Privacy Policy

Welcome to STEWARD (STWRD, Inc.):

  1. This is Our Privacy Policy (“Policy”) and it is very important to Our relationship with You. It details what information We collect from You, how We use and disclose this information, and what choices and rights You have with respect to this information.
  2. The Policy is meant to be read together with Our Terms of Service (“Terms”). Capitalized words used here have the meaning given in the Terms.

Information We Collect:

  1. On Registration. When You register an account, You provide Us with Your:
    1. Name
    2. Address
    3. Birthday (for age verification purposes)
    4. Email address
    5. Phone number
    6. Chosen username and password
  2. When You access the Platform or otherwise use the Service, We may collect the following information, either automatically or when You submit it to Us:
    1. Device Information, such as the make and model of the device You are using to access the Platform; the device’s hardware and software specifications; the operating system the device is running; the program or browser You are using to access the Platform; and other programs or software present on the device.
    2. Your IP address, information about the websites visited before and after accessing the Platform, the web pages and advertisements viewed on those websites, links clicked on within the Platform, interactions with e-mail messages sent by Us, information made available through the use of unique identifiers such as cookies, beacons, or tokens, Your internet service provider and other standard server log information and other publicly available information.
  3. Information About Your use of the Platform or Service.
    1. We collect data about Your activity on the Platform, including searches, websites visited, the length of time You spent on the Platform, and which features You utilized.
    2. We collect Location Information, the date and time of Your visit, and content You interact with on the Platform and/or on third-party sites.
    3. We receive data about You from third parties that have obtained Your permission to share Your information with Us. a) For example, if You choose to sign-up for Our Platform through Facebook or Google, or upload Your contacts from Your third-party email service, You will be asked to share certain information with Us as identified by those third-party platforms. 
      b) We may also receive information about You from Our partners. For instance, we receive your account information from payment processors like Apple Pay and Google Pay, to facilitate purchases. 
      c) Note that third parties will have their own privacy policies and terms of service. You should read and familiarize Yourself with those documents and make sure You agree to them.
    4. We receive information collected by third parties through tracking technologies, cookie information, IP addresses, or other identifiers from devices and/or browsers accessing the Platform in order to allow features to run properly and as intended on the Platform and use analytics and other tools to customize and improve the quality and performance of the Platform and Service for You.
    5. Use of the Platform may require certain device permissions and the Service may not function properly without the following: 
      a) Access to Your Camera and Photos; 
      b) Access to Your device’s location services and information; 
      c) Access to Your device’s sensors; 
      d) Access to the Internet.
    6. If You choose to connect the Platform to third-party devices or services, such as a smart thermostat, We will share Your information as necessary with that third-party device or service. You may be required to agree to additional terms and conditions from the manufacturer or provider of the third-party device. That third-party device or service may also share its information with Us, and We may use the information consistent with this Policy.
  4. Aggregation and Anonymization of Data.
    1. We may aggregate and anonymize data from across the Platform and Service and combine it with personal and non-personal information, including Location Information as described below.
    2. Data that is aggregated and anonymized may be used for marketing, serving advertisements, providing the Services, providing customer support, determining usage trends and feature promotion/demotion, building relationships with public or charitable organizations, in research and development, and any other lawful purpose.
  5. We do not collect biometric data.

Location Information:

Location Information is essential for Us to provide, and for You to utilize the Platform. We describe how We collect Location Information in our Terms. You understand that, in order for Us to provide the Service to You in accordance with the Terms, We link your Location Information to Your account. When you terminate Your account, We will remove your Location Information stored in Our system.

Rights for Persons Covered by GDPR:

If You are “data subject” for whom the processing of personal data is subject to REGULATION (EU) 2016/679 (GDPR) (“Covered Person”), the rights described in sections (A) through (G) apply to You.

A. Right of access, rectification, erasure and restriction of processing: You may obtain access to Your personal data stored by Us by contacting Us as provided in the Terms. If We process or use Your personal data, We shall endeavor to ensure, by implementing suitable measures, that Your personal data is accurate and up to date for the purposes for which they were collected. If Your personal data is inaccurate or incomplete, You may obtain the rectification of such personal data by contacting Us as provided in the Terms. You may obtain the erasure or restriction of processing of Your personal data, for example if no legitimate business purpose exists anymore for the data processing under this privacy policy or applicable law and the further storage is unnecessary under statutory storage obligations.

B. Right to data portability: You may receive the personal data about You that You have provided to Us, in a structured, commonly used and machine-readable format or transmit this data to another controller. To exercise this right, contact Us as provided in the Terms.

C. Right to object: You may object, on grounds relating to Your particular situation, to the processing of Your personal data. To exercise this right You must contact Us as provided herein. To the extent Your personal data is processed for reasons other than direct marketing, You understand and agree that We have compelling legitimate reasons for data processing, such as providing the Service to You, including all of the items in Section VI, below, and all of its features, and to ensure the quality standards of the Service and Platform. You may use ad-blocking software to limit data capture and usage. You may also contact Us with questions about Our policies or to make a removal request. Making a request does not guarantee that the request will be honored.

