Global Data Privacy Policy

Effective Date: June 11, 2018

This Global Data Privacy Policy (Policy) outlines how Outgrow collects, processes and uses information in compliance with applicable laws and regulations. User’s privacy and the confidentiality of the information that the user might obtain through or upload on the Outgrow Website or Application are priorities for Outgrow.

Outgrow (“OUTGROW”, “we”, “us” or “our”) is committed to protecting the privacy of information of identifiable individuals who visit the www.outgrow.co website (the “Site”) and use the services available thereon (the “Services”). If we make any material change to this Policy, we will post the revised Policy to this web page and update the “Effective” date above to reflect the date on which the revised Policy became effective. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendment.

Personal Data (“PII”) is any information concerning a specific or definable natural person. Outgrow respects the data entrusted to us by our clients, vendors, suppliers, contractors, and employees and is committed to ensuring its security through fair and transparent practices.

Statutory Regulations

This Policy includes the minimum standards for data privacy applicable to Outgrow. This Policy is primarily derived from the following:

However, where applicable, Outgrow seeks to exceed these standards to ensure compliance with stringent local laws, such as the European Union’s Data Protection Directive (95/46/EC)3 (as implemented by local law).

EU-U.S. Privacy Shield Frameworks

[Note: our Privacy Shield compliance assessment is currently underway; however, we have not yet completed this process.] With respect to Personal Data processed in the scope of this privacy policy, Outgrow complies with the EU-U.S. Privacy Shield Framework (the “Privacy Shield”) as adopted and set forth by the U.S. Department of Commerce regarding the processing of personal data. Outgrow commits to adhere to and has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.
To learn more about the Privacy Shield, and to view Outgrow’s certification, please visit https://www.privacyshield.gov and https://www.privacyshield.gov/list, respectively.

In compliance with the Privacy Shield Principles, Outgrow commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Outgrow at: questions@outgrow.co

Outgrow has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/endispute/ for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Privacy Principles

Outgrow performs the role of a data transmitter during the course of business. As a data transmitter, we transmit information on behalf of another group company or a third party. Outgrow does not process sensitive PII data like credit card numbers, social security numbers etc.

In the context of an onward transfer, a Privacy Shield organization has responsibility for the processing of personal information it receives under the Privacy Shield and subsequently transfers to a third party acting as an agent on its behalf. The Privacy Shield organization shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.

Choice and Consent

Where required by law, Outgrow obtains consent from individuals and uses that consent as the basis for the processing of PII, including to collect, use, retain, or disclose such data. Individuals are given the choice to opt-in or opt-out of this procedure.

For all contact or data forms hosted on Outgrow, if required by the user and the law of the concerned geography, the user is allowed to add opt-in widgets with clear data privacy statements for end user’s reference. When required, opt-out widgets can also be added by the user.

Also Outgrow’s double opt-in feature allows you to obtain consent from individuals twice, once when filling out the form and the second opt-in can be handled via email confirmation, where the user receives an email confirming their interest in joining your email list.

Consent and Information Collection and Use

When you join us as a user of our Services, we ask for information that will be used to activate your account, provide the Services to you, communicate with you about the status of your account, and for other purposes set out in this Privacy Policy. Your name, company name, address, telephone number, email address, credit card information and certain other information about you may be required to provide the Services or disclosed by you during your use of the Services. You will also be asked to create a private password, which will become part of your account information.

By providing information to us and by retaining us to provide you with the Services, you voluntarily consent to the collection, use and disclosure of such information as specified in this Privacy Policy. Without limiting the foregoing, we may on occasion ask you to consent when we collect, use, or disclose your information in specific circumstances. Sometimes your consent will be implied through your conduct with us if the purpose of the collection, use or disclosure is obvious and you voluntarily provide the information.

Information collected or contained in Outgrow created by Users

All the PII or any other type of information that the user might obtain through or upload on the Outgrow Website will be subject to our privacy policy. Even though Outgrow operates and manages the Website, as well as the storage of the information, the user is responsible and the rightful owner of said information. Outgrow is committed to:

Use, Retention and Disposal

All data collected by Outgrow is used expressly for legitimate business activities and for purposes consented to by the individual. Outgrow only uses data in strict adherence to contractual, regulatory and applicable laws.

