Privacy Policy

Effective Date: January 26, 2025

GRITS & Company, LLC (“GRITS,” “we,” “our,” or “us”), a company registered in Delaware, is committed to protecting your privacy. This Privacy Policy (the “Policy”) outlines how we collect, use, disclose, and protect your personal information when you access or use our platform, including the JoinGrits.com website (the “Website”), associated mobile applications (the “Application”), and any related services, features, or content (collectively, the “Platform”).

By using our Platform, you agree to the terms outlined in this Policy. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately. Please read this Policy carefully and contact us at info@joingrits.com if you have any questions.

1. INFORMATION WE COLLECT

We collect both personal and non-personal information about you to provide and improve our services.

Personal Information

“Personal Information” refers to data that identifies you as an individual, including:

Name, email address, phone number, and photograph.
Location, age, and gender.
Payment details (excluding full credit/debit card numbers).

Sensitive Personal Information

This includes information such as:

Passwords and financial data (e.g., truncated card details).
Government identifiers (e.g., Social Security number, driver’s license).
Biometric data, health information, race, ethnicity, and political or religious affiliations.

Non-Personal Information

We may collect non-identifiable data, such as:

Browser type, operating system, and device information.
Referring site and access timestamps.
General usage data through cookies or similar technologies.

2. How We Use Your Information

We use your information for the following purposes:

To Provide Services: Enable access to the Platform, fulfill transactions, and provide customer support.
To Improve the Platform: Analyze user behavior to enhance functionality and user experience.
To Communicate with You: Send updates about your account, offers, or new services (with the option to opt-out).
To Ensure Security: Detect and prevent fraud, misuse, or other harmful activities.

3. Sharing of Information

We do not sell, trade, or rent your Personal Information to others. However, we may share your information:

With trusted service providers who assist in operating the Platform.
In response to legal obligations, such as court orders or law enforcement requests.
To protect our rights, safety, and property or that of others.

We may also share anonymized or aggregated data that cannot be used to identify you.

4. Your Choices

Control the Information You Provide: You may update or delete your Personal Information through your account settings.
Manage Communications: Opt out of marketing emails by clicking “unsubscribe” in our communications.
Reject Cookies: Adjust your browser settings to refuse cookies, though some Platform features may be unavailable.

5. Your Rights

Depending on your location, you may have specific rights under applicable data protection laws, including:

Right to Access: Request a copy of the Personal Information we hold about you.
Right to Correct: Update incomplete or inaccurate information.
Right to Delete: Request deletion of your data, subject to legal or operational obligations.
Right to Restrict Processing: Limit how your data is used in certain circumstances.

To exercise these rights, please contact us at info@joingrits.com.

6. Data Security

We take reasonable precautions to safeguard your Personal Information from unauthorized access, alteration, or destruction. This includes limiting access to your information to employees or contractors who need it to provide services.

7. Cross-Border Data Transfers

Your information may be stored and processed in the United States or other countries where we or our service providers operate. By using our Platform, you consent to the transfer of your information outside your country of residence, subject to applicable data protection laws.

8. Data Retention

We retain your Personal Information for as long as necessary to provide our services, comply with legal obligations, and resolve disputes. Publicly shared content (e.g., comments or reviews) may remain visible on the Platform but will be anonymized where required.

9. Third-Party Links

Our Platform may include links to external websites. We are not responsible for the privacy practices or content of third-party sites. Please review their policies before sharing your information.

10. Changes to This Policy

We may update this Policy from time to time. Any changes will be posted on this page with the updated effective date. Continued use of the Platform after updates constitutes your acceptance of the revised Policy.

11. Contact Us

For questions, concerns, or to exercise your rights, contact us at:
GRITS & Company, LLC
Email: info@joingrits.com

COUNTRY SPECIFIC ADDITIONAL RIGHTS

TERMS APPLICABLE IF YOU ARE AN INDIAN RESIDENT

Your Rights: If you are located in India, you may have the following rights under the Personal Data Protection Bill (PDPB) when it becomes a legislation. All requests can be made by using the option provided to you within the Platform upon your login. You may also write to us as stated in the “Grievances” section above, and we will address you concerns to the extent required by law.
1. Right to Confirmation and Access: You have the right to get confirmation and access to your Personal Information that is with us along with other supporting information.
2. Right to Correction: You have the right to ask us to rectify your Personal Information that is with us that you think is inaccurate. You also have the right to ask us to update your Personal Information that you think is incomplete or out-of-date.
3. Right to Data Portability: You have the right to ask that we transfer the Personal Information you gave us to another organisation, or to you, under certain circumstances.
4. Right to be Forgotten: You have the right to restrict or prevent the continuing disclosure of your Personal Information under certain circumstances.
5. Right to Erasure: If you wish to withdraw/remove your Personal Information from our Platform, you have the right to request erasure of your Personal Information from our Platform. However, please note that such erasure will remove all your Personal Information from our Platform (except as specifically stated in this Policy) and may result in deletion of your account on the Platform permanently, and the same will not be retrievable.
TERMS APPLICABLE IF YOU ARE A RESIDENT OF UNITED KINGDOM (UK), A EUROPEAN UNION (EU) COUNTRY OR EUROPEAN ECONOMIC AREA (EEA)

