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GrowthVitals™ EKG™ System Privacy Policy

Updated November 7, 2021

GrowthVitals takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights.

We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections that are specifically applicable to Users (Section 2), Users (Section 3). Sections 1 and 5 are applicable to everyone.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 5.

To the extent we provide you with notice of different or additional privacy policies, those policies will govern such interactions.

1. The Basics

A. About Us

GrowthVitals is an online organizational development platform operated by Webolutions Inc., a company headquartered in the State of Colorado in the United States ("we," "us," "our," and "GrowthVitals").

Our Service enables our Users to, among other things, share their organizational Vision, convey strategic roles, responsibilities and key initiatives, recognize employees and gain insights into overall employee performance. We also provide other related services, such as marketing, branding, organizational development workshops and consulting.

B. Key Terms

In this privacy policy, these terms have the following meanings:

"Subscriber" means an entity who subscribes to our system.

"User" is a person who has been entered by the subscriber as a user of the system.

"System" means the GrowthVitals EKG and its related online tools.

2. Privacy for Users

This section applies to the Personal Information we collect and process from a User or potential User through the provision of the Service, including features offered through the Service.

A. Information We Collect

The Personal Information that we collect depends on the context of your interactions with GrowthVitals, your GrowthVitals account settings, the products and features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:

(i) Information you provide to us: You (or your organization) may provide certain Personal Information to us when you sign up for a GrowthVitals account and use the Service, consult with our customer service team, send us an email, integrate the Service with another website or service (for example, when you choose to connect your e-commerce account with GrowthVitals), or communicate with us in any other way.

This information may include:

• Business contact information (such as your name, job title, organization, location, phone number, email address, and country);
• Marketing information (such as your contact preferences);
• Account log-in credentials (such as your email address or username and password when you sign up for an account with us);
• Troubleshooting and support data (which is data you provide or we otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry); and
• Payment information (including your credit card numbers and associated identifiers and billing address).

(ii) Information we collect automatically: When you use the Service, we and our third-party partners may automatically collect or receive certain information about your device and usage of the Service (collectively “Service Usage Data”). In some (but not all) countries, including countries in the European Economic Area (“EEA”), this information is considered Personal Information under applicable data protection laws. We and our third-party partners use cookies and other tracking technologies to collect some of this information. If you are using our Mobile App, we may collect this information using our software development kits (“SDKs”) or APIs the first time the SDK or API is initiated on your Mobile App. For further information, please review the section below and our Cookie Statement available here.

/Service Usage Data may include:

• Device information: We collect information about the device and applications you use to access the Service, such as your IP address, your operating system, your browser ID, viewfinder size, and other information about your system and connection. If you are using our Mobile App, we may also collect information about the cellular network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s name and unique device ID, and information about the features of our Mobile App that you accessed.
• Log data: Our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP addresses and your activity in the Service (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you used)), device event information (such as system activity, error reports (sometimes called ‘crash dumps’)), and hardware settings. We may also access metadata and other information associated with files that you upload into our Service.
• Usage data: We collect usage data about you whenever you interact with our Service, which may include the dates and times you access the Service and your browsing activities (such as what portions of the Service you used, session duration, links clicked, non-sensitive text entered, and mouse movements). We also collect information regarding the performance of the Service, including metrics related to the deliverability of emails and other communications you send through the Service. If you are using our Mobile App, we may collect information about how often you use the Mobile App and other performance data. This information allows us to improve the content and operation of the Service, and facilitate research and analysis of the Service.

(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners.

Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other Personal Information we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products, features, and service.

B. Use of Personal Information

We may use the Personal Information we collect or receive through the Service (alone or in combination with other data we source) for the purposes and on the legal bases identified below:

