Capitalized terms used in this Privacy Policy have the same meanings as those defined in Terms of Use.
INTRODUCTION
1.1. This Privacy Policy (the “Policy”) explains how we collect, store, use, and disclose personal data. This Policy applies to the Website and the Services. By using visiting the Website, using the Services, or providing information to us, you consent to us collecting, storing, using, and disclosing information as described in this Policy.
1.2. Our processing of personal data adheres to the provisions set forth in the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation”, “GDPR”), UK GDPR and all relevant local data protection laws. All definitions and concepts used in this policy have the same meaning as in the GDPR.
YOUR ACCEPTANCE OF THIS POLICY
2.1. This Policy as well as Cookie Policy are part of the Terms of Use. Please read these three documents very carefully.
2.2. By accessing, visiting the Website, and/or registering account for using of the Services you are deemed to have read, understood and consented to the Policy and agreed to be bound by the Policy. The provisions contained in this Policy supersede all previous notices and statements regarding our privacy practices with respect to the Services. If you do not agree to all provisions of this Policy, you may not access, visit the Website and/or use the Services.
2.3. By registering an Account, you consent to the processing of your personal data by the Company in accordance with the provisions set below and to anonymize your personal data for the purposes of further use in anonymized form in order to improve the performance of the Service.
PRINCIPLES OF PERSONAL DATA PROCESSING
3.1 We are committed to protecting the privacy and security of personal data entrusted to us by you. In order to ensure transparency and compliance with applicable data protection laws and regulations, we adhere to the following principles of personal data processing:
3.1.1. Lawfulness, Fairness, and Transparency. We process personal data in a lawful, fair, and transparent manner. We ensure that Users are aware of the purposes for which their personal data is collected, used, and disclosed. We also inform Users about their rights and provide them with clear and easily understandable information about our data processing practices.
3.1.2. Purpose Limitation. We collect personal data for specified, explicit, and legitimate purposes, and we do not process personal data in a manner that is incompatible with those purposes. We only collect and use personal data to the extent necessary to fulfill the stated purposes and in accordance with the consent obtained, contractual obligations, compliance with legal obligations or legitimate interests pursued by the Company.
3.1.3. Data Minimization. We only collect and process personal data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed. We strive to minimize the amount of personal data we collect and retain, ensuring that the data is accurate, up-to-date, and necessary for the intended purposes.
3.1.4. Accuracy. We take reasonable steps to ensure the accuracy of personal data and keep it up-to-date. We rely on Users to provide accurate and complete information, and we provide mechanisms for them to update or correct their personal data when necessary.
3.1.5. Storage Limitation. We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law. When personal data is no longer needed, we securely delete or anonymize it to prevent unauthorized access or use.
3.1.6. Integrity and Confidentiality. We implement appropriate technical and organizational measures to protect personal data against unauthorized access, accidental loss, alteration, or disclosure. We maintain the confidentiality, integrity, and availability of personal data through physical, technical, and administrative safeguards.
3.1.7. Accountability. We take responsibility for our data processing activities and have implemented measures to ensure compliance with applicable data protection laws. We maintain records of our data processing activities, conduct regular assessments of our privacy practices, and provide training to our employees on privacy and data protection.
3.2 It is important to note that these principles guide our approach to personal data processing, and we continuously review and update our practices to ensure ongoing compliance with evolving legal and regulatory requirements.
WHAT DATA WE COLLECT AND WHY?
4.1. When using the Services, you agree to the processing of the personal data that the you provide to the Company your information as follows:
4.1.1. Account details. When creating an Account, you provide the Company with basic information for the purpose of providing Services, conducting marketing activities, and addressing inquiries related to the Services:
Email;
Project name.
4.1.2. Payment information. When you top up your internal balance or receive a refund via a payment service provider or virtual assets service provider, you provide the following information necessary for the purpose of performing such operations within the scope of Service provision, compliance with legal obligations, and fraud prevention:
Transaction Data;
Identification and verification data (like your name, email, phone number, address, signature, age, government ID and selfie for biometric verification);
Virtual assets wallet address.
