Privacy Policy

last updated：October 16, 2024

Welcome to MeGrow (“MeGrow”, “we” or “us” or “our”). This Privacy Policy applies to MeGrow services (the “Platform”), which includes the MeGrow app. This Privacy Policy explains how we collect, use, share, and otherwise process the personal information of Platform users and other individuals. The Platform is provided and controlled by Chongqing niruo Technology Co. Ltd. whose registered address is No.024, 10th floor, building B, No.24, Honghu West Road, Yubei District, Chongqing.

If you have any questions about how we use your personal information, please contact megrow@nieruo.com.

1. Our Commitment to Privacy

As we work with you to build better relationships, we are dedicated to protecting your privacy. For any personal data we collect during your cooperation with us, this Privacy Policy ("Policy") explains why we collect this data, how we process it, and your rights and choices when it comes to your personal data.
When you use our mobile application ("App"), visit our website, or interact and communicate with us through our online or social media channels, this Policy applies to you. In this Policy, we will refer to all these touch points with you as our Services ("Services").
To maintain transparency in how we use your personal data, we will notify you when there are significant updates to this Policy.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Email: megrow@nieruo.com
We are committed to addressing your inquiries and ensuring the protection of your personal information.

2. Who is collecting your data

You know us as MeGrow, but as a legal entity we are Chongqing niruo Technology Co. Ltd. We decide what personal data is collected from you and how this data will be used.
Our Services may contain links to sites run by our experts and other websites such as Twitter, Facebook, and Instagram. These experts and third-party organizations will have their own privacy policies, which you should read carefully before providing any of your personal data to them, as we do not accept any responsibility or liability for them.
Data Protection Officer To ensure the highest standards of privacy and data security, MeGrow has appointed a dedicated Data Protection Officer (DPO). Our DPO is responsible for overseeing our data protection strategy and ensuring that all personal data collected from you is handled in accordance with applicable privacy laws and regulations.
Role and Responsibilities: The DPO monitors our compliance with data protection laws, manages data protection risks, and serves as a point of contact for any questions or concerns you may have regarding your personal data.
Contact Information: If you have any inquiries about how we collect, store, or use your personal data, or if you wish to exercise any of your data protection rights, you can contact our Data Protection Officer directly at megrow@nieruo.com.
Your Rights: The DPO is also responsible for ensuring that you can exercise your data protection rights, such as accessing your data, requesting corrections, or asking for deletion of your personal data.
By appointing a Data Protection Officer, we demonstrate our commitment to safeguarding your privacy and maintaining transparency in our data handling practices.

3. How We Collect and Use Your Personal Data

We may collect information from and about you, including information that you provide, information from other sources, and automatically collected information:

1.1 Device Information

·What We Collect: We may gather information about your device, including its IP address, browser type, internet service provider, platform type, device model and manufacturer, operating system, mobile carrier, date and time stamps, unique device identifiers (such as UDID and other permanent device identifiers), battery status, WiFi connection status, and similar details.
·Why We Collect It: This data helps us uniquely identify your device or account, optimize the performance of our services, personalize your experience, and enhance security measures, including fraud prevention.
·Is This Necessary?: Yes. This information is essential for providing core services and ensuring the security of your account.

1.2 Files and Documents

·What We Collect: With your consent, we may access files and documents stored on your device.
·Why We Collect It: This feature allows you to upload and share files or documents within the app, facilitating easy storage and collaboration.
·Is This Necessary?: No. This is an optional feature and is only necessary if you choose to upload or share files and documents.

1.3 Health Information

·What We Collect: With your consent, we may access health information stored on your device.
·Why We Collect It: This information allows us to offer personalized health advice, track your health metrics, or provide other related services.
·Is This Necessary?: No. This is an optional feature, necessary only if you choose to use health-related services.

