Privacy Policy

We use your Personal Information only for providing and improving the Site. By using the Site, you agree to the collection and use of information in accordance with this policy.

Introduction: Who We Are and Why We Collect Your Information

Grow Sagely, Inc. (“Sagely,” “we,” “us,” “our”) allows users to create folders to add, submit, post, store, save, organize, distribute, and share links to a variety of resources, including research, articles, books, songs, videos, pictures, audio clips, software, graphics, scripts, information, data and other materials, that users can share with friends, acquaintances, and colleagues (“Services”). The Services can be accessed through our website that is owned and operated by Sagely, including the https://www.growsagely.com website (“Website”), and the mobile application Sagely (“Application”, and collectively with the Application, the “Sagely Platforms”).

Please read the following to learn more about our privacy practices. By using our Services or visiting or using the Sagely Platforms, you acknowledge that you have read our Privacy Policy, and you hereby consent to our collection, use, and sharing of your information in the following ways.

I. What Does This Privacy Policy Cover?

This Privacy Policy covers our collection and processing of (1) personally identifiable information, as defined by numerous statutes in the United States (such statutes, the “PII Laws”), (2) information protected by the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) amendments, and the California Online Privacy Protection Act (“CalOPPA”), (3) information protected by the Colorado Privacy Act (“CPA”), (4) information protected by the Connecticut Personal Data Privacy and Online Monitoring Act (“CTDPA”); (5) information protected by the Virginia Consumer Data Protection Act (“VCDP”), (6) information protected by Utah Consumer Privacy Act (“UCPA”), (7) personal information protected by Canada’s Personal Information Protection and Electronics Documents Act (“PIPEDA”), and (8) personal information, the confidentiality, availability, or integrity of which is protected by applicable law (such laws collectively the PII Laws, CCPA, CPRA, CalOPPA, CPA, CTDPA, PIPEDA, VCDP, and UCPA, the “Privacy Laws”), (collectively, “Personal Information”), which we gather when you are accessing, viewing or using the Sagely Platforms, and/or Services, and as otherwise described in this policy. We do not knowingly collect or process Personal Information from outside the United States or Canada. Where noted, the terms of this Privacy Policy are limited by the Privacy Laws that govern an individual’s jurisdiction, such that requirements created by the Privacy Laws of one jurisdiction with regard to Personal Information are not incorporated herein and made to apply to the Personal Information of an individual or user of another jurisdiction if such Privacy Laws would not otherwise govern. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or otherwise control.

II. What Information Does Sagely Collect?

Sagely respects the privacy of your Personal Information. We do not collect Personal Information indiscriminately. We do not collect Personal Information indiscriminately. We limit the type of Personal Information and the amount of Personal Information that we collect to what is necessary to fulfill the purposes identified in this Privacy Policy. With that in mind, we collect the following types of information:

A. Information You Provide to Us

We may collect Personal Information from you when visit the Sagely Platforms, register for the Services, contact us with questions or concerns, and/or otherwise interact with us. For example, in the course of providing the Services, Sagely may collect and process a variety of Personal Information, which includes, but is not necessarily limited to, the following: (1) account information, such as your name, phone number, billing address, user name, and/or e-mail address in combination with a password or security question to access the Services; (2) content you save to your folder(s), the description you use to label your folder(s), the descriptions/text you add to any specific content or links in the folder(s), and information regarding other people with whom you share the content in your folder(s); and (3) payment information, such as your credit or debit card in case you choose the premium version of the Services. You can choose not to provide us with certain information, although that may affect the functionality of the Services and/or Sagely Platforms.

B. Metadata from Links in Folders

If the links you save in your folder(s) contain metadata, we may collect that information. For example, if you save a link to an article about chess and the link contains metadata – e.g.¸the article is about chess, the article was written in 2019, etc. – we may collect that for further processing as described in this Privacy Policy.

C. Information Collected Automatically

When you visit the Sagely Platforms or use the Services, we may place a cookie (a text file containing a randomly assigned number) or another technology on your device so that we have the ability to customize the look and feel of the Sagely Platforms and Services for you. Cookies remember information about you, your preferences, and your device for a better user experience when visiting the Sagely Platforms. Using cookies or another technology, we may also collect a variety of other information regarding your usage of the Sagely Platforms and Services, including your IP address, the geolocation of that IP address, network service provider, operating system, demographic information, language preferences, device type, the list of contacts saved on your device, username, session identification, browser you are using, web pages you view and referring web pages, when you access the Sagely Platforms and Services, and general online behavior for performance and marketing purposes. You may decline to accept cookies by modifying your web browser settings. If you choose so, however, you may be unable to use all functions of the Sagely Platforms and/or the Services, or the Sagely Platforms or Services may operate less efficiently.

