Privacy Policy

Last updated: March 07, 2020

This privacy policy (the "Privacy Policy") explains how Growbase Ltd (the "Company") collects, uses, shares, and protects information of the users of the Company’s website and associated mobile applications or other software applications where this Privacy Policy is posted (collectively, the "Company Website"). This Privacy Policy is designed to fulfill the Company’s legal obligations in the places where the Company operates—including, without limitation and where applicable, the California Consumer Privacy Act ("CCPA"), the EU General Data Protection Regulation ("GDPR"), and Canada’s Personal Information Protection and Electronic Documents Act ("PIPEDA").

Please note that this Privacy Policy only applies to the Company Website, and not to websites, applications, operating systems, or other platforms of third parties (collectively, "Third-Party Platforms"), even if such Third-Party Platforms are linked to or accessible from the Company Website. Each Third-Party Platform will have its own data collection and usage practices, and may use its own cookies, web beacons, and other technology to collect information from you and the Company you represent (collectively, "You"). The Company is not responsible for the content or practices of any Third-Party Platforms and, if You choose to visit or use them, You do so at Your own risk.

1. Who controls Your information?

Any information or other data provided to or gathered by the Company is controlled by:

Growbase Ltd
Evagora Papachristoforou str. 18
Petroussis Building, Office 001
3030, Limassol, Cyprus
Email: contact@weopt.com


2. What types of information does the Company collect?

"Information," as used in this Privacy Policy, means personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or household. Examples include a user’s name, mailing address, email address, or IP address.

The Company collects and/or has collected over the past twelve (12) months the following categories of information about You and other users of the Company Website:

Information You Provide to the Company: The Company collects information from You when You voluntarily provide it to the Company through the Company Website, including as part of registering a user account or ordering goods or services from the Company. Such information may include Your name, email address, telephone number(s), street address, city, state, signature, social security number, passport number, driver’s license or state identification card number.

Transaction and Payment Information: The Company may gather additional information from You when You order a product or service through the Company Website or contact customer service regarding a prior transaction. Such information may include Your bank account number, credit card number, debit card number, or any other financial information, information regarding the products or services You purchased, and Your paid subscription plan or membership, if any.

Device/Internet Connection Information: When You use the Company Website, the Company automatically gathers information made available by Your web browser (such as Microsoft Edge or Google Chrome), internet service provider (such as Comcast or Cox), and device (such as Your computer, phone, tablet, or fitness tracker), depending on Your settings for each. For example, the Company may collect Your IP address, information about the operating system or type of device You use, the device ID associated with Your device, the date and time You access the Company Website, and Your log in attempts.

Internet Activity Information: As explained below in Sections 3 and 4 regarding Personalized Ads, the Company may also collect information about Your browsing history, search history, and information regarding Your interaction with a particular website, application, or advertisement, including the Company Website. The Company may collect information regarding the websites, application, or advertisement You visited immediately before and after Your use of the Company Website.

Geolocation Information: The Company may collect information about where You are located, both generally and at the time You access the Company Website. For example, the Company may collect Your mailing address or ascertain Your approximate location from Your IP address.

Employment Information: The Company may collect information about Your employment.

Other Information: From time to time, the Company may collect other information from You, such as when You request assistance through the Company’s customer service department, or when You voluntarily subscribe to the Company’s promotions, reminders, or newsletters. You will always be asked for Your consent in advance of providing such other information, and the Company will not collect such information without Your permission.

Inference Information: The Company may also create new information about You by drawing inferences from the information identified in the categories listed above, such as to create a profile about You reflecting Your preferences and characteristics.

3. How and when does the Company collect information about You?

The Company gathers information about You through the following sources and means:

When You enter or upload information to the Company Website: The Company collects information You provide to the Company, transaction and payment information, geolocation information, and employment information when You enter such information on a form on the Company Website (including during account registration), purchase products or services, sign up for newsletters or promotional material, upload content, and otherwise interact with the Company Website.

