Privacy Policy
Last updated: November 3rd, 2025
This Privacy Policy explains how GrowForce FZCO collects, uses, and protects information when users interact with the iEscrow website, participate in the token presale, or use our staking platform (collectively, the “Services”).
By using the Services, you agree to this Privacy Policy and our Terms of Service.
1. Information We Collect
We do not collect personal data such as names, addresses, or identification documents unless explicitly provided for KYC/AML or regulatory purposes.
We may collect:
- Address Information: Public blockchain addresses used to interact with our smart contracts.
- Transaction Data: Details related to your participation in the presale, staking, or reward distribution (e.g., amount, token type, timestamps).
- Technical Data: Browser type, device information, operating system, language preferences, IP address for security and analytics purposes, performance, and fraud prevention.
- Optional Data: Any information you voluntarily provide through contact forms or community interactions.
Our Services are intended for adult users. We do not knowingly collect or process data from individuals under 18 years of age, and any such information identified will be promptly deleted.
2. How We Use Information
We use the collected information to:
- Ensure platform functionality, integrity, and security.
- Comply with applicable laws and regulations (including AML/KYC requirements, if applicable).
- Analyze usage patterns to improve user experience and system performance.
We do not sell, rent, or trade your personal information to third parties.
3. KYC/AML Compliance
To comply with global know your customer (KYC) and anti-money laundering (AML) obligations, we require identity verification only for certain features, namely participation in our token presale and, for U.S. users, accredited investor verification under Regulation D Rule 506(c).
We work exclusively with Sumsub (Sum and Substance Ltd.), a third-party provider, to conduct identity verification services.
Sumsub processes this data on our behalf and may collect documents, video selfies, biometric data, and screen information against global sanctions and watchlists. Sumsub’s Privacy Policy is available here: https://sumsub.com/privacy/
KYC/AML submissions are processed solely for verification and compliance with applicable regulations. We retain KYC/AML data for at least five years or longer where required by applicable law.
We do not knowingly collect or process personal data from users in jurisdictions subject to international sanctions or identified as high-risk by the Financial Action Task Force (FATF), including jurisdictions on the FATF blacklist or under equivalent legal restrictions.
Users from these jurisdictions are strictly prohibited from participating in the token presale. We also do not knowingly allow participation from users in jurisdictions where cryptocurrency presales are restricted or prohibited by applicable law.
Please note: KYC/AML is not required to use other iEscrow Services such as escrow transactions or staking via externally acquired $ESCROW tokens.
4. Data on the Blockchain
Please note that any transaction executed on the blockchain (e.g., token purchases, staking, or reward claims) is public, immutable, and outside our control. Your wallet address and related on-chain activity may be visible to anyone inspecting the blockchain.
While we do not require personal identification to use our staking services, interactions with our smart contracts, including staking and reward claims, create permanent records linked to your wallet address. These records may be considered personal data under some data protection laws, depending on your jurisdiction.
Although we do not directly associate on-chain addresses with identity data in services that do not require KYC, we acknowledge that some jurisdictions may interpret such information as indirectly identifiable.
5. Legal Basis for Processing (GDPR)
If you are located in the European Economic Area (EEA), we only process your personal data when we have a valid legal basis, such as:
- Compliance with legal obligations (e.g., AML/KYC verification).
- Performance of a contract (e.g., presale access).
- Consent (e.g., for optional communications).
- Legitimate interest (e.g., fraud prevention, platform security).
6. Cookies and Analytics
Our website may use cookies and analytics tools (such as Google Analytics) to understand visitor behavior, improve functionality, and enhance performance. You can disable cookies through your browser settings at any time. To find out more on how to manage and delete cookies, visit https://www.allaboutcookies.org.
7. International Data Transfers
If you are located outside of the UAE, your data may be transferred to and stored in jurisdictions with different data protection laws. We apply appropriate safeguards, such as Standard Contractual Clauses, when required. International data transfers are conducted in accordance with Transfer Impact Assessments (TIAs) and valid data transfer agreements, as required by GDPR Article 46.
8. Data Retention and Security
We implement industry-standard measures to protect information against unauthorized access, alteration, or destruction. However, due to the decentralized nature of blockchain technology, we cannot guarantee the absolute security of data transmitted or stored online.
Personal data is only retained as long as necessary to meet compliance or legal obligations. For presale KYC/AML data, this period is at least five years. After this time, data is securely deleted. Additionally, standard security measures to protect your data from unauthorized access or misuse are implemented.
9. CCPA / CPRA Notice (California Residents)
If you are a California resident, we disclose the following:
- We collect identifiers (e.g., name, wallet address, KYC data), commercial data (presale or staking history), and internet activity (e.g., IP address).
- We do not sell or share your data for advertising.
- You may request access, deletion, or correction of your data under the CCPA and CPRA.
- We do not discriminate for exercising your privacy rights.
Email privacy inquiries to: [email protected]
10. Your Privacy Rights
Depending on your jurisdiction, you may have the right to:
- Request access, correction, or deletion of your personal data.
- Request portability of your personal data, where technically feasible.
- Withdraw consent for data processing (when applicable).
- File a complaint with a relevant data protection authority.
To exercise any of these rights, please contact us at: [email protected]
11. Updates to This Policy
We may update this Privacy Policy periodically. The latest version will be available on our website with a revised date. Continued use of our Services after such changes constitutes your acceptance of the revised policy.
12. Contact Us
For questions, inquiries, or concerns regarding this Privacy Policy, please contact us at:
Email: [email protected]
Company: GrowForce FZCO, Dubai, UAE.