Privacy Policy

This Privacy Policy explains how Growefy Media OÜ ("Growefy," "we," "us," or "our"), operating the website paydownway.com ("PayDownWay" or the "Site"), collects, uses, discloses, and safeguards information about U.S. consumers who visit the Site or submit an information request.

By using the Site or submitting information through the Site, you acknowledge the practices described in this Privacy Policy.

1. Who We Are

PayDownWay is operated by Growefy Media OÜ, a private limited company registered in the Republic of Estonia.

Growefy Media OÜ is a marketing-consulting firm. We are not a lender, credit broker, debt-settlement company, debt-management plan provider, credit-counseling agency, law firm, financial advisor, tax advisor, or insurer. We do not make loans, broker loans, collect debts, make credit decisions, or provide legal, tax, financial, credit, settlement, or insurance advice.

For this campaign, information submitted through the Site may be shared with our current marketing partner, AmOne / QuinStreet, Inc., and approved service providers for matching, eligibility, offer-display, contact, analytics, fraud prevention, compliance, and related business purposes.

2. Information We Collect

We may collect the following categories of personal information.

Information you provide:

• Name
• Email address
• Phone number
• State, ZIP code, or other location information
• Estimated unsecured debt amount
• Debt types
• Income range or employment-related information
• Date of birth, where requested for identity verification, eligibility, fraud prevention, or matching purposes
• Any information you submit through forms, messages, or support requests

Information collected automatically:

• IP address
• Approximate location derived from IP address
• Device type
• Browser type
• Operating system
• User agent
• Screen size and language settings
• Referring URL
• Pages viewed
• Clicks and interactions
• Time spent on the Site
• Form progress and submission events
• Marketing attribution parameters, including click IDs, campaign IDs, ad IDs, placement IDs, subids, pixels, variants, and similar identifiers
• Cookies, pixels, local storage, web beacons, and similar technologies

Categories of personal information:

The categories of personal information we may collect include identifiers, contact information, internet or electronic network activity, approximate geolocation, commercial or request information, financial-related information you provide, and inferences related to eligibility, fraud prevention, attribution, or matching.

3. Sensitive Personal Information

Some information you provide, such as debt amount, income range, financial situation, date of birth, or related eligibility information, may be considered sensitive personal information under certain privacy laws.

We use this information only to process your request, evaluate eligibility, support matching through our current marketing partner, prevent fraud, comply with legal obligations, maintain records, and operate the Site.

We do not use sensitive personal information to infer characteristics about you except as reasonably necessary to provide the service you request.

4. How We Use Information

We may use personal information to:

• Operate, maintain, secure, and improve the Site
• Process information requests you submit
• Share submitted information with AmOne / QuinStreet, Inc. and approved service providers
• Support matching, eligibility review, offer display, contact, and related business purposes
• Respond to questions or support requests
• Send or support communications where permitted by law and your consent
• Measure marketing performance
• Attribute conversions to ads, campaigns, traffic sources, and subids
• Detect, prevent, and investigate fraud, abuse, invalid submissions, and policy violations
• Maintain business, legal, tax, contract, and compliance records
• Comply with legal obligations and respond to lawful requests
• Enforce our rights, terms, and agreements

5. How We Share Information

We may share personal information with the following categories of recipients.

Current marketing partner:

When you submit information through the Site, Growefy Media OÜ may share the information you provide with AmOne / QuinStreet, Inc. for matching, eligibility, offer-display, contact, analytics, fraud prevention, compliance, and related business purposes.

Once information is transferred to AmOne / QuinStreet, Inc., it may also be governed by their own terms, privacy practices, and applicable legal obligations.

Approved service providers:

We may share information with vendors that help us operate the Site, including hosting providers, analytics providers, fraud-prevention providers, communications vendors, form-processing providers, data-security vendors, customer-support vendors, and similar service providers.

Advertising and analytics partners:

We may share information with advertising and analytics partners for measurement, attribution, campaign optimization, conversion tracking, and related advertising purposes.

Affiliates:

We may share information with entities that control, are controlled by, or are under common control with Growefy Media OÜ, provided they process information consistently with this Privacy Policy.

Legal and compliance recipients:

We may disclose information when we believe disclosure is necessary to comply with a legal obligation, respond to lawful requests, protect our rights or property, investigate wrongdoing, prevent fraud, protect users or the public, or protect against legal liability.

Business transfers:

We may share or transfer information in connection with a merger, acquisition, financing, restructuring, sale of assets, or similar business transaction.

We do not sell personal information for money. However, some sharing for advertising, analytics, attribution, or cross-context behavioral advertising may be considered a "sale" or "sharing" under certain U.S. state privacy laws.