D. Information from Customers

At times, Sagely may enter into agreements with companies (“Customers”) to provide the Services to their employees. In that event, we may receive Personal Information about individual users from Customers as part of facilitating the Services pursuant to those agreements. This information may include names, phone numbers, physical addresses, e-mail addresses, and employment information, including job titles and professional development and training information.

E. E-mail and Other Communications

We may contact you, by email or other means; for example, we may communicate with you about your use of the Services. When we do this, we may receive a confirmation when you open an email from us. This confirmation helps us make emails more interesting and improve our service. If you do not want to receive email or other mail from us, please inform us using the contact information in Section XIII below. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Sagely Platforms and Services, and you are responsible for reviewing such legal notices for changes.

F. Special Categories of Personal Information and Sensitive Personal Information

Except as otherwise stated in this Privacy Policy, we do not knowingly collect sensitive Personal Information, including: government identifiers (such as Social Security numbers and driver’s licenses); financial account and login information (such as credit or debit card number together with login credentials); precise geolocation; race, ethnicity, religious or philosophical beliefs, or union membership; content of nonpublic communications (mail, email and text messages); genetic data; biometric or health information (including mental health information); and sex life or sexual orientation information. As applicable under the relevant Privacy Laws, where we collect and use such information as a processor, contractor, service provider, or similar type of entity, we rely on the controller, business, or similar type of entity to obtain your informed consent. Please note that we may use Personal Information to profile users in order to enhance the Services, as described in Section III.A.1 below, and such inferences may result in the creation of sensitive Personal Information.

G. Personal Information Sagely Has Collected in the Last 12 Months

Sagely has collected all categories of Personal Information listed in Sections II (A), (B), (C), (D), and (E) of this Privacy Policy in the 12 months immediately preceding the Effective Date of this Privacy Policy. Please see the other portions of Section II above for an explanation of the categories of sources from which we collect the information described in the previous sentence. The business purposes of this information are described in Section III below. The categories of third parties we share this information with are described in Section IV.

III. What Does Sagely Do With Personal Information?

A. Use of Personal Information

Sagely uses all categories of Personal Information listed above for any and all legal and legitimate business purposes, including:

1. To provide, develop, maintain, and enhance the Services and the Sagely Platforms, including, but not limited to, by (a) developing profiles of our users, (b) recommending content you might like based on your activity on the Sagely Platforms and use of the Services, and (c) recommending other users who have interests similar to yours. When Sagely develops user profiles, we may make inferences about your preferences, interests and demographics based on the Personal Information we collect. Please note that when making such inferences, we may use automated processing, artificial intelligence, or algorithmic analysis. The inferences we are able to make and the profiles we are able to develop depend in large part on the Personal Information you provide while using the Services. For example, if you create a folder titled “Cancer Studies” and populate it with links to articles about skin cancer, we could infer that you or someone close to you has skin cancer;
2. To allow user to set up their user accounts and profiles;
3. To communicate with users and fulfill your requests for certain services;
4. To provide support for the Sagely Platforms and Services including responding to requests, questions, feedback, and technical support;
5. To understand how users utilize the Sagely Platforms and Services;
6. To protect user accounts with user names or e-mail addresses in combination with passwords;
7. To process payments to Sagely;
8. To operate, maintain, develop, and grow Sagely;
9. To maintain the safety, security, and integrity of the Sagely Platforms and Services;
10. To send you marketing and promotional communications;
11. To comply with legal and regulatory obligations; and
12. To establish, enforce, and otherwise exercise our rights and defend against claims.

B. Storage of Personal Information

We store and process all electronic Personal Information that we collect in the United States.

IV. Will Sagely Disclose Any of the Personal Information it Collects?

Except as necessary or appropriate to provide the Services, Sagely does not disclose Personal Information about you to unaffiliated third parties, provided that we may disclose Personal Information for the following purposes and in the following circumstances:

A. On Your Instructions

We may disclose Personal Information if directed to do so by the individual about whom such Personal Information pertains or that individual’s legal representative.

B. Our Customers

We may provide to Customers the Personal Information of their employees, if the employees visit the Sagely Platforms or use the Services pursuant to an agreement between the Customer and Sagely.

