Privacy Policy

Privacy Policy

Last updated April 2023

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

Welcome to YouGrow and our website at www.yougrow.xyz (our “website”). We appreciate your interest in our Privacy Policy. At YouGrow, we take the protection of your data very seriously, and in the below we explain what data we collect when you use our website and how it is used.

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General Information

1. What law applies?

Our use of your Personal Data is subject to both Estonia`s Personal Data Protection Act (“PDPA”) and the EU`s General Data Protection Regulation (“GDPR”), and of course we process your Personal Data accordingly.

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2. What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an individual. This may include, a name, date of birth, e-mail address, postal address, or telephone number but also online identifiers such as IP addresses or device ID`s.

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3. What is processing?

"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

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4. Who is responsible for data processing?

The responsible party within the meaning of the PDPA and the GDPR is YouGrow OÜ of Sepapaja tn 6, 15551, Tallinn, Harju, Estonia (“YouGrow”, “we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please contact us using our Contact Form, or write to us at marketing@yougrow.xyz.

5. What are the legal bases of processing?

In accordance with the PDPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data:

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• For the fulfillment of contractual obligations

• The purposes of the data processing are primarily based on the service we provide.

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• Within the framework of our legitimate interests

Where necessary, we process your data beyond the actual performance of the contract in order to safeguard legitimate interests of us or third parties. Examples are:

1. Ensuring IT security and IT operations,
2. Measures for business management and further development of our services,
3. Defense against third-party claims and enforcement of own claims.

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• Based on your consent

• Insofar as you have given us your consent to process personal data for certain purposes.

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6. Is there an obligation for me to provide data?

Within the scope of our business relationship, you are only required to provide personal data that is necessary for the establishment, implementation, and termination of a business relationship or that we are legally obliged to collect. Without this data, we will usually have to refuse to conclude the contract or will no longer be able to perform an existing contract and may have to terminate it.

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Data we collect automatically

1. Log data

Each time you visit our website, our system automatically records the following data from the visiting device and stores it in a so-called log file: i) Name of the retrieved file, ii) date and time of the visit, iii) amount of data transferred, iv) message about successful retrieval, type of browser and version used, v) IP address (identification of the user's device), vi) Operating system of the visiting device, vii) Internet service provider of the visiting device, viii) website from which you access our website, and ix) which of our website pages you are accessing. The legal basis for processing is our legitimate interest.

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2. Hosting

To provide our website, we use the services of Webflow, Inc. who processes all data to be processed in connection with the operation of this website on our behalf. The legal basis is our legitimate interest.

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3. Cookies

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. For further information on the Cookies we use, please refer to our Cookie Policy. The legal basis for processing is our legitimate interest and your consent.

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4. Third-party services and content

We use content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services ("services").

This always requires that the third-party providers of this content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any,

• Analytics: Google Analytics by Google LLC,

• Tag Management: Google Tag Manager and Google Site Tag by Google LLC,

• Remarketing and Advertisement:

• Facebook Remarketing by Meta Platforms Inc

• Google Ads by Google LLC,

If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices and the European Interactive Digital Advertising Alliance (Europe only).

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Data we collect directly

1. Contacting us

Personal data is processed depending on the contact method. In addition to your name and email address, IP address or phone number, we usually collect the context of your message, which may also include certain Personal Data. The personal data collected when you contact us is used to process your request and the legal basis is your consent.

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2. Providing our services

The protection of your data is particularly important to us in the performance of our services. We therefore only want to process as much Personal Data (for example, your name, address, e-mail address or telephone number) as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Data, to fulfill our contractual obligations to you or to carry out pre-contractual measures.

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3. When using our services

We process the data of our users in order to be able to provide you with our agency services as well as to ensure the security of our services and to be able to develop it further. This includes in particular our support, correspondence with you, fulfillment of our accounting and tax obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations as well as to fulfill our legal obligations. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent.

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Some of the data you choose to provide may be considered non-Personal Data and/or “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data. You may withdraw your consent and request us to stop using and/or disclosing your personal and special category data by submitting your written request to us.

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Where any Personal Data relates to a third party, you represent and warrant that the Personal Data is up-to-date, complete, and accurate and that you have obtained the third party’s prior consent for our collection, use and disclosure of their Personal Data for the Purposes. You agree that you shall promptly provide us with written evidence of such consent upon demand by us.

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4. Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

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5. Testimonials

Within your testimonial you may be able to display certain information, share certain details, knowledge, and insights. Content and data are publicly viewable. You have choices about the information on your testimonial. You don’t have to provide additional information and it is your choice whether to include sensitive information and to make it public. Please do not post or add personal data to your profile that you would not want to be available. The legal basis for the storage is our legitimate interest and your consent .

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General Principles

1. Who receives my data?

Within YouGrow, those that need your data to fulfill our contractual and legal obligations will receive access to it.

Processors used by us may also receive data for these purposes. These are companies in the categories of IT services, telecommunications, and sales and marketing. Where we use processors to provide our services, we take appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of personal data in accordance with the relevant legal provisions.

Data is only passed on to third parties within the framework of legal requirements. We only pass on users' data to third parties if this is necessary, for example, for contractual purposes or on the basis of legitimate interests in the economic and effective operation of our business or you have consented to the transfer of data.

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2. How long will my data be stored?

As far as necessary, we process and store your personal data for the duration of our business relationship, which also includes, for example, the initiation and execution of a contract.

In addition, we are subject to various storage and documentation obligations, which result from the minimum statutory retention periods and the Ministry of Finance, or Tax Administration, among others. The retention and documentation periods specified there are two to eleven years.

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3. How do we secure your data?

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of content or contact requests that you send to us. We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

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4. Are data transferred to a third country or to an international organization?

Your data is not transferred to third countries (countries outside Estonia and the EEA).

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5. Special Category Data

Unless specifically required when using our services and explicit consent is obtained for that service, we do not process special category data.

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6. Minors

We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

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7. Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

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8. Do Not Sell

We do not sell your Personal Data.

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Your Rights and Privileges

1. Privacy rights

Under the PDPA and GDPR, you can exercise the following rights:

• Right to information
• Right to rectification
• Right to object to processing
• Right to deletion
• Right to data portability
• Right of objection
• Right to withdraw consent
• Right to complain to a supervisory authority
• Right not to be subject to a decision based solely on automated processing.

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If you have any questions about the nature of the Personal Data we hold about you, or if you wish to exercise any of your rights, please contact us.

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2. Updating your information

If you believe that the information, we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us.

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3. Withdrawing your consent

You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

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4. Access Request

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

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5. Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Estonia is: Data Protection Inspectorate,

Tatari 39, Tallinn 10134, Estonia, www.aki.ee

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Changes and Questions

We may update this Privacy Policy from time to time. If we make changes to this Privacy Policy or materially change our use of your Personal Data, we will revise this Privacy Policy accordingly and also change the effective date at the end of this section. We encourage you to periodically review this Privacy Policy to be informed of how we use and protect your Personal Data. If you would like to contact us regarding our privacy practices for any reason, please do so using the details provided above.