4.1.3. Information Collected Automatically. When you visit the Website and use the Services, the Company may automatically collect certain information for the purpose of ensuring the proper functionality of the Website, optimizing the Website and Services, tailoring them to your needs, supporting marketing efforts, and complying with legal obligations.
IP address;
Location based on IP address;
Device identifiers;
Technical and statistical data;
Cookies and tracking data (see Cookie policy);
Interaction data like timestamps of events, page view statistics, referral URLs, ad data, transaction history, and web log information.
4.2. By providing information, including personal data to the Company, you warrant that such data is true, accurate, current, complete and up to date.
4.3. The Company does not knowingly collect any sensitive personal data or special categories of personal data.
4.4. The Company reserves the right to monitor or record interactions between Users and the support service for training purposes and to ensure high quality of service.
4.5. The Company reserves the right to record information when Users participating in surveys or focus groups such as insights and evaluation of the Company’s services and responses to the questions from the Company.
4.6. The Company undertakes not to access or use any personal data contained in the User Content, only in exceptional cases where it is necessary for the purposes of providing the Services, protecting the Company and users or fulfilling legal obligations.
ON WHAT BASIS DO WE PROCESS YOUR DATA?
The processing of personal data is based on the following lawful bases:
5.1. The processing of your personal data is necessary for the performance of the contract between you and the Company, including the provision of Services, account management, and customer support. The following data is processed under this legal basis:
- Account details;
- Payment information;
- Information Collected Automatically.
5.2. The Company processes your personal data to comply with applicable legal obligations, including tax, accounting, anti-money laundering, and fraud prevention requirements. The following data is processed under this legal basis:
- Payment information;
- Information Collected Automatically.
5.3. The Company processes your personal data based on its legitimate interests, provided that such processing does not override your rights and freedoms. This includes ensuring the functionality and security of the Website, improving the Services, and performing analytics. The following data is processed under this legal basis:
- Information Collected Automatically.
5.4. The Company processes your personal data based on your consent when required by law, specifically for marketing communications and optional cookies. You have the right to withdraw your consent at any time. The following data is processed under this legal basis:
- Email (for marketing communications);
- Certain Cookies (see Cookie Policy for details).
WHO AND WHY WE MAY DISCLOSE YOUR DATA?
6.1. We may disclose your personal data to our Affiliates and Subsidiaries. We may share information we collect within the Company’s group of companies to deliver Services to you, ensure a consistent level of service, and enhance our products, services, and your customer experience.
6.2. We may disclose your personal data to the service providers. The service providers are third parties whose services we use to operate and improve the Website and the Services, who supply software applications, provide data storage, customer support, web hosting, account management, authentication, verification tools, security, payment processing, legal services and other services and technologies for the Website and the Services, perform manage marketing and advertising activities by email, on other platforms and web pages. We will only provide these third parties with access to information that is reasonably necessary to perform their duties or to comply with the law. Those third parties will never use such information for any other purpose except to provide services in connection with the Website and the Services. Providing these services, the service provider shall abide by the present Policy, relevant legislations in force, and the provisions of the existing contracts of the Company. The list of the service providers (processors) is following:
Stripe (Stripe Payments Europe Limited (Ireland), payment provider).
Postmark (AC PM LLC (US), email communications service).
Mailchimp (Intuit Inc. (US), Intuit Limited, Credit Karma UK Limited (UK), Intuit France SAS (France), marketing and automation service).
6.3. We may disclose your personal data for the purpose of protection of the Company and others. By using the Services, you acknowledge and agree that we may access, retain and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary:
for any legal proceedings;
to enforce our Terms of Use, this Policy, Cookie Policy or other contracts with you, including investigation of potential violations thereof;
to respond to claims that any content violates the rights of third parties;
to respond to your requests for customer service; and/or
to protect the rights, property or personal safety of the Company, its agents and affiliates, its users and/or the public.
6.4. We may disclose your personal data in scope of business transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), user information may be among the transferred assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
6.5. From time to time, we may share aggregate/anonymous information about use of the Services, such as by publishing a report on usage trends. The sharing of such data is unrestricted.
