Privacy policy

1. Introduction

Groow International bv and its affiliated entities (together “GROOW”) wants to give you the best GROOW experience possible and therefore we are very committed to your privacy and keeping your personal data safe. We will protect your personal information in accordance with the principles set out.

This privacy statement (“Privacy Statement”) aims to give you a clear view of what personal data we collect and how we use it, our dedication to protecting it and your rights and options to control your personal data and protect your privacy. 

2. When does this privacy statement apply?

This Privacy Statement is applicable to the processing by GROOW of all personal data of applicants, trainers, mentors, investors, business partners, suppliers, experts, community members and other individuals (“Customers” and each a “Customer”). This Privacy Statement does not address the processing of personal data of students, employees and/or interns in the context of their employment or internship relationship with GROOW.

3. What is personal data and what does processing mean? 

Within GROOW, we consider all information that relates to you and identifies you personally, either alone or in combination with other personal information available to us as personal data. Processing of personal data is pretty much anything you can do with personal data. For example: gathering, storing, combining, transferring or deleting data.

4. How do we collect personal data?

We collect your personal data through a variety of sources:

  • Directly from you, such as the information you provided to us when you submitted a form for a specific event or program, when you opted-in for our mailings, when you contacted us or when you gave us your cv or business card;
  • From others, such as a partner, colleague or through a mutual connection / our network;
  • From sources that are publicly available such as LinkedIn or your company’s website;
  • By means of cookies.

More specifically, we collect personal data in the following ways:

  • News and publications – when you subscribe to our newsletter or confirm you wish to be added to (one of) our mailing lists;
  • Careers – when you (may) apply for a job or an internship;
  • Events – when you (may) sign up for an event or show interest in being notified about events;
  • Accelerator programs and challenges – when you (may) apply for a program or challenge or show interest in being notified thereof;
  • Mentorships – when you (may) become involved as a mentor;
  • Investors – when you (may) become involved as an investor;
  • Experts – when you (may) become involved as an expert in a certain field;
  • Partnerships – when we (may) enter into a collaboration with your organisation;
  • Academy – when you apply for a GROOW program in our academies or show interest in being notified about GROOW programs;
  • Photo, audio and video content – when you participate in an event or in one of our programs.

5. What categories of personal data do we collect?

  • Name, contact details, profession and other identifying information
    When you subscribe to our newsletter, (are eligible to) become part of our community as a Customer, apply for a job, to become a student or internship, or contact us we may record the following: your name, title, profession, areas of interest and contact details. Your contact details may include your address, telephone number, Skype account, social media accounts and/or email address.
  • Your personal account or registration details
    When you create a personal account or register for an event, program, challenge or service, we may record your sign-in details, name, and other information you fill out on your personal account or registration form or information we gather from your device.
  • Your program/challenge application details
    When you submit an application for a program or challenge as a student or a mentor, we may record your sign-in details, name, date and place of birth, nationality, title, profession, work experience, references, cv, t-shirt size, contact details, and other information you fill out on your application or registration form or information we gather from your device. Your contact details may include your address, telephone number, Skype account, social media accounts and/or email address. Once you have successfully applied as a student or applicant, we will ask you for your profile photo, (social media) contact details and bio.
    In addition, we may gather information through testing. If you undergo testing, we will always first request your consent to share this information with us or other parties.
  • Your job application details
    When you submit an application for an employment or internship position, we may record your name, Curriculum Vitae, motivation, contact details, and other information you fill out on your application form or information we gather from your device. Your contact details may include your address, telephone number, Skype account, social media accounts and/or email address.
    In addition, we may gather information through testing, in which case you will be informed in advance.
  • Legal identification
    You may be required to identify yourself if we enter into a contract with you which needs to be notarized or for compliance with anti-money laundering procedures. If we do ask you to identify yourself, we will always first request your consent to share this information with us or other parties. In addition, we may handle passport information in case we need to assist with visa applications.
  • Information about your visits to our websites or other digital media
    When you visit our websites, we may register your IP address, browser type, operating system, referring website web-browsing behaviour and use.
  • Your communication with us
    When you send us an email or chat with us online or via social media, we register your communication with us. When you call us, we may register your questions, queries or complaints in our database.
  • Information in relation to social media
    Depending on your social network settings we may receive information from your social network provider. For example, when you sign in for our services using a social network account (if applicable), we may receive your social network profile including your contact details, interests and contacts. For more information on the personal data that we receive from your social network provider and how to change your settings, please check the website and privacy policy of your social network provider.
  • Information you choose to share with us
    You may choose to share information with us, for example when you leave a comment for us on social media, fill out a survey or submit an entry for a contest.
  • Photo and/or video content
    If you take part in one of our events or programs, you will enter an area where photography, audio and video recording may occur and inevitability your image and/or voice may be recorded.
  • Cookies
    We also collect personal data through cookies and similar technologies. Cookies are small files of information stored on your equipment which save and retrieve information about your visit to this website – for example, how you entered our site, date and time of visit, location information, IP addresses, how you navigated through the site, and what information was of interest to you.

