Privacy Policy

1. Who this policy applies to

This policy applies to:

• Firm owners, administrators, employees and other GrowOn users.
• Clients, leads and other contacts whose information is entered into GrowOn by a firm.
• People who receive or send WhatsApp communications through a firm using GrowOn.
• Visitors to the GrowOn website.

Each firm determines what client information it enters into GrowOn and why it uses that information. GrowOn processes that information to provide services to the firm and according to the firm’s authorised instructions.

2. Information we collect

Depending on the features used, GrowOn may process:

GrowOn account information

• Name, email address, phone number and role.
• Firm name and business information.
• Login, authentication and account-security information.
• Subscription and account-status information.
• Support requests and communications with GrowOn.

CRM and business information

• Client and lead contact information.
• Portfolio and transaction information imported by the firm.
• Policy, investment and servicing information.
• Meetings, tasks, reminders and notes.
• Documents uploaded by authorised users.
• Consent, communication-preference and opt-out records.

Technical information

• IP address, browser, device and operating-system information.
• Sign-in records, security events, error reports and audit logs.
• Website usage information and essential cookie or analytics data used to operate, secure and improve the service.

3. Meta and WhatsApp information

When an authorised firm administrator connects a WhatsApp Business Account to GrowOn, GrowOn may receive or process:

• Meta Business Portfolio and WhatsApp Business Account identifiers.
• WhatsApp business phone-number identifiers and display phone number.
• Verified business or display name.
• Registration and connection status.
• Phone-number quality rating and account health information where provided by Meta.
• Permissions and authorisation information required to operate the integration.
• Access credentials issued by Meta for the connected business.
• WhatsApp message-template names, content, language, category, approval status and rejection reason.
• Recipient phone numbers supplied by the firm.
• Message content and template-variable values.
• WhatsApp message identifiers and sending timestamps.
• Sent, delivered, read and failed delivery statuses.
• Inbound replies and opt-out instructions, including messages such as “STOP”.
• Webhook events and technical logs required to secure and troubleshoot the integration.

GrowOn does not request access to a user’s Facebook friends, personal posts or unrelated personal Facebook activity.

Meta-issued access credentials must be stored in protected encrypted or sealed form, must never be displayed to firm users, and must not be stored in browser storage.

4. How we use information

GrowOn uses information to:

• Create and operate GrowOn accounts.
• Provide the CRM, reporting, servicing and communication features requested by firms.
• Connect and verify a firm’s WhatsApp Business Account and business number.
• Create, submit, synchronise and monitor WhatsApp message templates.
• Send messages authorised by the firm.
• Display message delivery and failure statuses.
• Apply consent, communication-preference and opt-out controls.
• Prevent messages after a recipient withdraws consent.
• Maintain security, auditability and tenant separation.
• Diagnose errors, provide customer support and improve the service.
• Comply with applicable legal, regulatory and security obligations.

GrowOn does not sell personal information. GrowOn does not use one firm’s client information for another firm. GrowOn does not use a firm’s client information to market GrowOn directly to those clients.

5. WhatsApp consent and communications

Firms using GrowOn are responsible for:

• Having a lawful reason to store and use their clients’ contact information.
• Obtaining any consent required before sending WhatsApp messages.
• Respecting client communication preferences and withdrawals.
• Ensuring message content complies with applicable law and WhatsApp’s policies.

GrowOn records applicable consent and opt-out information to help firms apply these requirements. Receiving “STOP” or another recognised withdrawal instruction must prevent further applicable automated communications.

GrowOn must not place PAN numbers, Aadhaar numbers, bank-account details or similarly sensitive identifiers in automatic WhatsApp message templates.

6. How information is shared

GrowOn may share or transmit information only as necessary with:

• Meta and WhatsApp to connect business accounts, manage templates, send messages and receive delivery events.
• Contracted service providers used for hosting, database storage, email, security, monitoring and customer support.
• Professional advisers, regulators, courts or law-enforcement authorities when legally required.
• A successor organisation if ProDeo Ventures LLP undergoes a merger, acquisition or sale, subject to applicable data-protection requirements.

Service providers may process information only to provide their contracted services to GrowOn.

Meta and WhatsApp process information under their own terms and policies:

• Meta Privacy Policy
• WhatsApp Privacy Policy
• WhatsApp Business Terms of Service
• WhatsApp Business Messaging Policy

7. WhatsApp billing

Each connected firm owns its WhatsApp Business Account and business phone number. The firm pays Meta directly for applicable WhatsApp message charges.

GrowOn does not collect or store the firm’s Meta card or payment-method details and does not add a per-message markup unless a separate written commercial arrangement explicitly states otherwise.

8. Security

GrowOn uses reasonable technical and organisational safeguards, including:

• Encryption in transit.
• Protected storage for Meta integration credentials.
• Role-based access controls.
• Separation of each firm’s information.
• Audit and security logging.
• Restricted administrative access.
• Monitoring and secure development practices.

No internet service can guarantee absolute security. Users must protect their passwords and immediately report suspected unauthorised access.

9. Retention and disconnection

GrowOn retains information for as long as necessary to provide the service, fulfil the firm’s instructions and meet applicable legal, security, audit and dispute-resolution obligations.

When a firm disconnects WhatsApp from GrowOn:

• GrowOn stops using the connection for new messages.
• Active Meta access credentials are revoked or removed where supported.
• Stored connection credentials are deleted from active GrowOn systems.
• WhatsApp automation for the firm is disabled.
• Historical communication and audit records may be retained where required for legitimate business, regulatory, security or legal purposes.
• Messages already delivered to recipients are not deleted from recipient devices.
• Information independently retained by Meta or WhatsApp remains subject to their policies.

10. Data deletion and user rights

Depending on applicable law, people may request access, correction, export or deletion of their personal information.

A client whose information was entered into GrowOn by a financial-advisory firm should normally contact that firm first. The firm controls the client relationship and can submit an authorised request to GrowOn.

GrowOn users and authorised firm administrators can follow the data deletion instructions.

Verified deletion requests are normally completed within 30 days, except where information must be retained for legal, regulatory, security, fraud-prevention, audit or dispute-resolution purposes.

Deleting information from GrowOn does not delete information independently retained by Meta, WhatsApp, telecommunications providers or message recipients.

11. International processing

Some infrastructure and technology providers may process information outside the user’s state or country. Where this occurs, GrowOn will use appropriate contractual, security and legal safeguards applicable to the processing.

12. Changes to this policy

GrowOn may update this policy when the service, law or data practices change. Material changes will be communicated to account holders where appropriate. The latest revision date must remain clearly visible at the top of this page.

13. Contact GrowOn

Questions about this policy or personal information should be sent to contact@growon.in.