Privacy Policy.
Last updated: January 1, 2025
1. Introduction
Growvest, Inc. ("Growvest," "we," "us," or "our") respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit or use the Growvest platform (the "Platform"). Please read this policy carefully. If you disagree with its terms, please discontinue use of the Platform. We reserve the right to make changes to this Privacy Policy at any time and for any reason, and we will notify you of material changes by updating the "Last updated" date.
2. Information We Collect
We collect information you provide directly to us, such as when you create an account, submit an investor profile, or contact us for support. This includes: (a) Identity information — your full name, date of birth, government-issued identification details, and Social Security number or tax identification number, collected as required to verify your accredited investor status and comply with anti-money-laundering (AML) and Know Your Customer (KYC) regulations; (b) Contact information — email address, phone number, and mailing address; (c) Financial information — bank account or wire transfer details, investment history, net worth attestations, and income documentation; (d) Account credentials — username and encrypted password; and (e) Communications — any messages you send to us. We also collect information automatically when you use the Platform, including IP address, browser type, operating system, referring URLs, pages viewed, and time spent on pages.
3. How We Use Your Information
We use the information we collect to: (a) create and manage your account and process your investment applications; (b) verify your identity and accredited investor status as required under Regulation D; (c) process transactions and send related information, including confirmations and receipts; (d) comply with applicable legal and regulatory obligations, including AML, KYC, and tax reporting requirements; (e) send you technical notices, updates, security alerts, and administrative messages; (f) respond to your comments, questions, and requests; (g) monitor and analyze trends, usage, and activities in connection with the Platform to improve our services; (h) detect, investigate, and prevent fraudulent transactions and other illegal activities; and (i) send promotional communications, subject to your right to opt out at any time.
4. Third-Party Sharing and Disclosure
We do not sell, trade, or rent your personal information to third parties for their own marketing purposes. We may share your information with: (a) Service providers — third-party vendors and partners who perform services on our behalf, such as identity verification, payment processing, data storage, email delivery, and customer support. These parties are contractually obligated to use your information only as directed by us; (b) Project sponsors — information necessary to facilitate investments in specific offerings, shared only with the relevant project sponsor and only to the extent necessary; (c) Legal and regulatory authorities — when required by law, regulation, legal process, or governmental request, including for tax reporting and regulatory compliance; (d) Business transfers — in connection with a merger, acquisition, reorganization, or sale of assets, in which case the successor entity will be bound by this Privacy Policy; and (e) With your consent — for any other purpose with your explicit consent.
5. Cookies and Tracking Technologies
We use cookies, web beacons, and similar tracking technologies to collect information about your browsing activities on the Platform. Cookies are small data files stored on your device that help us recognize you, remember your preferences, and improve your experience. We use: (a) Essential cookies, which are necessary for the Platform to function; (b) Analytics cookies, which help us understand how visitors interact with the Platform; and (c) Preference cookies, which remember your settings and choices. You can control cookies through your browser settings, though disabling certain cookies may affect the functionality of the Platform. We do not currently respond to "Do Not Track" signals.
6. Data Retention
We retain your personal information for as long as your account is active or as needed to provide you with our services. We also retain information as required to comply with our legal obligations, resolve disputes, enforce agreements, and fulfill regulatory requirements — which for securities-related records may be up to seven years or longer as mandated by applicable securities laws. When we no longer need personal information, we delete or anonymize it in accordance with our data retention policies and applicable law.
7. Data Security
We implement technical, administrative, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit and at rest, access controls limiting data access to authorized personnel, and regular security assessments. However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. If a data breach occurs that is likely to affect your rights or freedoms, we will notify you as required by applicable law.
8. Your Rights and Choices
Depending on your jurisdiction, you may have certain rights regarding your personal information, including: (a) Access — the right to request a copy of the personal information we hold about you; (b) Correction — the right to request correction of inaccurate or incomplete personal information; (c) Deletion — the right to request deletion of your personal information, subject to legal retention requirements; (d) Opt-out — the right to opt out of marketing emails at any time by clicking the "unsubscribe" link in any email or by contacting us directly; and (e) Data portability — the right to receive your personal information in a structured, machine-readable format. To exercise any of these rights, please contact us at privacy@growvest.com. We will respond to your request within 30 days, subject to any applicable legal limitations.
9. Children's Privacy
The Platform is not directed to individuals under the age of 18, and we do not knowingly collect personal information from minors. If we become aware that we have collected personal information from a person under 18, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a minor, please contact us at privacy@growvest.com.
10. Links to Third-Party Sites
The Platform may contain links to third-party websites or services that are not owned or controlled by Growvest. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. The presence of a link on the Platform does not constitute our endorsement of that site or its content.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you by updating the "Last updated" date at the top of this page and, where appropriate, by sending a notification to the email address associated with your account. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.
12. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at hello@growvest.com. We take privacy matters seriously and will work to address your inquiry promptly and thoroughly.