Privacy Policy
Version Date: October 11, 2022
Bowery Growth LLC (“Company” or “we” or “us” or “our”) respects the privacy of its users (“user” or “you”) whether they use our website located at www.bowerygrowth.com, including other media forms, media channels, mobile website or mobile application related or connected thereto (collectively, the “Website”) to access our data augmentation and intelligence service or simply to view the Website (the “Company Services”). The following Company privacy policy (“Privacy Policy”) is designed to inform you, as a user of the Company Services, about the types of information that Company may gather about or collect from you in connection with your use of the Company Services. It also is intended to explain the conditions under which Company uses and discloses that information, and your rights in relation to that information. Changes to this Privacy Policy are discussed at the end of this document. Each time you use the Company Services, however, the current version of this Privacy Policy will apply.
Our Services and Targeting Data. Personal Data is data that can be attributed to an individual. We work with a variety of sources to assist our Customers in targeting advertising based on demographic, geographic and employment profiles, but not any Personal Data. Using these profiles, we can target advertising toward groups of persons that fit these general profiles using online advertising services. We transmit the profiles as instructed by our Customers to advertisers using APIs to allow them to target advertising through specific ad networks through our platform.
What Data Do We Collect?
Personal Data. We collect the name, email address, address, phone number and payment information for users that want information regarding the Company Services, that are customers or who enter into contests or promotions with us.
Tracking Data. We use cookies, IP Addresses and device IDs to track use of our Company Services by our customer users. We also collect tracking data to better understand how people use our website and Company Services.
Cookie Policy
When you visit our Site we use cookies, or similar technologies like single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. They are unique and allow us to do site analytics, customization and track our customers’ use of the Company Services among other similar things. If you access our Site through your browser, you can manage your cookie settings.
How Do We Use Your Data?
We use Customer Personal Data for the purpose of providing the Company Services you pay for and tracking use of those Company Services for customer service and billing purposes. We also use your Personal Data connected with payment and use in order to bill you for the Company Services purchased by the Customer using a third-party service provider. We do not store your payment information. If you are a customer, we also may use your information to contact you for direct marketing purposes to let you know about our products or services that might be of interest to you.
From time to time, Company may offer users the opportunity to participate in contests, giveaways and other promotions. Any information submitted in connection with such activities will be treated in accordance with this Privacy Policy. From time to time, Company may also ask users to participate in surveys designed to help Company improve the Company Services. Any Personal Data provided to Company in connection with any survey will be used only in relation to that survey and will be disclosed to third parties not bound by this Privacy Policy only in non-personally identifying, aggregated form.
How Do We Share Your Data?
We may share Personal Data with third parties outside of our company in the following ways: Law Enforcement and Internal Operations. Personal Data may be provided where we are required to do so by law, or if we believe in good faith that it is reasonably necessary (i) to respond to claims asserted against Bowery Growth LLC or to comply with the legal process (for example, discovery requests, subpoenas or warrants); (ii) to enforce or administer our policies and agreements with users; (iii) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (iv) to protect the rights, property or safety of Bowery Growth LLC, its users or members of the general public. We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to any third-party request to compel disclosure of your information.
Business Transfer. We may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. Under such circumstances, we will use commercially reasonable efforts to notify its users if their personal information is to be disclosed or transferred and/or becomes subject to a different privacy policy.
Third Parties. We contract with other companies and individuals to perform functions or services on our behalf, such as software maintenance, data hosting, sending email messages, etc. We necessarily have to share your Personal Data with such third parties as may be required to perform their functions. We take steps to ensure that these parties take protecting your privacy as seriously as we do, including entering into Data Processing Addendum, EU Model Clauses and/or ensuring they have EU-U.S. and Swiss-US Privacy Shield certification.
With Your Consent. We may obtain your consent from time to time in electronic form by using online agreements or other acknowledgments, including for any other contemplated uses of your Personal Data not addressed in this Privacy Policy.
Legal Grounds
We rely on the following legal grounds to process your personal information:
Consent. Some uses of your Personal Data as described in this Privacy Policy are subject to your consent, such as marketing email communications. To withdraw your consent, please contact us at nate [at] bowerygrowth [dot] co. You may also refrain from providing, or withdraw, your consent for Cookies via your browser and mobile settings.
Performance of a Contract. We may need to collect and use your Personal Data to enter into a contract with you and to perform Company Services that you request.
