Enjoy Raising Healthy Eaters
Becoming GmbH (hereinafter, “GrowwW” or the “Provider”), with registered office in Oberschleißheim, operates the website www.growww-app.com (hereinafter, the “Website”) as well as the GrowwW app, a digital nutrition app (hereinafter, the “App” or the “Product”) for Android and iOS.
The following Data Protection Policy informs you about the types of personal data of GrowwW users that are processed, the purposes for which they are processed, and the scope of processing. The Data Protection Policy applies to all processing of personal data performed by GrowwW, both in connection with service provision and, in particular, on the Website and in the GrowwW App, which users can install on their mobile end device, as well as within external online presences, such as GrowwW’s social media profiles (hereinafter, collectively referred to as the “Online Offer”).
The controller within the meaning of the General Data Protection Regulation (GDPR)—i.e., the entity responsible for collecting, processing and using personal user data—is
Becomyng GmbH
Feierabendstr. 31
85764 Oberschleißheim
Germany
service@growww-app.com
All incoming and outgoing data—both in the communication with the Apps and in third-party provider communication—are transmitted in encrypted form. The encrypted connection when using the GrowwW Website can be seen, for instance, via the address bar of the browser being used, which begins with “https://”, and via the encryption symbol found there. Because of encryption, the transmitted data cannot be read by third parties.
“Personal data” for the purposes of the GDPR means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Personal data (e.g., e-mail address, nutritional data in the App) will be processed by the Provider only pursuant to the provisions of applicable data protection law. The following provisions inform you about the nature, scope and purpose of the collection, processing and use of personal data.
The IT infrastructure and associated services are provided by the web hosting service Backendless Corp 2591 Dallas Pkwy, Ste 300 Frisco, TX 75034, USA. Backendless Corp is a cloud service provider and offers a platform for internet-based business processes. For the hosting tools, only the personal data collected by GrowwW will be stored on the servers of Backendless These include, in particular, meta and communication data, contact data, such as names and addresses, contract and payment data and content data (completed forms). In this regard, the data are processed only to the extent necessary for fulfilling the hosting contract. The data protection policy and other information of Backendless Corp can be found here: https://backendless.com/privacy-policy/
In order to make the Website more user friendly and more effective overall, GrowwW itself or third parties engaged by GrowwW for this purpose store cookies on the user’s hard drive, provided the user has consented to this in accordance with Article 6(1)(a) GDPR.
A cookie is a small text file that is used, inter alia, to record information with respect to use of a website. These cookies cannot execute programs or transmit viruses to the user’s computer. They do not contain any personal data, cannot be attributed to specific persons, and, unless described otherwise, will be automatically deleted after one year, at the latest. These data are not combined with other data sources.
It is also possible to use websites operated by the Provider without cookies. The storage of cookies can be deactivated or limited to certain websites in the respective browser, or the browser can be configured in such a way that it notifies the user once a cookie is sent. The user can also delete cookies from the hard drive of their PC at any time.
In order to be able to use the App, the user must provide the required information “e-mail address” and “password”. These are used to identify the user and for the purpose of communication between the Provider and the user. The e-mail address and all other user data cannot be viewed by other users. The data are stored on the basis of the consent of each user under Article 6(1)(a) GDPR.
When creating a personalized user account, the user can optionally provide, in addition to the required information (e-mail address and password) the first name, which is then recorded by GrowwW.
In addition, GrowwW records data that are provided by the user through a personalized user account, which can be entered when using the App. This comprises a user profile, which includes, but is not limited to, the below-listed body and health data:
The data are collected on the basis of the user’s consent under Article 6(1)(a) GDPR. The provision of body data is necessary in order to be able to use the App’s features. GrowwW is aware of the importance of additional measures to protect the privacy of children. Should GrowwW learn that personal data about a child under the minimum age were collected without parental consent, GrowwW will initiate steps to erase these data without delay.
When the App is installed, the following are recorded one time:
These data are recorded in order to improve and personalize our services, and this takes place on the basis of our legitimate interest pursuant to Article 6(1)(f) GDPR.
When the App is being used, GrowwW furthermore records the following:
These data are recorded in order to improve and personalize the offered services, and this takes place on the basis of GrowwW’s legitimate interest pursuant to Article 6(1)(f) GDPR.
