Privacy Notice

1. Overview

Easy Grow Realty (“Easy Grow Realty,” “we,” “us,” and “our”) respects your privacy and is committed to protecting it through compliance with this Privacy Policy (“Privacy Policy”). This Privacy Policy describes how we collect and use your Personal Information when you visit our website www.easygrowrealty.com or otherwise use the Platform as described further in the Terms of Service, and that you may provide in electronic messages to Easy Grow Realty.

Please read this Privacy Policy to understand our policies and practices regarding your Personal Information and how we will handle it. If you do not agree with our policies and practices, do not use the Platform. By accessing our website, using our services or using the Platform, you agree and consent to this Privacy Policy.

Easy Grow Realty may change this Privacy Policy at any time, at its discretion. Your continued use of the Platform after we make changes is deemed to be acceptance of and consent to those changes, so please check the Privacy Policy periodically for updates.

This Privacy Policy is subject to and governed by the Easy Grow Realty Terms of Service. The Services are part of the Platform and are described further in the Terms of Service.

2. The Types of Information That Easy Grow Realty Collects About You and How Easy Grow Realty Collects Information About You

Easy Grow Realty may collect two types of information from you when you visit the Platform: Personal Information and Non-Personal Information (collectively “Information”).

“Personal Information” refers to data by which you may be personally identified, such as name, email address, company, employer, job title and department, social media pages/profiles and telephone number.

“Non-Personal Information” means data that is about you, but does not identify you specifically. If you do nothing during your visit to our Platform but browse, read pages, or view content, we will gather and store Information about your visit that does not identify you personally.

We collect Information:

Directly from you when you provide it to us. When you subscribe to a newsletter, create an account, make a purchase or request information from Easy Grow Realty, we will ask for things like your name, contact, billing, shipping and communication information, and account ID or credentials in order to fulfill your request. If you set up an appointment with us through the Platform, attend a trade show or event, or otherwise contact us, you may also voluntarily provide similar information. If you submit any Personal Information about other people to us or to our service providers, you are responsible for making sure that you have the authority to do so and to allow us to use their Personal Information in accordance with this Privacy Policy (for example, by You asking for their consent).

From third parties. We obtain information through publicly available platforms, partners, email finding tools, vendors, suppliers and other third parties. The parties from whom we obtain information are typically corporate enterprises (although some may also be educational or public enterprises) and they may be located in any of the locations in which we do business. These enterprises largely fall into the following categories: Advertising and marketing companies, data set and information vendors, public database providers, social media platforms, partners, providers of products or services, hosts or vendors at events or trade shows, research partners, or enterprises that use Easy Grow Realty Services. We take steps to confirm that information we receive from these third parties has been collected with your consent or that these parties are otherwise legally permitted to disclose your Personal Information to us. We might also obtain information through a partner, or co-create datasets with a partner, as part of our business operations. This kind of data is used for work like improving the Platform and other Easy Grow Realty Services, enhancing existing products and developing new capabilities and features. In some cases we combine Personal Information about individuals that we receive from multiple sources, including directly collected from you or through your use of the Platform.

Automatically as you navigate through the Platform or during the time in which you utilize our Services. We collect information about how you interact with the Platform through the use of cookies, pixel tags, and similar technologies. Please view our separate Cookies Policy for more information on our use of cookies and similar technologies, how you can manage cookies and how we respond to Do Not Track signals.

3. How Easy Grow Realty Uses Personal Information It Collects About You and the Purposes for the Collection and Use

We use Personal Information that we collect about you or that you provide to us for the following purposes:

For Functionality and Development of the Platform and Easy Grow Realty Services. We use information to provide, offer, and personalise the Platform and other Easy Grow Realty Services provided to you. Some information, like your IP address, is used to communicate with your device to provide network connectivity, measure usage levels of the Platform, diagnose server problems and provide security features. Other business purposes that depend on use of your information include data analysis related to testing, modifying, improving or developing new products, services and technologies, and to identify trends. We use cookies to make our websites and the Platform operate, work more efficiently, and provide analytic information. Technologies similar to cookies, such as pixel tags are also used in connection with the Platform. For more information on our use of cookies, please read our Cookies Policy.

