Privacy Policy (US)

Grin, Inc. (https://grin.co and https://app.grin.co), as well as any present or future affiliated or related application, website or company (collectively “Grin” or “we”), recognizes the importance of your privacy. This privacy policy tells you what personal information we collect and how we use it. Grin may change this privacy policy from time to time, in its sole discretion, as discussed in section 7 below. By using or visiting any Grin website, application, product, software, tool, data feed, and/or service (collectively the “Service”), you understand and agree to the terms of this privacy policy.  

1. What Information Do We Collect?

– Personally-IdentifiableInformation: We may collect personally identifiable information when you specifically and knowingly provide it to us, for example when you request support, or register and provide personal information such as your e-mail address, name, phone number, year of birth, or other information. Where applicable, personally identifiable information includes “personal data”, “personal information” and/or “sensitive personal information” each as defined in applicable law. We ask that you not send us, and you do not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through Services or otherwise. If you do send or disclose any sensitive personal data to us, you consent to our processing and use of such sensitive personal data in accordance with this Policy.

This privacy policy does not apply to the privacy practices of third parties that we do not own or control, including but not limited to any third party websites, services, applications, online resources to which this Site may link or otherwise reference (collectively “Third Party Services” or “TPS”) that you may access through the Services. For example, the Services utilize the YouTube API Services as a TPS, and you are agreeing to be bound by the YouTube Terms of Service (https://www. youtube.com /t/terms), Privacy Policy (https://policies.google.com/privacy?hl=en-US), and API Services Terms of Service (https://developers.google.com/youtube/terms/api-services-terms-of-service) when engaging YouTube content and services through the Service. We take no responsibility for the content or privacy practices of any TPS. We encourage you to carefully review the privacy policies of any TPS you access.

You may have the option to register using a TPS or connect your account to a TPS such as Instagram, Facebook, Twitter or YouTube. By authorizing us to access your TPS account, you understand that we may obtain certain information from your TPS account, you authorize us to obtain certain information from your TPS account, which may include your name, email address, birthday, work history, education history, current city, shared media, and the names, profile pictures, relationship status, and current cities of your TPS contacts. We only obtain information from your TPS account that you specifically authorize and grant us permission to obtain.

Grin does not consider personally identifiable information to include information that has been anonymized so that it does not allow a third party to easily identify a specific individual. We collect and use your personally-identifiable information to: provide the Services; operate and improve our Service; provide customer service; perform research and analysis aimed at improving our products, Service and technology; and display content that is customized to your interests and preferences.

You may always choose not to provide personally identifiable information, but if you so choose, certain parts of the Service may not be available to you. If you have registered an account with us, you will have agreed to provide your personally identifiable information in order to access the Services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this privacy policy, please do not use our Services.

– SensitivePersonalData: Subject to the following paragraph, we ask that you not send us, and you not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

If you send or disclose any sensitive personal data to us when you submit content to the Services, you consent to our processing and use of such sensitive personal data in accordance with this privacy policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to us.

– Non-Personally-IdentifiableInformation: We may collect and aggregate non-personally identifiable information which is information which does not permit you to be identified or identifiable either by itself or in combination with other information available to a third party. This information may include information, such as a website that referred you to us, your IP address, browser type and language, log data, hardware types, geographic location, and access times and durations. We also may collect navigational information, including information about the Service content or pages you view, the links you click, and other actions taken in connection with the Service.

– Cookies,PixelsandLocalStorage: We may collect information using “cookies”, which are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience when using the Services.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits any site or application that is party of the Services; and (2) third party cookies, which are served by service providers on sites or applications and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

Cookies we use

The Services use the following types of cookies for the purposes set out below:

Type of cookie Purpose	Information
Essential Cookies	These cookies are essential to provide you with services available through the Services and to enable you to use some of its features. For example, they allow you to log in to secure areas of the sites or applications and help the content of the pages you request load quickly.  Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
Functionality Cookies	These cookies allow the Services to remember choices you make when you use a site or application, such as remembering your language preferences, remembering your login details and remembering the changes you make to other parts of your account, or preferences. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you use the Services.
Analytics and Performance Cookies	hese cookies are used to collect information about traffic to the Services and how users use the Services. The information gathered does not identify any individual and visitor. The information is aggregated and anonymous. It includes the number of visitors to, the websites that referred them, the pages visited, what time of day they Performance visited, whether they have visited before, and other similar information. We use this information to help operate the Services more efficiently, to gather broad Cookies demographic information and to monitor the level of activity on our Services.
Social Media Cookies	We use Google Analytics for this purpose. Google Analytics uses its own cookies. It is only used to improve how the Services work. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage/.

Disabling cookies

You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. If you do not accept our cookies, you may experience some inconvenience in your use of the Services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you use the Services

Pixel Tags 

We may also use pixel tags (which are also known as web beacons and clear GIFs) on the Services to track the actions of users on our sites and applications. Unlike cookies, which are stored on the hard drive of your computer or mobile device by a website, pixel tags are embedded invisibly on webpages. Pixel tags measure the success of our marketing campaigns and compile statistics about usage of the Services, so that we can manage our content more effectively. The information we collect using pixel tags is not linked to our users’ personal data.

Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do respond to do not track signals. To find out more about “Do Not Track,” please visit https://allaboutdnt.com/.

2. What Do We Do With The Information That We Collect?

Except as disclosed in this privacy policy, Grin does not share your personal information with any outside parties.

Additional Limits on Use of Your Google User Data: Notwithstanding the foregoing or anything else in this privacy policy, if you provide us access to your Google data, our use of that data will be subject to these additional restrictions:

We may share this information with service providers who perform services on our behalf, such as processing information requests, displaying stored data you access, to assist us in marketing, to conduct audits, etc. Those companies will be permitted to obtain only the personal information they need to provide the service they provide, will be required to maintain the confidentiality of the information, and will be prohibited from using it for any other purpose.

We may also use information you provide to better serve you, and, if you have given your consent for us to do so, to send you email or text messages concerning offers from our partners and other third parties that we think may be of interest to you. If you do not wish to receive marketing emails, you may adjust your “Personal Information Preferences” as described below or follow the “unsubscribe” or “stop” instructions included within each communication.

We will only retain your personally identifiable information as long as reasonably required to provide you with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes). Data collected via the YouTube API will be retained for a maximum of 30 days unless required to provide you with the Services or a longer retention period is required by law. 

You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) our collection of sensitive personal data; (iii) any new processing of your personal data that we may carry out beyond the original purpose; or (iv) the transfer of your personal data outside the EEA. Please note that your use of some of the Services may be ineffective upon opt-out. You may also: (A) access the data we hold about you at any time via your account or by contacting us directly; (B) update or correct any inaccuracies in your personal data by contacting us; (C) move your data to other service provider; (D) in certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data. You may contact us at [email protected] anytime for any other questions you may have about your personally identifiable information and our use of it.

– Disclosure:  As a general rule, Grin will not disclose any of your personally identifiable information except under one of the following circumstances: we have your permission; we determine in good faith that it is legally required to be revealed by any relevant statute, regulation, ordinance, rule, administrative or court order, decree, or subpoena; it is information that we determine must be disclosed to correct what we believe to be false or misleading information or to address activities that we believe to be manipulative, deceptive or otherwise a violation of law; where you are otherwise notified at the time we collect the data; where we need to share your information to provide the product or service you have requested; when such disclosure is made subject to confidentiality restrictions in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by Grin. Grin may share the non-personally identifiable information that Grin gathers, in aggregate form only, with advertisers and other partners.

3. Your Rights

Consistent with applicable law, you may exercise any of the rights described in this section. See here for information on personal data rights requests and how to submit a request. Please note that we may ask you to verify your identity and request before taking action on your request.

Managing Your Information.

If you have an Account, you may access and update some of your information through your Account settings. If you have connected your Account to a TPS you can change your settings and remove permission for the TPS app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information about you (and which you cannot update yourself within your Account, if any).

Data Access and Portability.

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. In certain jurisdictions, you can request to have all your personal information deleted entirely. Please note that if you request the erasure of your personal information:

If we are processing your personal information based on your consent you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing pursuant to the next section and pending the verification whether our legitimate grounds override your own.

Objection to Processing.

In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to [email protected].

Lodging Complaints.

You have the right to lodge complaints about our data processing activities by filing a complaint with us via the “Contact Us” section below or with a supervisory authority.

4. Children’s Policy

The Terms of Service clearly provide that Users must be (i) 18 or older, or (ii) 13 and older if either (a) an emancipated minor, or (b) he/she possess legal parental or guardian consent. Grin does not knowingly collect personally identifiable information from users under 13.  In the event that we learn that we have collected any personal information from a user under the age of 13, we will attempt to identify and delete that information from our database. 

5. International Usage

The Service is owned by Grin and may be accessed in the United States and abroad. For data protection purposes, Grin is the controller and, unless otherwise noted, is also the processor of data. Information collected may be retained, and may be stored, processed, accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction.  If you are located outside of the United States, please note that the information you provide to us may be transferred to the United States. By using the Service, application and/or website, you consent to such transfer. We will take reasonable steps to ensure that your data is treated securely and in accordance with this privacy policy.

6. California Privacy Rights

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, “California Law”), grants certain rights to California residents to know about, collect, or delete the personal information that we have collected about them, to opt-out of the sale or sharing of their personal information by us to a third party, and not to be discriminated against for exercising these rights.

California residents have the right to know what personal information Grin collected, used, disclosed, and shared, and sold about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom Grin discloses personal information, and the specific pieces of personal information Grin has collected about you, within the preceding 12 months. Once we receive your request and confirm your identity and California resident status, we will disclose to you the information that we have collected about you, as required by California Law.  Please note that we are only required to honor requests to know twice in a 12-month period.

