Privacy Policy

Data Controller Information

Growvias LLC, located at Berkenlaan 101, 2566 FZ The Hague, South Holland, Netherlands (Registration Number: HBR314417, VAT: NL313277789B12), acts as the data controller for the personal data we collect through our website and services.

Data Collection

The data we collect depends on how you interact with our services. We collect personal information that you voluntarily provide to us when you express interest in our services, contact us, or participate in our programs.

Personal data we collect may include:

• • Name and contact information (email address, phone number, postal address)
• • Financial goals and preferences you share with us
• • Communication preferences and marketing consent
• • Technical information such as IP address, browser type, and device information
• • Usage data about how you interact with our website and services
• • Cookies and similar tracking technologies as described in our Cookie Policy

How We Use Your Information

We process your personal data based on legitimate interests, contract performance, and your consent. How we use your information includes:

• • Providing and delivering our financial education services
• • Responding to your inquiries and customer service requests
• • Sending you educational content and service updates
• • Improving our website functionality and user experience
• • Analyzing usage patterns to enhance our services
• • Complying with legal obligations and protecting our rights

Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds: performance of a contract when providing services you've requested, legitimate interests for improving our services and website functionality, consent for marketing communications and cookies, and legal obligations for compliance with applicable laws.

Data Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information only in limited circumstances: with service providers who assist us in operating our website and services (subject to confidentiality agreements), when required by law or to protect our rights and safety, with your explicit consent for specific purposes, or in connection with a business transfer or merger.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy. Generally, we keep contact information and communication records for up to 7 years after our last interaction, website usage data for up to 2 years, and marketing consent records until you withdraw consent. We may retain certain information longer if required by law or to resolve disputes.

Your Rights

Under GDPR, you have several important rights regarding your personal data:

• • Right of access: Request copies of your personal data
• • Right to rectification: Correct inaccurate or incomplete data
• • Right to erasure: Request deletion of your personal data
• • Right to restrict processing: Limit how we use your data
• • Right to data portability: Receive your data in a machine-readable format
• • Right to object: Opt out of certain types of processing
• • Right to withdraw consent: Withdraw consent for processing based on consent

International Data Transfers

Your personal data is primarily processed within the European Economic Area (EEA). If we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as adequacy decisions by the European Commission or standard contractual clauses approved by the European Commission.

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. This includes encryption of data in transit and at rest, regular security assessments, access controls and authentication measures, and staff training on data protection principles.

Cookies and Tracking

Our website uses cookies and similar technologies to enhance your browsing experience and analyze website usage. For detailed information about the cookies we use and how to manage them, please refer to our Cookie Policy.

Contact Information

If you have any questions about this Privacy Policy, want to exercise your rights, or need to contact us about your personal data, please reach out to us:

Supervisory Authority

You have the right to lodge a complaint with a supervisory authority if you believe we have processed your personal data in violation of applicable data protection laws. In the Netherlands, you can contact the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

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. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

Children's Privacy

Our services are not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal data from a child under 16 without parental consent, we will take steps to delete that information promptly.