Your data, explained.

Growy Consultoria em Tecnologia Digital LTDA., trading as Growy Digital, CNPJ 41.497.235/0001-18, in Paulínia, São Paulo, Brazil, is responsible for this policy. Our privacy contact is [email protected].

This is the general policy for growy.digital and for software, apps, platforms and services operated by Growy that refer to it as their privacy policy. A product may provide an additional notice describing its purposes, providers, retention periods and controls. That notice supplements this policy and takes precedence for the specifics of that product.

We act as a controller when we determine why and how personal data is used. When we develop or operate software for a client under their instructions, we may act as a processor. In that case, the client is responsible for the processing decisions and the service’s privacy notice.

If a request concerns a client’s service, we may direct you to the responsible organization or help it respond. This policy does not make Growy the controller of every product it helps develop.

We handle data relevant to the interaction or feature you use. This may include:

Avoid sending sensitive information or other people’s data without a need and without authorization or another appropriate legal basis. Listing a category here does not mean that every service collects it.

• Contact and communications: your name, email, company and information you send in messages, support requests or business discussions.
• Accounts and product use, where those features exist: user identifiers, preferences, access records and content you submit or create.
• Website and platform use: pages visited, interactions, referral sources, browser and device characteristics, timestamps, error logs and technical connection data.
• Contracts and billing, where relevant: information needed to manage the business relationship, issue records and track payments.
• AI features: instructions, documents or other content needed to carry out the feature you use. The data depends on the feature and should be described in the product.

We use data to respond to inquiries, assess and deliver projects, provide support, operate features, administer contracts, protect systems and understand how services are used so we can improve them.

The legal ground depends on the purpose and context. Visiting the website or reading this policy does not constitute consent to every kind of processing.

• Contract performance or preliminary steps: to respond to your request or provide an agreed service.
• Legal or regulatory obligations: to meet applicable requirements, such as those concerning tax records.
• Legitimate interests, where appropriate: for security, abuse prevention and service improvements, considering necessity and people’s rights.
• Consent, when required: for purposes or technologies that depend on your choice. You can withdraw it through our privacy contact.
• Establishment, exercise or defense of legal claims: for information needed in a claim or proceeding.

The company website uses Vercel Web Analytics to understand visits and page interactions. The tool is designed to produce metrics without cookies that identify individual visitors. Infrastructure logs may also be processed to deliver the website, maintain security and diagnose issues.

Other Growy platforms may require local storage, session cookies or their own measurement tools. The relevant technologies, purposes and choices should be described in that product. Where consent is required, it should be requested before activation. You can also manage cookies and storage through your browser settings.

We use AI tools to support our activities and may incorporate them into products and services. Depending on the task, processing may involve content you submit, instructions and information needed to generate a response, organize data or perform a feature.

Where a feature uses AI providers, the necessary data may be processed by those providers. The relevant product or interaction should explain the purpose, the data involved and relevant conditions, including any retention or use for model improvement. This policy alone does not authorize unrestricted use of your content for training. If a decision based solely on automated processing affects your interests, you may request information and review under applicable law.

We may share data with providers needed to operate services, such as hosting, infrastructure, communications, analytics and, where applicable, authentication, payment and AI providers. Sharing should be limited to what the corresponding purpose requires.

Data may also be disclosed to meet legal obligations, respond to competent authorities or exercise legal rights. Providers may process data outside Brazil; international transfers are subject to the mechanisms and safeguards required by applicable law. Product-specific details may appear in an additional notice or be requested through our privacy contact.

Retention depends on the purpose, the nature of the data and our relationship with you. We consider the time needed to provide the service, handle support, meet record-keeping duties and exercise legal rights.

When data is no longer needed, it should be deleted or anonymized unless there is a legal reason to retain it. Backup records may follow their own replacement cycles. You can ask about the retention criteria that apply to your situation.

We use technical and organizational measures appropriate to the data and activities, including access controls and care in configuring and operating systems. No digital environment is free of risk.

If you identify a possible incident or misuse of data related to Growy, contact us through our privacy channel. Incidents requiring notification will be handled according to applicable legal obligations.

Subject to applicable law, you may request:

Email [email protected], identifying the product or relationship with Growy and your request. We may ask for proportionate information to verify your identity and protect the data. We respond within applicable deadlines and explain any legal limitations. You may also contact Brazil’s National Data Protection Authority (ANPD) and other competent authorities.

• Confirmation of processing and access to your personal data.
• Correction of incomplete, inaccurate or outdated data.
• Anonymization, blocking or deletion of unnecessary, excessive or unlawfully processed data.
• Portability under the applicable rules.
• Information about sharing and about the option not to consent and its consequences.
• Withdrawal of consent and deletion of data processed on that basis, subject to lawful retention exceptions.
• Objection to unlawful processing and review of decisions based solely on automated processing that affect your interests.

The company website presents services for businesses. If a Growy product serves children or teenagers, its processing must consider their best interests and specific legal requirements, with appropriate information in the product.

If you believe a child’s or teenager’s data has been submitted inappropriately, contact us so we can assess the situation.

We may update this policy to reflect changes in our services, processing practices or the law. The date at the top identifies the published version. Material changes will be communicated in a way appropriate to the service and the impact of the change.

For questions, requests or concerns about personal data, contact [email protected]. Third-party sites or services reached through links are governed by their respective operators’ policies.