Your Rights: If you are located in the United Kingdom (UK) or European Union (EU) or European Economic Area (EEA), you have the following rights under the UK and EU General Data Protection Regulation (GDPR) respectively. All requests should be sent to the address noted in the “Grievances” section above, and we will fulfil requests to the extent required by applicable law.
1. Right to access Your Personal Information: You have the right to receive confirmation as to whether or not Personal Information concerning you is being processed and, where that is the case, access to the Personal Information can be sought;
2. Right to Rectification: Our goal is to keep your Personal Information accurate, current and complete. Please contact us if you believe your information is inaccurate or incomplete;
3. Right to Erasure: In some cases, you have a legal right to request that we erase your Personal Information;
4. Right to object to Processing: You have the right to object to our processing of your Personal Information under certain conditions;
5. Right to restrict Processing: You have the right to request that we restrict the processing of your Personal Information, under certain conditions;
6. Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions;
7. Right to make a complaint to a government supervisory authority: If you believe we have not processed your Personal Information in accordance with applicable provisions of the GDPR, we encourage you to contact us at email address provided in the ‘Grievances’ section above. You also have the right to make a GDPR complaint to the relevant Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities is available at: https://edpb.europa.eu/about-edpb/board/members_en. If you need further assistance regarding your rights, please contact us using the contact information provided below, and we will consider your request in accordance with applicable law. You can identify the supervising authority of your concern by visiting https://edpb.europa.eu/about-edpb/board/members_en.
8. Right to not be subject to automated decision-making, including profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal or similarly significant effects concerning you.
We collect and process Personal Information about you only where we have a legal rationale to do so. Specific legal rationale applied for the same will depend on the type of Personal Information collected and the context in which the same is being processed, including the Services involved.
TERMS APPLICABLE IF YOU ARE A CALIFORNIA STATE RESIDENT

If you are a California state resident, then you have the following rights to the extent, and in the manner, set out in the CCPA:
1. The right to access the Personal Information that we hold on you;
2. The right to know what Personal Information we intend on collecting from them before the point of collection;
3. The right to opt in or out of marketing, analytics, and other similar activities;
4. The right to equal services without discrimination; and
5. The right to request deletion of Personal Information.
The above rights, the manner in which you can exercise the same and the category of and the manner in which we collect your information, are detailed below.

CCPA NOTICE AT COLLECTION:

For purposes of the CCPA, in collecting the information described above, we collect the categories of Personal Information listed below from you:
1. Identifiers: We may collect your name, email address, mobile number, username, unique personal identifier, and Internet Protocol (IP) address. We use Identifiers as set forth in the “How We Use and Share the Information Collected” section of this Policy, like your name, contact information, and device and online identifiers.
2. Characteristics of Personal Information described in the California Customer Records statute: We may collect your name, email address, username, unique personal identifier, and gender. We use Categories of Personal Information described in the California Consumer Records statute as set forth in the ‘How We Use and Share the Information Collected’ section of this Policy.
3. Internet or other electronic network activity information: We collect cookies as described above, we will automatically receive information from your browser and your device, which includes the date and time of your visit to the Platform as well as your location, Internet Protocol (IP) address, domain server, browser type, access time, and data about which pages you visit on the Platform. We use Internet or other electronic network activity information as set forth in the “How We Use and Share the Information Collected” section of this Policy.
4. Geolocation data: We may collect your IP address. We may use Geolocation Data as set forth in the “How We Use and Share the Information Collected” section of this Policy.
5. Audio, electronic, visual or similar information: We may collect your profile picture or other audio or visual information uploaded as content to the Platform. We use audio, electronic, visual or similar information as set forth in the “How We Use and Share the Information Collected” section of this Policy.
6. Inferences: We may make inferences based upon the Personal Information collected (such as likelihood of retention or attrition). We use Inference information as set forth in the “How We Use and Share the Information Collected” section of this Policy.

