Privacy Policy

In order to use our App or website, we may ask you to enter your name, email and ask other onboarding questions. You may be able to skip some of the onboarding questions by tapping on Skip or similar indication.

We also may automatically collect from your device: language settings, IP address, time zone, type and model of a device, device settings, operating system and other technical information. We need this data to provide our services (for example, to render a certain element of the product), analyze how our customers use the App (for example, to know whether our customers use the features we release), to serve ads. Most of the time, you can influence such processing by limiting it via our privacy features available on the websites and/or apps.

Please read our Privacy Policy below to know more about what we do with data (Section 2), what data privacy rights are available to you (Section 4). Depending on the region from where you access our Services, we strive to provide you with various privacy control features and rights.

When such features are available to you, this will be prominently displayed either in footers, menus, or profile sections of our products. When they are not available as a feature, please submit a request to us.

If any questions remain unanswered or you would like to exercise your privacy rights, please contact us at support@growio.pro.

This Privacy Policy explains and lists the transparency information regarding what personal data is collected when you use our mobile applications, websites and the services provided through them (together “App” or “Service”) and how such personal data will be processed.

By using the Service, you promise us that (i) you have read, understand and agree to this Privacy Policy and the data processing described, and (ii) you are over 18 years of age. If you do not agree, or are unable to make this promise, you must not use the Service. In such a case, you must (a) delete your account and contact us and request deletion of your data; (b) cancel any subscriptions using the functionality provided by us if you purchased it directly from our websites; and (c) delete the App from your devices.

Contents:

  1. Categories of personal data we collect
  2. What are the purposes and legal bases for processing your personal data
  3. With whom we share your personal data
  4. How you can exercise your privacy rights
  5. Age limitation
  6. International data transfers
  7. Changes to this Privacy Policy
  8. Data retention
  9. Personal data controller
  10. Contact us

1. Categories of personal data we collect

We process data:

(i) you directly provide to us (for example, during account creation),
(ii) obtained from third-party sources (for example, payment service providers).
(iii) automatically when you use our Service (for example, your IP address via cookies or SDK technologies).

1.1. Data directly provided by you

  1. Identifiers
    This may include your name, phone number, email address. You provide us with this information when you register for the Service, purchase our Service or contact us by any other means.
  2. Onboarding and product data
    You provide us with this category of information when you register for the Service and/or go through the onboarding process and/or use the Service. This category includes general information about you (for example, age, date of birth, gender, etc) and information about your financial literacy and economic well-being.
  3. Comments and attachments you provide with your requests
    You may also provide us with some personal information by sending emails on our email addresses. This information may include any comments you log in when you send your inquiry.

1.2. Data obtained from third-party sources

  1. Commercial information
    When you make payments through the Service, you need to provide financial account data, such as your credit card number, to our third-party service providers that serve us as data and payments processors. We do not collect or store, or have access to full credit card number data, though we may receive some limited information, for example, credit card-related data (including a secure token reflecting your payment method), data about products or services purchased, date, time and amount of the purchase, the type of payment method used, limited digits of your card number.

1.3. Data we collect automatically

  1. Online activity
    We record how you interact with our Service. For example, we log your interactions with certain areas of the interface, the features, and content, how often you use the App, how long you are in the App, and your subscription orders.
  2. Device data
    We collect data from your mobile device. Examples of such data include: language settings, Internet Protocol address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.
  3. Advertising IDs
    We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).
  4. Cookies and similar tracking technologies
    Our products employ technologies (cookies, SDKs, etc.) to process your data to enhance your user experience, optimize ads, and analyze traffic. These technologies are activated when you interact with our services, visit our website, use our Apps, or enable certain features.

2. What are the purposes and legal bases for processing your personal data

We collect and utilize your data primarily to provide our services, enhance the quality of our services and to continuously improve them. Furthermore, we aim to attract new customers to our products. Below, you'll find a more comprehensive breakdown of how we use your information, illustrated with clear examples.

Purpose of processingDescription and examplesCategories of personal dataLawful basis
To provide our Service and administer your account

This includes verifying your identity, email verification, enabling you to access and use our Service in a seamless manner and preventing or addressing Service errors or technical issues, customizing your experience.

Consequences of this processing may also include:

Customizing your experience means that we adjust the content of the Service and provide content tailored to your personal preferences.

Responding to your requests for technical or customer support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests, providing a comprehensive answer to your inquiries, making sure that you are satisfied with our Service, as well as processing any disputes in regard of our Service, accessing your account to address technical support requests.

