Grow By Three’s Privacy Notice

Effective Date:  August 10, 2023

We value you as a consumer, and understand the importance of your privacy. This privacy policy serves to inform consumers of our privacy practices, and will notify you of the following:

· what personal information (PI) we collect;

· why we collect such PI;

· whether, and with whom, such PI is sold or shared;

· what rights you have in connection with your PI; and more.

Information We Collect

Grow By Three collects personal information from you when you engage with our websites or business offerings, and complies with applicable laws which control the manner in which we collect such information.

Personal information is defined as information that can reasonably identify a particular consumer or household. The chart below highlights the categories of personal information that we collect, along with examples of the types of personal information within each specified category.

Category (Type)

Contact information (like name, email address, phone number, social media handle, shipping address, billing address)

Demographic information, also considered “sensitive” information (like birthdate, age, gender, race)

Financial information (like credit card number, expiration date)

Use and geolocation information (like the length of time used to complete a form, request, or submission; the type of device used; the IP address from which the communication originated; cookies)

Commercial information (like records related to your engagement with Grow By Three products, services, and other offerings)

Education/professional information (like schools you have attended and organizations where you have worked)

User profile information (like a user number, ID number)

Audiovisual information (like audio, photo, or video footage in connection with an event we hosted)

We collect this information by receiving it directly, or indirectly, from you as you use our website or engage with information, products, services, or other offerings we provide. In some cases, we may receive your information from clients who use our program management services and have engaged us to provide services to you.

Why We Collect It

We use each category and type of personal information only as reasonably necessary, and in connection with our business’ operational purposes. Such business operational purposes may include the activities below.

  • Contacting you about the information, products, services, and/or offerings in which you have expressed interest

  • Delivering agreed-upon products, services, or other offerings to you and to provide support needed in the process of delivery

  • Improving the quality of an overall service, product, or offering, or a component of an overall service, product, or offering that we provide

  • Assisting in personalizing your experience as a recipient of any of our services, products, or other offerings

  • Recruiting and evaluating your candidacy for positions available within Grow By Three’s workforce

  • Communicating with you as a recipient of any of our services, products, or other offerings, and leveraging industry-standard means of communication to do so

  • Conducting activities that help us maintain the safety of our organization

  • Processing payments or completing transactions

  • Verifying user information

  • Complying with legal and regulatory obligations

We retain personal information over the course of our business relationship with you. For participants who are in programs managed by Grow By Three (“Participants”), we understand that you may need to make use of materials we have provided to you even after the program has ended. As a result, we may retain Participants’ personal information to keep your account active for up to two years after your program period has ended.

We may retain personal information beyond the duration of the business relationship or active account period to protect Grow By Three against legal claims, to meet reasonable and legitimate business purposes, or in instances when disposal is not reasonably practicable due to the manner in which the information is maintained.

Selling or Sharing of Information

Grow By Three does not sell personal information for monetary or other consideration. Grow By Three does not share personal information except in limited circumstances. Specifically, Grow By Three may share personal information:

  • with clients who use our program management services and have engaged us to provide services to you;

  • with Grow By Three contractors or providers who are under contract with Grow By Three to provide a service that allows us to ultimately deliver services, products, customer support, or other offerings to you; and

  • when required to do so by law or in order to protect against activities that violate the rights of others or any federal, state, or local laws.

Data Security

Grow By Three values your privacy, and takes precautions to protect it. In accordance with data security laws, Grow By Three implements and maintains security procedures and practices that are reasonable, and appropriate to (1) the nature of the personal information we collect, process, and use, and (2) the nature and size of our company and its operations. Through our data security program, we use various tools to implement reasonable security protocols and practices to safeguard your personal information in all forms. In addition, Grow By Three takes measures to disconnect data from elements that render such data capable of identifying a consumer or household.

External Links

Information or other programming that we share throughout your relationship with us may link you to third-party websites or information. These links do not constitute Grow By Three’s approval, ratification, or endorsement of the third-party websites or the information provided therein. We do not assume liability for use of third-party websites, and such use is subject to the privacy polices and terms of use governing those websites.

Our work with Participants may incorporate use of Moodle, an online education platform which may host our content. Moodle’s privacy notice can be reviewed here (https://moodle.com/privacy-notice/).

Do Not Track Signals

While some browsers may emit “do-not-track” signals when you engage with our website, services, or other offerings, our tracking practices may not change in response to such signals.

Children

Our website, programs, services, or other offerings are not designed for children at or under the age of 16. Accordingly, we do not intentionally seek or collect information about individuals at or under the age of 16.

Rights

Your geographical location can confer rights related to your personal information, including the:

· the right to delete PI;

· the right to correct PI;

· the right to know what PI is being collected;

· the right to access the PI we collected about you;

· the right to know what PI is being sold or shared, and to/with whom;

· the right to opt out of the sale or sharing of PI;

· the right to limit use and disclosure of sensitive PI; and

· the right of no retaliation after exercising any rights.

To exercise any of your rights related to your personal information, or to simply opt out of future communication from us, you may do so at any time. You can inform us of any related requests by contacting us via email at team@growbythree.com, or by calling our toll-free number, which is (877) 311-1004.

Please note that we may need to verify your identity in order to respond to your request, and reserve the right to deny your request based on applicable law.

Updates

We reserve the right to update our privacy policy. We will send you an email message or post a notice to our website to inform you of when we make material updates to this policy.

If you feel that we are not abiding by this privacy policy, you should contact us immediately via email at team@growbythree.com.