security standards. As stewards of your personal information, we are dedicated to transparency and accountability, giving you clear insights into how your data is used.

Who We Are and How to Contact Us

Growly Inc. is a company incorporated in the United States, with its registered office at 131 Continental Dr, Suite 305, Newark, DE 19713, USA.

References to “us,” “we,” “our,” or the “Company” in this Privacy Policy include Growly Inc. and any of its direct or indirect parent or subsidiary undertakings.

You may contact us regarding privacy matters at:

Email: support@growly.it.com

Mail: Privacy Inquiries, Growly Inc., 131 Continental Dr, Suite 305, Newark, DE 19713, USA

What “Personal Information” Means

“Personal Information” means information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, to a particular individual or household. As a United States-based company, we use this term throughout this Policy consistent with U.S. privacy law terminology.

Where applicable international privacy laws — such as the EU General Data Protection Regulation (“GDPR”) or UK GDPR — apply extraterritorially to our processing of your personal data (for example, because you are located in the European Economic Area (“EEA”) or United Kingdom), we may also be regarded as a “controller” of that data within the meaning of those laws. References to “Personal Data” in this Policy should be read as equivalent to “Personal Information” where the context requires it.

Information We Collect

As you engage with this Site, we gather Personal Information through the following means:

Information Automatically Collected

• When you access this Site, we automatically collect certain details about your engagement and device. This may include your device model, operating system, Internet Protocol (IP) address, browser type and version, Media Access Control (MAC) address, screen resolution, and data about your actions within the Site.

Information Collected via Cookies and Similar Technologies

• We use cookies and similar technologies to understand how you interact with this Site. Please see Cookies and Tracking Technologies for further details.

Information You Provide Directly

• If you contact us with questions, queries, or feedback, we may collect the information you provide, including your email address and the content of your message.

In summary, the categories of Personal Information we collect include:

• Contact information and communications (e.g., email address, message content) when you contact us;
• Technical identifiers (e.g., IP address, browser type and version, device information); and
• Site usage information (e.g., pages visited, actions taken within the Site).

How We Use Your Information

We use Personal Information for the following purposes:

• To provide information about our services and products;
• To respond to your inquiries, fulfill your requests, and manage our communications with you;
• To analyze and improve this Site’s functionality, security, and user experience;
• To understand how this Site is used and to ensure it operates correctly and securely;
• To comply with applicable legal obligations; and
• To pursue our legitimate business interests in operating and improving this Site, provided those interests are not overridden by your rights or interests.

We process your Personal Information on the following bases:

• Legitimate Interests: Much of our processing is based on our legitimate interests in operating this Site, communicating with you, and maintaining and improving our online presence.
• Legal Obligation: We may process certain information to comply with applicable laws, regulations, or legal process.
• Consent: Where we rely on your consent (including for certain optional cookies or communications), you may withdraw that consent at any time.

For Individuals in the EEA or UK: To the extent the GDPR or UK GDPR applies extraterritorially to our processing of your personal data, the purposes and bases described above are intended to satisfy the lawful basis requirements under Article 6 of the GDPR (and, where applicable, Article 9 for special categories of data). We rely primarily on our legitimate interests under Article 6(1)(f) and on legal obligation under Article 6(1)(c) for the processing activities described in this Policy.

Cookies and Tracking Technologies

Cookies are standard website features that allow us to store small amounts of data on your device about your visit to this Site. We use cookies and similar technologies to understand which areas of the Site are useful and which areas need improvement.

We currently use only cookies that are strictly necessary for this Site to function properly. Certain information may also be collected automatically by your browser or device, including your MAC address, screen resolution, operating system name and version, device manufacturer and model, language, and browser type and version. We use this information to ensure the Site functions properly.

You can manage or disable cookies through your browser settings. For information on managing cookies across commonly used browsers, please visit http://www.allaboutcookies.org/manage-cookies/. Please be aware that disabling cookies may affect your experience on this Site and certain features may not operate as intended.

To the extent any Personal Information is collected through cookies or similar technologies, all other provisions of this Privacy Policy apply to that information.

How Long We Retain Your Information

We retain your Personal Information only for as long as necessary for the purposes described in this Privacy Policy, or as required or permitted by applicable law. After the applicable retention period, data is securely deleted or anonymized.

Our standard retention periods are as follows:

• Feedback and contact data (including email correspondence): up to 2 years from the date of collection;
• Access log data containing IP addresses: deleted after 120 days, where applicable.
• We may retain information for longer periods where required by applicable law, regulation, or legal process.