Where a contractual relationship between the user and GrowwW is to be established, substantively structured or changed, GrowwW stores personal data of the user on the basis of Article 6(1)(b) GDPR (see the list of personal data under No. 3.3.5 to 3.3.7), provided this is necessary for the performance of the contract. Through an in-app purchase, the user has the ability to acquire the GrowwW App in connection with a subscription. If the user decides to acquire the GrowwW and presses the order button, they will be forwarded directly to the Apple App Store or the Google Play Store, depending on their operating system.
When the user is forwarded to the appropriate app store, GrowwW in cooperation with the service provider RevenueCat transmits the starting and ending date and, if applicable, the subscription termination date, as well as the reason for termination (e.g., after a possible cancellation). The payment processing data are collected directly by the app stores and RevenueCat. The data protection policies of the app stores can be viewed here:
Applicable to the payment transactions are the business terms and conditions and the data protection policies of the respective payment service providers, which are available on the respective websites or transaction apps.
GrowwW takes the protection of personal user data very seriously. For this reason, GrowwW treats personal data confidentially and in accordance with statutory provisions concerning data protection as well as this Data Protection Policy. GrowwW therefore collects and stores only data that are provided by third-party providers on the basis of the respective user consent under Article 6(1)(a) GDPR and transmits corresponding data to them. Subject to statutory or contractual permissions, GrowwW processes the data in a third country or has the data processed there only where the special requirements of Articles 44 et seqq. GDPR are met. Processing takes place, e.g., on the basis of special safeguards, such as the observance of officially recognized, special contractual obligations (“standard contract clauses”).
If the European Commission does not attribute to a third country the same level of data protection as the EU, then GrowwW ensures the maintenance of the European level of data protection through the use of standard contract clauses (SCC) and binding company rules pursuant to Article 46(1) and (2)(c) GDPR. Nevertheless, it is possible under certain circumstances that authorities in a third country may access user data for control and monitoring purposes and, in this regard, that effective legal remedies and data subject rights may not be enforceable.
GrowwW regularly notifies its users by e-mail about child nutrition, recipes and other interesting offers and tips from the field of child nutrition, etc. Registration is voluntary and takes place using a double opt-in procedure. After registering, the user receives an e-mail requesting that they confirm their registration. This is necessary so that a third party cannot register to receive the newsletter using someone else’s e-mail address. In order to document that the registration meets the legal requirements, it is logged on the basis of GrowwW‘s legitimate interest pursuant to Article 6(1)(f) GDPR.
As part of registration on the Website or in the App, the user consents to the processing of the provided data for the purpose of sending and receiving e-mails (Article 6(1)(a) GDPR). Furthermore, the user consents that GrowwW may collect and process data about their usage behavior (namely, opening the e-mail and clicking on links in it) so that the content of the mailings can be tailored to the respective needs, e.g., if a user repeatedly clicks on links about topic A but not about topic B, they will receive only links about topic A in future mailings.
The consent granted by the user to receive these emails may be withdrawn at any time and without providing reasons with prospective effect by deactivating the functionality in the app settings or contacting the customer service via serice@growww-app.com.
In addition, receipt can be stopped by using a link found at the end of each newsletter. GrowwW may store the provided e-mail address and the data stored in connection with logging the registration for up to three years on the basis of its legitimate interest in order to be able to demonstrate that consent had previously been given. The processing of these data is limited to the purpose of possible defense against claims. An individual erasure request is possible at any time, provided that the former existence of consent is confirmed at the same time.
The newsletter, as well as transactional-emails, is sent via Klaviyo, 125 Summer Street, Boston, MA 02110, USA. The data protection provisions of Klaviyo can be viewed here: https://www.klaviyo.com/legal/privacy. Klaviyo may use the data of recipients in pseudonymous form, i.e., with attribution to a user, for the purpose of optimizing or improving its own services, e.g., for technical optimization of the sending and presentation of the newsletter and the transaction e-mail or for statistical purposes. However, Klaviyo does not use the data of GrowwW mailing recipients to contact them directly or to share the data with third parties.