• To bill and collect money owed to us by you to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in accordance with our legitimate interests to operate and administer our Service. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see the "Our Security" section of this privacy policy.
• To send you system alert messages in reliance on our legitimate interests in administering the Service and providing certain features. For example, we may inform you about temporary or permanent changes to our Service, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.
• To communicate with you about your account and provide customer support to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Service. For example, if you use our Mobile Apps, we may ask you if you want to receive push notifications about activity in your account. If you have opted in to these push notifications and no longer want to receive them, you may turn them off through your operating system.
• To enforce compliance with our Standard Terms of Use and applicable law, and to protect the rights and safety of our Users in reliance on our legitimate interest to protect against misuse or abuse of our Service and to pursue remedies available. This may include developing tools and algorithms that help us prevent violations. For example, sometimes we review the content our Users send or display to ensure it complies with our Standard Terms of Use. To improve that process, we have software that helps us find content that may violate our Standard Terms of Use. We may or our third-party service provider may also review content that our Users send or display. This benefits all Users who comply with our Standard Terms of Use because it reduces abuse and helps us maintain a reliable platform. Please do not use GrowthVitals to send or display confidential information.
• To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
• To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests.
• To prosecute and defend a court, arbitration, or similar legal proceeding.
• To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• To provide, support and improve the Service to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Service and providing certain features. For example, this may include improving the navigation and content of the Service and sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to you. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws. For further information about how we share your information, refer to Section 5 below.
• To provide suggestions to you and to provide tailored features within our Service that optimize and personalize your experience in reliance on our legitimate interests in administering the Service and providing certain features. This includes adding features that compare Users’ engagements, or using data to recommend products or services that you may be interested in or that may be relevant to you. Some of these suggestions are generated through analysis of the data used in our data analytics projects, as described below.
• To perform data analytics projects in reliance on our legitimate business interests in improving and enhancing our products and services for our Users. Our data analytics projects use data from GrowthVitals accounts, including Personal Information, to provide and improve the Service. As always, we take the privacy of Personal Information seriously, and will continue to implement appropriate safeguards to protect this Personal Information from misuse or unauthorized disclosure.
• To combine and de-identify data about our Users and our User's use of the Service in order to create aggregate, de-identified statistics which we may use to provide certain features within the Service and for promoting and improving the Service in reliance on our legitimate interests.
• To personalize the Service, content, and advertisements we serve to you in reliance on our legitimate interests in supporting our marketing activities and providing certain features within the Service. We and our third-party marketing and advertising partners may use your Personal Information to serve you specifically, such as to deliver gifts and promotional materials, marketing information, product recommendations, non-transactional communications (e.g., email, telemarketing calls, SMS, or push notifications), and personalized advertising about us, in accordance with your applicable marketing preferences and this privacy policy. For further information about how we may share your information with our third-party partners, refer to Section 5 below.

C. Third-Party Integrations

We may use the Personal Information we collect or receive through the Service, as a processor and as otherwise stated in this privacy policy, to enable your use of the integrations and plugins you choose to connect to your GrowthVitals account. For instance, if you choose to connect a Google integration to your GrowthVitals account, we’ll ask you to grant us permission to view and/or download, as applicable, your Google Sheets, Google Contacts, Google Analytics and Google Drive. This allows us to configure your Google integration(s) in accordance with your preferences.

D. Your Data Protection Rights

Depending on the country in which you reside, you may have the following data protection rights:

• To access; correct; update; port; delete; restrict; or object to our processing of your Personal Information.
• You can manage your individual account and profile settings within the dashboard provided through the GrowthVitals platform, or you may contact us directly by emailing us at [email protected].
• The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA and UK are available and Switzerland are also available
• Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

3. General Information

A. How We Share Information

We may share and disclose your Personal Information with our subsidiaries or Affiliates and to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, "you" and "your" refer to Users).

(i) Our service providers: Sometimes, we share your information with our third-party service providers working on our behalf for the purposes described in this privacy policy. For example, companies we’ve hired to help us provide and support our Service or assist in protecting and securing our systems and services and other business-related functions.

Other examples include analyzing data, hosting data, engaging technical support for our Service, processing payments, and delivering content.

