Privacy Notice
Version 1.0 Last updated: July 29, 2026 Effective date: on publication
This notice explains what personal information we collect through growedyn.com and the waitlist, why we collect it, who we share it with, how long we keep it, and the choices and rights you have. It also serves as our notice at collection under California law.
1. Who we are
Edyn Financial Inc., a Delaware corporation at 1900 Market Street, Philadelphia, Pennsylvania 19103, is the business responsible for the personal information described here, and is the controller of that information for the purposes of the European Union and United Kingdom General Data Protection Regulations. You can reach us at tillers@growedyn.com.
2. What this notice covers, and what it does not
This notice covers the website and the waitlist. It does not cover the client relationship. If you later open an advisory account with us, you will receive a separate privacy notice under the Gramm Leach Bliley Act and Regulation S P at the time the customer relationship is established, and thereafter as that rule requires. That notice governs the information we collect in connection with advisory services, and it is a different document with different content.
3. Personal information we collect
| Category, using the California statutory names | What that means here | Where it comes from |
|---|---|---|
| Identifiers | Name and email address | You, through the waitlist form |
| Internet or other electronic network activity information | Pages viewed, referring page, time on page, browser and device type, operating system, and email open and click events | Automatically, through the site and through our email provider |
| Identifiers, technical | Internet protocol address and request metadata | Automatically, when you visit |
| Geolocation data | Country and region derived from your internet protocol address, at coarse granularity only | Automatically, at the network edge |
| Commercial information | Your position on the waitlist, your consent record, the version of the terms you accepted, and the date and time you accepted them | Generated when you register |
| Inferences | Your apparent interest in the service | Derived from the above |
We do not ask for sensitive personal information through this site, including government identifiers, financial account numbers, precise location, health information, or information revealing race, religion, union membership, sexual orientation or immigration status. Please do not send it to us. We do not knowingly collect information from anyone under 18.
4. Why we use it
To operate the waitlist, confirm your registration and tell you when the service is available. To respond to messages you send us. To measure how the site performs and improve it. To protect the site against fraudulent, automated and abusive registrations. To comply with law, including the books and records obligations that apply to registered investment advisers, and to establish, exercise or defend legal claims.
We do not use your information to make decisions producing legal or similarly significant effects about you, and we do not profile you for that purpose.
5. Legal bases, for visitors in the European Economic Area and the United Kingdom
We rely on your consent for marketing email, for text messages, and for analytics and marketing cookies. We rely on our legitimate interests in operating and securing the site, preventing abuse, and understanding aggregate usage, where those interests are not overridden by your rights and freedoms. We rely on compliance with a legal obligation for the records we are required to retain. Where we rely on consent you may withdraw it at any time, and withdrawal does not affect the lawfulness of processing carried out before you withdrew.
6. Cookies and similar technologies
The public site does not currently set cookies or write to local storage or session storage. Vercel Web Analytics measures public page visits without storing an identifier on your device. Our email messages may use measurement images and link redirection to record opens and clicks. The current technology and how choices are honored are described in the Cookie Notice.
7. Who we disclose personal information to
We disclose personal information to the service providers below, each of which is contractually restricted to processing it on our instructions and for our purposes.
| Provider | Role in the flow | Personal information reaching them | Location of processing |
|---|---|---|---|
| Vercel Inc. | Website hosting, edge delivery, geolocation header, request logging | Internet protocol address, request metadata, coarse location | United States |
| Microsoft Corporation | Microsoft 365, including Microsoft Lists where waitlist entries are stored and Exchange Online where correspondence is held | Name, email address, answers submitted through the waitlist, consent and acceptance record | United States, because our tenant is located there and the European Union Data Boundary does not apply to tenants outside the European Union and European Free Trade Association |
| Plus Five Five, Inc., trading as Resend | Transactional and marketing email delivery, and open and click measurement | Name, email address, delivery and engagement events | United States |
Resend engages its own subprocessors to deliver that service, which as of the date of this notice include Amazon Web Services, Vercel, Cloudflare, PlanetScale, Supabase, Snowflake, Datadog, Google, Stripe, Attio, Elastic, Inngest, Liveblocks, Metabase, Retool, Salesforce, Svix, Tinybird, Estuary, Not Just Tickets, Anthropic and RunPod. Resend publishes the current list, and its data processing addendum requires advance notice of changes to it.