For Customer Support, Platform Updating and Reporting. The Platform may use information to provide Easy Grow Realty with updates and reports, and to check that the Platform is working properly. Update functions may automatically check your system to see whether files need to be refreshed, updated, or modernized, in order to provide you with the up-to-date security, versions, features, options and controls associated with your systems or devices. We rely on information to analyze performance and improve and maintain the Platform. We also rely on Personal Information you provide to us to provide you with customer support for the Platform and other Easy Grow Realty Services, and to verify eligibility for promotional offers.

For Business Operations. We use information to operate our business; for example, to perform accounting, auditing, billing, reconciliation, and collection activities. Other business purposes that depend on use of your Personal Information include crime or fraud monitoring and prevention, protecting our legal rights, and performing contractual obligations. We also use Personal Information to contact you to advertise, market and sell Easy Grow Realty Services in accordance with your communications preferences.

To Communicate. We use contact information to send messages; to provide Easy Grow Realty Services; to respond to customer service requests; to provide alerts such as security updates or changes in our policies or about subscriptions that are ending; and to send marketing or informational materials like newsletters or white papers, in accordance with your communication preferences. We occasionally conduct surveys, or do focused research or studies which may require you to voluntarily share Personal Information in order to participate. These activities typically have additional notices that provide more information about the use of your Personal Information and to which you may be asked to consent.

For Advertising and Marketing. We may use Personal Information collected from you, combined with information about what advertisements you viewed and other information we collect, to enable us to provide personalized content and to study the effectiveness of advertising and marketing campaigns. You may choose whether to allow or deny uses or sharing of your device’s location by changing your device settings, but if you choose to deny such uses or sharing, we may not be able to provide you with certain personalized Easy Grow Realty Services and content on the Platform.

For Statistical Purposes to Improve the Platform and our services. We may compile Platform statistics into traffic reports, which help Easy Grow Realty understand, anticipate, and respond to user needs. If we learn, for example, of heightened interest in certain aspects of the Easy Grow Realty Platform, we are likely to highlight that information on the Platform home page. This Information helps us create a better overall experience for Platform users.

LEGAL BASIS FOR OUR USE (APPLICABLE ONLY TO EEA AND UNITED KINGDOM VISITORS): If you are in the European Economic Area or the United Kingdom, 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 collect Personal Information from you only where we have your consent to do so, where we need the Personal Information to perform a contract with you, where we have a legal obligation to do so, or where the processing is in our legitimate interests (such as processing for administrative purposes, direct marketing, product development or improvement, preventing fraud or criminal acts and in support of information security) and not overridden by your data protection interests or fundamental rights and freedoms.

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 time of collection. We will also tell you whether the requirement for that information is mandatory and explain any consequences to you if you do not provide the information.

Easy Grow Realty is the Data Controller of all Personal Information collected through the Platform in the EEA and the United Kingdom, except with respect to the Services (where Easy Grow Realty is the Data Processor) or where a supplemental Privacy Policy says otherwise. The contact details for Easy Grow Realty are set out in the "HOW TO CONTACT US” section.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information for any specific processing activity, please contact us using the contact details provided under the “HOW TO CONTACT US” Section below.

RETENTION OF YOUR PERSONAL INFORMATION: We will only retain your Personal Information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements and for other purposes described in this Privacy Policy. We may retain your Personal Information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances you can ask us to delete your data: see “YOUR LEGAL RIGHTS” below for further information. And in some circumstances we will anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Personal Information we collect:

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.

The personal information we collect may include the following:

names

phone numbers

email addresses

addresses

job titles

usernames

passwords

contact preferences

contact or authentication data

billing addresses

debit/credit card numbers for payments

sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

financial data

information revealing trade union membership

credit worthiness data

student data

payment Data

property information

4. How Easy Grow Realty Protects Your Information

The Platform is designed to provide reasonable and appropriate administrative, technical and organisational security measures to protect your Personal Information against risks such as temporary or permanent loss, destruction, and unauthorised or unlawful access, alteration, use or disclosure. We require our suppliers and vendors to apply similar protections when they access or use Personal Information that we share with them. Users of the Platform must also do their part in protecting the data, systems, networks, and service they are utilizing. No technology, data transmission or system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that your password to any Easy Grow Realty account has been compromised), please immediately notify us by contacting us using the instructions in the “HOW TO CONTACT US” section below.