C. Affiliated Businesses and Third-Party Websites We Do Not Control

In certain situations, businesses or third-party websites we’re affiliated with may sell items or provide services to you through a website (either alone or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Information with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites as to privacy or anything else, so if you choose to enter into such transaction or to receive such service, please review the applicable third-party websites’ policies.

D. Advertisers

We may share your Personal Information with advertisers and vendors in order to provide advertising content that will be of greater interest to you. For example, if you create a “Fishing” folder and populate it with links about fishing, you may be more likely to see advertisements about fishing products. When we share Personal Information with advertisers, it is only to the extent necessary for them to provide you relevant advertising, based on our profile of you, through the Services and/or on the Sagely Platforms.

E. Agents and Service Providers

We may disclose Personal Information to other companies or people in order to perform tasks on our behalf while providing the Services to you and our Customers. These tasks include, but are not limited to, cloud storage and processing credit card payments. Unless we tell you differently, our agents and service providers do not have any right to use the Personal Information we share with them beyond what is necessary to assist us. We acknowledge our potential liability if our agents misuse your Personal Information.

F. Business Transfers

We may choose to buy or sell assets. In these types of transactions, Personal Information is typically one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information would be one of the assets transferred to or acquired by a third party.

G. Protection of Sagely and Others

Sagely will disclose any Personal Information that Sagely reasonably believes is necessary or appropriate to comply with law or court order, enforce or apply Sagely’s Privacy Policy, and other agreements, or protect the rights, property, or safety of Sagely, our employees, our Customers, our users, the public, or others. This includes disclosing Personal Information to third parties for fraud protection and credit risk reduction. In addition, in certain situations, Sagely may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. Sagely will notify you of any such requests unless prohibited by law.

H. With Your Consent

Except as set forth above, we will obtain your consent before disclosing your Personal Information to a third party.

I. Personal Information Sagely Has Sold to Customers or Shared with Third Parties in the Last 12 Months

Sagely has not sold Personal Information in the last 12 months. Sagely relies on third party vendors to support the Services, including, but not limited to, cloud hosting Sagely Platforms for all data storage. As a result, all Personal Information collected and described in Section II has been disclosed to third-party vendors in the 12 months immediately preceding the Effective Date. Please see Section VI below for instructions on how to opt-out of the sale, sharing, trading, or exchanging of your Personal Information.

V. How Long Does Sagely Retain Your Personal Information?

Except upon the request of an individual, as explained in Section VI below, and except as the law permits and requires, the duration for which we retain Personal Information varies significantly, depending on the types of Services that Sagely provides to you and any relevant Customers, the duration and depth of Sagely’s relationship with you and any relevant Customers, and the nature of the Personal Information in question. Sagely retains Personal Information for only as long as is necessary or appropriate.

VI. What Are Your Rights to Control Your Personal Information?

You have the following rights regarding Sagely’s collection and use of your Personal Information, although the scope and conditions for each of these vary depending on the circumstances and local law:

A. Requests to Sagely

To the extent required by the Privacy Laws, except where permitted or required by law (including, but not limited to, compliance with a legal obligation, to further a public interest, and establishing and/or exercising a legal claim or defense), you have the following rights regarding Sagely’s collection and use of your Personal Information:

1. Be informed about how your Personal Information is being processed, the categories of Personal Information being processed, and the categories of sources from which your Personal Information has been collected;
2. Be informed about whether and how your Personal Information being processed is being sold, shared, traded, exchanged or brokered with unaffiliated third parties, and which categories of your Personal Information are being sold, shared, traded, exchanged or brokered with unaffiliated third parties;
3. Access or receive a copy of your Personal Information;
4. Rectify, update or correct inaccurate or incomplete Personal Information about you;
5. Erasure or deletion of your Personal Information;
6. Object and opt-out of processing of your Personal Information, including profiling;
7. Limit processing of your Personal Information;
8. Opt-out of the sale, sharing, trading, exchange, and brokering of your Personal Information with unaffiliated third parties;
9. Portability of your Personal Information in a commonly used format;
10. Withdrawal of your consent to processing of your Personal Information to the extent such processing is based on your consent, provided that such withdrawal will not affect the lawfulness of Sagely’s use of your Personal Information before such withdrawal; and
Non-discrimination for exercising your privacy rights.

To make a request concerning these rights, please complete and submit the Privacy Rights Request Form on our Website. We will confirm receipt of all such complete Privacy Rights Request Forms within 10 days of receipt. We will substantively respond to all such requests within 30 days, subject to any lawful extension of that period. Please note that there may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized person.