6. For what purposes do we collect and use your personal data?

We may use your personal data for various purposes, all of which have been set-out below. This may be data that you provided to us explicitly, but also data that we collected ourselves (for example, data relating to your visits of our websites). Some information that we collect is mandated by law or otherwise necessary for the delivery of our services or products. Some information we collect is based on your consent. If you do not allow us to collect all the information we request, we may not be able to deliver all our services or products effectively.

6.1 To provide you with our programs, events, and services

We and our service providers collect, use, hold and disclose personal information to provide you with services and/or products that you have requested from us, or we think is of interest to you. This includes personal data that directly relate to the fulfilment of our services and are required to:

  • apply for, participate or be involved in any other way in one or more of our programs or jobs;
  • confirm your attendance of an event;
  • send you tickets and/or any services regarding your visit at one of our events;
  • send you information regarding the venue, service e-mails or after-visit messages;
  • communicate with you (e.g. show details, answer to questions and complaints);
  • conduct statistical research;
  • deliver products to you;
  • register complaints.

6.2 To send you our newsletter

When you sign up for our newsletter or if you have registered for one of our jobs, events, programs or challenges, shared your contact details with us to stay in touch, or received other services or products in the past, we will send you regular updates on the activities of GROOW which may be relevant for you. We can update you via e-mail, regular mail or our social media channels. You have the right to unsubscribe at any time from our newsletter by using the “unsubscribe” button at the bottom of the newsletter.

We process this personal information based on your consent if you have subscribed to our newsletter, or for our legitimate business purposes to communicate about our activities and to enhance, modify, ersonalize or otherwise improve our programs, challenges, events, products, services and communications towards our Customers, to better understand how people interact directly with us (through our communications or our websites) and to determine the effectiveness of promotional campaigns or advertising.

6.3 To send you ersonalized marketing messages

When you have visited our website, signed up for our newsletter, registered for one of our events, applied for one of our jobs, programs or challenges, or shared your contact details with us during one of our events or otherwise, we may send direct marketing communications to you, such as email, phone, or social media. We ask for your consent, where required by applicable law to send our personalised marketing communications.

The messages you receive will be personalised and tailored to your individual preferences and interests. We use analytics to generate such personalised messages. These analytics will process your personal information and place you in marketing segments, which determine the content of the messages and the offers you will receive from us.

We also undertake opinion research (such as to ask if you would like to participate in a survey) to learn about your experience and improve your experience with GROOW, including by sending you personalised messages.

We process this personal information for legitimate business purposes, to send you relevant information about our programs, events, products and services or promotions and GROOW news that might be of interest to you.

6.4 To combine and analyse your data 

We will use your personal information to create a profile based on the information we hold about you, which is stored and processed in a central database. This is necessary to ensure that we have all accurate information about you in one place. We create your profile in accordance with your preferences to provide you with the best personalised experience, to send you personalised marketing messages and newsletters and for opinion research purposes. Below you can find a more detailed description of the ways in which we will use your personal information for these purposes.

