GrowSurf and the GDPR

Privacy and Security Contact

Kevin Yun
legal@growsurf.com

1 E Erie St
Suite 525-2424
Chicago, IL 60611

As part of our ongoing efforts to protect the security and privacy of our users, we are working to meet or exceed the GDPR (General Data Protection Regulation). This site contains information on what steps we are taking, their progress, and who to contact for any security concerns. Please see our FAQ at the bottom of the page for more information.

Data Processing Addendum

In order to use our products and services, you need to accept our DPA.

Data Processing Partners

We rely on a number of trusted 3rd parties to assist with our operations. Depending on the exact nature of your account and what you've requested we do, your data may be shared with one of these partners. We carefully evaluate each to make sure they're handling your personal data with the utmost of respect, security, and privacy.

Services
Partner Locale Data Shared Purpose
Atlassian (Trello) Email Address

Project management and bug tracking

ChartMogul Email

Revenue analysis

Cloudinary IP Address

Image management & delivery solution.

Cohere.so IP Address Email First Name Last Name

Screenshare and debugging

Customer.io IP Address Email First Name Last Name

With Customer.io, send targeted emails, push notifications, and SMS to lower churn, create stronger relationships, and drive subscriptions.

Datadog IP Address Email First Name Last Name

Logging (errors and monitoring)

Delighted IP Address Email First Name Last Name

NPS survey forms

Digital Ocean IP Address

Managed databases and hosted servers

Elastic.co IP Address

Managed Elasticsearch hosting

Facebook Conversion Tracking IP Address

Conversion tracking functionality from Facebook, allows a user to track advertisement clicks.

Facebook Pixel IP Address

Facebook Pixel is Facebooks conversion tracking system for ads on Facebook to websites.

Firebase IP Address Email First Name Last Name

Managed authentication and database hosting

Global Site Tag IP Address

Google's primary tag for Google Measurement/Conversion Tracking, Adwords and DoubleClick.

Google Analytics IP Address

Google Analytics offers a host of compelling features and benefits for everyone from senior executives and advertising and marketing professionals to site owners and content developers.

Google Apps for Business IP Address

Web-based email, calendar, and documents for teams. Renamed to Google Apps for Work, but now known as G Suite From Google Cloud.

Google Cloud Platform IP Address Email First Name Last Name

Managed database and backups hosting service

Google Tag Manager IP Address

Tag management that lets you add and update website tags without changes to underlying website code.

Google Universal Analytics IP Address

The analytics.js JavaScript snippet is a new way to measure how users interact with your website. It is similar to the previous Google tracking code, ga.js, but offers more flexibility for developers to customize their implementations.

GrowSurf IP Address Email First Name Last Name

Referral tracking

Heap IP Address

Heap automatically captures every user action in your web app and lets you measure it all.

HelpScout IP Address Email First Name Last Name

Customer support and sales communication

Heroku IP Address

Application hosting

Hubspot IP Address Email First Name Last Name

Sales and customer success software

Mailerlite IP Address Email First Name Last Name

Marketing email and automation forms

Postmark IP Address Email First Name Last Name

Email service provider for sending transactional emails

Profitwell Email

Revenue analysis

Retool IP Address Email First Name Last Name

Internal tool for customer support and troubleshooting support

Rewardful IP Address Email

Affiliate tracking

Slack Email First Name Last Name

Real-time team communication and internal notifications

Stripe IP Address Email First Name Last Name

Processing payments and managing subscriptions

Tango Card IP Address Email

Gift card rewarding

Twilio (SendGrid) IP Address Email First Name Last Name

Email service provider for sending transactional emails

Zapier IP Address Email First Name Last Name

Automating business workflows and notifications

Compliance Tasks

GDPR Compliance requires maintenance and ongoing work. We are tracking our efforts here.

