1. Introduction
SheGrows ("we," "us," "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information when you visit shegrows.ch, join our waitlist, receive our Babylon Letters, or eventually use our platform.
By using our services, you agree to the collection and use of information in accordance with this policy. If you do not agree with this policy, please do not use our services.
2. Data Controller
The data controller responsible for your personal information is:
[Association full legal name]
3 Avenue Adrien Jeandin
1226 Thonex
Switzerland
Registration number: [Swiss registration number]
Email: hello@shegrows.ch
Note: Bracketed placeholders will be completed with the registered association details before this policy goes live.
3. Information We Collect
We collect information in the following ways:
3.1 Information you provide
- Waitlist signup: first name, email address, language preference.
- Communications: any information you include when emailing us at hello@shegrows.ch or otherwise contacting us.
- Future platform use: when the platform launches in Q4 2026, we will collect financial profile information you choose to share through the conversational AI Sovereign Profile, including income, expenses, life situation, and financial goals. This collection will be subject to a separate, more detailed consent at that time.
3.2 Information collected automatically
- Analytics: we use Vercel Analytics to understand how visitors use our site. This includes pages viewed, time on site, country of origin (via IP), and device type. Vercel Analytics is privacy-focused and does not use cookies for tracking.
- Email engagement: when you receive our Babylon Letters, we may track whether they were opened and which links were clicked, to improve our communications.
3.3 Information from third parties
We do not currently purchase or receive personal information from third-party data brokers. When the platform launches, we will integrate with licensed brokerage partners for investment execution. Information shared with those partners will be governed by their own privacy policies, which we will link to clearly.
4. How We Use Your Information
We use your information solely to:
- Deliver the Babylon Letters series you signed up for
- Notify you when the platform launches and your founding member access opens
- Operate the platform itself when it launches (creating and maintaining your Sovereign Profile)
- Respond to your inquiries and support requests
- Process subscription payments through Stripe (when applicable)
- Improve our services through anonymous usage analytics
- Comply with legal obligations
- Protect against fraud and abuse
We do not sell your personal information. We do not share it with third parties for their marketing purposes. We do not use your data to target you with advertising on other platforms.
5. Legal Basis (GDPR)
For users in the European Economic Area, we process your information under the following legal bases:
- Consent: when you join our waitlist or sign up for the platform, you consent to the processing described in this policy.
- Contract: processing necessary to deliver the services you have requested (the Babylon Letters, platform access).
- Legitimate interests: minimal processing required to operate the website, prevent fraud, and improve services through anonymous analytics. We balance this against your privacy rights and never use it as a basis for invasive processing.
- Legal obligation: when required by Swiss, EU, or other applicable law.
6. Data Storage and Location
Your personal data is stored within the European Economic Area, specifically in Frankfurt, Germany, on Supabase infrastructure. This means your data benefits from the full protection of the EU General Data Protection Regulation (GDPR) and Swiss data protection law.
Email delivery is handled by Resend, which operates from US infrastructure under EU-US Data Privacy Framework certification. Email metadata (delivery status, open rates) is processed by Resend; the email content is held briefly during sending and then discarded.
9. Data Retention
We retain your information only as long as needed:
- Waitlist data: retained until you unsubscribe, request deletion, or two years after your last interaction with our communications, whichever comes first.
- Member account data (when applicable): retained for the duration of your membership plus 7 years (for tax and regulatory compliance), then deleted.
- Analytics data: aggregated and anonymized after 90 days.
- Legal/compliance records: as required by Swiss, EU, or other applicable law.
10. Your Rights Under GDPR
If you are in the European Economic Area or the UK, you have the following rights:
- Right to access: request a copy of the personal data we hold about you.
- Right to rectification: request correction of inaccurate or incomplete data.
- Right to erasure ("right to be forgotten"): request deletion of your data, subject to certain legal exceptions.
- Right to restrict processing: request that we limit how we use your data.
- Right to data portability: receive your data in a structured, machine-readable format.
- Right to object: object to processing based on legitimate interests.
- Right to withdraw consent: at any time, where processing is based on consent.
- Right to lodge a complaint: with your local data protection authority.
To exercise any of these rights, email us at hello@shegrows.ch. We will respond within 30 days.
11. Your Rights Under California Law
If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):
- Right to know: what categories of personal information we collect and for what purpose.
- Right to access: request the specific pieces of information we hold about you.
- Right to delete: request deletion of your personal information.
- Right to correct: request correction of inaccurate information.
- Right to opt-out: we do not sell or share your personal information for cross-context behavioral advertising. There is nothing to opt out of, but the right exists.
- Right to limit use of sensitive information: we collect minimal sensitive information and use it only for the services you request.
- Right to non-discrimination: we will not discriminate against you for exercising any of these rights.
To exercise these rights, email hello@shegrows.ch. You may designate an authorized agent to make a request on your behalf.
12. Your Rights Under Other US Laws
Residents of Virginia, Colorado, Connecticut, Utah, and other US states with comprehensive privacy laws have similar rights to those described above for California residents. These include the right to know, access, delete, correct, and opt out of certain processing.
To exercise these rights, email hello@shegrows.ch. We will respond in accordance with applicable law.
13. International Transfers
Your data is primarily stored within the EU. When data needs to be transferred outside the EU (for example, to a US-based service provider), we ensure appropriate safeguards are in place:
- EU Standard Contractual Clauses with all non-EU processors
- EU-US Data Privacy Framework certification where applicable
- Additional supplementary measures as required by the European Court of Justice
14. Children's Data
Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us at hello@shegrows.ch and we will take steps to delete that information.
15. Security
We implement industry-standard security measures to protect your data:
- All data transmission encrypted via HTTPS/TLS
- Data at rest encrypted on Supabase infrastructure
- Row-level security policies governing database access
- Regular security audits and updates
- Access to personal data limited to authorized personnel on a need-to-know basis
- Two-factor authentication required for all administrative access
Despite our best efforts, no system is completely secure. If you believe your account has been compromised, contact us immediately at hello@shegrows.ch.
16. Changes to This Policy
We may update this Privacy Policy from time to time. When we make material changes, we will notify you by email at least 14 days before the changes take effect, and we will update the "Last updated" date at the top of this policy. Continued use of our services after the changes take effect constitutes acceptance of the updated policy.
17. Contact Us
For any questions about this Privacy Policy or to exercise your privacy rights, contact us at:
SheGrows Data Protection
Email: hello@shegrows.ch
Postal: 3 Avenue Adrien Jeandin, 1226 Thonex, Switzerland
If you are in the EU and not satisfied with our response, you have the right to lodge a complaint with your local data protection authority.