We use YouTube's API services in connection with our Service to provide certain features. As such, you acknowledge and agree that by signing up for an account and using the Service, you are also bound by Google's Privacy Policy. In addition to the rights set forth in Section 2, you may manage your YouTube API data by visiting Google's security settings page at https://security.google.com/settings/security/permissions

In connection with our Service, we also use a third-party service provider, Twilio, Inc. We use Twilio's API, which allows us to build features into our GrowthVitals application to enable us to communicate with our Users through texting and calling, and their "Authy" product, which we use for two-factor authentication for our application. If you are a User, Twilio may need to collect and process certain Personal Information about you as a controller to provide such services. To learn more about Twilio's privacy practices, please visit https://www.twilio.com/legal/privacy

(ii) Advertising partners: We may partner with third-party advertising networks, exchanges, and social media platforms (like Google and LiveRamp) to display advertising on the GrowthVitals Sites or to manage and serve our advertising on other sites. We and our third-party partners may use cookies and other similar tracking technologies, such as pixels and web beacons, to gather information about your activities on the GrowthVitals Sites and other sites in order to provide you with targeted advertising based on your browsing activities and interests. For more information about how we and our third-party partners use cookies, please see our Cookie Statement available here. In certain cases, we may also share limited Personal Information about our Users with our third-party advertising partners for our own marketing purposes. If you prefer us not to share your Personal Information, you can alter the settings on your account as described here.

(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our GrowthVitals Site.

(v) Any other person with your consent.

We may also share information with selected third parties for statistical or research purposes that has been aggregated and made unidentifiable to the third party.

B. Legal Basis for Processing Personal Information (EEA and UK Persons Only)

If you are located in the EEA or UK, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests are described in more detail in this privacy policy in the sections above titled “Use of Personal Information”, but they typically include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Service and our GrowthVitals Sites; and supporting our marketing activities.

If you are a User, we may need the Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not, as well as of the possible consequences if you do not provide your Personal Information.

Where required by law, we will collect Personal Information only where we have your consent to do so.

If you have questions or need further information concerning the legal basis on which we collect and use your Personal Information, please contact us using the contact details provided in the "Questions and Concerns" section below.

C. Your Choices and Opt-Outs

(i) Marketing: Users and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.

Also, all opt-out requests can be made by emailing us using the contact details provided in the "Questions and Concerns" section below. Please note that some communications (such as service messages, account notifications, and billing information) are considered transactional and necessary for account management, and Users cannot opt out of these messages unless you cancel your GrowthVitals account.

(ii) Data Analytics: Our data analytics projects use data from GrowthVitals accounts, including Personal Information of Users and Contacts, to provide and improve the Service. If you are a User and prefer not to have your data used for this purpose, you can alter the settings on your account (as described here). If you are a Contact, you can also opt out of data analytics projects at any time by completing this form or emailing us at [email protected]. For further information about our data analytics projects, refer to Section 2, B (for Users) or Section 3, B (for Contacts) above.

(iii) Personalized Advertising: We may share limited Personal Information of our Users with third-party advertising networks, exchanges, and social media platforms (like Google and LiveRamp) to display advertising on the GrowthVitals Sites or to manage and serve our advertising on other sites. If you are a User and prefer us not to share your Personal Information, you can alter the settings on your account (as described here). For further information about how we may share your information, refer to Section 5, A above.

D. Our Security

We take appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. For further information about our security practices, please see our Security page available here. If you have any questions about the security of your Personal Information, you may contact us.

GrowthVitals accounts require a username and password to log in. Users must keep their username and password secure, and never disclose it to a third party. Because the information in a User’s GrowthVitals account is private, account passwords are hashed, which means we cannot see a User’s password. We cannot resend forgotten passwords either. We will only provide Users with instructions on how to reset them.

E. International Transfers

(i) We operate in the United States

GrowthVitals is headquartered in and has offices in the United States and our servers are also located in the United States. This means data we process may be transferred to, stored, or processed in the United States.

(ii) Data transfers from Switzerland, United Kingdom, or the EEA to the United States

GrowthVitals has in place appropriate safeguards in accordance with applicable legal requirements to provide adequate protection for any personal data transferred from Switzerland, the UK, or the EEA to the United States. For example, we use and have incorporated European Commission approved "Standard Contractual Clauses" or "Model Clauses" into our Data Processing Agreement.

In addition, GrowthVitals participates in and will continue to certify its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. While the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks were invalidated in 2020 by the Court of Justice of the European Unition, we will continue to honor our obligations under our certification and adhere to the Privacy Shield's principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield website available here.

We adhere to the Privacy Shield Principles for all onward transfers of Personal Information from the EEA, the United Kingdom, and Switzerland.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge to you) at https://feedback-form.truste.com/watchdog/request.