Account Deletion and Data Retention Policy

You may delete your MeGrow account at any time. To delete your information, you can: tap the Settings icon in the top-right corner of the Me screen > Edit Profile > Delete Account to request the removal of your account. If you have a Premium subscription, you will still need to cancel it through your Apple or Google ID. If you log back in within 7 days of deactivation, your account will automatically be reactivated. Deleting your account is irreversible. You will not be able to recover it, even if you use the same credentials. After 7 days, your account will be officially deleted, and we will ensure that your data is securely and thoroughly removed from our servers, or retained only in anonymized form.

4. Information Sharing You Control

We value your privacy and give you control over how your information is shared. Here's how we handle your data and your rights to opt out:

Consent-Based Sharing: We will not disclose your personal information to independent third parties without your prior consent, except as discussed in this Privacy Policy.
Third-Party Sharing: We may disclose your information to selected third parties and our subsidiaries as described in this policy. You have the right to opt out of this sharing.
Targeted Advertising: We may use your data for targeted advertising purposes. You have the right to opt out of this use of your data. Sale of Personal Data: We do not sell your personal data. However, if this policy changes in the future, you will have the right to opt out of such sales.
Profiling: We may use your data for profiling that supports decisions that could produce legal or similarly significant consequences for you. You have the right to opt out of this type of data processing.
How to Opt Out: To exercise your opt-out rights for any of the above:
Email us at megrow@nieruo.com. We will process your opt-out request within 30 days of receipt.
Protection and Legal Compliance: We may use and disclose your information to protect ourselves and others, prevent illegal activities, and comply with legal obligations. You cannot opt out of these necessary uses of your data. Anonymized Data: We may disclose information within our company, to our subsidiaries, and to third parties in an anonymous or aggregated form that does not identify you personally. We are committed to complying with all applicable data protection laws, including the Virginia Consumer Data Protection Act (VCDPA). If you have any questions about your privacy rights or how to exercise them, please contact our privacy team.

5. Sharing Personal Data and Your Rights

We are committed to transparency regarding the sharing of your personal data. You have the right to know whether and how your personal data is shared. Here's how we handle your data:

Our Data Sharing Practices
No Sale of Data: We never sell or disclose your personal data to advertisers or other third parties for compensation.
Service Providers: We share personal data with service providers who perform functions on our behalf, such as:
We only share data necessary for these providers to perform their services. - Network and technology services - Payment processing - Data storage and analysis - Mailing activities - Support desk management - Subscription management

Data Storage: Your personal data is securely stored on Alibaba Cloud servers, ensuring protection according to industry standards.
ADJUST Platform: We share your advertising ID with ADJUST to analyze user engagement and marketing performance.
Other Organizations: We may share personal data in the following situations:
When required by law or public authorities
To establish, exercise, or defend our legal rights
In case of a business sale or transfer (the receiving organization may use your data as we do)
Your Rights Regarding Data Sharing
As a user, you have the right to:

Know About Data Sharing: You can request information about whether and how your personal data is shared with third parties.
Access Shared Data: You can request details about the specific personal information that has been shared.
Opt-Out of Certain Sharing: In some cases, you may have the right to opt-out of certain types of data sharing.
CCPA Rights for California Residents: If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:
The right to know about personal information collected, used, disclosed, or sold
The right to delete personal information (with some exceptions)
The right to opt-out of the sale of personal information
The right to non-discrimination for exercising your CCPA rights
Note: Under California law, "sharing" has a specific definition that includes sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a consumer's personal information to another business or a third party for cross-context behavioral advertising.

How to Exercise Your Rights
To exercise any of these rights or to inquire about our data sharing practices:

Email us at megrow@nieruo.com
We will respond to your request within the timeframe required by applicable law.

We are committed to protecting your privacy rights and complying with all applicable data protection laws, including the CCPA. If you have any questions about your rights or how we share your data, please contact our privacy team.

6. How We Protect Your Information and Our Storage Locations

MeGrow has physical, electronic, and procedural safeguards in place that comply with legal regulations to protect your personal information. We also ensure that all our service providers have industry-recognized safeguards. However, data transmission over the internet cannot be guaranteed to be 100% secure. As such, MeGrow cannot ensure or warrant the security of any information you provide to us via the internet.
The personal information we collect from you may be stored on a server located outside of the country where you live. We maintain major servers around the world to bring you our services globally and continuously.
MeGrow limits access to your personal information to employees of MeGrow who have a reasonable need to access the information in order to provide you with products or services or to complete their work.