Application Site Security
Status Name
Completed SSL (TLS) Deployed on App Site
Completed Establish Development Environment Data Handling Guidelines
Completed HSTS (HTTP Strict Transport Security) added to SSL/TLS of App Site
Completed Added External Javascript Files to Data Partners
Completed Restrict Personal Data at Signup to the Minimum Necessary
Completed Personal Data in File Storage is Encrypted
Completed Personal Data in Databases is Encrypted
Completed Ensure Access to Backups is Restricted
Completed Registered with HaveIBeenPwned Domain Notification
Completed Ensure Web Application Firewall enabled and blocking common attacks
Completed Ensure Backups are Stored in on Encrypted File Storage
Completed Ensure Database Backups of Personal Data are working
Completed Redact Logs from Writing Unneeded Personal or Sensitive Data
Completed Inform Users about the GDPR Page
Completed Affirmative Consent mechanism added to User Signup
Completed Ensure internal employees and contractors behaviors around personal data are documented.
Data Mapping
Status Name
Completed Add Customer Support (Helpdesk) Service to Partners
Completed Add Exception/Error Reporting Services to Data Partners
Completed Add Web Analytics Service to Data Partners
Completed Add Internal Email Service to Data Partners
Completed Add Hosting Provider to Data Partners
Completed Add Social Embeds to Data Partners
Completed Add Third Party Web Font Services to Data Partners
Completed Add Transactional Email Service to Partners
Completed Add Email Newsletter Service to Partners
Completed Add CDN Provider to Data Partners
Completed Add File Collaboration Service to Data Partners
Completed Add Database Provider to Data Partner
Completed Add Performance Monitoring Applications to Data Providers
Marketing Site Security
Status Name
Completed Reviewed list of users with access to site
Completed SSL (TLS) Deployed on Marketing Site
Completed HSTS (HTTP Strict Transport Security) added to SSL/TLS of Marketing Site
Privacy Procedures
Status Name
Completed Nominate a Data Protection Lead or Data Protection
Completed Get Management Approval for GDPR Efforts
Completed Process established for subject data requests
Completed Procedure established to allow for people to request that inaccuracies in their data are fixed.
Completed Briefed all Staff on GDPR Impact to the organization
Completed Developed a Data Processing Agreement
Completed Data Protection Policy Created
Completed Privacy Policy Updates
Completed Informed all Employees and Contractors about GDPR Compliance
Security Procedures
Status Name
Completed Publish statement on public website on how to report security and data issues.
Completed Data Breach Notification Policy has been established

Frequently Asked Questions

If you have any concerns not answered here, please reach out to our contact (listed above) and we'll be happy to assist.

Do Non EU Companies need to comply with the GDPR?

While it remains to be seen if the EU has the legislative power to levy fines and enforcement against organizations around the globe, GDPR compliance is being sought by non EU companies for a variety of reasons.

  • Customers and Prospects are making it a requirement
  • It's a solid framework for improving the handling of personal information and complying with the GDPR requirements improves our own security.

How Do I Report a Security Issue?

We take all security reports seriously. Please email our security contact (information listed above) with any information you have regarding any potential data breaches, vulnerabilities or concerns.

What's the GDPR?

The General Data Protection Regulation (GDPR) is a new piece of privacy legislation enacted by the European Union. It represents a significant change in how personal (IP Addresses, Emails, Names) and sensitive (religion, ethnic origin, health, orientation) data is handled by companies.

How do I request a DPA?

In order to use our products and services, you need to accept our DPA, which we have provided a link to here: Data Processing Agreement.

By agreeing to our Terms of Service, you are automatically accepting our DPA and do not need to sign a separate document.

How does GrowSurf enable me to be GDPR compliant?

GrowSurf enables customers to be GDPR compliant. Briefly stated, that means GrowSurf:

  • Provides sufficient guarantees to the controller to implement appropriate technical and organizational measures designed to safeguard customer data
  • Processes data (that could include personal data) only to fulfill its obligations as related to the Services
  • Enables users to modify and delete their account
  • Enables users to gain informed consent from participants
  • Enables users to modify and delete all participant data
  • Enables users to adhere to privacy standards by masking specific participant data in GrowSurf elements
  • Provides security documentation that describes the processes and procedures for safeguarding the data, outlined at https://growsurf.gdprpage.com