California residents have the right to request the deletion of their personal information that we collect or maintain. Once we receive your request and confirm your identity and California resident status, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. Such exceptions include, but are not limited to, when the personal information is necessary to complete a transaction or provide goods or services to you, detect security incidents, comply with the law, and for internal uses reasonably aligned with your expectations.

California residents have the right to request the correction of inaccuracies in their personal information, taking into account the nature of the personal information and the purposes for which Grin processes it.  Once we receive your request and confirm your identity and California resident status, we will use commercially reasonable efforts to correct inaccurate personal information in our records. 

California residents have the right to opt-out of the selling or sharing of their personal information, which can be done by following the directions below.  California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information Grin has “sold” or “shared” about you, and you have a right to opt-out of such sale or sharing. In addition, and as set forth below, California Law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have “sold” or “shared” about you. For the 12-month period prior to the date of this Privacy Policy, Grin has not sold any personal information about its customers. For the 12-month period prior to the date of this Privacy Policy, Grin has only shared personal information about its customers as described above.

California Residents have the right not to receive discriminatory treatment if and when they exercise their rights to know, delete, correct, or opt-out under California Law.

This means Grin cannot, for example: deny goods or services to you; charge different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties; provide a different level or quality of goods or services to you; or suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to you by your personal information.

In order to exercise your “knowledge”, “deletion”, “correction”, and/or “opt-out” rights, you may submit a request as provided in the Contact Us” section below.  

We will endeavor to honor such requests unless such a request conflicts with certain lawful exemptions under California’s consumer privacy law.  We may also verify your status as a California resident. We aim to respond to a verifiable request within 45 days of its receipt. If we need more time to respond to your request (up to 45 additional days), we will inform you in writing.

We will retain your information for no longer than is reasonably necessary to provide your services, comply with our legal obligations, resolve disputes, and enforce our agreements.  We retain your personal information for the period you are actively using our services plus six (6) years.

California- Direct Marketing Information

Under California Civil Code Section 1798.83 (the “Shine The Light” law), customers who are California residents and have a relationship with Grin primarily for personal, family, or household purposes are entitled to receive, upon request and free of charge, information about the personal information (if any) we disclosed to third parties for their direct marketing purposes in the prior calendar year. This information may be requested once a year. If applicable, this information will include a list of the categories of personal information that was shared and the names and addresses of the third parties that received the information. If you are a California resident and want to make a request for this information, please submit your request as provided in the Contact Us” section below (please reference the “Shine The Light Law” in your email or letter).

Privacy Policy for California Residents 

Under California Civil Code Section 1789.3, California users are entitled to the following consumer notice: If you have a question or complaint regarding the websites, please see the “Contact Us” section below for where to send such questions or complaints.

7. Security and Encryption

We follow generally accepted industry standards to help protect your personal information. No method of transmission over the internet, mobile technology, or method of electronic storage, is completely secure. Therefore, while we endeavor to maintain physical, electronic, and procedural safeguards to protect the confidentiality of the information that we collect online, we cannot guarantee its absolute security. Our Service has security measures in place designed to protect against the loss, misuse and alteration of the information under our control. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All Service information is maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords. You are responsible to keep your password secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at [email protected].

8. Changes to This Policy

We reserve the right to change the terms of this privacy policy at any time. When we make changes, we will revise the “last updated” date at the top of the policy. If there are material changes to this statement or in how we will use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. We encourage you to review this policy whenever you visit one of our websites or applications.

9. Contact Us

For general inquires or to lodge a complaint, email us at [email protected], or by mail to Grin Data Inquiries, 400 Capitol Mall 9th Floor, Sacramento, CA 95814. To opt-out of use of your data for direct marketing, email us at [email protected].

To deactivate your account, go to your Account, click Settings, and then click Deactivate my account.  

Deactivating an Account and an Account deletion request are two different things. When you choose to deactivate your account, you can reactivate it at a later date if you wish; when you delete your Account, no deleted information can thereafter be recovered. You can request permanent deletion of your personal data and closure of your Account at any point by submitting a deletion request to [email protected]. We may ask you to verify your identity before taking action on your request. Please include the subject line “Personal Data Right Request – Deletion Request”, and your country of residence.

To access your data, you can visit the Dashboard of your Account. If you would like to get a copy of some or all of the personal data we hold about you pursuant to applicable law, you can send us an email to [email protected]. Please note that we may ask you to verify your identity before taking further action on your request. Please include the subject line “Personal Data Right Request – Access Request”, provide us your country of residence, and provide as much information as you have regarding the data you would like a copy of.

To exercise a right to portability under applicable law, please email us at [email protected] and include the subject line “Personal Data Right Request – Portability Request” and your country of residence.

To object to our processing of some of your personal data where allowed under the laws of the jurisdiction where you reside, you may request that we not process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing, we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or such processing is required for the establishment, exercise, or defense of legal claims. You may exercise your rights to object to processing by sending us an email to [email protected]. Please include the subject line “Personal Data Right Request – Processing Objection” and your country of residence.

© 2023 Grin, Inc.  All rights reserved.