(Last Updated April 15, 2024)
This Privacy Policy (the “Policy”) applies to personal data Grin processes when providing our services, including various Grin websites, such as https://grin.co and https://app.grin.co, applications, ads, communications, and other instances where we link to this Policy (collectively “Services”). Any term not defined in this Policy has the meaning set forth in our Terms of Use. As used in this Policy, the word “including” means “including but not limited to.”
Through our Services, we process data about three types of users:
Depending on the Services we provide to you and how you interact with us, we may collect, use, store, and transfer different kinds of personal data about you. You aren’t required to provide us with personal data. However, if you don’t share certain data with us, we may not be able to provide you with our Services or respond to your requests.
We May collect and process the following categories of Personal data:
| Personal Data Category | Example of Personal Data in the Category | Applicable US State Law Data Category |
| Call Recordings and Call Transcripts | Audio and visual content from audio or video calls with Grin. | Audio information |
| Contact Data | email address, postal address, billing address, and telephone number | Identifiers |
| Communications Data | email message bodies, subject lines, attachments, metadata, and headings; online chat, and text messages | Sensitive Personal Information |
| Creator Data | Social media and content-sharing platform accounts and links (e.g., Facebook, Twitter, Instagram, Snap, YouTube, Vimeo, and Pinterest), including any access to your accounts that you authorize, including messages, drafts, posts, analytics, etc., as well as any content posted and made publicly available on such platforms. | Internet or other electronic network activity information |
| Financial and Transaction Data | Payment method details, payment history, and other financial and billing information. | Commercial information |
| Identity Data | First name, last name, date of birth, job title, organization | Identifiers |
| Profile Data | Purchase history, product interests, preferences, feedback, and survey responses. | Commercial information |
| Technical Data | IP address, cookie identifiers, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, logs, | Internet or other electronic network activity information |
| Usage Data | Clicks to, through, and from our Services (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. | Internet or other electronic network activity information |
Third-Party Services
This 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 Grin Services may link or otherwise reference (collectively “TPS”) that you may access through the Services.
We may use your personal data to enable our advertising.
We may send service-related and promotional communications to our users. We may also send promotional communications to prospective users and customers to inform them about our Services.
If you use our chat feature, we and our service providers may record your chats and keep transcripts. If you talk to us on the phone, we may record your phone calls.
Unless you choose to delete your account, you cannot unsubscribe from certain communications that are required as part of your use of our services (e.g., communications about changes to this Policy.)
If you provide us access to your email data by connecting your email account to our Services, our use of your email data will be subject to these additional restrictions:
Customer Relationship Management
We will utilize your personal data to facilitate your customer relationship with us. This includes providing customer support, managing and troubleshooting your account, executing contracts, billing, etc.
Facilitate Contracts
If you connect with another user on our Services, we may process your personal data to facilitate your contractual relationship with the other user. This includes managing contracts and other documentation.
Fraud Detection & Prevention
We monitor use of the Services to detect fraud, abuse, and violations of our Terms. We may actively or passively monitor Services activity, including communications, transactions, and usage.
Grin Brand and Creator Services
We process data to make the Grin Services available to you. This includes personal data used to manage your account and profile on the Services, provide the Services’ features, and fulfill our contractual relationship.
If you connect your social media account to your Grin account, you may authorize us to access aspects of your social media account, including your messages, drafts, posts, analytics, etc.
Grin Potential Creator Services
In some instances, we process personal data about Potential Creators. We source public information about Potential Creators to make it available to our Brand Customers so they can identify creators for their brand deals. This benefits Potential Creators, who gain visibility for potential business, and our Brand Customers who gain access to additional creators who may create or advertise content for them. This is considered a “sale” of personal data under applicable law.
Payments (sent and received via Grin)
When you utilize the Services to send or receive payments between you and other users, we process your data to facilitate these transactions.
Registration
You will need to create an account and provide personal data to access most of our services. If you register for or purchase our Services, we use your personal data to create a Grin account for you.
Service Improvements
We may use your data for data analytics to improve our Services. This may include data you explicitly provide as well as data we collect via cookies, pixels, tags, beacons, and other technologies.
We also collect and share personal data with third-party service providers acting on our behalf, including providers of analytics services that may record or log your activities on our services, including text you enter, pages you visit, and features you interact with. By using our Services, you agree to this data processing and sharing.