Collection

Outgrow collects data in a fair, transparent, and lawful manner. As such, we adhere to the following guidelines:

The user’s data collected through the registration form on the Outgrow website and application are incorporated in the databases of Outgrow in order to open an account that allows the user to make use of our services. The data may be used to perform the services requested and to review, investigate and analyze how to improve the services provided. Outgrow may also collect and analyze from visitors and users certain information regarding their use of the Website. The information collected may include: Website traffic volume, frequency of visits, type and time of transactions, type of browser and operating system, etc. Outgrow may collaborate with third parties in order to provide the services, in which case those third parties are required to comply with our privacy policy and any other adequate technical and organisational measures to prevent the unauthorized or illegal processing of the information and the accidental loss, destruction or impairment of the same. Data is not disclosed to any third party except for providing the services you requested and for which Outgrow collaborates with third parties; when it is required by a competent authority in the exercise of its duties (for example in order to investigate, prevent or take action regarding illegal activities) or as otherwise required by law.

Retention

Outgrow does not retain data any longer than is absolutely necessary. The retention period for data is determined by:

As part of our retention practices, Outgrow documents and tracks:

Disposal, Destruction and Redaction of Data

Outgrow’s Data Retention and Disposal Policy require managerial approval for the disposal, destruction and deletion of any data. Our disposal, destruction and redaction procedures prevent the recovery, theft, misuse or unauthorized access of data.

Right to be Forgotten

Any user who previously consented to being added to an email list can request to remove and delete all their information permanently. An Outgrow user can easily delete any lead data directly from the Outgrow analytics tab.

Access

All individuals are given access to review, update or correct their PII. The mode of access to this information is clearly communicated to the individual within an appropriate timeframe. Where required by law, Outgrow will respond to requests from individuals to provide them with information relating to the data, we hold about them. Access to data may be denied if an unreasonable request is made, subject to local laws. If access is denied, Outgrow provides the reason and a point of contact for further inquiry to the individual.

Disclosure to Third Parties

Outgrow may disclose data to third parties as a part of normal business operations. Such third parties must adhere to our appropriate privacy clauses. Third parties are mandated to handle all data in accordance with the following:

Security

Outgrow has implemented physical, administrative and technical security measures across the organization which are designed to prevent data loss, unauthorized access to data and misuse, disclosure, alteration, damage or destruction of data. We fully understand that the data collected from individuals should be protected. Therefore, we train our employees on the privacy policy as well as information security procedures regarding the appropriate access, use, and disclosure of data. Outgrow also conducts periodic risk assessments on our processes, information systems and third parties. Outgrow has in place an incident response plan with trained personnel to respond to, investigate and mitigate the impact of any incident. Outgrow also maintains adequate plans for business continuity management, as well as disaster recovery processes for testing databases, servers, information systems and processes that handle data.

We will strive to prevent unauthorized access to your information, however, no data transmission over the Internet, by wireless device or over the air is guaranteed to be 100% secure. We will continue to enhance security procedures as new technologies and procedures become available.

We strongly recommend that you do not disclose your password to anyone. If you forget your password, we will ask you for your email and send you an email containing a link that will allow you to reset your password.

Please remember that you control what information you provide while using the Services. Ultimately, you are responsible for maintaining the secrecy of your identification, passwords and/or any information in your possession for the use of the Services. Always be careful and responsible regarding your information. We are not responsible for, and cannot control, the use by others of any information which you provide to them and you should use caution in selecting the information you provide to others through the Services. Similarly, we cannot assume any responsibility for the content of an information or other information which you receive from other users through the Services, and you release us from any and all liability in connection with the contents of any information or other information which you may receive using the Services. We cannot guarantee, or assume any responsibility for verifying, the accuracy of the information or other information provided by any third party. You release us from any and all liability in connection with the use of such information or other information of others.

Quality

Outgrow informs individuals that they have a responsibility to provide accurate, complete and relevant information in order to maintain the quality and integrity of all data. Individuals may contact our designated personnel for any updates or corrections. Individuals may verify and challenge the accuracy and completeness of their data and have it amended or deleted if appropriate. Additionally, Outgrow has a system in place to record the date, edits, validation and verification of all data collected, maintained and updated.

Modification of Privacy Policy

This Privacy Policy may be modified, without said modification involving any prejudice to the privacy of the user or the confidentiality of the information the user might collect through or upload on the Outgrow Website.

Dispute Resolution

Dispute resolution will be conducted as part of the Dispute resolution program established by JAMS.

Binding Arbitration

If your dispute or complaint can’t be resolved by us, nor through the dispute resolution program established by JAMS, you may have the right to require that we enter into binding arbitration with you pursuant to the Privacy Shield’s Recourse, Enforcement and Liability Principle and Annex I of the Privacy Shield.

Regulatory Oversight

Outgrow is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.

Contact Us

If you have any questions or suggestions regarding our Privacy Policy, please contact us questions@outgrow.co

Please allow up to four weeks for us to reply.

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