Users located in Switzerland, the United Kingdom, and the EEA are subject to our Data Processing Addendum available here, as described in our Standard Terms of Use.

(iii) Users located in Australia

If you are a User, Contact or Visitor who accesses our Service in Australia, this section applies to you. We are subject to the operation of the Privacy Act 1988 ("Australian Privacy Act"). Here are the specific points you should be aware of:

• As stated in our Acceptable Use Policy available here, sensitive personal information is not permitted on GrowthVitals’s platform and Users are prohibited from importing or incorporating any sensitive personal information into their GrowthVitals accounts or uploading any sensitive personal information to GrowthVitals’s servers.
• Please note that if you do not provide us with your Personal Information or if you withdraw your consent for us to collect, use and disclose your Personal Information, we may be unable to provide the Service to you.
• Where we collect Personal Information of our Visitors, the Personal Information we ask you to provide will be information that is reasonably necessary for, or directly related to, one or more of our functions or activities. Please see Section 4, of this privacy policy for examples of the types of Personal Information we may ask Visitors to provide.
• Where we say we assume an obligation about Personal Information, we will also require our contractors and subcontractors to undertake a similar obligation.
• We will not use or disclose Personal Information for the purpose of our direct marketing to you unless:
  • you have consented to receive direct marketing;
  • you would reasonably expect us to use your personal details for marketing; or
  • we believe you may be interested in the material but it is impractical for us to obtain your consent.

You may opt out of any marketing materials we send to you through an unsubscribe mechanism. If you have requested not to receive further direct marketing messages, we may continue to provide you with messages that are not regarded as "direct marketing" under the Australian Privacy Act, including changes to our terms, system alerts, and other information related to your account as permitted under the Australian Privacy Act and the Spam Act 2003 (Cth).

• Our servers are located in the United States. In addition, we or our subcontractors may use cloud technology to store or process Personal Information, which may result in storage of data outside Australia. It is not practicable for us to specify in advance which country will have jurisdiction over this type of offshore activity. All of our subcontractors, however, are required to comply with the Australian Privacy Act in relation to the transfer or storage of Personal Information overseas.
• We may also share your Personal Information outside of Australia to our business operations in other countries. While it is not practicable for us to specify in advance each country where your Personal Information may be disclosed, typically we may disclose your Personal Information to the United States, Canada and the European Union.
• You may access the Personal Information we hold about you. If you wish to access your Personal Information, you may do so by visiting this page, or by emailing us at [email protected]. We will respond to all requests for access within a reasonable time.

If you think the information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, we will take reasonable steps, consistent with our obligations under the Australian Privacy Act, to correct that information upon your request. If you find that the information we have is not up to date or is inaccurate or incomplete, please contact us in writing, so we can update our records. We will respond to all requests for correction within a reasonable time.

• If you are unsatisfied with our response to a privacy matter, you may consult either an independent advisor or contact the Office of the Australian Information Commissioner for additional help. We will provide our full cooperation if you pursue this course of action.

F. Retention of Data

We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:

• Whether we have a legal or contractual need to retain the data.
• Whether the data is necessary to provide our Service.
• Whether our Users have the ability to access and delete the data within their GrowthVitals accounts.
• Whether our Users would reasonably expect that we would retain the data until they remove it or until their GrowthVitals accounts are closed or terminated.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or de-identify it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

G. California Privacy

The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which may include our Users with whom you have a relationship) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.

When offering services to its Users, GrowthVitals acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Users in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to the User with whom you have a direct relationship.

Consistent with California law, if you choose to exercise your applicable CCPA rights, we won’t charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.

H. Do not Track

Certain state laws require us to indicate whether we honor “Do Not Track” settings in your browser. GrowthVitals adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.

I. Changes to this Policy

We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the GrowthVitals Sites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the GrowthVitals Site.

J. Questions & Concerns

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please send an email to [email protected]. For the purposes of EU data protection legislation, The Rocket Science Group LLC d/b/a GrowthVitals is the controller of your Personal Information. Our Data Protection Officer can be contacted at [email protected]. You may also contact us by postal mail or email at:

For EEA and UK Residents:

If you are located in the EEA or the United Kingdom and have questions about your personal data or would like to request access, update, or delete it, you may contact us.