Your privacy matters to us. This policy explains, in plain language, what personal information Grow204 collects, why, who we share it with, and the choices you have.
1. Who we are and what this policy covers
Grow204 (“Grow204”, “we”, “us”) is a marketing agency based in Winnipeg, Manitoba, Canada. This policy explains how we handle personal information when you:
- visit our website at grow204.ca or use our free tools;
- contact us or book an audit;
- become a client of our marketing services; or
- use the Grow204 apps at app.grow204.ca, such as Review Manager (the “Apps”).
We follow Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, where it applies, Alberta's Personal Information Protection Act (PIPA).
2. Information we collect
Information you give us
- Contact and audit requests: name, business name, email, phone number, city, website or social links, and anything you write in your message.
- App accounts: name, email address, password (stored only as a secure hash by our authentication provider), business name and business contact details you enter in Settings.
- Client work: information you share so we can deliver services, such as brand files, website content, login access you grant us, and footage you send for editing.
- Billing: when paid plans are available, payments are processed by our payment provider. We do not store full card numbers.
Information collected automatically
- Technical data: IP address, browser and device type, pages requested and timestamps, collected in server logs by our hosting provider for security and troubleshooting.
- Cookies and local storage: see Cookies below.
Information our clients upload to the Apps
Businesses using the Apps may upload information about their own customers, such as names, phone numbers, email addresses and whether the customer agreed to receive messages. See Information we process for our clients.
3. How we use information
- to respond to enquiries and provide audits, quotes and our services;
- to create and secure your account, sign you in and provide the Apps' features;
- to send review requests, reminders and other messages that our clients ask the Apps to send;
- to generate AI-drafted replies and other content when you ask for them;
- to send service and account emails, such as confirmations, password resets and important changes;
- to bill for paid services and keep business and tax records;
- to keep our services secure, prevent abuse and fix problems; and
- to meet legal obligations.
4. Consent and marketing messages
We collect, use and share personal information with your consent, except where the law allows otherwise. By submitting a form or creating an account, you consent to the uses described in this policy. You may withdraw consent at any time by contacting us, although this may mean we can no longer provide some services.
We follow Canada's Anti-Spam Legislation (CASL). We only send marketing emails with your consent, and every commercial message includes our contact details and a way to unsubscribe. Service messages about your account or an active request are not marketing.
6. Storage outside Canada
Our main database is hosted in Canada, but some providers above process information in the United States or other countries. When information is outside Canada, it is protected by our contracts with those providers but may be accessible to courts, law enforcement and national security authorities of those countries under their laws.
7. Google user data
If you connect a Google Business Profile to the Apps, we request access to manage that profile (Google scope business.manage). We use it only to:
- read your business accounts and locations so you can choose which ones to connect;
- import reviews for the locations you connect and show them in your Review Manager inbox; and
- post replies to reviews when you write or approve a reply and choose to publish it.
We do not use Google user data for advertising, we do not sell it, and we do not use it to train AI models. When you ask for an AI-drafted reply, the text of that review is sent to our AI provider only to generate the draft for you. We store only the data needed for these features, together with an encrypted access token, and you can disconnect Google at any time in the App's settings or through your Google Account permissions. When you disconnect, we delete the stored token and stop importing data.
Grow204's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
8. Information we process for our clients
When a business uses the Apps to store its customers' details or send them review requests, that business decides what information is collected and why. We process that information only on the business's instructions and to provide the Apps, and we do not use it for our own marketing.
The business is responsible for having its customers' consent to be contacted and for honouring opt-outs. Every message sent through the Apps includes an opt-out option, and opt-outs are recorded so the customer is not contacted again. If you received a message from a business using our Apps and have questions, please contact that business first. You can also contact us and we will help.
9. How long we keep information
- Enquiries and audit requests: up to 2 years after our last contact, unless you become a client.
- App account data and client-uploaded data: while the account is active. After an account is closed, we delete it within 30 days, and it is removed from backups within 90 days.
- Opt-out records: kept as long as needed to respect the opt-out.
- Billing and tax records: as long as Canadian tax law requires, generally 6 years.
- Server logs: kept for a limited time by our hosting provider for security purposes.
10. How we protect information
We use reasonable safeguards for the sensitivity of the information, including encrypted connections (HTTPS), encryption of stored data by our providers, access controls that keep each business's data separate, limited staff access, and encrypted storage of connected-account tokens. No system is perfectly secure. If a breach creates a real risk of significant harm, we will notify affected people and the Office of the Privacy Commissioner of Canada as the law requires.
11. Your rights and choices
You can ask us to:
- tell you what personal information we hold about you and how it is used;
- correct information that is inaccurate or incomplete;
- delete your information or close your account, subject to legal record-keeping requirements; or
- withdraw your consent or unsubscribe from marketing.
Email hello@grow204.ca from the address linked to your account or enquiry. We may need to confirm your identity and will respond within 30 days. If you are not satisfied with our response, you can contact the Office of the Privacy Commissioner of Canada or, in Alberta, the Office of the Information and Privacy Commissioner of Alberta.
13. Children
Our website and Apps are meant for businesses and are not directed to children under 16. We do not knowingly collect their information.
14. Changes to this policy
We may update this policy from time to time. We will post the new version here with a new date and, for significant changes, notify account holders by email or in the Apps before they take effect.
15. Contact our Privacy Officer
Questions, requests or complaints about privacy can be sent to our Privacy Officer at hello@grow204.ca, or by writing to Grow204, Winnipeg, Manitoba, Canada. See also our Terms of Service.