Privacy Policy

Last updated: March 7, 2026

At GROWL, we are committed to protecting your personal data. This policy explains what data we collect, how we use it, and your rights.

1

Data Collected

We collect the following personal data when you use GROWL:

• Account information: name, email address, profile picture, and password hash
• Profile data: biography, social media links, and preferences
• Transaction data: purchase history, payment amounts, and payout information
• Usage data: pages visited, features used, device information, and IP address
• Communication data: messages sent through the platform and support requests

We only collect data that is necessary for providing and improving our services.

2

Legal Basis

We process your personal data based on the following legal grounds:

• Contract performance: processing necessary to provide our marketplace services (account management, transactions, payouts)
• Legitimate interest: analytics, fraud prevention, platform security, and service improvement
• Consent: marketing communications, cookies, and optional data collection
• Legal obligation: tax reporting, regulatory compliance, and law enforcement requests

You may withdraw consent at any time for processing based on consent, without affecting the lawfulness of prior processing.

3

Data Usage

Your personal data is used to:

• Operate and maintain your account and the marketplace
• Process transactions and manage payouts to sellers
• Send transactional notifications (order confirmations, payout alerts)
• Improve our platform through analytics and usage patterns
• Detect and prevent fraud, abuse, and security threats
• Provide customer support
• Send marketing communications (only with your consent)

We do not use your data for automated decision-making or profiling that produces legal effects.

4

Third-Party Sharing

We share your data with trusted third parties only as necessary:

• Payment processors: to process transactions securely (CinetPay)
• Cloud infrastructure: to host and deliver the platform (hosting providers)
• Analytics: to understand platform usage (anonymized data only)
• Authentication providers: to enable social login (Google, when used)

We do not sell your personal data to third parties. All third-party partners are bound by data processing agreements that ensure adequate protection of your data.

5

Cookies

GROWL uses cookies and similar technologies for:

• Essential cookies: authentication, session management, and security (required)
• Preference cookies: language selection and theme preference (required)
• Analytics cookies: anonymous usage statistics (optional)

You can manage cookie preferences through your browser settings. Disabling essential cookies may prevent you from using certain platform features.

6

Data Retention

We retain your personal data for as long as necessary to provide our services:

• Active accounts: data is retained for the duration of your account
• Deleted accounts: personal data is deleted within 30 days, except where retention is required by law
• Transaction records: retained for 5 years for tax and legal compliance
• Analytics data: anonymized and retained indefinitely

You may request early deletion of your data, subject to legal retention requirements.

7

User Rights (GDPR)

Under applicable data protection laws, you have the following rights:

• Right of access: request a copy of your personal data
• Right to rectification: correct inaccurate or incomplete data
• Right to erasure: request deletion of your personal data
• Right to restriction: limit how we process your data
• Right to data portability: receive your data in a structured, machine-readable format
• Right to object: object to processing based on legitimate interest
• Right to withdraw consent: withdraw consent at any time

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

8

DPO Contact

For any questions regarding this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer:

• Email: [email protected]
• Address: GROWL, Abidjan, Côte d'Ivoire

You also have the right to file a complaint with the relevant data protection authority in your country of residence.