We also disclose personal information where the law requires it or permits it: to regulators, including the Securities and Exchange Commission in connection with examinations and requests; to law enforcement in response to valid legal process; to our professional advisers under duties of confidentiality; to protect our rights, property or safety, or those of any person; and to an acquirer or successor in a merger, financing, or sale of assets, in which case we will tell you before your information becomes subject to a different privacy notice.
8. Sale, sharing and targeted advertising
We do not sell personal information for money. As of this version we do not share personal information for cross context behavioral advertising, and no advertising technology operates on the site. If that changes, we will update this notice before the change takes effect, add a "Your Privacy Choices" link to the footer, and treat the change as material.
We recognize the Global Privacy Control browser signal as a valid opt out of sale, sharing and targeted advertising for every visitor, regardless of location.
9. How long we keep it
| Record | Retention |
|---|---|
| Waitlist entry, including name, email address and submitted answers | Until you ask us to delete it, or eighteen months after the waitlist closes, whichever is earlier |
| Consent and terms acceptance record | Six years from the end of the relevant consent, so that we can evidence what was agreed |
| Email delivery and engagement events held by our email provider | Twelve months, then deleted or aggregated |
| Website and security logs, including internet protocol addresses | The hosting provider default that applies to our account. We do not extend that period through a separate log drain at this version |
| Communications sent to ten or more persons, and records supporting statements made in them | Five years from the end of the fiscal year in which the communication was last used, with the first two years in an easily accessible place, as the investment adviser books and records rule requires |
Where a record must be retained under the securities laws, we retain that record and delete everything not covered by the requirement. We tell you when this applies to a deletion request.
10. Your rights, United States
Depending on your state of residence, you may have the right to confirm whether we process your personal information and to access it, to obtain a copy in a portable form, to correct inaccuracies, to delete it, to opt out of targeted advertising and of any sale or sharing, to limit the use of sensitive personal information, and to be free from discrimination or retaliation for exercising any of these rights. States currently providing rights of this kind include California, Virginia, Colorado, Connecticut, Utah, Iowa, Nebraska, New Hampshire, Tennessee, Minnesota, Maryland, Delaware, Oklahoma, Montana, New Jersey, Indiana, Kentucky, Rhode Island, Oregon and Texas.
To exercise a right, write to tillers@growedyn.com with the word Privacy in the subject line. The address is routed to the founder until a compliance owner is named. We verify your identity before acting, ordinarily by confirming control of the email address on file, and by other reasonable means if you are not on the waitlist. An authorized agent may act for you with written permission, and we may ask the agent to prove it.
We respond within forty five days of receiving a verifiable request. Where the law allows, we may extend that period once by a further forty five days, and we will tell you before we do. There is no charge for a reasonable request.
If we decline your request, we tell you why, and you may appeal by replying to our decision. We respond to appeals within the period your state requires, and if we decline the appeal we tell you how to submit a complaint to your state attorney general.
11. Your rights, European Economic Area and United Kingdom
You have the rights of access, rectification, erasure, restriction, portability and objection, the right to withdraw consent, and the right to lodge a complaint with your supervisory authority. Use the contact details above to exercise them.
Your information is processed in the United States by us and by the providers named in Section 7. Where personal information is transferred out of the European Economic Area or the United Kingdom, we rely on the European Commission and United Kingdom standard contractual clauses incorporated into our agreements with those providers, together with encryption in transit and at rest and contractual limits on further disclosure.
12. Security
We protect personal information with encryption in transit and at rest, access limited to personnel who need it, multi factor authentication on the systems that hold it, logging of administrative access, and review of the providers we rely on. No method of transmission or storage is completely secure, and we do not represent that ours is.
As a registered investment adviser we maintain a written incident response program covering the detection of, response to and recovery from unauthorized access to customer information, including obligations on our service providers to notify us promptly of an incident, and notification to affected individuals no later than thirty days after we become aware that unauthorized access has occurred or is reasonably likely to have occurred, as Regulation S P requires.
13. Children
The site and the waitlist are not directed to anyone under 18, and we do not knowingly collect their personal information. If you believe a minor has provided us with information, write to us and we will delete it.
14. Changes to this notice
We may update this notice. The version and the last updated date appear at the top. If a change materially affects how we use personal information we already hold about you, we will notify you by email or through the site before the change takes effect.
15. Contact
Edyn Financial Inc. 1900 Market Street, Philadelphia, Pennsylvania 19103 tillers@growedyn.com
If you need this notice in an alternative accessible format, write to us and we will provide one.