GrowX User Privacy Policy
Update Time: June 24, 2024
Effective Time: July 24, 2022
Overview
GrowX is fully aware of the importance of personal information (including sensitive personal information) to you and will make every effort to protect the security of your personal information. We are committed to maintaining your trust in us and will abide by the following principles to protect your personal information: the principle of consistency between rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the principle of minimum necessity, the principle of openness and transparency, the principle of ensuring security, the principle of subject participation, etc. At the same time, we promise to take corresponding security protection measures in accordance with the mature security standards in the industry to protect your personal information.
Before using GrowX products and/or services, please carefully read and thoroughly understand this policy and make an appropriate choice. For the clauses in this policy that may have a significant impact on your rights and interests, we have used bold fonts to distinguish them. Please pay special attention to these clauses. If you do not agree with any content of this policy, you should immediately stop using our products and/or services, and we will not be able to provide you with products and/or services. By using our products and/or services, you indicate that you have read and agreed that we collect, use, store, share, publicly disclose, and protect your relevant information in accordance with this policy. After this policy is updated, we will promptly publish the latest version on the GrowX platform for your timely reference.
Please note that we have tried our best to formulate and implement this policy in accordance with the latest relevant laws, regulations, departmental rules, and regulatory documents in our country (hereinafter referred to as "laws and regulations" for convenience of expression), referring to the latest national standards. However, due to the frequent changes in the aforementioned regulations and the different understandings of the same regulations among different departments and individuals, if there are any inconsistencies or contradictions between the provisions of this policy and the effective laws and regulations in our country at that time, the provisions of the effective laws and regulations in our country at that time shall prevail. We will also process your personal information and safeguard your personal information rights and interests in accordance with the relevant provisions of the effective laws and regulations at that time.
This policy will help you understand the following content:
I. Scope of application of this policy and basis for personal information processing
II. How we collect and use your personal information
III. How we use Cookies and similar technologies
IV. How we store and protect your personal information
V. How we entrust, share, transfer, and publicly disclose your personal information
VI. How we protect your personal information
VII. Your rights
VIII. How your personal information is transferred globally
IX. How this policy is updated
X. Protection of minors
XI. How to contact us
XII. Dispute resolution
Related terms and definitions:
1. User or You: refers to the registered users of the GrowX platform.
2. GrowX platform: refers to the GrowX APP client, etc.
3. Affiliated parties: refer to any company, institution, and the legal representative of the above - mentioned company or institution that is currently or will be controlled by, controls, or is under common control with one party. "Control" means the ability to directly or indirectly influence the management of the mentioned company, whether through ownership, voting shares, contracts, or other means recognized by the court.
4. GrowX products and/or services: refer to the products or services provided to you through the GrowX platform, including but not limited to services such as service browsing.
5. Personal information: refers to various information related to an identified or identifiable natural person recorded in electronic or other forms, excluding information after anonymization.
6. Sensitive personal information: refers to personal information that, once leaked or illegally used, is likely to cause infringement of a natural person's personal dignity or endanger their personal and property safety.
7. Processing of personal information: includes collection, storage, use, processing, transmission, provision, disclosure, deletion, etc. of personal information.
I. Scope of application of this policy and basis for personal information processing
1. Scope of application
This policy applies to the GrowX products and/or services provided by the GrowX platform. Whether you access or log in to the relevant clients of the GrowX platform to use the products and/or services we provide, this policy shall apply.
Please note that this policy only applies to the information we collect and does not apply to the information collected by third - party products and/or services (including any third - party websites) accessed through our products and/or services, nor to the information collected by other companies or institutions providing advertising services in our products and/or services.
2. Basis for personal information processing
Except for the following situations, we shall obtain your explicit consent (including the separate consent or written consent required by relevant laws and administrative regulations) for the processing of your personal information:
(1) It is necessary for concluding and performing a contract to which you are a party, or for implementing human resources management in accordance with legally formulated labor rules and regulations and legally concluded collective contracts.
(2) It is necessary for fulfilling legal duties or obligations.
(3) It is necessary for responding to public health emergencies or protecting the life, health, and property safety of natural persons in emergency situations.
(4) It is for the public interest, such as news reporting and public opinion supervision, and the personal information is processed within a reasonable scope.
(5) It is to process personal information that you have publicly disclosed by yourself or that has been legally disclosed by others within a reasonable scope in accordance with this law.
(6) Other situations stipulated by laws and administrative regulations.