For this purpose, we may send you, for example, notifications or emails about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use or this Privacy Policy.

We may also process your data for these purposes if you take part in our giveaways or other similar events that are subject to specific terms and conditions.

All categoriesPerforming our contract with you
To communicate with you regarding your use of our Service

We communicate with you, for example, by push notifications. These may include reminders, password resets or account updates. To opt out of receiving push notifications, you need to change the settings on your device.

We may also communicate with you regarding important updates or changes to our Service, to gather feedback on our Service or to respond to any inquiries or complaints you may have.

All categoriesPerforming our contract with you (or legitimate interest*, when it is not necessary for provision of our Service)
To communicate with you regarding possible cooperation

This includes being able to contact you to discuss possible forms of cooperation, such as partnership opportunities or service enhancements that may be of interest to you.

IdentifiersLegitimate interest*
To process and fulfill your transactionsWe provide paid services. For this purpose, we use third-party services for payment processing. As a result of this processing, you will be able to make a payment for our Service and we will be notified that the payment has been made and will provide you with the purchase. We will not store or collect your payment card details ourselves.
  • Identifiers
  • Commercial information
  • Device data
Performing our contract with you
To research and analyze your use of the Service and conduct user research (surveys, interviews)

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products.

We also use data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features of the Service our users like more, what categories of users use our Service. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.

We may also process your data for these purposes if you participate in a specific survey or interview.

All categoriesLegitimate interest* (unless it requires consent)
To send our marketing communications

We may add your email address to our marketing list, provided we receive consent or otherwise establish a legal basis for sending you marketing communications. As a result, you will receive information about our products, for example, special offers.

If you do not want to receive marketing emails from us, you can unsubscribe following instructions in the footer of the marketing emails.

IdentifiersConsent or Legitimate interest* (in jurisdictions that allow exception to consent requirements)
To personalize our adsWe and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our Service, you might see ads of our products, for example, in your Instagram's feed.
  • Onboarding and product data
  • Online activity
  • Commercial information
  • Device data
  • Advertising IDs (for example, we may use it for preventing or fixing technical issues);
  • Cookies and similar tracking technologies
Legitimate interest* (unless it requires consent)
To audit ad performances

That means to conduct auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.

  • Identifiers
  • Onboarding and product data
  • Online activity
  • Commercial information
  • Device data
  • Advertising IDs
  • Cookies and similar tracking technologies
Legitimate interest* (unless it requires consent)
To enforce our Terms and Conditions of Use and to defend our legal rights and interestsWe collect and store personal data to the extent necessary to defend our legal rights and interests in the event of legal disputes or claims. This may include using the data to support our legal claims, respond to legal requests, or establish, exercise, or defend our legal position. All categoriesLegitimate interest*
To comply with legal obligations

We may use this data to comply with legal obligations, such as tax regulations, accounting standards, or other applicable laws and regulations.

Specifically, we may use your Commercial information to calculate and report taxes owed, issue invoices or receipts, respond to tax-related inquiries from government authorities, maintain accurate financial records, comply with data protection laws, respond to lawful requests from law enforcement or regulatory agencies, etc.

All categoriesComplying with legal obligations
To prevent and combat fraudWe use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. This may involve verifying user identities, monitoring transactions for suspicious activities, and taking appropriate action to protect our users and our Service from fraudulent activities.All categoriesLegitimate interest*

*We rely, in particular, on the following legitimate interests:

3. With whom we share your personal data

We engage partners to carry out specific services or business functions on our behalf using their technologies and resources, based on our instructions. This cooperation may involve, in particular, processing your data using their software development kits (SDKs), APIs, cookies, and other technologies. Consequently, your information is transferred and processed on their servers (usually without a partner's direct access to the specific pieces of information) on our behalf for our purposes.

Such type of processing of personal data may be regarded as sharing of information with third parties. We strive to conclude specific data processing agreements with all such parties to establish the rules for processing of your data specifically on our behalf and limited to it. Our partners help us operate, provide, improve, integrate, customize, support, and market our Service.