7. How Long We Use Personal Data

The retention period of your personal data will not exceed what is reasonably necessary and will take into account the original purpose of collection, the age of the data, any legal/regulatory reasons for retaining it, and whether it is necessary to protect you or us. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means, in addition to applicable legal and regulatory requirements.

8. Your Data Protection Rights

Below, we list the rights you have under GDPR concerning your personal data. If you wish to exercise any of these rights, please write to us using the information provided in the "How to Contact Us" section of this policy.
Right to Access – You have the right to access the personal data we hold about you and the circumstances of our processing activities.
Right to Correct Inaccurate Information – If you believe we hold inaccurate or missing information, please inform us, and we will correct it.
Right to Object to Our Use of Your Personal Data – We will consider your objection to our use of your personal data. If, upon balancing, your rights outweigh our interests in using your personal data, we will restrict our use of it or delete it according to your request.
Right to Object to Direct Marketing – If we engage in direct marketing activities (with your consent), if you object, we will stop using your personal data for direct marketing purposes.
Right to Restrict Our Use of Your Personal Data – You can restrict our use of your personal data if you have successfully raised a general objection, if you have questioned the accuracy of the personal data we hold, or if we have unlawfully used your personal data – but you do not want us to delete the data.
Right to Erase Your Personal Data – You can request that we delete your personal data in the following situations: we no longer need to retain your personal data; you have successfully raised a general objection; you have withdrawn your consent to our use of your personal data (if we rely on consent as a legal basis); or we have unlawfully processed your personal data.
Right to Complain to Data Protection Regulators – We would like the opportunity to resolve any complaints you may have, but you also have the right to complain to data protection regulators in the UK or the European Economic Area country where you receive our products about our use of your personal data. In the UK, the data protection regulator is the ICO, and their website is: https://ico.org.uk

9. International Transfer

By using MeGrow, you agree that all information collected through or by MeGrow may be transferred, processed, and stored in various locations worldwide, including but not limited to, the United States, the United Kingdom, the European Union, in the cloud, on our servers, on the servers of our affiliates, or the servers of our service providers. Your information may be accessible to law enforcement or other authorities in accordance with applicable laws. By providing information to MeGrow, you explicitly consent to the storage and processing of your information in these locations. This may mean that your personal information will be stored in a jurisdiction that provides a level of data protection that may, in certain instances, be less stringent than the protection provided in the jurisdiction where you reside.
We will implement appropriate safeguards to ensure that your personal information is treated securely and in compliance with this privacy policy. These safeguards include: (i) ensuring that your personal information is used in accordance with standard data protection clauses adopted by the European Commission for the transfer of personal data to recipients outside the EEA and UK; and (ii) ensuring that any recipients of your personal information commit to maintaining the same high standards of data protection as we do. If you wish to learn more about the safeguards we employ, please contact us using the details provided at the end of this privacy policy.

10. Children's Data

At MeGrow, we take special precautions to protect the privacy and safety of our younger users. MeGrow does not knowingly collect personal information from children who do not meet the applicable minimum age requirements without obtaining verifiable consent from a parent or guardian. Our Services are designed to be used by children only with significant involvement and approval from a parent or guardian.

If MeGrow becomes aware that we have inadvertently collected personal information from a child without the necessary parental consent, we will take immediate steps to delete that information. If you are a parent or guardian and discover that your child has registered an account with our Services or is using our Products without your consent, please notify us immediately by emailing megrow@nieruo.com By allowing your child to create a member account and/or permitting your child to use the Products or Services, you expressly agree to the practices described in this Privacy Policy and consent to the collection, use, and disclosure of your child’s personal information as outlined herein.

11. International Privacy Laws

This policy is a supplement to, not a replacement for, any applicable national data protection laws. Any applicable national data protection laws will supersede this policy if they provide stronger requirements. This policy should apply in locations where there are no national data protection laws.