II. How we collect and use your personal information
(I) When you use our services, we need to collect and use the following personal information from you:
1. Complete account information. After you complete the registration, you can choose to upload an avatar, modify your nickname, fill in your date of birth, location, or personal profile information in the personal center to complete your personal information. If you do not fill in or provide the aforementioned personal information, it will not affect your use of GrowX products and/or services.
2. GrowX is a software for parents to record their children's height, weight, vision development, travel plans, etc. in the process of growth. In the vision file, parents will fill in information such as axial length, degree, and curvature, and then a curve of eye development will be generated. In the height and weight section, parents will fill in height and weight information, and then a height - weight curve will be generated.
3. GrowX includes a vision chart function. When using this service, GrowX will call the TrueDepth camera to measure the distance between you and the phone in real - time to prompt you to keep a certain distance from the phone for more accurate results. Regarding the call of the TrueDepth camera, we only use it for distance measurement. We will not record or save the data obtained through the TrueDepth camera, nor will we share it with other third - party companies.
4. Product/service information display and search. In order to help you quickly find the products/services you need, we may collect information about the device you use to access our products and/or services (including device name, device model, MAC address, IMEI, device identifier, list of mobile applications, and other hardware and software feature information, operating system and application version, language settings, resolution, service provider network ID (PLMN), device location - related information (including GPS location information provided with your separate authorization and WLAN access point, Bluetooth, and base station sensor information), browser type) to provide you with the best way to display service information. We will also use your above - mentioned personal information to continuously improve and optimize the above functions.
You can also use the search function to accurately find the products or services you need. We will keep your search content to facilitate your repeated input or to display products or services related to your search content.
Please note that standalone device information, browser type, or just your search keywords alone cannot identify your identity and do not belong to your personal information. We have the right to use them for any purpose. Only when your standalone device information, browser type, or search keywords are used in combination with your other information and can identify your identity, during the combined use period, we will treat your device information, browser type, or search keywords as your personal information and process and protect them in accordance with this privacy policy.
5. Event promotion. Users can click on the H5 page promotion link on the GrowX platform to download or launch the App client. At that time, we need to collect your device identifier (such as IMEI/Mac/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information) to provide intelligent hyper - link services. If you refuse to provide the aforementioned information, you may not be able to jump from the H5 web page to the App client, but it will not affect your use of our core business functions.
6. Software upgrade and application launch. To help users improve the service experience of "upgrading the GrowX APP" and "launching the locally installed map software", we will read the list of installed software on the user's device. If you refuse to provide the aforementioned information, you may not be able to upgrade the GrowX APP, but it will not affect your use of our core business functions.
7. Service improvement. To ensure the stability and security of the system when you use our products and/or services, better prevent network and information security risks such as fraud, network vulnerabilities, computer viruses, network attacks, and network intrusions, and protect your, other users', or the public's personal and property safety from infringement, and we may record some links ("URLs") that we consider risky. We need to collect information about the device you use and log information. Specifically, it includes: device brand and model, device screen specifications, operating system version, screen resolution, browser type, telecom operator, language used, hardware serial number, IP address, MEID, Android ID, Bluetooth address, WLAN access point (BSSID, SSID), OAID, IMSI, ICCID, IDFA, IDFV, GAID, Open UDID, device sensor data when you use the terminal device to access our platform, access date and time information, service logs. For risk - control and security purposes, we also need to collect IMSI and device MAC address in the background or silent mode; We will also collect your device information to analyze system problems of GrowX, count traffic, and investigate possible risks, and to troubleshoot when you choose to send us abnormal information. If you do not provide the above information, we will not be able to protect your service and account security during your use of GrowX services.
(II) Reminder regarding sensitive personal information
We will not actively ask you to provide sensitive personal information to us, unless you use the vision file/positioning service. In this case, you need to follow the page operation instructions to provide us with your age, axial length, etc. (subject to the actual display page of the GrowX platform) for creating a vision file. Please be cautious and pay attention to the provision of your sensitive personal information. By consenting to provide sensitive personal information, you agree that we can process it for the purposes and in the manner described in this policy.
If we need to collect and use personal information beyond the above scope, we will obtain your consent again.
If you choose not to provide the above information, you may not be able to register as our user or enjoy some of our products and/or services.
(III) Explanation of device permission invocation
When you use our products/services, we may need to request the following system-sensitive permissions related to personal information from the device you use:
1. Read/write external storage permission: When using services such as sharing content in the Android version of GrowX, you can use or save pictures, videos, or files by enabling the storage permission. If you do not enable this permission, you will not be able to use functions related to reading/writing or caching on the memory card, but it will not affect your use of other services.
