THE GROW CLUB – GLOBAL PRIVACY POLICY

Last Updated: July 18, 2025

Grow Club Holdings, LLC, its founders, and affiliates (collectively, "The Grow Club," "we," "us," or "our") are committed to protecting your privacy and handling your data in an open and transparent manner. This Global Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, The Grow Club (the "App"), and its associated services (the "Services").

This policy is designed to comply with U.S. privacy principles and the European Union's General Data Protection Regulation (GDPR). By accessing or using our Services, you acknowledge that you have read and understood the terms of this policy.

1. Information We Collect

We collect information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual ("Personal Information").

• 1.1. Information You Provide to Us Directly: Account Information (name, email, etc), Payment Information (processed by third parties), Communications.
• 1.2. Information Collected Automatically: Usage Information, Device Information, Location Information (with your consent), Transaction Information.

2. How We Use Your Information & Our Lawful Bases for Processing

We use the information we collect for specific business purposes. For individuals in the European Economic Area (EEA) and the UK, we must have a "lawful basis" for each use.

• To Provide and Operate the Services: We process your Account and Device Information to deliver the core functionality of the App.
  • Lawful Basis (GDPR): Performance of our contract with you.
• To Process Transactions and Manage Rewards: We use your Payment and Transaction Information to facilitate purchases and manage your "Petals."
  • Lawful Basis (GDPR): Performance of our contract with you.
• For Security and Fraud Prevention: We monitor usage and analyze data to protect the App, our users, and prevent illegal activity.
  • Lawful Basis (GDPR): Our legitimate interests in maintaining a secure platform.
• To Communicate with You: We use your contact information to send administrative messages, security alerts, and provide customer support.
  • Lawful Basis (GDPR): Performance of our contract and our legitimate interests in providing quality service.
• For Marketing and Promotions: With your permission, we will send you information about offers and new features.
  • Lawful Basis (GDPR): Your explicit Consent. You can withdraw this consent at any time.
• To Improve Our Services: We analyze usage and device information to understand how our users interact with the App, allowing us to improve the user experience.
  • Lawful Basis (GDPR): Our legitimate interests in developing and improving our business.

3. How We Share Your Information

We do not sell your Personal Information. We may share your information in the following limited circumstances:

• With Third-Party Merchants: We share transaction information with merchants as necessary to confirm your payment and facilitate your purchase.
• With Third-Party Service Providers: We share information with third-party vendors, consultants, and other service providers who perform services on our behalf, such as payment processing, data analysis, cloud hosting, and customer support. These service providers are contractually obligated to safeguard your information and are not permitted to use it for their own purposes.
• For Legal Reasons and Safety: We may disclose your information if we believe disclosure is necessary to (a) comply with any applicable law, regulation, legal process, or governmental request; (b) enforce our Terms of Service; (c) protect the security or integrity of our Services; or (d) protect the rights, property, or safety of The Grow Club, our users, or the public.
• In Connection with a Business Transfer: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• With Your Consent: We may share your information for any other purpose with your consent.

4. International Data Transfers

The Grow Club is based in the United States. Your Personal Information will be transferred to, processed, and stored on our servers in the United States. For individuals in the EEA or UK, this means your data is transferred outside of your home jurisdiction.

We have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Privacy Policy. The transfer mechanism we rely upon is the Standard Contractual Clauses (SCCs) adopted by the European Commission, which contractually obligate the receiving party to protect your data to a standard equivalent to that of the EU.

5. Data Security

We implement commercially reasonable administrative, technical, and physical security measures designed to protect your Personal Information from unauthorized access, use, or disclosure. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

6. Data Retention

We retain your Personal Information for as long as your account is active or as needed to fulfill the purposes outlined in this policy. We will also retain information as necessary to comply with our legal obligations (e.g., for tax and accounting purposes), resolve disputes, and enforce our agreements. After such time, data will be deleted or anonymized.

7. Your Rights and Choices

• 7.1. Rights for All Users:
  • Account Information: You may review and update your account information at any time within the App's settings.
  • Marketing Opt-Out: You may opt-out of receiving promotional emails by following the unsubscribe instructions in those emails.
• 7.2. Legal Rights for Residents of the EEA, UK, and Switzerland:
  If you are a resident of the European Economic Area, United Kingdom, or Switzerland, you have enhanced rights regarding your Personal Information. These include:
  • The right to access: You have the right to request a copy of the Personal Information we hold about you.
  • The right to rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
  • The right to erasure: You have the right to request that we erase your Personal Information, under certain conditions.
  • The right to restrict processing: You have the right to request that we restrict the processing of your Personal Information, under certain conditions.
  • The right to object to processing: You have the right to object to our processing of your Personal Information based on our legitimate interests.
  • The right to data portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, in a structured, commonly used, machine-readable format.
• To exercise any of these rights, please contact us at the email address provided below. We will respond to your request in accordance with applicable data protection laws.

8. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect Personal Information from children under 18. If we become aware that a child under 18 has provided us with Personal Information, we will take steps to delete such information.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email (sent to the email address specified in your account) or by means of a prominent notice within the App prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

10. Contact Us 

For any questions, concerns, or to exercise your rights under this Privacy Policy, please contact our privacy team:

Grow Club Holdings, LLC

Attn: Privacy Department

Email: privacy@growclub.com

Residents of the EEA and UK have the right to lodge a complaint with a data protection supervisory authority. You can find your local authority's contact information here.