5. When Easy Grow Realty Shares Your Information

We work through our affiliates to provide the Platform and other Easy Grow Realty Services. We also work with authorised suppliers and business partners. When we share your Personal Information with these companies, we put in place appropriate measures to limit the use of your information only for legal and authorised purposes that are consistent with this Privacy Policy, as well as appropriate confidentiality and security measures.

We also share information with third parties for advertising and marketing; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Platform; and to protect our legal rights. We may disclose Personal Information that we collect or you provide as described in this

Privacy Policy:

With Affiliates and Subsidiaries. For purposes limited to and consistent with this Privacy Policy.

With Suppliers. Our authorised vendors and suppliers may require Personal Information to provide services we have contracted for, such as product delivery, website hosting, data analysis, IT services, auditing, or customer service. We use a wide variety of software and tools at Easy Grow Realty, and we process Personal Information using these tools as a regular course of business. Our contracts with suppliers and vendors include provisions to protect your Personal Information and limit its use.

With Partners. We occasionally have relationships with third parties that are not suppliers or vendors but are working with us to offer certain opportunities such as marketing and similar promotions, to enable joint products or research studies, or to facilitate services on the Platform. In these cases, additional terms or Privacy Policies may be provided. For third parties or uses not described in this Privacy Policy, we share your information only with a lawful basis to do so.

For Advertising and Marketing. We share your information with our third-party company partners to prepare and deliver advertising and marketing content, to provide content services and to enable them to provide you with more personalised ads and to study the effectiveness of our campaigns.

In particular, we use third-party companies to communicate regarding goods and services that may be of interest to you, in accordance with your preferences. You may receive this content by a variety of means such as email, phone or when you access and use the Platform or other Easy Grow Realty Services, and other websites. Content may be based on information obtained, for example, through prior purchases or transactions, through your device’s physical location, through information about what advertisements and content you have viewed, or through cookies and similar technologies relating to your access to and use of the Platform and other websites. Please read our Cookies Policy for more information. You can choose whether to allow or deny uses and/or sharing of your device’s location by changing your device settings, but if you choose to deny such uses or sharing, our partners may not be able to provide you with the applicable Platform Services and content.

For Connections to Social Networks and Third Party Services. Where you are using our Services and have chosen to connect your social networks profiles to the Easy Grow Realty Services, or if you authorise a third party service to access your account, you are agreeing to provide information about you to the social networks and the third party services under their respective terms and privacy policies. For example, if you choose to connect your YouTube account to the Easy Grow Realty Services, this connection uses YouTube’s API services, and the Google Privacy Policy (located here) will apply to you. If you have authorised us to access your information via the YouTube API services, in addition to our normal procedure for deleting stored data, you may revoke our access to your data via the Google security settings page, located here.

Sales, Mergers & Acquisitions. We may disclose Personal Information as part of a contemplated or actual corporate transaction such as a reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

With Your Consent. Easy Grow Realty may disclose your Personal Information to any other person or entity where you consent to the disclosure. For information about how to decline our advertising and marketing, please see the section entitled "Your Choices & Rights" below.

We also share non-personally identifiable information, such as anonymised or aggregated information, with suppliers for purposes such as analysis, identifying trends in the areas of our products and helping research and develop new Easy Grow Realty Services.

Easy Grow Realty does not sell any of your Personal Information for monetary compensation.

6. Information From Children

We do not knowingly collect, use, or disclose Information from children under 16. If we learn that we have collected the Personal Information of a child under 16—or the equivalent minimum age depending on the jurisdiction, such as 13 in the United States per the Children’s Online Privacy Protection Act—we will take steps to delete the information as soon as possible. If you are under 16, do not provide any Information about yourself to Easy Grow Realty, including your name, address, telephone number or email address. If you become aware that Information of a child under 16 years of age has been provided, please use one of the methods provided under the “HOW TO CONTACT US” section below.

