This Privacy Policy (“Policy”) describes the “Personal Data” that GrowSocial (“We”), (“Us”) collect, how we use it, how we share it, how we store it, the purpose and legal basis for the processing and our general policies regarding privacy and compliance with GDPR and other applicable laws.
This Policy also outlines your data subject rights, including the right to object to some uses of your Personal Data by us.
By visiting any of GrowSocial’s websites or services, you give consent to have your personal data collected and processed by us, and you give consent to have your data processed by third parties in accordance with this the specifications in this Policy.
With regards to cookies, you can read our separate cookie policy here: growsocial.com/cookie-policy/
The following terms used herein shall have the meanings set forth below (with references to the singular also referring to the plural and vice versa):
“We”, “Us”, “Our”, “GrowSocial” means GrowSocial LTD, a company established under the laws of Malta, having its registered office at Level 5, Carolina Court, Giuseppe Cali Street, TA‘XBIEX, XBX 1425, Malta, registered with the Malta Business Registry under number C 79065.
“Visitor” means any individual who visits/accesses any of our websites.
“Client”, “User” means any person or legal entity who has an account with GrowSocial, paid or otherwise.
“You” means either Visitor or Client, whichever applies to you in the context of the provision.
“GDPR” means The General Data Protection Regulation (EU Regulation 2016/679), the Data Protection Law Enforcement Directive and other rules concerning the protection of personal data.
You can read more about GDPR at EU’s official website:
https://commission.europa.eu/law/law-topic/data-protection/data-protection-eu_en
and en.wikipedia.org/wiki/General_Data_Protection_Regulation
“Personal Data” means Personal Data as defined in GDPR law. For further details, please visit EU’s official page: https://commission.europa.eu/law/law-topic/data-protection/reform/what-personal-data_en
“Controller” means “Data Controller” as defined in GDPR law.
“The data controller determines the purposes for which and the means by which personal data is processed. So, if your company/organisation decides ‘why’ and ‘how’ the personal data should be processed it is the data controller…”
“Processor” means “Data Processor” as defined in GDPR law.
“The data processor processes personal data only on behalf of the controller. The data processor is usually a third party external to the company…”
“Client Data” means data that GrowSocial collects and/or processes of its Clients and Users.
“Consent” means consent as defined by GDPR law:
https://edpb.europa.eu/sites/default/files/files/file1/edpb_guidelines_202005_consent_en.pdf
“Legitimate Interest” means legitimate interests as defined in GDPR law (Art. 6(1)(f) and Recital 47 GDPR).
https://commission.europa.eu/law/law-topic/data-protection/reform/rules-business-and-organisations/legal-grounds-processing-data/grounds-processing/what-does-grounds-legitimate-interest-mean_en
https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679&from=EN#d1e40-1-1
“DPO” means Data Protection Officer as defined by EU’s GDPR laws.
https://edps.europa.eu/data-protection/data-protection/reference-library/data-protection-officer-dpo_en
“Platform” means the Software system built by GrowSocial, accessible at app.growsocial.com and available to Clients for payment.
“Influencer” means a social media user with more than 1000 followers.
“Influencer Marketing” or “IM” means a form of social media marketing involving paid or free endorsements and/or product placement with influencers.
“Prospect” or “Prospective Clients” means companies and individuals working for such companies GrowSocial and its affiliates believe are interested in GrowSocial’s free and/or paid Services.
“EU” means European Union.
“US” means the United States of America.
“UK” means the United Kingdom.
“AI” means artificial intelligence.
GrowSocial reserves the right to modify, amend, or alter our Privacy Policy at any time and without previous notification to anyone. You understand and agree that it is your duty to check our Privacy Policy for updates routinely.
The Privacy Policy were latest edited on the 12th of March 2023.
3.1. You have the right to request and receive/access any personal data that we may have about you.
3.2. You have the right to have your personal data removed from our systems. We may need to keep certain basic information for legal reasons such as bookkeeping.
3.3. You have the right to request rectification of your personal data if you believe the data we have about you is incorrect.
3.4. Whenever GrowSocial processes/collects your personal data, you have the legal right to get a copy of the data we may have about you.
3.5. You have the right to request to have any of your personal data removed from our systems.
3.6. You have the right to object to our collecting/processing of your personal data.
3.7. Withdraw your consent to processing of your Personal Data.
We have appointed a Data Protection Officer to ensure that we continuously process your Personal Data in an open, accurate, and legal manner. If you have any questions regarding your privacy, or your data, or would like to file a complaint, or have any other related questions, please contact our Data Protection Officer at: dpo@growsocial.com
If you consider GrowSocial to process your personal data in an incorrect way, please contact our DPO.
Personal data we may collect/process from you is stored within the European Economic Area (EEA). It may be transferred to and processed in a country outside of EEA through third-party services, for example, payment processors, and credit card providers. Any such transfer of your personal data will be done in compliance with the GDPR and local laws.
GrowSocial.com follows a standard procedure of using log files. These files log Visitors when they interact with our websites. Most server hosting companies do this and a part of hosting services’ analytics.
