1. PERSONAL DATA WE COLLECT We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows: Personal Data You Provide: We collect Personal Data when you create an account through our website. ● Registration. When you create an account, we collect your first name, middle name, last name, residence address, social security number, and your email address. We also collect your phone number and password to be used for two-factor verification. We collect your bank account number and routing number to facilitate ACH transfers. We also collect information about your occupation and education level in order to determine your account limit. ● Account Usage. As you use your account to trade, we collect your account and portfolio details, such as live and historical orders, trades and positions, and balances. We also collect your site and account preferences, including site notification, sounds and confirmation dialogs and leaderboard preferences. We may collect your marketing and other communication preferences and a record of any consents you have given us. ● Identification. We will ask you to provide a copy of photo ID, a bank statement and photograph or video of your face for identity verification. ● Communications. If you contact us directly (e.g., via email, SMS, phone call, in-app messaging), we will collect your name, contact details, the content, date and time of your message and any attachments thereto, and other information you may directly provide to us. We will keep a record of how your communication with us was handled. If you contact us to request an increase in your account limit, we will ask for and collect additional information about your occupation and education level. Personal Data We Collect From Third Parties: We may engage a vendor to verify your credit score. We may collect all information that our vendor gathers about you from the check.
Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
● Internet Explorer ● Mozilla Firefox ● Google Chrome ● Apple Safari
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
2. HOW WE USE PERSONAL DATA We may use Personal Data for the following purposes:
● To operate, provide, and maintain our Services, to communicate with you about our Services, to respond to your inquiries, to fulfill our contract with you, to complete your transactions, and for other customer service purposes. This includes taking deposits and fees, paying out withdrawals. allowing you to make trades, maintaining your account and trading history, and closing / auto-deleveraging / liquidating positions in accordance with our published policies and terms of service. ● To run credit checks to determine an appropriate account limit for you; ● To respond to your inquiries, comments, feedback or questions; ● To send administrative information to you, for example, information regarding the Service, and changes to our terms, conditions, and policies; ● To analyze how you interact with our Service; ● To maintain and improve the content and functionality of the Service; ● To develop new products and services; ● To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture and networks; and ● To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties.
3. SHARING AND DISCLOSURE OF PERSONAL DATA In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below: ● Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, business intelligence tools, email newsletter services, payment processors, and web analytics services. Pursuant to our instructions, these parties will access, process or store Personal Data in the course of performing their duties to us. ● BusinessTransfers:If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets. ● Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Services, or the public, or (v) protect against legal liability. The information we share with law enforcement authorities will be determined on a case-by-case basis and based on the type of request.
4. UPDATE YOUR INFORMATION Please contact us if you need to change or correct your Personal Data.
5. CHILDREN Our Service is not directed to children who are under the age of 18. GrowSmart does not knowingly collect Personal Data from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided Personal Data to GrowSmart through the Service please contact us and we will endeavor to delete that information from our databases.
7. SECURITY You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration or destruction. We have access control policies that include multi-factor authentication and real-time access monitoring and alerting. The Personal Data that we store is encrypted in transit (to and from our server), as well as in storage. We use web securities like Web Application Firewall, TLS1.2, Intrusion Preventions System, Web Reputation and VA-PT to ensure the confidentiality, integrity, availability, and resilience of your Personal Data.
However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Site or e-mail. Please keep this in mind when disclosing any Personal Data to GrowSmart via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Site or third party websites.
8. YOUR CHOICES In certain circumstances providing Personal Data is optional. You will be asked to opt in for certain disclosures, such as permitting us to use your Personal Data for marketing purposes. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. For example, if you trade with us, we must share your Personal Data with our banking partners. You can also contact us to ask us to update or correct your Personal Data. Your Personal Data will be based on the documents you provide and the update will be approved by our compliance officer.
Any concerns or complaints you have will be escalated to the appropriate team who is in charge of your issue. The investigation into your issue will be supervised by the manager of the team. You will receive an update within 24 hours of our resolution of your issue. If your team is larger, a team member will email you with an update about the status of your issue. You will always be able to update your issue and track the status of its resolution online. Once your issue is resolved, you will be able to provide feedback on our resolution and process.