When You communicate with the Company: The Company may also collect information You provide to the Company, content You make public, transaction and payment information, geolocation information, and employment information from You outside of the Company Website, such as when You contact the Company’s customer service department, email the Company (including any response to an email communication from the Company), or communicate with the Company via social media, such as by posting on a page hosted by the Company or tagging the Company in Your own post. The information collected through the Company Website may be combined with information collected through other sources—for example, if You create a user account through the Company Website and later call the Company’s customer service about Your account, the information collected in both interactions may be linked.

Through Cookies, tracking tools, and other automated technologies: When You use any website, certain information can be automatically collected through technological means. When You access the Company Website, Your web browser automatically sends the Company device and internet connection information and certain internet activity information as described in Section 2.

Company also uses Cookies and web beacon technology to gather device and internet connection information, internet activity information, and geolocation information. "Cookies" are files that are placed on Your computer or other device by websites You visit. The primary purpose of a Cookie is to identify You as a unique user of the Company Website. The Company uses the following types of Cookies, some of which are placed by third parties, to customize Your Internet experience, keep You logged into websites, remember Your search terms, and advertise products or services to You:

Type of Cookie Purpose of Cookie
Necessary Necessary Cookies are essential in order for the Company Website to display and perform properly. Necessary Cookies are used to identify You, prevent security risks, and to allow You to perform account-related functions.
Preferences Preferences Cookies are used to store preferences set by You and each user for their account, such as Your language preferences. Preferences Cookies improve Your experience using the Company Website.
Analytics and Performance Analytics and Performance Cookies collect information on how You and other users interact with the Company Website. Often, this information is aggregated, as discussed in Section 4, and is used to improve the Company Website.

You can change Your Cookie settings in Your Internet browser (e.g., Chrome, Edge, Firefox). If You disable Cookies, some of the features of the Company Website may not function correctly. For more information, see www.allaboutcookies.org.

From Third Parties: The Company may also collect the following types of information from third parties: transaction and payment information (such as when You have Your payment information saved in Your web browser); device/internet connection information; internet activity information; and geolocation information.

Like many websites, the Company uses Google services and Cookies to improve the Company Website and to advertise to users like You, as described more fully below. As such, when You use the Company Website, Your personal information may be shared with Google, and shared by Google with the Company. You can learn more about how Google uses Cookies, and how to manage Your Cookie preferences in Your Internet browser and revoke Your consent to Personalized Ads, by visiting the Google Cookie Policy.

The Company may also use the Facebook Cookie and the Cookies of other social media companies to deliver Personalized Ads to you, as that term is described below. You can learn more about how Facebook gathers and uses personal information via Cookies, including how to set your Cookie preferences within Facebook, by visiting the Facebook Cookie Policy.

Remember, You can change Your Cookie settings in Your Internet browser (e.g., Chrome, Edge, Firefox). For more information, see www.allaboutcookies.org.

You can better learn about such third-party data collection and advertising practices, including how to revoke Your consent to Personalized Ads, at the following websites:

www.youronlinechoices.com/uk/your-ad-choices

www.networkadvertising.org/choices

www.aboutads.info/choices

4. How does the Company use Your information?

The Company may use the information we’ve gathered from You or Your device, including through Cookies and third parties, for the following purposes:

Business Purposes: When the Company uses Your information for a "Business Purpose," it means such use is reasonably necessary and proportionate to achieve an operational purpose of the Company. The following are the Business Purposes for which the Company may use Your information:


Commercial Purposes. When the Company uses Your information for a "Commercial Purpose," it means such use is intended to advance the Company’s business interests, such as by inducing You to buy one of the Company’s products or services. The following are the Commercial Purposes for which the Company may use Your information:

Business Purpose Types of Information
For Security: The Company uses the information it collects from You and other users to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and prosecute those responsible for that activity. Information You provide to us; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information
To Provide the Services: The Company uses the information the Company collects from You to process Your payments, fulfill Your orders, and provide the Company’s goods and services. Information You provide to us; Transaction and Payment Information; Device/Internet Connection Information; Geolocation Information; Employment Information
To Improve our Products and Services: The Company uses the information the Company collects from You and other users to improve its product offerings and services. Information You provide to us; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Employment Information; Inference Information
To Improve the Company Website: The Company uses the information it collects from You and other users to provide and improve the Company Website. The Company uses information to debug and identify and repair errors that impair existing intended functionality of the Company Website. As explained above, the Company uses Cookies, including those placed by third parties, to gather statistical information that helps the Company understand how You and other users engage with the Company Website and improve its performance via technological development. Information You provide to us; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Employment Information; Inference Information
To Personalize Your User Experience: The Company uses information gathered from Cookies to authenticate Your logins, determine whether You are logged in or not, to allow You to set personal preferences when using the Company Website, and to make it so You don’t have to reenter the same information when You visit the Company Website several times within a short timeframe. Information You provide to us; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Employment Information; Inference Information
To Communicate with You: The Company uses Your information to personalize communications with You, and to respond to Your requests regarding Your use of the Company Website and the Company’s services. The Company also use Your information to notify You of updates to the Terms of Service or this Privacy Policy. Information You provide to us; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Employment Information; Inference Information
To Create Deidentified Aggregate Information: The Company may combine Your information with that of other users to create "Aggregate Information"—namely, statistical information about all users or a subset thereof. Aggregate Information is pseudonymized and deidentified. In other words, Aggregate Information cannot be used to identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer, including You.

In turn, Aggregate Information may be used by the Company for the Business and Commercial Purposes listed herein.
Information You provide to us; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Employment Information; Inference Information



Scope and Legal Bases for Use

The Company only processes Your information to the extent that is necessary to accomplish the above-stated Business and Commercial Purposes, which serves as the Company’s legitimate interest.

If You reside in a location governed by the GDPR, then the following are the Company’s legal bases for the processing of Your information: In so far as the Company has obtained consent for processing operations of information by the data subject, Art. 6(1) lit. a GDPR serves as the legal basis. For the processing of information necessary for the performance of a contract to which the data subject is a party, Art. 6(1) lit. b GDPR serves as the legal basis. The same applies to such processing operations which are necessary for carrying out pre-contractual measures. In so far as the processing of information is required to comply with a legal obligation to which the Company is subject, Art. 6(1) lit. c GDPR serves as the legal basis. In the event that processing of information may be necessary to protect the vital interests of the data subject or of another natural person, Art. 6(1) lit. d GDPR serves as the legal basis. If processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, processing operations are based on Art 6 (1) f DSGVO.

5. How does the Company use Your information?

Company may share Your information with Third Parties for the following purposes:

Business Purposes. When Company shares Your information for a Business Purpose, it means such use is reasonably necessary and proportionate to achieve an operational purpose of the Company. The following are the Business Purposes for which the Company may share Your information:

Commercial Purpose Types of Information
To Advertise to You: The Company may use information gathered through Cookies and web beacons, including those placed by Third Parties, to deliver ads to You via the Company Website, and after You’ve left the Company Website, including advertising specific to Your personal interests. The purpose of this practice, which is sometimes called "Personalized Ads," "retargeting," or "remarketing" is to deliver content and advertising that is of interest to You, and to avoid displaying irrelevant advertising to You.

You can better learn about such third-party data collection and advertising practices, including how to revoke Your consent to Personalized Ads, at the following websites:

www.youronlinechoices.com/uk/your-ad-choices

www.networkadvertising.org/choices

www.aboutads.info/choices
Information You provide to us; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Employment Information; Inference Information
To Build a Profile: As stated above, the Company creates new information about You by drawing inferences from the information identified in the categories listed above, such as to create a profile about You reflecting Your preferences and characteristics. Such information and profile may be used by the Company for advertising purposes. Information You provide to us; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Employment Information; Inference Information
To Advertise to Others: The Company may share Your reviews, comments, and other content uploaded by You to advertise and market the Company Website and the Company’s services, including by reposting Your reviews on the Company Website, in our advertising, or through our social media accounts. Content You make public
Third Parties Business Purpose Types of Information
Service Providers: These third parties provide services to the Company that allow the Company to operate the Company Website, provide services to users of the Company Website, communicate with users of the Company Website, and so forth. Examples include payment processors, email fulfillment providers, customer management services, and so forth. For Security; To Fulfill Your Orders; to Improve the Company’s Products and Services; to Improve the Company Website, to Personalize Your User Experience; and to Create Aggregate Information. See Section 4 for more information on these Business Purposes. Information You provide to us; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Employment Information; Inference Information
Our Affiliated Entities: Affiliated entities are different than third parties in that they are businesses that are directly related to the Company and have common ownership with the Company. The Company may disclose, transfer, and sell Your information to its affiliated entities, in which event, Your information shall be treated by the affiliated entity in accordance with this Privacy Policy. Should the Company be subject to an acquisition, merger, sale or other change of control or business entity status, the Company reserves the right to transfer or assign Your information as part of that acquisition, merger or sale. For Security; To Fulfill Your Orders; to Improve Our Products and Services; to Improve the Company Website, to Personalize Your User Experience; and to Create Aggregate Information. See Section 4 for more information on these Business Purposes. Information You provide to us; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Employment Information; Inference Information
Government Officials and Private Parties Pursuant to Valid Legal Process: The Company may disclose Your information in response to subpoenas, court orders, and other legal processes. In very rare circumstances, the Company may disclose personal information when it believes such disclosure is necessary in order to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals. To comply with the Company’s legal obligations and to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals. Information You provide to us; Transaction and Payment Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Employment Information; Inference Information

Commercial Purposes: When the Company shares Your information for a "Commercial Purpose", it means its disclosure is intended to advance the Company’s business interests, such as by advertising our products or services. The following are the Commercial Purposes for which the Company may share Your information with third parties:

Third Parties Commercial Purpose Types of Information
Advertising Partners: The Company may disclose Your personal information as needed to our third-party advertising partners. For example, the Company may share information gathered through Cookies and tracking technology to allow a third party to advertise the Company’s products and services to You after You leave the Company Website. To Advertise to You, including through Personalized Ads; to Advertise to Others. See See Section 4 for more information on these Business Purposes. Information You provide to us; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Employment Information; Inference Information

6. How does the Company protect Your information?

The Company, and the third-party vendors the Company uses to store Your information, employ technical, administrative, and physical security measures (such as SSL encryption and HTTPS protocol) that are designed to protect against the loss, misuse, and alteration of the information under the Company’s control. The Company regularly reviews its security procedures to consider appropriate new technology and methods.

However, no system can be completely secure. Therefore, although the Company takes steps to secure Your information, the Company cannot promise, and You should not expect, that Your personal and commercial information, or other communications, will always remain secure.

The safety and security of Your information also depends on You. Never share Your user account password with anyone else and notify the Company as soon as possible if You believe Your account security has been breached.

7. How long does the Company keep Your information?

The Company will retain Your information for the length of time necessary to fulfill the Business Purposes and Commercial Purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law or valid court order. If You request deletion of Your information pursuant to Section 9, Your request will be processed according to the timeframes indicated therein and/or pursuant to any applicable legislation.

8. Does the Company transfer Your information to a different country?

If You are visiting the Company Website from a location outside of the United States, Your connection will be through and to servers located in the United States, and all information You provide will be processed and securely maintained in our web servers and internal systems located within the United States. By using the Company Website, You authorize and specifically consent to the transfer of personal data to the United States and its storage and use as specified above when You provide such information to us.

9. What are Your rights when it comes to accessing, correcting, or deleting Your information, and how can You exercise them?

You may access all information the Company has collected and retained about You for purposes of correcting, amending, downloading, or deleting such information. Access can be obtained by logging into Your account if applicable, filling out a Privacy Request at CCPA Privacy Request Form, or contacting the Company at privacy@weopt.com.

