GDPR Compliance

General Data Protection Regulation (GDPR) is a European Union regulation that establishes a framework for handling and protecting the personal data of EU-based residents.

Please note that this GDPR compliance statement may be updated from time to time.

GDPR Concepts

GDPR is intended to offer protections for you or any identifiable natural person (the "Data Subject") regarding your information (your "Personal Data"). You, as a Data Subject, have broad rights, whether you are identified directly or indirectly through interaction context in which your information was captured.

Your rights under GDPR

Consent

Under GDPR, you opt in to have an organization (the "Data Controller") process your Personal Data. Data Controllers must obtain your consent before they can process your data.

Special Categories of Data

Unless authorized, GDPR prohibits processing of certain special categories of data such as race, ethnicity, political and religious beliefs, sexual orientation, genetic and biometric data. Johnny Grow does not process any data belonging to these categories.

Right of Access

If you consented to a Data Controller processing your Personal Data, you may then request the following:

• A copy of the personal data undergoing processing
• Purpose of processing
• In particular, if automated decision-making or profiling takes place, and if so, the logic involved, significance and likely consequences of such processing
• Categories of data processed
• Any third-party recipients of this personal data, especially recipients in third party countries (i.e., countries outside of the EU)
• Any third-party sources of Data Subject's personal data (i.e., not collected from the Data Subject directly, for instance by purchasing said data from another source that previously collected the data directly)
• How long such Personal Data would be stored, or if that's not determinable, how the length of this period would be determined
• Data rectification
• Data erasure
• Restriction of data processing
• Objection to data processing
• Right to Rectification

You, as a Data Subject have the right to have any errors on inaccuracies of Personal Data corrected. Your Data Controller shall implement such requests without undue delay.

Right of Erasure

You have the right to have your Personal Data erased or forgotten. Your Data Controller shall remove your personal data and confirm deletion via a notification to you.

Right to Data Portability

You have the right to have your Personal Data exported and provided to you in complete form.

Breach Notification

In the event of a data breach and your Personal Data is compromised, your Data Controllers are required to notify you within 72 hours.

Johnny Grow's Commitment to Protecting Your Personal Data

Johnny Grow is committed to partnering with its customers and users to ensure that Johnny Grow is fully compliant with the requirements of GDPR. Johnny Grow recognizes your rights under GDPR and will ensure that these rights are honored, and your Personal Data is protected.

International Data Transfers:  Contractual Terms

To comply with E.U. data protection laws around international data transfer mechanisms, Johnny Grow utilizes the European Union Model Clauses, also known as Standard Contractual Clauses, to meet adequacy and security requirements for our customers who operate in the EU.

Johnny Grow as Data Controller vs Data Processor

Your personal data may enter Johnny Grow processing in multiple ways. Based on how your personal data is consented to, who has control over the data and who has responsibility for protecting and administering your rights, Johnny Grow is either a Data Controller or a Data Processor. This section describes Johnny Grow's role as both a Data Controller and Processor and explains how you can interact with Johnny Grow in either role.

Role of Johnny Grow as a Data Controller

When you interact with Johnny Grow via its research, marketing and sales development outreach programs as a website visitor, webinar participant or content downloads, Johnny Grow is the primary Data Controller from the GDPR perspective. In these cases, Johnny Grow is responsible for obtaining your consent and providing means for exercising your data rights.

Personal Data

• Personal Data you submit during registration, such as your name, email and phone number
• Any other Personal Data that Johnny Grow obtains via sources to which you have already provided consent. Johnny Grow may use data from these sources for data identification and enrichment. As an example, if you provided only email and company name to Johnny Grow, Johnny Grow may use another service to identify your business contact phone, or your title, as this information was submitted by you to the third-party service.

Consent

• When you interact with web forms and similar registration pages at Johnny Grow's website (or partners that we collaborate with), we may request explicit consent prior to you submitting your Personal Data.
• If Sales Development Representatives contact you and you provide information to us, and you consent to us for using the information we obtained from you.
• When your colleague from your organization volunteers your personal data to us via email, or other information channels. We may follow up to obtain consent using the email provided to us, or indicate in our email communication that we do not yet have consent but you provide us consent to continue our use of your personal data.
• If you had previously provided consent to Johnny Grow to collect your personal data, you may choose to withdraw that consent at a later point. Please make your request using the website Contact Us page and we will implement the request.