The way you and other Customers interact with our brand across all the different channels described above (e.g. our website, social media channels and marketing messages we send you) and the information we collect in that regard from each of these channels provides us valuable information about your interests and preferences and the interests and preferences of our Customers in general. If you consent thereto, we may combine the information we collect with information we lawfully obtain from third parties.

We process this personal information based on your consent where required, for example if we combine third party databases with ours. We also process this information based on our legitimate business purposes, which includes the ability to enhance, modify, ersonalize or otherwise improve our services and communications towards our Customers, to better understand how people interact directly with us (through our communications or our websites), determine the effectiveness of promotional campaigns or advertising, and/or to identify and prevent fraud.

6.5 To develop and improve our services

We use aggregated personal data to analyse customer behaviour and to adjust our services accordingly, to ensure that it is relevant to our Customers. We may also process your personal data to compile analytics reports. This means that we analyse how often you read our newsletters, how often you visit our website or apps and which pages you click to understand which services, products and topics you are interested in.

We also test the level of satisfaction of our Customers, using surveys. We use your responses to such surveys for quality assessments and to improve our services and products.

Only insofar as necessary for our legitimate business interest, we use the information above to adjust our services, products, newsletters or website to make these more relevant and attractive for our Customers.

6.6 To comply with the law

In some cases, GROOW processes your personal data to comply with laws and regulations. This could, for example, be the case where tax or business conduct related obligations apply. To comply with relevant laws and regulations, we may need to disclose your personal data to government institutions or supervisory authorities.

6.7 To perform a contract

If we are (about to enter) in a contractual relationship, we will process your personal information if it is necessary for the performance of the contract or in order to create the respective contract. See chapter 7 for further information.

6.8 To interact with you

If you contact our team (or vice versa), we will use personal information such as your name and contact history to process your request and provide you with the best service possible.

6.9 For publicity purposes

If you participate in one of our events, programs or challenges, your image and/or voice may be recorded and used for promotional purposes. If you don’t want to be recorded, please contact the photographer or cameraman.

7. When you enter a business relationship with us

You may provide personal information to GROOW based on a contract or a broader business relationship and the preparatory stages to enter into a contract. In this part of the policy, we set out how we may process such personal data.

7.1 To process your application for and your entry to a program or job

This includes personal data that directly relates to your application for or participation in an accelerator program and is required to:

  • Administer your application and verify your identity, credentials and any other information you may have provided us with as part of your application;
  • Assess your eligibility to take part in our accelerator program.

7.2 For the assessment and acceptance of a business partner

When you get in contact with GROOW, we process your personal data for assessment and acceptance purposes, for example to confirm and verify your identity. GROOW further processes personal data of business partners for other administrative purposes such as due diligence and screening against publicly available government and/or law enforcement agency sanctions lists.

7.3 For the conclusion and execution of agreements with business partners

We process your personal data for administrative purposes such as sending invoices and making payments. We also use your personal data to deliver or receive and administer our or your services or products. GROOW will process your personal data to further execute our agreement, including for the delivery of services and communications.

7.4 For relationship management and marketing

GROOW uses the information stored in its central marketing database to send you suitable

offers and newsletters, keep you updated on our events and to provide services and perform account management. We also use your personal data for the development, execution and analysis of market surveys and marketing strategies.

7.5 For business process execution

We process your personal data in the performance and organisation of our business. This

includes internal management, general management and portfolio management. We provide central processing facilities to work more efficiently. We conduct audits and investigations, implement business controls, and manage and use various directories. Also, we process your personal data for finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution.

7.6 To monitor compliance

GROOW monitors its IT systems to check compliance with GROOW’s internal policies and regulations, such as the Privacy Policy and the Information Security Policy. During monitoring activities, your personal data may be accessed and viewed.

8. Who is responsible for your data?

GROOW is responsible for the processing of all personal data that falls within the scope of this Privacy Statement. GROOW may share your personal data with third parties, but if it does so, it will remain responsible for your personal data, unless your personal data has been summoned as part of a court order or another legal obligation to share this data rests on GROOW.