| Purpose/Activity | Categories of Personal Data | Source of Personal Data Categories | Categories of Third Party we Share Data with | Legal Basis for Processing |
| Registration | (a) Identity (b) Contact (c) Influencer | Brand Customers, Creator Customers | Performance of a contract | |
| Payments (sent and received via Grin) ) | (a) Identity (b) Contact (c) Financial (d)Transaction | Brand Customers, Creator Customers | Performance of a contract | |
| Facilitate Contracts | (a) Identity (b) Contact (c) Creator | Brand Customers, Creator Customers, Third-Party Data Providers | Performance of a contract | |
| Communications with Grin | (a) Identity (b) Contact (c)Call Recordings | Brand Customers, Creator Customers, Third-Party Data Providers | (a) Performance of a contract, where we have a direct relationship with you (b) Necessary for our legitimate interests (for marketing and promoting our Services) where we do not have your consent or a direct relationship with you (c) Consent, only where you have consented to receive promotional communications | |
| Communications with Third Parties via Grin | (a) Identity (b) Contact | Brand Customers, Creator Customers, Third-Party Data Providers | Performance of a contract | |
| Customer Relationship Management | (a) Identity (b) Contact (c)Transaction (d) Profile (e)Call Recordings | Brand Customers, Creator Customers | (a) Performance of a contract (b) Necessary to comply with our legal obligations | |
| Grin Brand & Creator Services | (a) Identity (b) Contact (c)Technical (d)Transaction (e) Profile | Brand Customers, Creator Customers, Third-Party Data Providers | (a) Performance of a contract, where we have a direct relationship with you (b) Necessary for our legitimate interests where we don’t have a direct relationship with you | |
| Grin Potential Creator Services | (a) Identity (b) Contact (c) Creator | Third-Party Data Providers | ||
| Service Improvements | (a) Technical (b) Usage (c) Profile (d) Creator | Brand Customers, Creator Customers | Necessary for our legitimate interests (to define types of customers for our products and services; to keep our Services updated and relevant and ensure that content is presented in the most effective manner for you and for your device; to develop our business and to inform our marketing strategy) | |
| Fraud Detection & Prevention | (a) Identity (b) Contact (c) Financial (d) Transaction | Brand Customers, Creator Customers | Necessary for our legitimate interests (for detecting and preventing fraud) |
We may share information with service providers (also known as third-parties) who perform services on our behalf. Those companies will be permitted to obtain only the personal data they need to provide services to us, will be required to maintain the confidentiality of the information, and will be prohibited from using it for any other purpose unless permitted by law.
We may disclose personal data if we believe in good faith the disclosure is necessary in order to:
We may also disclose personal data in a reorganization or sale of our company or assets, subject to the acquirer and its affiliates (as applicable) accepting the commitments made in this Policy and compliance with applicable law.
Data Security
While we endeavor to maintain physical, electronic, and procedural safeguards to protect the personal data that we collect, we cannot guarantee its absolute security.
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 | These 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 | For example, we use Google Analytics to understand traffic on our Services. 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 use 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 not respond to do not track signals.
Cookies
For further information on cookies (including how we use them, when we will request your consent before placing them, and how to disable them), please see our detailed Cookie Notice, which includes a list of all cookies on our services and instructions for updating your cookie preferences.
International transfers of your information
The data we process is hosted, controlled, and services are provided by Grin Technologies Inc., including, where applicable, outside of the European Economic Area (EEA), Switzerland, and the UK, including in the United States. Your personal data may be transferred to or accessed by entities around the world, including Grin-affiliated companies and our services providers, to perform processing activities such as those described in this Policy. Grin complies with laws on the transfer of personal data between countries to help ensure your data is protected, wherever it may be.
Anonymized, Aggregate, and De-Identified Data
We may anonymize, aggregate, and/or otherwise de-identify your data and subsequently use and/or disclose such data for the purpose of research, improving our services, or for another business purpose authorized by applicable law, provided that we have implemented technical and contractual safeguards and business processes designed to prevent the re-identification or inadvertent release of anonymized, aggregate, or de-identified data.
Automated Decision-Making
We do not use algorithms or profiling to make any decision that would have a significant legal effect on you without the opportunity for human review.
How long we keep your information
We keep your personal data only so long as we need it to provide or offer our Services to you and fulfill the purposes described in this Policy. Retention periods can vary significantly based on the type of data and how it is used. Our retention periods are based on criteria that include legally mandated retention periods, pending or potential litigation, our intellectual property or ownership rights, contract requirements, operational directives or needs, the expected lifetime of our users’ use of our services, and historical archiving. When we no longer need to use your personal data and there is no need for us to keep it to comply with our legal or regulatory obligations, resolve disputes, and enforce our agreements, we’ll either remove it from our systems or, anonymize, aggregate, or de-identify it so that we can’t identify you.
Privacy of Minors
Our Terms require that Users be (i) 18 or older, or (ii) 13 and older if either (a) an emancipated minor, or (b) they possess legal parental or guardian consent. Grin does not knowingly collect personal data from users under 13. In the event that we learn that we have collected any personal data from a user under the age of 13, we will attempt to identify and delete that information from our database. If you believe that a child under the age of 13 has provided personal data to us, please contact us.
Depending on where you live, you may have certain rights for controlling your personal data. You may avail yourself of your rights by contacting us using the contact methods described at the end of this Policy.
Access/Portability: In certain jurisdictions, you may request certain copies of your personal data held by us. You may also be entitled to request copies of personal data that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this data to another service provider (where technically feasible).
Erasure/Deletion: In certain jurisdictions, you may request to have your personal data deleted. Please note that if you request the erasure of your personal data:
Withdrawing Consent and Restriction/Objection to Processing: In certain jurisdictions, if we are processing your personal data 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.
Rectification of Inaccurate or Incomplete 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 TPSl, you may change your settings and remove permission for the TPS app by changing your account settings.
You may also have the right to ask us to correct inaccurate or incomplete personal data about you.
Updates to this Privacy Policy
We reserve the right to update this Policy at any time. When we make changes, we will revise the “last updated” date at the top of the policy. If there are changes to the Policy that we believe materially reduce your rights or increase your responsibilities, we will notify you by prominently posting a notice of such changes here or on our home page, and/or by sending you an email. We encourage you to review this Policy whenever you use our Services.
How to contact us
For questions, to avail yourself of a privacy right, or to lodge a complaint, email us at privacy.support @ grin.co, or by mail to Grin Data Inquiries, 901 H St Ste 120, Sacramento, CA 95814.