2. Photo album permission: When using services such as posting and editing content in the iOS version of GrowX, you can upload pictures or videos from your device by enabling the photo album permission. If you do not enable this permission, you will not be able to use functions related to uploading pictures or videos, but it will not affect your use of other services.
3. Camera permission: When using services such as posting, editing content, and binding smart hardware in the Android or iOS version of GrowX, you can scan QR codes, take real-time pictures or videos and upload them for sharing, and set your avatar by enabling the camera permission. If you do not enable this permission, you will not be able to use the shooting function, but it will not affect your use of other services.
III. How we use Cookies and similar technologies
Cookies and similar technologies such as device information identifiers are commonly used in the Internet. We may collect information about your device model, operating system, unique device identifier, login IP address, and cache your browsing and click information through Cookies or similar technologies. We send Cookies to you to ensure the safe and efficient operation of our products and services. We may set authentication and security - related Cookies or anonymous identifiers to confirm whether you are safely logged in to the service or whether there are any acts of theft, fraud, or other illegal activities. These technologies also help us improve service efficiency, enhance login and response speeds. In addition, they can simplify the steps of repeated logins, allowing you to log in without repeatedly entering your username and password, and help us determine your login status and the security of your account or data. We promise that we will not use Cookies for any purpose other than those described in this policy.
IV. How we store and protect your personal information
We will take technical measures such as encryption to store your personal information and ensure its security. We will only store your personal information for the period necessary for the purposes described in this policy and within the time limits stipulated by laws, regulations, and regulatory requirements. Unless otherwise stipulated by laws or relevant regulations, the GrowX platform will retain your personal information for the period necessary to provide services, except when you request us to delete it immediately or cancel your account, or as otherwise provided by laws and regulations.
If we discontinue our services or operations, we will promptly stop collecting your personal information. At the same time, we will comply with relevant laws and regulations and notify you in advance. After discontinuing the services or operations, we will delete or anonymize your personal information, unless otherwise stipulated by laws, regulations, or regulatory authorities.
V. How we entrust, share, transfer, and publicly disclose your personal information
We are fully aware of the legal liability we should bear when personal information is illegally shared or publicly disclosed, causing harm to the personal information subject. We undertake the obligation to keep your personal information confidential and will not sell or rent any of your information. All entrusted processing, sharing, and public disclosure of your personal information will be carried out strictly in accordance with the following terms:
(I) Entrusted processing
To improve efficiency and reduce costs, we may entrust third - party professional service providers to process information on our behalf. For example, we may hire professional service providers to provide us with infrastructure technology services, customer service, advertising services, content services, and value - added services. For the companies, organizations, and individuals we entrust to process personal information, we will require them to abide by strict confidentiality obligations and take effective confidentiality measures through written agreements, on - site audits, etc. We will require them to process your personal information only within the agreed scope of the entrustment and not to use your personal information for their own interests.
(II) Sharing
We will not share your personal information with other companies, organizations, or individuals, except in the following situations:
1. Sharing with your consent: After obtaining your explicit consent, we will share your personal information with other parties.
2. Sharing necessary for concluding and performing a contract to which you are a party: When you purchase goods or services through the GrowX platform, we will provide your services to third - party service providers according to your choice, including:
(1) In cases clearly stipulated by relevant laws and regulations, we will provide information required for real - name authentication, such as your name and ID number, to the real - name authentication service provider through the background system to complete the real - name authentication.
(2) Other necessary sharing with suppliers, service providers, and business partners related to our services/functions. We will inform you of the relevant information sharing situation through product pages or other means that can reach you and seek your consent in accordance with the law.
3. Sharing necessary for fulfilling legal obligations: We may share your personal information in accordance with laws and regulations, for the needs of litigation or dispute resolution, or as required by administrative or judicial authorities in accordance with the law, and for other legal obligations.
To enable you to use the relevant services and functions we provide normally, the SDKs of authorized cooperation partners or other similar applications will be embedded in our application. We will conduct strict security monitoring on such embedded SDKs or other similar applications and ensure data security through agreement constraints. The third - party embedded SDKs or other similar applications in GrowX are as follows: Please click to view
(III) Public disclosure
1. After obtaining your explicit consent;
2. Disclosure based on the law: In cases required by laws, legal procedures, litigation, or mandatory requirements of government authorities, we may publicly disclose your personal information. On the premise of complying with laws and regulations, when we receive a request to disclose personal information, we will require the recipient to have corresponding legal documents, such as subpoenas or investigation letters. We firmly believe that the personal information we are required to provide should be as transparent as possible within the scope permitted by law. We carefully review all requests to ensure that they have a legal basis and are limited to the data that law enforcement agencies have the legal right to obtain for specific investigation purposes.
