This Privacy Policy explains how Wellgrow.io (“we”, “our”, or “us”) collects, uses, discloses, and protects your personal data in accordance with the Hong Kong Personal Data (Privacy) Ordinance (PDPO), the General Data Protection Regulation (GDPR), and other applicable laws, including where we serve users in the EU, UK, and California.
1. Data Controller
Wellgrow Limited Hong Kong SAR, Wan Chai, ROOMS 1703-1704, 17/F TUNG, CHIU COMM CTR 193 LOCKHART RD Email: [email protected]
2. What Data We Collect
We collect the following categories of personal data: – Identification data (e.g., name, email address) – Billing and payment data (processed via Stripe) – Technical data (IP address, device type, browser) – Usage data (pages visited, time spent, clicks) – Communication data (e.g., support queries, form submissions)
3. How We Collect Data
– Directly from you (when you create an account, subscribe, or contact us) – Automatically (via cookies and tracking technologies) – From third-party providers (e.g., payment processors, analytics tools)
4. Legal Bases for Processing (GDPR)
We process personal data under the following legal bases: – Consent (Art. 6(1)(a) GDPR) – for analytics and marketing cookies – Contract (Art. 6(1)(b) GDPR) – to provide subscription services – Legal obligations (Art. 6(1)(c) GDPR) – Legitimate interests (Art. 6(1)(f) GDPR) – for security, troubleshooting, analytics
5. Use of Personal Data
We use your personal data for the following purposes: – To register accounts and manage subscriptions – To process payments via Stripe – To provide and maintain our services – To analyze and improve our website and platform – To conduct marketing and retargeting (with consent) – To comply with legal obligations
6. Cookies and Tracking Technologies
We use cookies and similar technologies for: – Essential functionality – Analytics (Google Analytics, Microsoft Clarity) – Advertising and retargeting (Meta Pixel) You can manage or withdraw your cookie consent at any time through our cookie banner.
7. Sharing of Personal Data
We may share your data with: – Payment processors (e.g., Stripe) – Analytics and advertising platforms (Google, Meta, Microsoft) – CRM and marketing platforms (GoHighLevel) – IT service providers and subcontractors under strict confidentiality
8. International Data Transfers
If personal data is transferred outside Hong Kong or the EU (e.g., to the U.S.), we implement safeguards such as Standard Contractual Clauses (SCCs) and contractual obligations to ensure data protection.
9. Data Retention
We retain your data for as long as necessary to fulfill the purposes described in this policy, including to comply with legal, tax, or accounting requirements. Data related to inactive accounts may be deleted after 24 months unless extended by user activity.
10. Your Rights
Under GDPR and PDPO, you have the right to: – Access and obtain a copy of your data – Rectify inaccurate or incomplete data – Request deletion or restriction of processing – Object to processing for direct marketing – Withdraw consent at any time – Lodge a complaint with a supervisory authority
11. Data Security
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, loss, misuse, or alteration. These include encrypted storage, access controls, and secure hosting.
12. Contact
If you have any questions or wish to exercise your rights, please contact us at: Email: [email protected]