D. Right to withdraw Your consent: If You have given Your consent to the collection or processing of Your personal data, You may withdraw Your consent without affecting the lawfulness of processing based on consent before its withdrawal by contacting us in writing.

E. Your personal data may be transferred, stored, or processed in a location outside the UK or the European Economic Area. We currently store Your personal data in the United States.

F. If You make a request under sections (A) – (E), above, We have 30 days to respond to You. To exercise any of these rights, please contact us.

G. The legal basis for processing your personal data is:

i. You have given Us consent by agreeing to abide by Our Terms of Service and continuing to access the Platform; and
ii. Processing is necessary in order for Us to comply with legal obligations.

How We Use Your Content and Information.

  1. We use the Content and Information to:
    1. Provide the features of the Service to You;
    2. Measure, analyze, and understand usage of the Platform;
    3. Tailor content and personalize Your experience on the Platform, including saving Your account information and any settings;
    4. Enable the internal functioning of the Platform and Service;
    5. Identify ways We can improve the Service for You and other users, including by feature promotion/demotion;
    6. Help Us maintain and administer the Platform in order to provide customer service, ensure uptime, and keep the Platform secure;
    7. Evaluate the effectiveness of Our marketing campaigns or promotions and make sure You are receiving relevant information;
    8. Communicate with You about your account, use of the Service, answer Your questions, and let You know about updates, problems, or other issues with the Service, or to request information from You;
    9. Back up Our systems;
    10. Improve the security of Our systems;
    11. Evaluate use of the Platform for business purposes and to improve and develop Our products and services;
    12. Prevent fraud and maintain a quality experience for Our business purposes;
    13. Enforce Our agreements with You; comply with Our legal obligations; prosecute or defend a lawsuit, arbitration, or similar legal proceeding; and respond to lawful requests by public authorities.
  2. How We share Information:
    1. We do not rent or sell Your personal contact information (such as Your email address associated with Your name, address, and/or phone number) to third parties to use for their own marketing purposes.
    2. We would like to send you information about products and services We offer that You might like, as well as those of Our partners or affiliates. We may share Your information with others for Our uses described in the Terms and this Policy.
    3. You may specifically agree to share Your information with a third-party if You:
      a) Are interested in receiving goods/services from the third-party;
      b) Purchasing Services; or
      c) Otherwise authorize Us to share Your information.
    4. If You have identified Yourself as residing in the EU, We will not share Your email address or other personally identifiable information with third parties for advertising or marketing purposes unless You have "opted-in."
    5. If You have agreed to receive marketing information or materials, you can always opt-out whenever you want, so long as You notify us that You want to opt-out. You can opt-out of marketing communications here: hello@growsteward.com.
    6. If required by law or if We believe it is in the interest of Us or of Our users to share information to law enforcement officials or similar individuals, or in the event that Steward, Inc. is transferred or sold to another entity as a result of, for example, a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy, information may be transferred to the acquiring entity.

Updates.

We may modify this Policy at any time for any reason. If the Policy is modified, to the extent reasonable and practicable, You will be notified via email and we will post the updated Policy on the Platform. Any changes We make to the Policy may take effect immediately. If You continue to access the Platform after We make changes to it, Your continued access to and use of the Platform shall affirm Your consent to be bound by the modified Policy. You consent to receiving electronic communications or notifications regarding modifications to the Policy by email. You are advised to check this Policy frequently for any updates.

Cookie Policy.

  1. A browser cookie is a small piece of data that is stored on Your device to help websites and mobile apps remember things about You. Other technologies, including Web storage and identifiers associated with Your device, may be used for similar purposes. We use “cookies” to mean all of these technologies.
  2. Cookies allow Us to collect information about Your use of the Platform, including what content You viewed and what links You clicked on. This data may be shared with third-party advertisers for advertising purposes. When You visit a website, You may be shown advertising based on Your browsing data.
  3. We use cookies for a number of reasons, including:
    1. Maintaining your settings and preferences;
    2. Identifying users and account maintenance;
    3. Working on keeping the Platform secure;
    4. Personalizing Your experience and interaction with the Platform;
    5. Improving the Platform and Services; and
    6. Measuring and analyzing how the Platform and Service is used.
  4. Your browser or device may allow You to block or otherwise limit cookies. You can do this, but Your experience on the Platform may be limited and the information you receive from the Service may be inaccurate or incomplete.
  5. We do not honor “Do Not Track” requests when you visit the Webpage.

Data retention.