The aforementioned service providers are utilized based on GrowwW’s legitimate interest pursuant to Article 6(1)(f) GDPR and a processing contract pursuant to Article 28(3) GDPR.
GrowwW is aware of the importance of additional measures to protect the privacy of children. Persons under the age of 16 may not open an account unless a parent has consented in accordance with applicable law. Should GrowwW learn that personal data about a child under the minimum age were collected without parental consent, GrowwW will initiate steps to erase these data without delay. Parents who believe that their child has sent us personal data and would like to have these erased should contact GrowwW using the contact data provided in No. 1.
Based on the user’s consent within the meaning of Article 6(1)(a) GDPR, GrowwW utilizes various tools and plug-ins for the purpose of web analysis, remarketing and retargeting. In doing so, cookies are used that forward the IP address and/or record and analyze different types of data. This includes, for example, the number of Website visitors, visit duration, average page-loading time and visitor origin. These cookies are used for the purpose of being able to put together more targeted offers for GrowwW users.
Specifically:
GrowwW utilizes Google Tag Manager on its Website. The provider is Google Ireland Ltd. (“Google”), Google Building Gordon House, Barrow Street, Dublin 4, Ireland. Google Tag Manager is a tool used to embed tracking or statistics tools and other technologies on the Website. Google Tag Manager does not itself create any user profiles, store any cookies, or perform any independent analyses. It is merely used to manage and run the tools embedded through it. For this purpose, however, Google Tag Manager records certain aggregated data for the purpose of diagnosing how the tracking and statistics tools are running. These data do not contain any IP addresses or IDs that can be linked to a specific person.
GrowwW uses Google Analytics on the Website for the purpose of analyzing use of the Website. The provider of web analysis services is Google Ireland Ltd. (“Google”), Google Building Gordon House, Barrow Street, Dublin 4, Ireland.
Firebase provides app developers with a technical infrastructure and a variety of tools, including Google Analytics by Firebase. With it, GrowwW can record and analyze user behavior in order to adjust the App to meet the needs of users and to better control features and events. Google Analytics use cookies, which facilitate an analysis of the use of the Website by users. The information generated by the cookie about user activities on this Website is normally transferred to a Google server in the U.S. and stored there. On behalf of GrowwW, Google uses this information in order to evaluate user activities on the Website, to compile reports about Website activities for GrowwW, and to provide additional services associated with Website use and internet use. In addition, Google will, if necessary, transmit this information to third parties if this is required by law or if third parties process these data on behalf of Google.
Further information about Google’s use of data for marketing purposes can be found at https://www.google.com/policies/technologies/ads. If the user wishes to object to interest-related advertising by Google marketing services, they can use the settings and opt-out options provided by Google at http://www.google.com/ads/preferences.
Google’s data protection policy is available at https://www.google.com/policies/privacy.
On the Website and in the App, the Provider uses Google Ads Remarketing, an online advertising program of Google Ireland Ltd. (“Google”), Google Building Gordon House, Barrow Street, Dublin 4, Ireland. In connection with Google Ads Remarketing, GrowwW uses what is known as conversion tracking. If the user clicks on an advertisement placed by Google, a cookie is set for the conversion tracking. These cookies lose their validity after 30 days and are not used to personally identify users. If the user visits certain pages on this Website and the cookie has not yet expired, Google and the Provider can recognize that the user clicked on the advertisement and was redirected to this site.
Each Google Ads Remarketing customer receives a different cookie. The cookies cannot be tracked across the websites of Ads Remarketing customers. The information obtained with the aid of conversion cookies is used to compile conversion statistics for Ads Remarketing customers that have elected to use conversion tracking. Customers learn about the total number of users who clicked on their advertisements and were redirected to a site furnished with a conversion tracking tag. However, they do not receive any information that can be used to identify the user. If a user wishes to decline to take part in tracking, they can object to such use by deactivating the Google conversion tracking cookie through their internet browser under user settings. In addition, the user can prevent the capture and processing by Google of the data generated by the cookie relating to their use of the Website (including their IP address) by downloading and installing the browser plug-in available at the following link: tools.google.com/dlpage/gaoptout. The user will then no longer be included in conversion tracking statistics. However, this will likely limit the functionality of this Website.