9. Who has access to your personal data?

9.1 Access to your personal data within GROOW

As a global organisation, all the personal data we collect may be transferred internationally throughout GROOW’s organisation, but only if GROOW has a legitimate interest to do so. Based on such legitimate business interest, your personal data may be exchanged within the GROOW group and with companies working under the GROOW brand. We exchange your data within the GROOW group for administrative purposes to create a complete overview of your contacts and contracts. We may also exchange your data to offer you a complete package of services.

GROOW employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs.

9.2 Access to your personal data by third parties

The following third parties may have access to your personal data, where relevant, for the provisioning of their products or services to GROOW or to you:

  • Third parties relevant to the services that we provide, such as clients, workshop facilitators, mentors, trainers, experts and alike parties;
  • Bank payment system operators and credit card companies, for the fulfilment of payments, as identified while you undertake your payment;
  • Insurance companies;
  • IT suppliers hosting our customer database, websites and technology service providers;
  • Parties that provide ticketing and customer services for us as identified by the website through which you are ordering a ticket;
  • Parties who support GROOW in their marketing activities, such as digital agencies, mailing houses, statistical research partners, and Google and Facebook;
  • Debt collectors;
  • Fraud bureaus or other organisations to identify, investigate or prevent fraud or other misconduct;
  • External dispute resolution schemes;
  • Regulatory bodies, government agencies and law enforcement bodies;
  • Our financial advisors, legal advisors and auditors;
  • Other third parties with whom we are required by law to share the personal data.

We may also disclose your personal information to others outside GROOW where:

  • we are required or authorised by law or where we have a public duty to do so;
  • you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
  • we are otherwise permitted to disclose the information under applicable privacy laws.

When such third parties are given access to your personal data, we will take the required contractual, technical and organisational measures to ensure that your personal data is only processed to the extent that such processing is necessary or within the scope of the consent we have received from you. We will ensure that third parties will only process your personal data in accordance with applicable (local) law.

We may need to transfer your personal information outside of the European Economic Area (“EEA”) to a country that is not regarded under European Law as providing the same level of data protection as the country in which you normally use our services. For example, if you register for a GROOW event outside the EU or participate in an accelerator program outside the EU.

In these circumstances we will take appropriate steps to ensure that your personal information is adequately protected. Typically, such steps include carrying out data security reviews of any recipients and putting in place contracts with such recipients to ensure they employ the same or similar appropriate technical and organisational measures as GROOW, so your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the contact details below.

We will not sell, distribute or lease your personal information to third parties other than as set out above, unless we have your permission or are required by law to do so.

9.3 The use of your personal data by data processors

When a third party processes your personal data for or on behalf of GROOW we will enter into an agreement with such third party to agree on appropriate conditions subject to which the processing of personal data is allowed. In this agreement we include obligations to ensure that your personal data is processed by the data processor solely to provide services to us.

10. How is my personal data secured?

GROOW has taken adequate safeguards to ensure the confidentiality and security of your personal data. We have implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing. Examples are our internal Privacy and Information Security policies that all staff must comply with, staff training and secure servers.

11. How long do you retain my personal data?

Your personal data will be retained for as long as required for the purposes described in this Privacy Statement or in so far as such is necessary for compliance with statutory obligations and for solving any disputes.

12. How can I exercise my rights?

You can at all times request access, correction, restriction, portability or removal of the data that GROOW processes or if you have any questions regarding the processing of your personal data by sending a request to compliance@groow.co

if you prefer to contact us by regular mail, please send your request to the following address:

Groow Global bv
Prins Boudewijnlaan 24 C / 2
2550 Kontich, Belgium 

We are very committed to working with you to always obtain a fair resolution of any complaint or concern you might have in relation to our processing of your personal data. If, however, you feel that we have not been able to assist you adequately and do not comply with applicable privacy rules you have the right to lodge a complaint with the relevant data protection authority.

Phone

+32 3 375 83 43

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Email

info@groow.co