To protect Your privacy and security, the Company may take reasonable steps to help verify Your identity before granting access, making corrections, providing You with information, or deleting information.

Access and Correction

The easiest way to access and correct the personal information the Company has collected about You is to log into Your account if applicable. In the alternative, You may fill out a Privacy Request at CCPA Privacy Request Form, or contact the Company at privacy@weopt.com.

Right to Request Disclosure

You have the right to request that the Company disclose the following to You:

  • The categories of personal information the Company has collected about You;
  • The categories of sources from which the personal information is collected;
  • The business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom the Company shares personal information; and
  • The specific pieces of personal information the Company has collected about You.
  • To request such a disclosure, please fill out a Privacy Request at CCPA Privacy Request Form, or contact the Company at privacy@weopt.com.

Right to Request Deletion

You have the right to request that the Company delete any personal information about You which the Company has collected from You. To make such a request, please fill out a Privacy Request at CCPA Privacy Request Form, or contact the Company at privacy@weopt.com.

California Shine the Light Disclosure

Under California’s "Shine the Light" law, California residents who provide personal information to the Company Website may request certain information regarding the Company’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please fill out a Privacy Request at CCPA Privacy Request Form, or contact the Company at privacy@weopt.com.

Cal. Bus. Prof. Code § 22581 Disclosure

If You are a California resident under the age of 18, and a registered user of the Company Website, California Business and Professions Code section 22581 permits You to request and obtain removal of content or information You have publicly posted. To make such a request, please fill out a Privacy Request at CCPA Privacy Request Form, or contact the Company at privacy@weopt.com with a detailed description of the specific content or information. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information You have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

10. How does the Company protect the privacy of children?

No Users Under 13

The Company will never knowingly collect any personal information about children under the age of 13. If the Company obtains actual knowledge that it has collected personal information about a child under the age of 13, that information will be immediately deleted from the Company’s database. Because the Company does not collect such information, it has no such information to use or to disclose to third parties. The Company has designed this policy in order to comply with the Children’s Online Privacy Protection Act (COPPA).

11. How can You receive and opt-out from marketing communications?

By providing Your email address to the Company through the Company Website or an email initiated by You, You consent to receive emails from the Company, including information concerning Your account and advertising messages. Depending upon Your location, the company may obtain additional consent from You via a checkbox disclosure or an email requesting confirmation before You can receive such information.

Providing consent to promotional emails is NOT a condition of purchasing any goods or services from the Company. You can unsubscribe to advertising emails at any time by clicking the unsubscribe link within the email, or by contacting the Company at unsubscribe@weopt.com. Please note that, even if You unsubscribe from advertising emails, the Company will still send You any necessary, non-promotional emails about Your purchase, account, or updates to our Privacy Policy and Terms of Service.

12. Does the Company respond to Do Not Track (DNT) Signals?

DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that Your browsing is not tracked. The Company does not currently respond to DNT requests.

13. How will You know when the Company changes the Privacy Policy?

Each time You use the Company Website, the then-current version of this Privacy Policy will apply. Although most changes are likely to be minor, the Company reserves the right to modify this Privacy Policy by posting such modification on this page; however, if changes are significant, the Company may provide a more prominent notice or email You. Depending upon Your location, the Company may obtain additional consent from You via a checkbox disclosure or an email requesting consent before You can continue to use the Company Website.

Unless the Company receives Your express consent, any revised Privacy Policy will apply only to information collected after the effective date of such revised Privacy Policy, and not to information collected under any earlier version.

14. How can You contact the Company regarding this Privacy Policy?

The Company Website contains a Contact Form at Contact Us, which can be used for electronic contact with the Company. If You use this option to contact the Company, the data entered by You in the form will be transmitted to the Company and stored as part of Your information.

Alternatively, You can contact the Company via email at contact@weopt.com. In this case, Your information transmitted by email will be stored. If needed, Your information will be relayed to the Company’s third-party partners to for the sole purpose of processing any request by You in the communication.