Disclosure of Your Information to Third Parties

We may share your Personal Information in the following circumstances:

• Service Providers: We engage technology vendors and service providers (such as hosting providers and analytics partners) that process Personal Information on our behalf and only as directed by us. These service providers are contractually required to protect your information and are prohibited from using it for their own independent purposes.
• Legal Requirements: We may disclose your Personal Information if required to do so by applicable law, court order, or governmental or regulatory authority, or where necessary to prevent fraud or other criminal activity.
• Business Transfers: In the event of a merger, acquisition, financing, or sale of all or a portion of our business, your Personal Information may be transferred as part of that transaction, subject to the acquirer’s commitment to honor this Privacy Policy or provide you with equivalent protections.

We will not:

• Sell or rent your Personal Information to third parties for their own use; or
• Share your Personal Information with third parties for their independent marketing purposes.

California-Specific Note: Although we do not sell Personal Information for monetary consideration, we may share certain limited Personal Information (such as online identifiers and browsing information) with analytics and advertising partners in ways that may constitute “sharing” or “sale” as defined under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”). Please see below information on how to exercise your opt-out rights with respect to such sharing.

Where Your Information Is Processed and Stored

Growly Inc. is based in the United States, and your Personal Information is primarily processed and stored in the United States on access-controlled, secure servers. You should be aware that the United States may not have data protection laws equivalent to those in your home jurisdiction.

We may engage service providers or partners located in countries other than the United States. Where we transfer Personal Information internationally, we take commercially reasonable steps to ensure that such transfers are subject to appropriate protections consistent with applicable law.

For Individuals in the EEA or UK: To the extent the GDPR or UK GDPR applies to our processing of your personal data, any transfer of your personal data to a country outside the EEA or UK that has not received an adequacy decision from the European Commission or, as applicable, the UK Secretary of State or Information Commissioner’s Office, will be subject to appropriate transfer safeguards — such as Standard Contractual Clauses approved under Article 46 of the GDPR, or equivalent UK mechanisms. If you would like further information about the transfer safeguards applicable to your personal data, please contact us at support@growly.it.com.

Security

We implement commercially reasonable technical and organizational security measures to protect your Personal Information against unauthorized access, disclosure, alteration, or destruction. Our current measures include:

• SSL/TLS encryption (HTTPS) for secure data transmission between your browser and our Site;
• Encrypted databases stored on access-controlled, secure servers.
• While we strive to use appropriate security measures, no transmission over the internet or method of electronic storage is completely secure. We cannot guarantee the absolute security of your information. If you need to report a suspected security incident or data concern, please contact us promptly at support@growly.it.com.

For Individuals in the EEA or UK: To the extent required by the GDPR or UK GDPR, in the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, we will notify the relevant supervisory authority without undue delay and, where required, will notify affected individuals in accordance with the timelines and requirements of applicable law.

Children’s Privacy

This Site is not directed to, designed for, or intentionally targeted at children under the age of 13. We do not knowingly collect or maintain Personal Information from children under 13. If you believe we have inadvertently collected information from a child under 13, please contact us at support@growly.it.com and we will promptly take steps to delete such information in accordance with applicable law.

Your Privacy Rights

The rights available to you depend on your jurisdiction. We describe the principal rights below. To exercise any of the rights described in this Section, please contact us at support@growly.it.com. We will not discriminate against you for exercising any privacy right.

Rights for California Residents (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (together, “CCPA/CPRA”) provide you with the following rights:

• Right to Know: You may request disclosure of (i) the categories and specific pieces of Personal Information we have collected about you; (ii) the categories of sources from which it was collected; (iii) the business or commercial purposes for which it was collected, sold, or shared; and (iv) the categories of third parties to whom we have disclosed, sold, or shared it in the past 12 months. You may make this request up to twice per calendar year at no cost to you.
• Right to Delete: You may request that we delete Personal Information we have collected from you, subject to certain exceptions permitted by applicable law (such as where retention is necessary to complete a transaction, detect security incidents, comply with a legal obligation, or for other lawful purposes).
• Right to Correct: You may request that we correct inaccurate Personal Information that we maintain about you, taking into account the nature of the information and the purposes of processing.
• Right to Opt Out of Sale / Sharing: You have the right to opt out of the “sale” or “sharing” of your Personal Information as those terms are defined under CCPA/CPRA. As noted in Section above, while we do not sell Personal Information for money, certain disclosures to analytics and advertising partners may constitute “sharing” or “sale” under CCPA/CPRA. To opt out, you may adjust your browser or device privacy settings, or contact us directly at support@growly.it.com.
• Right to Limit Use of Sensitive Personal Information: We process sensitive Personal Information only to the limited extent necessary to provide you with access to this Site. We do not use or disclose sensitive Personal Information for purposes that would require us to offer a right to limit its use beyond what is already described in this Policy.
• Right to Non-Discrimination: We will not deny you goods or services, charge you different prices, or provide a different level of quality of goods or services because you exercised any of your rights under CCPA/CPRA.

To submit a California privacy rights request, contact us at support@growly.it.com. We will verify your identity before processing your request. We will respond to verifiable consumer requests within the timeframes required by CCPA/CPRA.