Please be aware there may be valid reasons to refuse a request, including legal and regulatory requirements that we retain and process certain information. Also, please be aware that certain requests may limit or prevent us from providing Services to you. In those situations, we will notify you in writing within 30 days. You may also contact our Data Privacy Officer for help with those situations. Contact information is in Section XIII below.

Sagely will not discriminate against you if you exercise any of the foregoing rights or any other rights under Privacy Laws, including, by not denying Services to you, not providing a different level or quality of Services to you, and not suggesting that you will receive a different level or quality of Services. However, as noted above, certain requests may limit or prevent us from providing Services to you.

Sagely retains records of all of the above requests and our responses for 24 months, unless otherwise prohibited by the Privacy Laws.

B. “Do Not Sell or Share My Personal Information”

You may opt out of Sagely’s disclosure and sharing of your Personal Information by completing and submitting the Privacy Rights Request Form.

C. Profiling

The Services we provide may include profiling, as that term is defined in most Privacy Laws to include the use of automated processing of Personal Information to evaluate, analyze, or predict a person’s behavior. Although Sagely’s profiling does not produce a legal or other similarly significant effect, you may opt out of profiling by completing and submitting the Privacy Rights Request Form.

D. Authorized Agent

You may authorize an agent to take any of the acts permitted in this Section VI on your behalf. To do so, you must provide written and signed authority to the agent, and written and signed notice to Sagely that Sagely may act on such requests by that agent.

E. Filing a Complaint

Regulatory authorities that oversee the Privacy Laws typically advise individuals to file an objection or challenge with the company before lodging a formal complaint with a regulatory authority. Please contact us as outlined in Section XIII of this Privacy Policy for any complaints and inquiries. We appreciate the opportunity to discuss and solve your complaint.

If you are dissatisfied with Sagely’s response or you wish to file a complaint with a regulatory authority first, please contact the office of the attorney general where you reside or the state agency that oversees enforcement of privacy regulation.

F. Accessibility for Users with Disabilities

If you are unable to review this Privacy Policy or any portion of this Policy, please contact us as outlined in Section XIII below.

G. Non-Discrimination

Sagely will not discriminate against you because you have exercised any of the rights above or any other rights you retain pursuant to Privacy Laws, including, but not limited to by:

1. Denying goods or services to you;
2. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
3. Providing a different level or quality of goods or services to you; and
4. Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Consistent with Privacy Laws, Sagely: (i) retains the right to charge you a different price or rate, or provide a different level or quality of goods or services to you, if that difference is reasonably related to the value provided to Sagely by your Personal Information; (ii) may offer financial incentives, including payments to you as compensation, for the collection, disclosure, or deletion of your Personal Information; (iii) may enter you into a financial incentive program only if Sagely clearly describes the material terms of the financial incentive program, so long as you give Sagely prior opt-in consent, which you may revoke at any time; and (iv) shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.

VII. Is Personal Information About Me Secure?

We employ appropriate administrative, organizational, technical, and physical measures to protect your Personal Information, which we regularly review and update as necessary.

If you have an account with us, that account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

The Sagely Platforms and Services may contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When following a link to another site you should read that site’s privacy policy.

VIII. Children’s Privacy

We do not intend to, and do not knowingly, process Personal Information about individuals who are minors in the jurisdictions where they reside (“Children”). Individuals who are Children should not provide any Personal Information to us, and individuals should not provide Personal Information to us about Children. If we discover or are informed that we have Personal Information about Children, we reserve the right to delete that Personal Information from our systems.

IX. Failure to Provide Personal Information

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of the Sagely Platforms and Services or some of our special features.

X. Automated Decision Making

Although Sagely may rely on automated decision making for profiling, we do make decisions based solely on automated processing that will produce legal effects concerning you or similarly significantly affecting you.

XI. Periodic Review

Sagely will conduct a self-assessment at least once every year to ensure that our attestations and assertions with regard to processing of Personal Information are accurate and that Sagely has appropriately implemented these practices.

XII. Changes to this Privacy Policy

Sagely reserves the right to change or amend this Policy at any time and for any reasons, including to remain in compliance with Privacy Laws.

XIII. Questions or Concerns; Contact Information

For questions or concerns, please contact our Data Privacy Officer as follows:

Name: Katherine Frydryk
Phone: 401-216-9810
Email: privacy@growsagely.com
Address: 320 S Main St. Providence, RI 02903