CROSS-BORDER DATA TRANSFERS
7.1. We store personal information about you on our servers in the EU. However, as part of our services providers is outside EU, EEA and UK, your personal information may be processed by recipients outside of the EU in countries, which is not subject to an adequacy decision by the European Commission and which does not provide for the same level of data protection as in the EU. In this event, we will ensure that the recipient of your personal information offers an adequate level of protection, for instance by entering into Standard Contractual Clauses for the transfer of data as approved by the European Commission (Article 46 GDPR). This way, if we transfer personal data collected from Users located within the EU to a third-party acting as a data processor, such third-party processes your personal information in a manner consistent with the GDPR.
LINKS TO THIRD-PARTY WEBSITES
When you use the Services, you may be directed to other Websites and applications that are beyond our control. We may also allow third-party websites or applications to link to the Website. We are not responsible for the privacy practices of any third parties or the content of linked websites and applications, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties, websites, and applications. This Policy only applies to the Website and the Services.
HOW DO WE SECURE AND RETAIN DATA?
9.1. We have implemented reasonable technical and organizational precautions to protect the confidentiality, security and integrity of your personal information from accidental or unlawful destruction, loss, alteration, disclosure, or unauthorized access.
9.2. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
9.3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9.4. Regarding the nature of the Internet connections, we cannot guarantee the security of information transmitted to us over the Internet.
9.5. We only store your information for as long as necessary to serve the purpose of the processing, basically it is the duration of subscription. We delete it or block access to it as soon as such purpose ceases to apply. If your Account terminated, we retain your data for 30 days in order to complete all outstanding transactions or restore your Account.
9.6. Furthermore, information may be stored if this has been provided for by the applicable law. The data will also be blocked or deleted if a storage period prescribed by the applicable law expires, unless there is a need for further storage of the data for the conclusion or fulfilment of a contract.
YOUR RIGHTS
10.1. If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Information” section below at any time.10.2. You have the following rights under the applicable data protection laws:
Information and Access. The right to know whether your personal data is being processed, right to get information regarding processing of personal data, right to request a copy of personal data being processed. The right to information about public and private entities with which we have shared data.
Rectification (correction).The right to correct your personal data in a situation when such data available to us or disclosed to third parties is inaccurate or incomplete.
Erasure. The right to request deletion of your personal data from our database so that we are not able to continue processing and storing of such data, with exceptions, provided in applicable law.
Restrict processing. The right to introduce the restriction regime on the processing of your personal data, including prevention the processing of your information for direct-marketing purposes (e.g. any direct marketing processing based on profiling);
Data portability. The right to request for the personal data to be given in a machine-readable format so that it could be transferred to another service provider or transfer directly to a third party designated by you.
Object. The right to object to processing of your personal data in a case when the corresponding processing is not performed on the basis of your consent.
Withdraw consent. Right to withdraw consent to processing of your personal data by us or third parties to which we have previously disclosed your personal data.
10.3. We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.
10.4. You may instruct us not to use your contact information to contact you by email regarding products, services, promotions and special events that might appeal to your interests by contacting us using the information below. In commercial email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and share certain information as permitted by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you, or important notifications regarding courses, classes in which you are enrolled.
10.5. You also have a right to lodge a complaint with the data protection authority. Please find the contact details of EU data protection authorities below:https://www.edpb.europa.eu/about-edpb/about-edpb/members_en. However we would appreciate the chance to deal with your concerns before you approach the data protection authority.
CHANGES TO THIS POLICY
We may update or modify this Policy from time to time at our sole discretion and will alert you that changes have been made by indicating on the Policy the date it was last updated at the top of this Policy, prominently posting an announcement of the changes on the Website, or by sending you a written communication using the contact information you provided us prior to the new policy taking effect. Users are bound by any changes to the Policy if they visit the Website and/or using the Services after notice of such changes has been communicated. We encourage you to review this Policy regularly to ensure that you are familiar with the Company's current practices.