The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and preventing fraud.
These may have access to your Personal Data:
The legal ground for collecting and/or processing data of Visitors is Legitimate Interest.
With regards to data from Visitors, GrowSocial is a “Controller” in accordance with GDPR law.
We and/or third parties such as Google Analytics may collect data such as:
The purpose of collecting the data is to:
We use various cookies to analyse the behavior of Visitors, please read more details in our cookie policy here: growsocial.com/cookie-policy/
Using third-party providers such as Google Analytics, we track anonymized data of Visitors. You can read Google’s privacy policy here: https://policies.google.com/privacy?hl=en-US
The legal ground for collecting and/or processing data of Clients/Users is Consent.
When you accept the terms to create an account with GrowSocial, you consent to all of our terms, including privacy policy, cookie policy, and Platform Terms (https://growsocial.com/terms-conditions/ ).
GrowSocial is a Controller of the “Client data”, the data of You as a client.
All of the provisions of the Platforms Terms are applicable and combined with the Privacy Policy they form a binding contract between you and GrowSocial.
You acknowledge that you are using or accessing the Platform on your own behalf or on behalf of a legal entity you represent and that you have read, understand, and agree to be bound by these Terms and Conditions.
The terms “Client” or “You” refer to the legal person and its affiliates if you are accepting these Terms on behalf of a legal person and you represent that you are authorized to enter into a legal agreement on behalf of the legal entity.
We may process the following personal data from Clients/Users:
Why we collect this data:
More information:
In case you want to permanently remove your data from our databases, please contact customer support.
In terms of the Personal Data the Clients collect, generate, and create inside the Platform, GrowSocial is a Processor and the Client is the Controller of Personal Data.
In other words, when Clients/Users create and/or collect data from Influencers and other third parties inside the system, the Client is the Controller of the Personal Data of the Influencer. The Client is responsible for handling the information in accordance with GDPR and all other applicable laws, GrowSocial is in this context the Processor (service provider) of the data.
The legal ground for collecting and/or processing data is Legitimate Interest.
GrowSocial has a legitimate interest to collect publicly available data of prospective clients in order to contact them and offer our products and services.
GrowSocial is a Controller of data of Prospects.
We may process the following personal data of Prospective Clients:
GrowSocial is a Controller of data of Influencers.
The legal ground for collecting and/or processing data is Legitimate Interest.
GrowSocial has a legitimate interest to collect publicly available data of Influencers in order to help Clients work with Influencers.
We process the personal data obtained only from publicly available social media profiles through automatic means.
The Influencers benefit from appearing on GrowSocial’s Platform since Clients who spend money on Influencer Marketing is more likely to find them and offer them paid sponsorship deals.
There is very limited potential privacy damage to the Influencers as the information we show is already publicly available on social media. For the average Influencer, 100+ times more people will see the information on social media vs through GrowSocial’s platform.
We only collect and process information from Influencers with an open public profile and 1000+ followers. We will process the following Personal Data or content:
We also use AI and scripts to calculate statistics from publicly available data.
In accordance with Recital 62 and Article 14(5)(b) of GDPR, We are allowed to collect and process this information without individually informing each data subject because, due to 25+ million Influencers on the Platform, the provision of such information proves impossible or would involve a disproportionate effort.
“(1) However, it is not necessary to impose the obligation to provide information where the data subject already possesses the information, where the recording or disclosure of the personal data is expressly laid down by law, or where the provision of information to the data subject proves to be impossible or would involve a disproportionate effort. (2) The latter could in particular be the case where processing is carried out for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes. (3) In that regard, the number of data subjects, the age of the data, and any appropriate safeguards adopted should be taken into consideration.”
If an influencer wishes to be removed from the Platform, they can contact GrowSocial’s support team at: support@growsocial.com. Please use the subject line “Remove me from the Platform”.
The update frequency varies depending on the number of followers of the account, the more followers, the more often the profile data is updated.
When an account profile is deleted, our automatic system will delete it from the Platform. This process may take months.
When an account profile is set to private, our automatic system will make it private the next time the profile is updated. This process may take months.
If you want your profile updated or deleted from our Platform, please contact support@growsocial.com, we strive to remove Influencers from the Platform within 24 hours on business days.
The legal ground for collecting and/or processing data of Affiliate Partners is Consent.
When you accept the terms to create an account with GrowSocial’s affiliate partner program, you consent to GrowSocial processing your data.
GrowSocial is a Controller of the data, Rewardful is the Processor of the data.
We may process the following personal data from Affiliate Partners:
Why we collect this data:
More information:
In case you want to permanently remove your data from our databases, please contact affiliates@growsocial.com
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
GrowSocial.com does not knowingly collect any Personal Data from children under the age of 16. If you think that your child has any kind of information on our websites, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our systems.
Under the CCPA, among other rights, California consumers have the right to:
Request that a business that collects a consumer’s personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
Request that a business deletes any personal data about the consumer that a business has collected.
Request that a business that sells a consumer’s personal data, not sell the consumer’s personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.