CCPA DATA PRACTICES DURING THE LAST 12 MONTHS:
1. Personal Information collected: As described in this Policy, we have collected the categories of Personal Information listed below during the preceding 12 months:
  - Identifiers
  - Characteristics of Personal Information described in the California Customer Records statute
  - Internet or other electronic network activity information
  - Geolocation data
  - Commercial information
  - Audio, electronic, visual, thermal, olfactory, or similar information Inferences
2. Categories of sources: We have collected the Personal Information identified in this Policy from you and our payment processors.
3. Business and commercial purposes for collecting: We have collected the categories of Personal Information listed above for the following purposes:
  - Operate the Platform;
  - Provide our Services to you;
  - Honor our Terms and Conditions and contracts;
  - Ensure the privacy and security of our Platform and Services;
  - Manage our relationships with you;
  - Communicate with you;
  - Analyze use of the Platform and our Services;
  - Enhance your experience;
  - Track visits to the Platform;
  - Provide you with a more personal and interactive experience on the Platform; and
  - Usage analytics purposes.
4. Personal Information sold: We have not sold categories of Personal Information during the preceding 12 months.
5. Personal Information disclosed for a business purpose: We have disclosed for a business purpose the categories of Personal Information listed below during the preceding 12 months:
  - Identifiers
  - Characteristics of Personal Information described in the California Customer Records statute
  - Internet or other electronic network activity information
  - Geolocation data
  - Commercial information
  - Audio, electronic, visual, thermal, olfactory, or similar information Inferences
  We have disclosed each category of Personal Information to the following categories of third parties: (1) corporate parents, subsidiaries, and affiliates; (2) advisors (accountants, attorneys); (3) service providers (data analytics, data storage, mailing, marketing, website and platform administration, technical support); and (4) operating systems and platforms.

CONSUMER RIGHTS AND REQUESTS UNDER THE CCPA

The CCPA gives consumers the right to request that we (1) disclose what Personal Information we collect, use, disclose, and sell, and (2) delete certain Personal Information that we have collected or maintained. you may submit these requests to us as described below, and we honor these rights where they apply.

If a request is submitted in a manner that is not one of the designated methods for submission, or if the request is deficient in some manner unrelated to our verification process, we will either (i) treat the request as if it had been submitted in accordance with the designated manner, or (ii) provide you with specific directions on how to submit the request or remedy any deficiencies with the request, as applicable.
1. Request to Know: As a California resident, you have the right to request: (1) the specific pieces of Personal Information we have collected about you; (2) the categories of Personal Information we have collected about you; (3) the categories of sources from which the Personal Information is collected; (4) the categories of Personal Information about you that we have sold and the categories of third parties to whom the Personal Information was sold; (5) the categories of Personal Information about you that we disclosed for a business purpose and the categories of third parties to whom the Personal Information was disclosed for a business purpose; (6) the business or commercial purpose for collecting, disclosing, or selling Personal Information; and (7) the categories of third parties with whom we share Personal Information. Our response will cover the 12-month period preceding our receipt of a verifiable request.
2. Request to Delete: As a California resident, you have a right to request the erasure/deletion of certain Personal Information collected or maintained by us. As described herein, we will delete your Personal Information from our records and direct any service providers (as defined under applicable law) to delete your Personal Information from their records. However, we are not required to honor a deletion request if an exemption applies under the law.
3. Submitting a Request:
  1. Submission of Instructions: You may submit a request to know or to delete by email to the address provided in the ‘Grievances’ section above or by submitting a request via mail to address provided by us in our Terms of Use or the Platform page. Regarding requests to delete, we may present you with the choice to delete select portions of your Personal Information, but a global option to delete all Personal Information will be offered and more prominently presented.
  2. Verification Process: We are required by law to verify the identities of those who submit requests to know or to delete. To determine whether the individual making the request is the consumer about whom we have collected information, we will verify your identity by matching the identifying information provided by you in the request to the Personal Information that we already maintain about you. As a part of this process, you will be required to provide your name and email address, and mobile number (if the same have been voluntarily provided by you at the time of registering on the Platform or otherwise while using the Platform). We will inform you if we cannot verify your identity. Please note-
    1. If we cannot verify the identity of the person making a request for categories of Personal Information, we may deny the request. If the request is denied in whole or in part for this reason, we will provide a copy of, or direct you to, our Privacy Policy.
    2. If we cannot verify the identity of the person making the request for specific pieces of Personal Information, we are prohibited from disclosing any specific pieces of Personal Information to the requestor. However, if denied in whole or in part for this reason, we will evaluate the request as if it is seeking the disclosure of categories of Personal Information about the consumer.
    3. If we cannot verify the identity of the person making a request to delete, we may deny the request. If there is no reasonable method by which we can verify the identity of the requestor to the degree of certainty required, we will state this in our response and explain why we have no reasonable method by which we can verify the identity of the requestor.
  3. Authorized Agents: Authorized agents may submit requests via the methods identified in this Policy. If you use an authorized agent to submit a request to know or a request to delete, we may require you to: (1) provide the authorized agent with signed permission to do so; (2) verify your identity directly with us; and (3) directly confirm with us that you provided the authorized agent permission to submit the request. However, we will not require these actions if you have provided the authorized agent with power of attorney pursuant to the California Probate Code.
  4. Excessive Requests: If requests from a User are manifestly unfounded or excessive, in particular because of their repetitive character, we may either (1) charge a reasonable fee, or (2) refuse to act on the request and notify the User of the reason for refusing the request. If we charge a fee, the amount will be based upon the administrative costs of providing the information or communication or taking the action requested.
  5. CCPA Non-Discrimination: You have the right not to receive discriminatory treatment by us due to your exercise of the rights provided by the CCPA. We do not offer financial incentives and price or service differences, and we do not discriminate against Users/consumers for exercising their rights under the CCPA.

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