Legitimate Interests. We may use your Personal Data for our legitimate interests to provide our Company Services and to improve our Company Services. We may use technical information as described in this Privacy Policy and use Personal Data for our (and our customers’) marketing purposes consistent with our (and their) legitimate interests and any choices that may be offered or consents that may be required under applicable law.
Advertising Resources We work with, and our customers may share data to target ads through, the following advertising technology providers:
Facebook. Subject to their privacy policy and data policy, you may make a data subject request.
LinkedIn. Subject to their privacy policy, you may contact their Data Protection Officer.
These providers also collect tracking data via cookies on our site as well.
How is My Data Protected?
We have implemented reasonable administrative, technical and physical security measures to protect your personal information against unauthorized access, destruction or alteration. For example: SSL encryption (https) everywhere we deal with personal data. Restricting staff access to Personal Data. However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we store, process or transmit.
Your Choices
Third Party Advertising and Profile Sources. We work with third party advertising technology and information databases to build profiles for our customers to target advertising. However, we do not directly place advertisements or control the information they collect. Even if they endeavor to be compliant with data protection laws, we are not responsible for their data protection policies. If you would like to exercise any of your data subject rights, such as the ones listed below, they will be subject to the privacy policies of the sources of such data and you should make such requests directly to them.
Right to Review and Rectify Your Personal Data. Customers can review and update most of your Personal Data by logging on to your account and changing your settings. However, if you are located in the European Economic Area (EEA) and additional assistance is required to review, change or delete inaccuracies within your Personal Data or would like to know what information about you was collected, please contact us at nate [at] bowerygrowth [dot] com. We reserve the right to charge for copies of data requested, subject to applicable law.
Right to Remove or Withdraw Consent. You have the right to withdraw consent where such consent is required to share or use data and you may request that we delete your Personal Data. If you receive communications from us and no longer wish to receive them, please follow the removal instructions in the email or change your account settings. You can request that we delete your Personal Data and your account by sending an email to us at nate [at] bowerygrowth [dot] com. However, since your Personal Data is required for us to provide the Company Services to you, deleting it will also terminate your access to the Company Services. Deleting your Personal Data does not mean that all of it will be removed. We take steps to delete Personal Data that is no longer necessary in relation to provide the Company Services or when we no longer have a legitimate purpose to retain such Personal Data. We may be required by law, to retain it to exercise or defend legal claims, or contractual obligations with our customers to retain some information in connection with our obligation to provide the Company Services. We may de-identify and anonymize some data for purposes of retaining it.
Data Portability. If you would like us to transmit your Personal Data to another company providing similar services, we will work with them to do so upon request and verification of such request with both the requestor and the company receiving the Personal Data.
Right to Redress. If you are located in the European Economic Area and you believe we have violated any data protection laws, you may file a complaint with your local data protection authority.
Processing End User Data for Customers
Our Company Services may involve the processing of Personal Data on behalf of our customers. When we do so, we are acting as processors for the controllers of such data. As such, we take steps to ensure that Personal Data subject to GDPR is processed in accordance with controller instructions and GDPR, such as entering into a Data Processing Addendum incorporating EU Standard Contractual Clauses governing the processing, transmission and use of such End User Personal Data. If you wish to exercise your data subject rights to review, rectify, delete or port your End User Personal Data, please contact the controller to make such request. If you make the request to us, we will work with the controller to process and evaluate such request to confirm whether deletion is required by GDPR.
Transnational Transfer of Data
If you are providing your Personal Data to us directly to use our Company Services, we will transmit your data, including your Personal Data, to the United States in order to fulfill our contractual obligations to you.
Minors Under 18 Years of Age
Bowery Growth LLC does not knowingly collect or store any personal information from or about children under the age of 18. If you believe a child under the age of 18 has under any circumstances provided us with personal information and data, a parent or legal guardian can email us at nate [at] bowerygrowth [dot] com to request that their children’s information be deleted from our records.
Do Not Track
“Do Not Track” or DNT is a feature enabled on some browsers that sends a signal to request that a web application disable its tracking or cross-site user tracking. At present, there is no industry-recognized way to recognize when a browser-based DNT signal is received.
Changes to Privacy Policy
We reserve the right to amend this Privacy Policy at any time. If we make material changes to its Privacy Policy, we will notify you by (1) changing the Effective Date on our Privacy Policy and provide additional notification either (1) via email or other means as we may deem commercially reasonable.
Questions? If you ever have any questions about our online Privacy Policy, please contact us. We respect your rights and privacy and will be happy to answer any questions or concerns you might have.
You may direct any such questions to us at: 30 N Gould St Ste N, Sheridan, WY 82801.