7. Links to Other Websites and Services

We are not responsible for the practices employed by websites, third parties, platform users or services linked to or from the Platform, including the information or content contained therein. This Privacy Policy does not address, and we are not responsible for, the policies and practices of third parties or other organizations that are not operating on Easy Grow Realty’s behalf, including policies and practices related to privacy and security, data collection, processing, use, storage, and disclosure. This includes: (a) any third party operating any site or service to which the Platform links – the inclusion of a link on the Platform does not imply endorsement of the linked site or service by us or by our affiliates; or (b) any app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer (such as Facebook, Apple, Google, Microsoft, LinkedIn, etc.) - including any Personal Information you disclose to other organizations through or in connection with the Platform or other Easy Grow Realty Services.

8. Do Not Track

Some browsers incorporate a "Do Not Track" (“DNT”) feature that, when turned on, signals to websites and online services that you do not want to be tracked. At this time, the Platform does not respond to DNT signals.

9. YOUR LEGAL RIGHTS

Easy Grow Realty respects your rights in how your Personal Information is used and shared. Depending on where you live, you may have rights to request access or corrections to your personal data and make choices about the kinds of marketing materials you receive (or choose not to receive marketing from Easy Grow Realty at all). See below for more information, depending on your location.

10. European Privacy Rights

If you are in Europe, you may have additional rights under the GDPR, the UK GDPR, or nFADP. Additional choices and rights may be available to you depending on which Easy Grow Realty Services you use.

Access, Correction to or Deletion of Your Information. If you would like to correct or update your Personal Information, or to request access to or deletion of your Personal Information, you may contact us by visiting the Platform or by using the contact details provided under the “HOW TO CONTACT US” section below. If you request a change to or deletion of your Personal Information, please note that we may still need to retain certain information for recordkeeping purposes, and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). Some of your information may also remain within our systems and other records where necessary for compliance with applicable law.

At your request and where the law requires us to do so, we will confirm what Personal Information we hold about you. You may also have a legal right to obtain a copy of your Personal Information. You can make such a request by making a written request in one of the ways described in the “HOW TO CONTACT US” section below. We may charge a processing fee for this service where permitted by law and we will require evidence of your identity before fulfilling your request.

Data Privacy Rights Specific to Individuals in the European Economic Area, the United Kingdom, and Switzerland. You can object to processing of your Personal Information, ask us to restrict processing of your Personal Information, or request portability of your Personal Information. You can exercise these rights by making a written request in one of the ways described in the “HOW TO CONTACT US” section below.

Similarly, if we have collected your Personal Information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect (1) the lawfulness of any processing we conducted prior to your withdrawal, or (2) processing your Personal Information under other legal bases.

Advertising and Marketing Choices. We give you many choices regarding our use and disclosure of your Personal Information for advertising and marketing purposes. You may access or update your contact details and modify your communication preferences by using one of the methods provided under the “HOW TO CONTACT US” section below. Please also note that if you choose not to receive marketing communications from us, we may still send you communications related to your products or the Platform, such as information about a security update, service issue or product delivery. Some advertising content is delivered through the Platform’s use of cookies and similar technologies. Our Cookies Policy includes more information on Easy Grow Realty’s use of such technologies for advertising and other purposes.

11. International Compliance

Easy Grow Realty is a global company with its headquarters in the United Kingdom. As such, we may transfer your Personal Information between the United Kingdom, Europe, India, Indonesia and our affiliates and business partners in other countries. We may also transfer your Personal Information to our third party service providers, who may be located in a different country to you.

Easy Grow Realty transfers information internationally in order to operate efficiently, to improve performance, and to create redundancies to protect information in the event of an outage or other problem. In so doing, we will process your Personal Information in a way that meets the commitments of this Privacy Policy and complies with the law wherever we transfer it.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

Our servers are located in Spain, and United Kingdom. If you are accessing our Services from outside Spain, and United Kingdom, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?' above), in Spain, United Kingdom, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

HOW CAN YOU CONTACT US

If you have questions or comments about this notice, or to contact us about disclosing the data we have associated with you, you may contact us by post at:

Top Floor Claridon House, London Road, Stanford Le Hope, Essex, England, SS17 0JU or by email at [email protected]