For Shine the Light Requests (California Civil Code § 1798.83): We do not share Personal Information with third parties for their own direct marketing purposes. You may nonetheless submit a request by emailing us with the subject line “California Privacy Rights Request,” including your name, street address, city, state, and ZIP code.

All references to “Personal Information” in this Policy include “sensitive personal information” as defined under CCPA/CPRA to the extent applicable.

Rights for Residents of Other U.S. States

Residents of certain other states may have privacy rights under applicable state law. This Section applies to residents of states including Virginia (Virginia Consumer Data Protection Act, “VCDPA”), Colorado (Colorado Privacy Act, “CPA”), Connecticut (Connecticut Data Privacy Act, “CTDPA”), Utah (Utah Consumer Privacy Act, “UCPA”), and Nevada (Nevada privacy law).

Depending on your state of residence, you may have some or all of the following rights:

• Right to Access: Request access to the Personal Information we hold about you and confirmation of whether we are processing your Personal Information.
• Right to Correct: Request correction of inaccurate Personal Information.
• Right to Delete: Request deletion of Personal Information we have collected from or about you.
• Right to Data Portability: Where applicable under your state’s law, request that we provide your Personal Information in a portable, readily usable format.
• Right to Opt Out of Targeted Advertising and Sale: Residents of Colorado, Connecticut, Virginia, and Utah have the right to opt out of the processing of their Personal Information for targeted advertising and the sale of Personal Information. We do not sell Personal Information for monetary consideration. You may opt out of any sharing for advertising purposes as described therein.
• Right to Opt Out of Profiling: Residents of Colorado, Connecticut, and Virginia may opt out of profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. We do not currently use automated profiling in this manner.
• Nevada Opt-Out: Nevada residents have a limited right to opt out of the sale of covered information for monetary consideration. We do not sell Personal Information for monetary consideration.

We will respond to verifiable requests within the time period required by applicable state law. To exercise any of these rights, please contact us at support@growly.it.com. Where your state law provides for an appeals process, we will inform you of that process in our response if we decline to act on your request.

Additional Rights Under Applicable International Privacy Law

This Section applies conditionally and only to the extent that applicable international privacy laws — including the GDPR or UK GDPR — apply extraterritorially to our processing of your personal data. Growly Inc. is established in the United States and does not have an EU or UK establishment. These rights apply only where such laws extend to our activities by virtue of their territorial scope provisions (for example, where we offer goods or services to individuals in the EEA or UK, or monitor their behavior).

Where the GDPR or UK GDPR applies to our processing of your personal data, you may have the following rights:

• Right of Access (Article 15 GDPR): Request a copy of the personal data we hold about you, together with information about how it is processed.
• Right to Rectification (Article 16 GDPR): Request correction of inaccurate or incomplete personal data.
• Right to Erasure (Article 17 GDPR): Request deletion of your personal data where one of the grounds in Article 17(1) applies and no exception under Article 17(3) is engaged.
• Right to Restriction of Processing (Article 18 GDPR): Request that we restrict our processing of your personal data in certain defined circumstances.
• Right to Data Portability (Article 20 GDPR): Receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Object (Article 21 GDPR): Object to our processing of your personal data where we rely on legitimate interests as our lawful basis, including objection to processing for direct marketing.
• Right to Withdraw Consent: Where we rely on consent as the lawful basis for processing, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to Lodge a Complaint: If you believe our processing of your personal data infringes applicable data protection law, you have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or the location of the alleged infringement. A list of EEA supervisory authorities is available at https://edpb.europa.eu. The UK supervisory authority is the Information Commissioner’s Office (https://ico.org.uk).

Growly Inc. is established in the United States and is not subject to the primary jurisdiction of any EEA or UK data protection supervisory authority. However, we are committed to cooperating with applicable supervisory authorities in the resolution of complaints from EEA and UK individuals concerning our processing of their personal data.

To exercise any of the rights listed in this Section, please contact us at support@growly.it.com. We will endeavor to respond within 30 days, though we reserve the right to extend this period in complex cases as permitted by applicable law. We reserve the right to decline requests that are manifestly unfounded or excessive. We may ask you to verify your identity before fulfilling your request.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in applicable law, our data practices, the features of this Site, or advances in technology. We will post the revised policy on this page and update the “Last Updated” date at the top.

We encourage you to review this Privacy Policy periodically. If we make material changes that meaningfully affect your rights or how we process your Personal Information, we will provide appropriate advance notice, which may include posting a notice on this Site or, where required by law, notifying you directly.

Your continued use of this Site after any changes to this Privacy Policy constitutes your acknowledgment of the updated policy.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Growly Inc.

Privacy Inquiries

131 Continental Dr, Suite 305

Newark, DE 19713, USA

Email: support@growly.it.com