3. Based on the need for normal management and maintenance of the order of the GrowX platform, we will issue penalty announcements for acts such as violating accounts and fraud that seriously damage the legitimate rights and interests of the GrowX platform. The announcement information mainly includes user accounts and user violations.
(IV) Transfer
We will not transfer your personal information to any company, organization, or individual, except in the following situations:
1. After obtaining your explicit consent, we will transfer your personal information to other parties;
2. Providing it as required by applicable laws, regulations, legal procedures, or mandatory administrative or judicial requirements;
3. In the event of a merger, acquisition, or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this policy. Otherwise, we will require the company or organization to seek your authorization and consent again.
VI. How we protect your personal information
We attach great importance to the security of personal information and take all reasonable and feasible measures to protect your personal information:
1. We will adopt security protection measures in line with industry standards, including establishing reasonable institutional norms and security technologies to prevent your personal information from being accessed, used, or modified without authorization and to avoid data damage or loss.
2. If we discontinue the operation of the GrowX platform and related businesses, we will promptly stop collecting your personal information, notify you of the discontinuation of operations through individual notifications or announcements, and delete or anonymize the personal information we hold.
3. We take physical, technical, and administrative security measures to reduce the risks of personal information loss, misuse, unauthorized access, disclosure, and alteration, including but not limited to data encryption at the transmission layer, firewalls, encrypted storage, physical access control, and information access authorization control. For this purpose, we have set up security procedures to protect your personal information from being stolen by unauthorized access.
4. We will hold training courses on security and privacy protection to enhance employees' awareness of the importance of protecting personal information.
5. We have formulated relevant emergency response plans for information security incidents and regularly organize internal relevant personnel for emergency response training and drills to enable them to master their job responsibilities and emergency response strategies and procedures.
6. The Internet environment is not 100% secure. We will do our best to ensure the security of any information you send to us. In the unfortunate event of a personal information security incident, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will promptly inform you of the relevant situation of the incident through push notifications on the GrowX platform, sending emails/text messages, or making phone calls. When it is difficult to notify individual information subjects one by one, we will issue announcements in a reasonable and effective manner. At the same time, we will also take the initiative to report the handling situation of the personal information security incident as required by regulatory authorities. If your legitimate rights and interests are damaged, we will bear the corresponding legal liability.
7. The Internet is not an absolutely secure environment. We strongly recommend that you use a secure method and a complex password to help us ensure the security of your account. If you find that your personal information has been leaked, especially if your account or password has been compromised, please immediately contact us through the contact information provided in this policy so that we can take corresponding measures. However, we will not be responsible for any losses before we are aware of such a situation and take actions within a reasonable time.
8. The Internet is not an absolutely secure environment. We strongly recommend that you use a secure method and a complex password to help us ensure the security of your account. If you find that your personal information has been leaked, especially if your account or password has been compromised, please immediately contact us through the contact information provided in this policy so that we can take corresponding measures. However, we will not be responsible for any losses before we are aware of such a situation and take actions within a reasonable time.
VII. Your Rights
Whenever you use our relevant products and/or services, we will do our best to ensure that you can access your account information smoothly. If the information is incorrect, we will try to provide various ways for you to quickly update or delete the information in your account. If you reside in California, you can also request disclosure of the types, sources, and uses of your personal information that we have collected and ask for the deletion of your data. To enable you to fully protect your privacy and security, you have the following rights:
1. Right of Access
You have the right to access your personal information stored on the GrowX platform. After logging in to GrowX with your account, you can access your personal information on the "My" function page.
2. Right of Correction
You have the right to directly correct your personal information through the GrowX platform. If you are unable to make corrections, you can contact us through the customer service contact information provided in this policy and request us to correct or supplement the incorrect or incomplete information.
3. Right of Revocation
To change the scope of your authorized consent or withdraw your authorization, we will safeguard your right to withdraw consent in the following ways: You can turn off the corresponding device permissions (including location, contacts, photos, microphone, camera, notifications, etc.) through the device settings to revoke the authorization for the GrowX platform to access your device permissions. Users can turn off the relevant privacy authorizations in "Phone Settings → Permissions".
4. Right of Deletion
You can request us to delete your personal information in the following situations:
(1) The purpose of processing has been achieved, cannot be achieved, or is no longer necessary for achieving the processing purpose;
(2) We stop providing products or services, or the storage period has expired;
(3) You withdraw your consent for the processing of personal information;
(4) We violate laws, administrative regulations, or the agreement with you regarding the processing of personal information;
(5) Other situations stipulated by laws and administrative regulations.