6. TCPA and Marketing Consent

By submitting your information through the Site, you authorize Growefy Media OÜ, AmOne / QuinStreet, Inc., and parties acting on their behalf to contact you at the telephone number(s) you provide, including through automated dialing systems, prerecorded messages, artificial-voice messages, SMS/MMS messages, and email, for marketing, eligibility, matching, and related purposes.

You understand that consent is not a condition of purchase. Message and data rates may apply. You may opt out of SMS by replying STOP or following the instructions in the message. You may also contact us at support@paydownway.com.

7. Cookies, Pixels, and Tracking Technologies

We and our partners may use cookies, pixels, web beacons, local storage, server-to-server tracking, postbacks, and similar technologies to operate the Site, remember preferences, measure performance, prevent fraud, attribute conversions, and improve marketing.

We may use:

• Necessary cookies, which are required for site functionality, security, and form submission
• Preference cookies, which remember user choices
• Analytics cookies, which help us understand Site usage
• Advertising and attribution cookies/pixels, which help measure ad performance and conversions
• Fraud-prevention technologies, which help detect invalid or suspicious activity

You can control cookies through your browser settings. Disabling cookies may affect Site functionality. Where required by law, we provide a cookie banner or preference tool so you can manage non-essential cookies and tracking technologies.

8. Global Privacy Control

Where required by applicable law, we honor valid browser-based opt-out preference signals, such as Global Privacy Control, as an opt-out of sale or sharing for targeted advertising for that browser or device.

California recognizes the right to opt out of the sale or sharing of personal information, including through GPC.

9. Your U.S. State Privacy Rights

Depending on your state of residence and applicable law, you may have some or all of the following rights:

• Right to know or access the personal information we collect about you
• Right to request deletion of personal information
• Right to request correction of inaccurate personal information
• Right to obtain a copy of personal information in a portable format
• Right to opt out of sale or sharing of personal information
• Right to opt out of targeted advertising
• Right to opt out of certain profiling, where applicable
• Right to limit certain uses of sensitive personal information, where applicable
• Right to appeal a denied privacy request, where applicable
• Right not to be discriminated against for exercising privacy rights

California law provides rights to know, delete, opt out of sale/sharing, and non-discrimination, among other protections. Virginia law also provides consumer privacy rights, including access, correction, deletion, portability, and opt-out rights under applicable conditions.

To exercise your rights, you may email:

support@paydownway.com

or use our Do Not Sell or Share My Personal Information page.

We may need to verify your identity before processing your request. Verification may include matching information you provide against information we maintain. Authorized agents may submit requests where permitted by law, but we may require proof of authorization.

10. Do Not Sell or Share My Personal Information

We do not sell personal information for money.

However, our use of advertising, analytics, pixels, cookies, postbacks, or cross-context behavioral advertising may be considered a "sale," "sharing," or "targeted advertising" under certain U.S. state privacy laws.

You may opt out by using our Do Not Sell or Share My Personal Information page or by enabling a valid Global Privacy Control signal in your browser, where required by law.

11. Data Retention

We retain personal information for as long as reasonably necessary to provide the service, process requests, support matching, maintain business records, prevent fraud, resolve disputes, comply with legal, tax, contract, and compliance obligations, and enforce agreements.

Typical retention is up to five years from your last interaction with the Site, unless a longer or shorter period is required or permitted by law.

12. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls, and security monitoring where appropriate.

No website, transmission, database, or system is 100% secure. We cannot guarantee absolute security.

13. Children

The Site is intended for U.S. residents aged 18 or older. We do not knowingly collect personal information from anyone under 18.

If you believe a child has provided information to us, contact us at support@paydownway.com.

14. International Data Transfers

Growefy Media OÜ is based in Estonia. Information collected from U.S. consumers may be processed in the United States, Estonia, the European Economic Area, or other jurisdictions where we, our current marketing partner, or our service providers operate.

Privacy laws in those jurisdictions may differ from the laws where you live. By submitting information through the Site, you understand that your information may be transferred and processed outside your state or country.

15. Links to Other Websites

The Site may contain links to websites not operated by us. We are not responsible for the content, privacy policies, or practices of third-party websites or services.

You should review the privacy policy of any third-party site you visit.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will update the "Last updated" date above.

If changes are material, we may provide additional notice, such as a notice on the Site or another appropriate method.

17. Contact Us

Growefy Media OÜ
Registry code: 17059227
Männikäbi Tee 2, Viimsi Vald, Harjumaa, 74017, Estonia

Privacy questions:
support@paydownway.com

General support:
support@paydownway.com