Privacy policy

European / GDPR

Last updated: 9 November 2025

Introduction

This Privacy Policy explains how GROW (“we”, “us”, “our”) collects, uses and shares personal data when you use our website, platform and related services. If you are located in the EU, this policy describes processing under the GDPR.

Controller & Contact

Data Controller: GROW
Contact / DPO (if applicable): [email protected]

Personal Data We Collect

Identity & contact data (name, email, phone);
Payment details processed via Cardcom (we do not store full card numbers);
Technical data (IP address, device, browser);
Usage & analytics data (Google Analytics, Facebook Pixel);

Lawful bases for processing

We rely on the following lawful bases under the GDPR:

Contractual necessity — to provide services;
Legal obligation — to comply with laws and tax obligations;
Legitimate interests — security, fraud prevention, improving services (we balance our interests against your rights);
Consent — for marketing communications and non‑essential cookies.

Data subject rights (EU)

You have the right to access, rectify, erase, restrict processing, portability and object. To exercise rights, contact [email protected]. We will respond in accordance with GDPR deadlines.

International transfers

Data may be transferred to third‑country processors (e.g. AWS, Google Cloud, Cardcom). We implement appropriate safeguards such as standard contractual clauses (SCCs) and assess recipient adequacy where applicable.

Additional notice for EU users

Where relevant, EU users are entitled to exercise the GDPR rights above. We maintain records of processing activities and retention schedules, and strive to minimise held personal data.

Cookies & Tracking

We use cookies for essential site functions and analytics. Non‑essential cookies are only used with consent. You can manage cookie preferences via the cookie banner.

Security & retention

We protect personal data using technical and organisational measures. Retention periods depend on the purpose; we keep data only as long as necessary or as required by law.

Complaints

If you are an EU resident and wish to lodge a complaint, please contact [email protected]. You may also contact your local supervisory authority.

Company: GROW • Address: Harav Kook St 62, Tel‑Aviv, Israel • Email: [email protected]

United States — CCPA/State Notices

Last updated: 9 November 2025

Overview

This section addresses privacy notices relevant to residents of the United States, including California residents under the California Consumer Privacy Act (CCPA).

Information We Collect

We collect categories of personal information similar to those described above (identifiers, commercial information, internet/network activity, professional information, and payment data processed by Cardcom).

CCPA — Your Rights (California)

Right to Know: You can request categories and specific pieces of personal information we have collected.
Right to Delete: Request deletion of personal information subject to exceptions.
Right to Opt‑Out of Sale: We do not sell personal information as defined by the CCPA. If our practice changes, we will provide a proper opt‑out mechanism.
Non‑Discrimination: We will not discriminate against consumers for exercising CCPA rights.

How to exercise your rights

To exercise rights under CCPA/other state laws, contact: [email protected]. We will verify requests and respond within statutory timeframes.

Third‑party processors

We share personal information with service providers for business purposes (billing, hosting, analytics). Contracts require service providers to implement security safeguards and to process data only per our instructions.

GROW — Contact: [email protected]