Once the above deletion request is responded to, except for the information required to be retained by laws and regulations (such as transaction records), your personal information will be promptly deleted or anonymized. After your personal information under certain or all of our services is deleted, we may not immediately delete the corresponding information from the backup system, but we will delete this information in a timely manner when the backup is updated. If we delete or anonymize your personal information within the shortest storage period required by this policy, the user agreement, and laws and regulations, it may result in our inability to provide you with the corresponding services.
5. Right of Account Cancellation
You can cancel your registered account through "Me → Account and Security → Cancel Account" on the GrowX platform.
6. Right to Obtain a Copy of Your Personal Information
We will provide you with the following types of copies of your personal information upon your written request: your basic personal information and identity information. You can contact our customer service staff at any time, and we will respond to your request within fifteen days. Please note that the copies of information we provide to you are limited to the information we have collected.
7. Right to Restrict Automated Decision - Making by Information Systems
In some business functions, we may make decisions based solely on non - human automated decision - making mechanisms such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation from us, and we will also provide appropriate remedies.
8. Right to Transfer Personal Information
If you request to transfer your personal information to a personal information processor you specify and it meets the conditions stipulated by the national Internet information department, we will provide you with a way to transfer the information.
9. Response to Your Above - Mentioned Requests
(1) If you are unable to access, correct, or delete your personal information through the above - mentioned methods, or if you need to access, correct, or delete other personal information generated during your use of our products and/or services, or if you believe that we have violated any laws, regulations, or agreements regarding the collection or use of personal information, you can contact us through the customer service contact information provided in this policy.
(2) To ensure security, you may need to provide a written request or prove your identity in other ways. We may first require you to verify your identity and then process your request. We will respond within fifteen days. In principle, we will not charge a fee for your reasonable requests, but for repeated requests that exceed a reasonable limit, we may charge a certain cost depending on the situation. We may reject requests that are groundlessly repeated, require excessive technical means (such as the development of a new system or a fundamental change to current practices), pose a risk to the legitimate rights and interests of others, or are very unrealistic (for example, requests related to information stored on backup tapes).
VIII. How This Policy Is Updated
1. Our privacy policy may be changed.
2. Without your explicit consent, we will not reduce the rights you should enjoy under this policy. We will publish any changes made to this policy on this page and seek your and your guardian's consent.
3. GrowX is committed to complying with applicable privacy laws in the United States, especially the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR). If there are any updates to the privacy policy, you will be notified and have the right to choose whether to continue using our services.
4. For significant changes, we will also provide more prominent notifications (including, for some services, sending notifications via mobile phone to explain the specific changes to the privacy policy). The significant changes referred to in this policy include but are not limited to:
(1) A significant change in our service model, such as the purpose of processing personal information, the types of personal information processed, and the way of using personal information;
(2) A significant change in our ownership structure, organizational framework, etc., such as a change in ownership due to business adjustment, bankruptcy merger, etc.;
(3) A change in the main recipients of personal information sharing, transfer, or public disclosure;
(4) A significant change in your rights and the way of exercising them in relation to personal information processing;
(5) A change in the responsible department, contact information, and complaint channel for personal information security;
(6) When the personal information security impact assessment report indicates a high risk.
IX. Protection of Minors
1. If you are a minor, please ask your parents or other guardians to carefully read this policy. You should use our services or provide information to us only after obtaining the consent of your parents or other guardians.
2. If you are a child under the age of 14 (inclusive), before using our services, you and your parents or other guardians should carefully read and understand the Rules for the Protection of Children's Personal Information specially formulated by us in accordance with relevant laws and regulations. You can use our services under the guidance of your guardians only after your guardians have given their consent to the "Rules for the Protection of Children's Personal Information" to ensure your safety when using our services and conducting transactions.
3. If you are the parent or other guardian of a child, please pay attention to whether the child uses our services after obtaining your authorization and consent. If you have any questions about the child's personal information, please contact us.
X. How to Contact Us
If you have any questions, comments, or suggestions regarding this policy, you can contact us in any of the following ways:
1. Send an email to leylfl@yeah.net to contact our person in charge of personal information protection.
We will review the relevant issues as soon as possible and respond within fifteen days after verifying your identity.
XI. Dispute Resolution
1. If you believe that our personal information processing actions have damaged your legitimate rights and interests, you can report the issue to relevant government departments.