12. U.S.State Data Privacy

California

The California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA"), requires us to provide California consumers with some additional information regarding how we collect, use, and disclose your personal information, and the rights available to California consumers under the CCPA. The terms used in this section have the same meaning as in the CCPA.

As described above in Section 3. How We Collect and Use Your Personal Data, MeGrow may have collected the following categories of "personal information" (as that term is defined by the CCPA) about you through our Services within the last 12 months:

Identifiers, such as your name, email address, and username;
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as your contact information and profile photo;
Commercial information, such as transaction information and purchase history;
Internet or network activity information, such as your browsing history and interactions with our Website;
Geolocation data, such as your approximate location based on your IP address;
Audio, electronic, visual, and similar information, such as video content you may have uploaded;
Your account log-in information i.e., username and password to access your account (if you have a MeGrow account); and Inferences drawn from any of the above personal information to create a summary about you, for example your preferences and characteristics. Sales and Sharing of Personal Information

As described above in Section 6, MeGrow does not sell personal information as the term “sell” is traditionally understood (i.e., for money). However, like many websites and apps, our Services use cookies and other tracking technologies to provide you with a more personalized experience and to advertise our Services to you, if you choose to enable such cookies. The use of such cookies which disclose a California resident’s personal information (which includes IP addresses and cookie IDs) to third party service providers and advertisers may be considered a “sale” of personal information under the CCPA (given its broad definition of "sale"), or a "sharing" of personal information under the CCPA (which is defined as the disclosure of personal information for the purposes of cross-context be behavioral advertising). You may opt out of such cookies at any time by adjusting your cookie choices in our cookie banner, or by clicking the "Your Privacy Choices" link in the footer of our Website.

We do not knowingly sell or share personal information of California residents who are under 16 years old.

Virginia Privacy Rights

The Virginia Consumer Data Protection Act ("VCDPA") defines "consumer" as a Virginia resident who is acting in an individual or household context only and does not include residents acting in a commercial or employment context. If you are a Virginia "consumer", you may have the following rights concerning your personal data, subject to certain limitations and exceptions under applicable law:

Access: You have the right to request to confirm whether we are processing personal data about you, and to access such personal data.
Data Portability: You have the right to obtain your personal data in a portable and readily usable format.
Correction: You have the right to request that we correct inaccuracies in your personal data.
Deletion: You have the right to request to delete the personal data provided by you or obtained about you.
Opt-out of Data Processing for purposes of Targeted Advertising; Sales to Third Parties; and Profiling: As described in the section "Sales and Sharing of Personal Information" above, we do not sell personal data to third parties for money, nor for the purpose of profiling in connection with decisions that produce legal or similarly significant effects. However, we do process personal data for the purpose of displaying targeted advertisements, if you instruct us to do so. You have the right to opt out of the processing of personal data for targeted advertising purposes at any time by changing your cookies choices via our cookie banner or via the ‘Cookie Policy’ link in the footer of our website.
Appeal: You have the right to appeal a refusal to take action on your request. You may ask us to reconsider our decision within 45 days after we send you our decision. We will endeavor to respond to your appeal within 60 days of such an appeal, including a written explanation of the reasons for the decision, and any action taken or not taken in response to the appeal.
If you are a resident of one of the above U.S. states and would like to make a request to exercise one of the rights described above, please submit your rights request to megrow@nieruo.com. To protect the personal data that we maintain, we may verify your identity when you make a request.

In certain states (such as California), an authorized agent may submit a rights request on your behalf. We may require an authorized agent to verify their authority to submit a request on your behalf, or we may require you to verify your own identity or confirm with us that you provided the agent with permission to submit the request. We will only use the information provided for verification to confirm the requestor’s identity or authority to make the request, and for our compliance records.

We endeavor to respond to a verifiable request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

13. How to Contact Us

If you have any questions about how we collect, store, and use personal data or wish to exercise any of your rights mentioned above, please email us at: megrow@nieruo.com