CONTACT INFORMATION
If you have any questions about this Privacy Policy or if you want exercise your rights, you can contact us by email: support@granite.so or via the Website: https://granite.so/support
PRIVACY NOTICE FOR BRAZIL RESIDENTS
The terms of this Privacy Notice apply to residents of Brazil under the Lei Geral de Proteção de Dados (Lei nº 13.709, de 14 de agosto de 2018) and its implementing regulations, as amended or superseded from time to time (“LGPD”). For the purposes of this Privacy Notice, Personal Information has the meaning as defined in the LGPD.
In addition to rights provided in Privacy Policy, the LGPD provides residents of Brazil with certain legal rights. To exercise these rights, contact us. These rights are not absolute and are subject to exemptions. In particular, you have the right to:
- Ask whether we hold personal information about you and request copies of such personal information and information about how it is processed.
- Restrict the processing of your personal information that is not being processed in compliance with the LGPD.
- Obtain information on the possibility of refusing consent and the consequences of doing so.
- Obtain information about the third parties with whom we share your personal information.
- Obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in Art. 16 of the LGPD apply.
- Revoke your consent at any time.
- Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law.
PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Privacy Notice for California Residents (this "Privacy Notice") supplements the information contained in Privacy Policy and applies solely to all visitors, users and others who reside in the State of California ("consumers", "you" or "your"). We adopt this Privacy This Notice to comply with the California Consumer Privacy Act of 2018 ("CCPA") and any terms defined in the CCPA have the same meaning when used in this Privacy Notice. All capitalized terms not herein defined will have the meaning set forth in the Company’s Privacy Policy. In case on any inconsistencies with Company’s Privacy Policy, this Privacy Notice shall prevail.
INFORMATION WE COLLECT
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device ("personal information"). In particular, we have collected personal information as provided in Section 4 of Privacy Policy from our consumers within the last twelve (12) months.
Personal information does not include:
- Publicly available information from government records
- De-identified or aggregated consumer information,
- Information excluded from the CCPA's scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, from information our clients provide to us related to the Services for which they engage us.
- Directly from you when you provide it to us. For example, if you share your name and contact information to ask a question about our Website or Services.
- Indirectly from you. For example, from observing your actions on our Website.
- From third parties, for example, our service providers.
USE OF PERSONAL INFORMATION
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our Website or Services we will use that personal information to respond to your inquiry.
- To provide, support, personalize and develop our apps and products.
- To process your requests and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To notify you about changes to our Website or Services we offer or provide through it.
- To notify you about changes to our policies and/or user agreements.
- To maintain a record of our dealings with you.
- To understand and analyze the usage trends and preferences of our users, to improve Website and Services and to develop new features, and functionality.
- To contact you for administrative and information purposes - this may include providing customer service or sending communications, including changes to our terms of use.
- To engage features of third party social networks.
- For testing, research, analytics and product development.
- To help maintain the safety, security, and integrity of our Website, Services, and our databases, other technology assets and business.
- To diagnose or fix technological problems in relation to our Website or Services.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
- To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
SHARING PERSONAL INFORMATION
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the personal information as provided in Section 4 of Privacy Policy for a business purpose.
We disclose your personal information for a business purpose to the following categories of third parties:
- Our affiliates.
- Service providers.
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
- Law enforcement bodies and courts.
We share your personal information for the following general purposes:
- Service Providers: We may disclose personal information to third-party service providers that assist us with our operations. For example, analytics, log management, payment processing and data storage and processing services.
- Protecting our Rights: We may disclose personal information to third parties if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.
- Corporate Transaction: Personal information may be disclosed as part of a corporate transaction, such as a merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.
In the preceding twelve (12) months, we have not sold any personal information.
YOUR RIGHTS AND CHOICES
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights Section), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting and selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed your personal information for a business purpose, a list with disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Data Deletion Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights Section), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code В§ 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Rights Exercising
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us as provided in Section 12 of Privacy Policy. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are a California resident, you have the right to direct us to not sell your personal information at any time (the "right to opt-out").
We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt-in") from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a variable notice as provided in Section 12 of Privacy Policy.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.
NON-DISCRIMINATION
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
CHANGES TO OUR PRIVACY NOTICE
We reserve the right to amend this Privacy Notice in same way as the Privacy Policy