The types of third parties we share information with include, in particular:

  1. Third-party services providers

    We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We process your personal information using the following types of service providers (and in certain cases, their subprocessors):

    1. Cloud storage providers

      • To host personal data and enable our Service to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon. You may read more on Amazon’s security practices on its website.
    2. Product monitoring service providers

    3. Data analytics providers

      1. Ad performance measurement systems

        • To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Appsflyer allows you to Opt Out of having data from my device sent to AppsFlyer's servers for apps usage collection. You can read more about Appsflyer’s privacy practices in its Privacy Policy.
      2. General analytics tools

        We also use Amplitude that is an analytics service that we use to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone or tablet), unique identifiers (such as IDFA). Amplitude also allows us to track various interactions that occur in our App. As a result, Amplitude helps us to decide what features we should focus on. Amplitude complies with the EU-U.S. Data Privacy Framework ("EU-U.S. DPF"). Amplitude provides more information on how they process data in its Privacy Policy.

        To analyze how visitors use the Service and to measure the effectiveness of some ads we use Google Analytics, a web analysis program of Google. On Google Analytics we get, in particular, information on the data you enter on our website and users’ interactions within the website. Google allows you to influence the collection and processing of the information generated by Google, in particular, by installing a browser plug-in, available here. You can read more about how Google uses the information here.

        To track and analyze behavior of our App’s users (in particular, how they react to changes of the App structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google, which also enables us to tailor the content that our App’s users see (for example, it allows us to show different onboarding screens to different users).You can read more about Firebase’s privacy practices in its Privacy Policy and Privacy and Security in Firebase.

    4. Gateway service providers and payment processing partners

      • We use various payment processing and payment gateway providers that help us connect with different banks and payment systems around the world. These providers allow us to offer our customers a wide range of payment options and ensure fast and smooth transactions. Due to the large number of payment processing providers we work with, we cannot list them all here. Each payment processing provider has its own terms and conditions and privacy policy that may apply to the transactions they process.
    5. Communication services providers

      • Zendesk provides us with customer service software, which enables us to handle your inquiries and requests via email, chat, phone and other channels. Thus, when you contact us via any of these channels, some of your information is automatically transferred to Zendesk. The transfer is required to provide you with timely and effective support. Read more about Zendesk’s approach to privacy on their website.
    6. Marketing service providers

      • Meta. We use Meta Ads Manager together with Meta Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Meta’s products (for example, Instagram). Through Meta Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the App (for example, installed it). As a result, we may ask Meta to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Meta’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Meta Custom Audience here.

        Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.

      • Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear only to users that have conducted certain actions with our App (for example, show our ads to users who have purchased a subscription). Some other examples of events that may be used for tailoring ads include, in particular, installing our App. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.
      • Ad networks, ad agencies and direct publishers are third-party services that provide us with advertising solutions for displaying our ads on various websites and apps. In particular, these services allow us to target our ads based on your interests and activities on our App and other websites. Some examples of events that may be used for targeting ads include, in particular, installing our App or purchasing a subscription. These services may also collect some information about you such as your device ID or IP address for delivering relevant ads. You can opt out of interest-based advertising by visiting the Digital Advertising Alliance’s consumer choice page or the Network Advertising Initiative’s consumer opt-out page.
  2. Law enforcement agencies and other public authorities

    We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

  3. Third parties as part of a merger or acquisition

    As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

  4. Affiliates

    We may share your personal information with our partner organizations that are part of our corporate group – these are companies that are owned by, own, or are jointly-owned with us. These partner organizations will use the information in ways that align with this Privacy Policy, ensuring that your privacy is respected and protected across all our affiliated services.

4. How you can exercise your privacy rights

To be in control of your personal data, you have the following rights:

Exercising your rights
To exercise any of the available privacy rights, please send a request to support@growio.pro or use the privacy features available in our products.

5. Age limitations

We do not knowingly process personal data from persons under 18 years of age. If you learn that anyone younger than 18 has provided us with personal data, please contact us at support@growio.pro.

6. International data transfers

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy appropriate safeguards, such as standard contractual clauses adopted by the European Commission.

7. Changes to this Privacy Policy

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

8. Data retention

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy and our the Terms and Conditions of Use (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the Service.

We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. For example, under certain accounting and tax laws we are required to store Commercial Information for long periods of time to comply with laws we are subject to. Therefore, even if you submit a data deletion request, a small portion of the data that relates to our compliance obligations will be stored even after the request is satisfied.

9. Personal data controller

Imponilox Limited (reg. No. HE 405373 with a registered office at Themistokli Dervi 39, 1st floor, Office 104, 1066, Nicosia, Cyprus) will be the controller of your personal data.

10. Contact us

You may contact us at any time for details regarding this Privacy Policy, its previous versions, or our information practices. For any questions concerning your account or your personal data, please contact us at support@growio.pro.

Last update: February 20, 2026