The information generated by the cookie about the user’s use of this Website is transferred to a Google server in the U.S. and stored there. In the event of activation of IP anonymization on this Website, however, the user’s IP address is first truncated by Google within the Member States of the European Union or in other Contracting States of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a Google server in the U.S. and truncated there. Google uses this information on behalf of the operator of this Website in order to evaluate the user’s activity on the Website, to compile reports about Website activities, and to provide other services to the Website operator associated with Website use and internet use.
More information about Google Ads Remarketing and conversion tracking can be found in the data protection provisions at https://safety.google/privacy/ads-and-data/.
GrowwW utilizes Apple Search Ads in the App. Apple Search Ads is an online advertising program of the technology group Apple, One Infinite Loop, 95014 Cupertino, USA. Through Apple Search Ads, the Provider’s App will be displayed to the user as the top result when the user searches in the App Store.
The user can view and limit their personal data that Apple uses in order to display relevant advertising to them. In addition, the user can prevent location-specific information from being used to find out which advertisements they can see. Further data protection notices are available at https://searchads.apple.com/privacy.
Based on the respective user consent within the meaning of Article 6(1)(a) GDPR, GrowwW uses various social media plug-ins for the purpose to provide educational content.
Features and content of the service YouTube, offered by YouTube LLC, 901 Cherry Ave. San Bruno, CA 94066, USA, may be embedded on both the GrowwW Website and in the App. This may include content such as videos, which allow users to like content and follow content creators or the Provider’s posts.
If the user is a member of the YouTube platform, YouTube can allocate the selection of the aforementioned content and features to their profile there. The information generated by the plug-in about their use of this Website is transferred to a YouTube server in the U.S. and stored there. In the event of activation of IP anonymization on this website, however, the user’s IP address is first truncated by YouTube within the Member States of the European Union or in other Contracting States of the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transferred to a YouTube server in the U.S. and truncated there. YouTube uses this information on behalf of the operator of this Website in order to evaluate the user’s activity on the Website, to compile reports about Website activities, and to provide other services to the Website operator associated with Website use and internet use.
The YouTube data protection policy can be found at https://www.youtube.com/howyoutubeworks/our-commitments/protecting-user-data/.
GrowwW stores the user’s personal data for the period of use of the App. If the user account is deleted, the e-mail address, first name and links to third-party providers will be definitively and irretrievably deleted.
The user has the following rights, which, with the exception of No. 14.9, can be asserted with the controller. The contact data can be found in No. 1.
The user has the right at any time to obtain free information about their personal data stored by GrowwW, the origin and recipients of the data, the purpose of data processing and the planned duration of data storage, including a copy of the personal data that are the subject of the processing.
In addition, the user has the right at any time to have inaccurate or incomplete personal data rectified or completed without undue delay.
The user has the right to withdraw their consent to data processing at any time with prospective effect, without there needing to be a ground for withdrawal.
Subject to the prerequisites of Article 17 GDPR, the user may request erasure of their personal data. Their entitlement to erasure depends, inter alia, on whether the data concerning them are still needed by GrowwW for fulfilling its statutory duties.
Subject to the prerequisites of Article 18 GDPR, the user may request restriction of the processing of the personal data concerning them.
The user has the right to receive their provided personal data in a structured, commonly used and machine-readable format or to transmit those data to another controller, where the processing is based on consent and the processing is carried out by automated means.
The user may at any time make use of their right to object to the creation of user profiles and to the processing of personal data concerning them, where the processing takes place on the basis of Article 6(1)(e) or (f) GDPR. The personal data will no longer be processed unless compelling, legitimate grounds outweigh the user’s interests, rights and freedoms. Where a user’s personal data are used for direct marketing purposes, they of course have the right to object at any time to such processing.
The user has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.
In addition, the user has the right to lodge a complaint with the competent data protection authority about our processing of your personal data.
This Data Protection Policy is currently valid in the version of February 2024.
If our Website or our Product is enhanced, or if legal requirements should change, it may become necessary to amend this Data Protection Policy. The current version of this Data Protection Policy can be viewed and printed out at any time by visiting https://www.growww-app.com/privacy.
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