Privacy Preferences

During the course of your registration process, we may offer certain preferences that control privacy of your data. Additionally, some registration processes may offer submission of certain data as optional items. You may choose not to provide optional data, but if you do provide them, Johnny Grow may track your submissions. Additionally, Johnny Grow will honor your choices and will ensure that these preferences and optional data are part of the data that you have access to via GDPR framework-based requests.

Onward transfers

Johnny Grow does not sell your Personal Data to any other third-party organization. Johnny Grow also does not transfer the rights to your personal data to any other party nor does it use the data other than the original intent. Any transfer to a third party is solely intended for the processing of data and Johnny Grow has secured agreements with downstream Data Processors to protect Personal Data and enforce GDPR data rights for you.

Data Subject Access Rights

Data Access

As part of GDPR you have the right to request all Personal Data about you to be made available to you. We will provide:

• Whether any data was transferred to any other third party

Data Erasure, Accuracy and Portability

You may submit a request to delete all data about you. Johnny Grow will comply with this request but may use your email to send a confirmation notice that we performed the requested action.

• Update Personal Data: You may submit a request to update Personal Data that we have about you. Johnny Grow will perform this and may use your email to send a confirmation notice that we performed the requested action. If email itself was requested to be changed, Johnny Grow may send a confirmation to both the old and new email.
• Request an export of all your data for data portability: You may also submit a request to export your data for data portability. Johnny Grow will provide this information via a CSV or similar file. Such a report may include meta-data such as when particular data was added, any updates to the data etc. - i.e., an audit trail of the data.

Data Breach Notification

We will notify you if your Personal Data was compromised via a breach using one or more methods of contact information we have about you, within 72 hours. This includes a breach that was caused by a Data Processor that Johnny Grow has authorized to process your data.

Filing a complaint

Johnny Grow has put in place processes for providing you the rights to your personal data, per GDPR guidelines. If you are not satisfied with our resolution of your requests, you have the right to file a complaint. You also have a right to file a similar complaint with a supervisory authority for the jurisdiction you are in and seek appropriate remediation.

Role of Johnny Grow as a Data Processor

If we are processing your Personal Data on behalf of your employer or the organization, you may submit a request here and Johnny Grow will forward the request to your employer. Any final action on the request will need to be approved by the employer (the Data Controller). Johnny Grow may assist the Data Controller in expeditiously completing the request.

Consent

When Johnny Grow processes and displays your personal data, that data was acquired from your employer or organization that you interact with. If it is personal data that you submitted to your employer, you provided consent to your employer to that data for their business purpose. If it is personal data that Johnny Grow's customer obtained in the process of conducting business with you or your employer, they rely on your consent to use the data for business purpose. As an example, if you are a purchaser of a product or service from Johnny Grow's customer, your relationship to our customer would be that of a vendor, and in furthering that relationship, our customer would have acquired your personal data.

To withdraw an earlier consent that you provided, contact your employer or the organization to which you provided the original Personal Data. Johnny Grow will not be able to alter your consent, as we are the Data Controller.

Data Access

To request your Personal Data, please submit a request using the website Contact Us web page. For data processed by Johnny Grow, we may forward your request to your employer (the Data Controller), who will then initiate a request to provide that information. Since Johnny Grow's role is only that of a Data Processor, Johnny Grow will not be able to provide your Personal Data directly.

Data Breach Notification

In the event of a data breach, Johnny Grow, as a Data Processor, is required to notify your employer/organization that there was a data breach. Your organization will then notify you regarding the breach, its impact and potential remedies. Johnny Grow will not notify you directly.

Data Erasure, Accuracy and Portability

To request an export or erasure or update of Personal Data held by Johnny Grow, please send your request using the website Contact Us web page. We may then forward your request to your employer or organization, who will then initiate a request Johnny Grow to complete the request. Since Johnny Grow's role is only that of a Data Processor, Johnny Grow will not be able to perform these actions directly.

Filing a complaint

For filing a complaint related to personal data processed by Johnny Grow, use the complaint process of your employer or organization (the Data Controller). Johnny Grow will assist the Data Controller in resolving the complaint but will not take any action until and unless such action is authorized by the Data Controller.

Contact

All requests should be sent using the website Contact Us page. Please be specific in your request so we can be responsive to you.

Please also see the Johnny Grow Website Terms of Use, Privacy Policy and Cookie Policy