Privacy Policy
1. Who we are
Groewy is operated by TTP Tech sp. z o.o. (TTP TECH SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ), a limited liability company registered in Poland, with its registered office at ul. Floriańska 6 lok. 02, 03-707 Warsaw, Poland, entered in the Register of Entrepreneurs of the National Court Register (KRS) under number 0001200085, tax identification number (NIP) 1133182288, REGON 542997692 ("TTP Tech", "we", "us").
TTP Tech is the data controller within the meaning of Regulation (EU) 2016/679 (the "GDPR") for the personal data described in this policy. You can reach us about anything in this policy at team@groewy.com or by post at the address above.
2. What this policy covers
This policy applies to the Groewy mobile application for iOS and Android (the "App"), the website groewy.com and its subdomains (the "Website"), and any related communications. It explains what personal data we collect, why, on what legal basis, who we share it with, how long we keep it, and what rights you have.
3. Data we collect
We collect only what the App needs to work and to improve. We do not ask for, and do not want, more than that.
| Category | Examples | Source |
|---|---|---|
| Account data | Name, email address, password (stored only as a cryptographic hash), language, country | You, when you register |
| Financial profile | Answers to the onboarding questionnaire: financial goals, time horizon, approximate income and savings ranges, investment experience, risk tolerance, age range | You, in the App |
| Plans and activity | Goals you create, AI-generated plans and roadmaps, notes, progress you record, in-App settings | You and the App |
| Subscription data | Subscription tier, status, renewal and expiry dates, store transaction identifier | Apple App Store or Google Play |
| Device and usage data | Device model, operating system version, App version, language, time zone, anonymised device identifier, crash reports, screens visited, feature usage, IP address in server logs | Your device, automatically |
| Communications | Messages you send to our support, survey answers, notification preferences | You |
| Website data | Server access logs (IP address, browser type, pages requested, timestamp), waitlist email address if you join the waitlist | Your browser |
What we do not collect. We never receive your card number or bank details: payments are processed entirely by Apple or Google. The App does not currently connect to your bank, brokerage or other financial accounts. If we introduce account linking in the future, it will be optional, explained separately, and will require your explicit action to switch on.
4. Why we use your data and on what legal basis
| Purpose | Data used | Legal basis (GDPR) |
|---|---|---|
| Creating and maintaining your account, delivering the App's features, including AI-generated plans | Account data, financial profile, plans and activity | Art. 6(1)(b), performance of a contract |
| Managing your subscription and entitlements | Subscription data | Art. 6(1)(b), performance of a contract |
| Keeping the App secure, preventing fraud and abuse, fixing bugs | Device and usage data, server logs | Art. 6(1)(f), our legitimate interest in a secure and reliable service |
| Understanding how the App is used so we can improve it | Aggregated or pseudonymised usage data | Art. 6(1)(f), our legitimate interest in product development |
| Sending service messages (security notices, changes to terms, billing) | Account data | Art. 6(1)(b) and 6(1)(c) |
| Sending push notifications and product news | Account data, notification preferences | Art. 6(1)(a), your consent, which you can withdraw at any time |
| Responding to your requests and complaints | Communications | Art. 6(1)(b) and 6(1)(f) |
| Complying with accounting, tax and other legal obligations | Subscription data, communications | Art. 6(1)(c), legal obligation |
5. AI-generated plans and automated processing
The App uses automated processing, including machine-learning models, to turn your financial profile and goals into suggested plans and roadmaps. These outputs are suggestions for your own consideration. They are educational and planning content, not professional financial, investment, tax or legal advice, and the App does not execute transactions or make decisions that produce legal effects concerning you. You always decide whether and how to act on a plan. If you would like a human to review how a plan was generated, write to team@groewy.com.
6. Who we share data with
We do not sell personal data and we do not share it with advertisers. We share data only with service providers that process it on our behalf and under our instructions, and only to the extent needed:
- Hosting and infrastructure: Contabo GmbH, Munich, Germany, where our servers and databases run (European Economic Area).
- Transactional email: Twilio SendGrid, used to send account and service emails.
- App distribution and payments: Apple Inc. and Google LLC, which process your purchase and give us the subscription data described above under their own privacy policies.
- Market data: providers of securities prices and reference data. They receive requests for market information only and no personal data about you.
- Analytics and crash reporting: tools that help us detect errors and understand feature usage, configured to work with pseudonymised identifiers.
We may also disclose data where the law requires it, to protect our rights or the safety of users, or, in the event of a merger, acquisition or sale of assets, to the acquiring party under the same protections.
7. International transfers
Your data is stored in the European Economic Area. Some providers listed above operate from the United States. Where data leaves the EEA, we rely on the European Commission's Standard Contractual Clauses or on the provider's certification under the EU-US Data Privacy Framework, together with additional safeguards where needed. You can ask us for a copy of the relevant safeguards.
8. How long we keep data
- Account, financial profile, plans: for as long as your account exists, then deleted within 30 days of account deletion.
- Subscription and billing records: for the period required by Polish accounting and tax law, currently five years from the end of the relevant financial year.
- Server and security logs: up to 12 months.
- Support communications: up to three years after the matter is closed, to handle any follow-up claims.
- Waitlist email: until you unsubscribe or until the launch communications end, whichever comes first.
9. Security
We protect data with encryption in transit (TLS) and at rest, hashed passwords, access controls limited to staff and contractors who need access, logging, and regular updates of our infrastructure. No system is perfectly secure, so if you believe your account has been compromised, contact us at once.
10. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you and receive a copy;
- have inaccurate data corrected and incomplete data completed;
- have your data erased, where there is no overriding reason for us to keep it;
- restrict processing in the situations set out in Article 18 GDPR;
- receive the data you provided in a portable, machine-readable format;
- object to processing based on our legitimate interests, and object at any time to direct marketing;
- withdraw consent at any time, without affecting processing carried out before withdrawal.
To exercise any of these rights, email team@groewy.com. We respond within one month, extendable by two further months for complex requests, and we may ask you to confirm your identity first.
You also have the right to lodge a complaint with a supervisory authority. In Poland this is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warsaw, uodo.gov.pl. You may also complain to the authority of the EU country where you live or work.
11. Deleting your account
You can delete your account at any time in the App under Settings → Account → Delete account, or by emailing team@groewy.com from the address registered to your account. Deletion removes your profile, financial data and plans as described in section 8. Cancelling a subscription is done separately through the App Store or Google Play; deleting your account does not by itself stop a store subscription.
12. Notifications and marketing
Push notifications require your permission on your device and can be switched off in the App or in your device settings at any time. Product emails contain an unsubscribe link. Service messages about your account, security or billing are sent regardless, because we need them to run the service.
13. Children
Groewy is intended for adults. You must be at least 18 years old to create an account. We do not knowingly collect data from anyone under 18; if you believe we have, contact us and we will delete it.
14. Cookies on the Website
The Website uses no advertising or tracking cookies. Our web server keeps standard access logs for security and troubleshooting, retained as described in section 8. If we introduce analytics or other non-essential cookies, we will ask for your consent first.
15. Changes to this policy
We will update this policy when our practices or the law change. For material changes we will notify you in the App or by email at least 14 days before they take effect. The current version is always available at groewy.com/privacy.
16. Contact
TTP Tech sp. z o.o., ul. Floriańska 6 lok. 02, 03-707 Warsaw, Poland · team@groewy.com