Privacy Policy

Effective Date: April 8, 2026

Operating Entity: GrowlineAI, a registered DBA of Ascendry Ventures

Support: support@growlineai.com | +1 302-600-1695

Privacy Requests: https://growlineai.com/privacy

Optin URL: https://growlineai.com/contact

1. Introduction

Ascendry Ventures, operating as GrowlineAI ("GrowlineAI," "we," "us," or "our"), respects your privacy and is committed to protecting the personal information of our clients and website visitors. This Privacy Policy describes how we collect, use, share, and protect information in connection with the GrowlineAI platform and website at growlineai.com.

This Policy applies to information collected from our direct clients (businesses that subscribe to GrowlineAI). It does not govern how our clients handle their own customers' data — those practices are governed by each client's own privacy documentation. If you are a contact or customer of a GrowlineAI client, please review that client's privacy policy for information about how your data is handled.

By using the Services, you acknowledge this Policy. We will notify you of material changes with at least fourteen (14) days' advance notice by email or Platform notification.

2. Information We Collect

2.1 Information You Provide

• Account and registration data: name, business name, email address, phone number, mailing address, and role
• Billing information: processed by our PCI-compliant payment processor; we do not store full payment card numbers
• Business information: industry, company size, and intended use case
• Support communications: records of your interactions with our support and sales teams
• Platform content: campaigns, workflows, contact lists, and materials you create or upload

2.2 Automatically Collected Information

• Technical data: IP address, browser type, operating system, and device identifiers
• Usage data: pages visited, features accessed, session duration, and navigation paths
• Log data: server access logs and error records
• Cookie and tracking technology data (see Section 7)

2.3 Information From Third Parties

We may receive information from payment processors, identity verification services, analytics providers, and other business data sources, solely to operate and improve our services.

2.4 Client Contact Data — Processor Role

When clients manage their customer and contact data through the Platform, GrowlineAI processes that data as a data processor on the client's behalf. GrowlineAI uses client contact data only to provide the Platform services — we do not use it for our own marketing, analysis, or any other independent purpose.

3. How We Use Your Information

We use information we collect for the following purposes:

• Providing and operating the Platform: account management, billing, feature delivery, and support
• Communicating with you: transactional notices (invoices, security alerts, service updates) and, with your consent, product and marketing communications
• Improving the Platform: using aggregated and anonymized usage data to analyze performance and develop new features
• Compliance and enforcement: meeting our legal obligations and enforcing our Terms of Service
• Security: detecting and preventing fraud, abuse, and unauthorized access

We do not use Client Content or Client contact data for any purpose beyond operating the Platform for Client's benefit.

4. How We Share Information

We do not sell personal information. We share information only in the following circumstances:

4.1 Service Providers

We share information with vendors who provide services on our behalf, including cloud hosting, payment processing, telecommunications carriers and SMS aggregators (for message delivery), customer support tools, and analytics platforms. Service providers are permitted to use your information only as necessary to provide their services to us and are subject to confidentiality obligations.

4.2 Business Transfers

If GrowlineAI is involved in a merger, acquisition, or asset sale, client information may be transferred to the successor entity. We will provide advance notice if your information becomes subject to a materially different privacy policy.

4.3 Legal Requirements

We may disclose information when required by law, legal process, or government request, or when reasonably necessary to protect the safety, rights, or property of GrowlineAI, our clients, or the public.

4.4 With Consent

We may share information for other purposes with your express prior consent.

4.5 What We Will Not Do

• We will not sell personal information to data brokers or advertisers
• We will not use Client contact data for GrowlineAI's own marketing purposes
• We will not share SMS opt-in data or consent records for marketing purposes
• We will not share Client data with affiliates or third parties for their independent marketing use

5. Data Retention

We retain personal information for as long as necessary to maintain your account, provide services, satisfy legal obligations, and enforce our agreements. Specific retention periods:

• Active account data: retained for the duration of the subscription
• Post-termination: Client data is retained for thirty (30) days before deletion, during which clients may request an export
• Billing and transaction records: minimum of seven (7) years per tax and accounting requirements
• Opt-out and suppression records: retained indefinitely to support compliance obligations

6. Security

GrowlineAI maintains commercially reasonable technical, administrative, and physical safeguards, including TLS/SSL encryption in transit, encryption of sensitive data at rest, access controls, and regular security monitoring. In the event of a data breach affecting your information, we will notify you as required by applicable law.

While we work to protect your data, no security system is completely impenetrable. You are responsible for maintaining the security of your account credentials and for the security of your own systems and devices.

7. Cookies and Tracking

We use cookies and similar technologies to operate and improve our website and Platform:

• Strictly necessary: required for core functionality and security; cannot be disabled
• Functional: remember your preferences and settings
• Analytics: help us understand usage patterns and improve performance
• Marketing: support advertising on our public website only — not within the Platform

You can manage cookies through your browser settings. Disabling certain cookies may affect Platform functionality.

8. Children's Privacy

The Platform is intended for business users and is not directed to individuals under 18. We do not knowingly collect personal information from minors. If we learn we have collected such information inadvertently, we will delete it promptly.

9. Your Privacy Rights

9.1 General Rights

Subject to applicable law and identity verification, you may request access to, correction of, or deletion of personal information we hold about you. Requests can be submitted to support@growlineai.com. We will respond within legally required timeframes.

9.2 California Residents (CCPA/CPRA)

California residents have rights under CCPA/CPRA, including the right to know, delete, correct, and limit use of sensitive personal information. GrowlineAI does not sell personal information and does not share personal information for cross-context behavioral advertising. Submit CCPA requests to support@growlineai.com with "CCPA Request" in the subject line.

9.3 Other State Privacy Laws

Residents of Virginia, Colorado, Connecticut, Texas, Oregon, Montana, and other states with comprehensive privacy laws have similar rights. Contact support@growlineai.com to submit a request.

9.4 International Users

The Platform is operated from the United States. By using our Services, you consent to the transfer of your information to the US, where privacy laws may differ from your jurisdiction. For GDPR-related Data Processing Agreement requests, contact support@growlineai.com.

9.5 Marketing Opt-Out

You may opt out of marketing communications at any time using the unsubscribe link in any marketing email or by contacting support@growlineai.com. Opting out does not affect transactional communications.

10. SMS and Mobile Communications — Dedicated Disclosure

When GrowlineAI clients send SMS/MMS messages through the Platform, the following applies to subscriber data:

• Phone numbers and consent records are used exclusively to deliver the program the subscriber opted into
• Data is transmitted to licensed telecommunications carriers and aggregators solely for message routing
• Opt-out records are maintained indefinitely to prevent unwanted future messages
• GrowlineAI does not use subscriber phone numbers to market its own products or services
• GrowlineAI does not sell, rent, or trade subscriber phone numbers to any third party

For full details, review our SMS Terms of Service at https://growlineai.com/sms-terms.

11. Third-Party Links

Our website and Platform may link to third-party websites. GrowlineAI is not responsible for the privacy practices of those sites. We encourage you to review the privacy policy of any site you visit.

12. Updates to This Policy

We may update this Privacy Policy from time to time. We will provide at least fourteen (14) days' advance notice of material changes via email or Platform notification. The "Effective Date" reflects the most recent update. Your continued use of the Services after the effective date of any change constitutes acceptance of the updated Policy.

13. Contact Us

GrowlineAI / Ascendry Ventures
Email: support@growlineai.com
Phone: +1 302-600-1695
Privacy Policy: https://growlineai.com/privacy

We will respond to privacy inquiries within thirty (30) days.