  1. Users can request that their account be deleted by emailing Us, but it may take Us a reasonable amount of time to complete Your request. Your request must contain enough information to specifically identify Your account for deletion, or Your account will not be deleted. Upon receiving a compliant request from You, We will remove Your data, including Your Location Information, from the Platform as follows: everything will be deleted except photos relating to plant health and condition and the related information that You’ve provided Us, all of which is anonymized. Since the Service largely depends on Your Location Information, if You move You can either delete Your photos, or download them if Your location change is temporary.
  2. We will keep Your personal information only for as long as necessary to fulfill the purposes for which We are processing Your personal information unless the law permits or requires Us to retain Your personal information for a longer period. We will retain aggregated, anonymized information after Your account has been closed. We can only remove Information that is stored on Our servers. Please note that copies of information that You have updated, modified, or deleted may continue to reside, in whole or in part, in Our systems for a period of time, and We may maintain copies of this information as part of Our business records or to fulfil legal obligations.
  3. Third-Party Service Providers may have different terms and conditions related to data privacy and retention; You should carefully review those as well.

Other Sites.

While using the Platform, You may come into contact with links to other sites not affiliated, owned, or controlled by Us. These other websites are outside the scope of this Policy and may be governed by their own privacy policies or information collection practices, which may be substantially different from Ours. We caution You to review the privacy policies and information collection practices of those websites outside of the Platform.

Governing Law.

  1. The Platform is operated in accordance with the laws of the U.S. and the State of Delaware. While users from countries other than the U.S. may access the Platform, We make no representation that the Platform, including Service Providers, are operated in accordance with the laws or regulations of, or governed by, Your particular jurisdiction.
  2. If You are located outside of the U.S., You use this Site at Your own risk and initiative and You, not Us, are responsible for compliance with any applicable local and national laws. Please be aware that any personal information and other information You provide to Us or We obtain as a result of Your use of this Site shall be collected in the U.S. and/or transferred to the U.S. and subject to U.S. law unless We agree otherwise in this Policy.
  3. By using the Platform and/or providing Us with Your personal information and other information, You (a) consent to the transfer and/or processing of any Information to and in the U.S., (b) acknowledge that U.S. law may provide a lower standard of protection for personal data than the laws of Your location and (c) understand that We shall collect, transfer, store, process and/or deal with Your Information in accordance with this Policy and U.S. law. Consequently, to the full extent permitted by law, You hereby waive any claims relating to the processing of Your personal information or other information in accordance with this Policy that may arise under the laws and regulations that apply to You in or of any other country or jurisdiction.

Your California Privacy Rights.

  1. Starting January 1, 2020, California Users have new rights under the California Consumer Privacy Act (“CCPA”). California Users may:
    1. Request information about Our data collection and sales practices that impact your personal information, the source of that information, and, if that information was disclosed or sold to third parties, the categories of personal information disclosed or sold, and categories of third parties to whom information was disclosed or sold.
    2. Request a copy of the specific personal information collected about them during the 12 months preceding the request (two times max per year);
    3. Request that the personal information be deleted (subject to other provisions in the law);
    4. Request their personal information not be sold to third parties; and
    5. Not be discriminated against for choosing to exercise any of these rights.
  2. To request any of the information in Section A, you may contact us via email at hello@growsteward.com
  3. In the 12 months preceding the effective date of this Privacy Policy, We have collected the following categories of personal information:
    • Identifiers (contact information, government ID, cookies)
    • Information protected against security breaches (name and
    • financial information, driver’s license number, etc.
    • Protected classification information (race, gender, etc.)
    • Commercial information
    • Internet/electronic activity
    • Geolocation
    • Audio/video data
    • Professional or employment related information
    • Education information
    • Biometrics
    • Inferences from any of the foregoing.

    We have not sold any of this personal information in the past 12 months. If we do sell any of this personal information, we will indicate in this Policy. If you request the category of the third party receiving any sold information, we are required to respond to you with that information.

  4. For each category of information selected above, the source is from either the individual submitting the information, a third party, or our own business intelligence and observational activity (including the use of cookies). We also use the personal information in other was as described more fully herein. 

    We disclose personal information for business purposes.

    • Auditing
    • Detecting security incidents, prevention, and prosecution
    • Protected classification information (race, gender, etc.)
    • Our business services, such as maintenance, customer service, order processing/fulfilment, etc.
    • Debugging to identify and repair errors in Platform functionality
    • Short-term transient use
    • Internal research and development, demonstrations
    • Activities to verify or maintain the quality of the Platform and Service

    * indicates we have disclosed this category of information for business purposes in the last 12 months.

Reviewing Your Information.

You have the right to access, update and correct factual inaccuracies in personally identifiable information that We collect online, subject to certain exceptions. To do so, e-mail Us using Your registered email address at hello@growsteward.com. To help protect Your privacy and the security of Your personally identifiable information, We will take reasonable steps to verify Your identity before granting access. 

Contacting Us. 

If You have any other questions about Our information handling practices, including Our practices with respect to children's personal information, or would like further information, please contact Us at: hello@stewardhome.com, or You may contact Us via regular mail at: 
Steward (STWRD, Inc.) 
17A Stuyvesant Oval 
New York, NY 10009