(Last Updated May 25, 2018)
1. What Information Do We Collect?
a. Personally-Identifiable Information: 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" as defined in applicable law.
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 Policy, please do not use our Services.
b.Sensitive Personal Data: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 Policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to us.
c. Non-Personally-Identifiable Information: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, 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.
d. Cookies, Pixels and Local Storage: 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
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.
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 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 visited,whether they have visited before, and other similar information.We use this information to help operate the Services more efficiently, to gather broad demographic information and to monitor the level of activity on our Services.
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/resources/concepts/gaConceptsCookies
You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of the Services by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB
Social Media Cookies
These cookies are used when you share information using a social media sharing button or "like" button on any site or application for the Services or you link your account or engage with our content on or through a social networking website such as Instagram, Facebook, Twitter or Google+. The social network will record that you have done this.
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
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 http://www.allaboutdnt.com.
2. What Do We Do With The Information That We Collect?
a. Grin will use the personally identifiable information directly provided by you solely for the purpose for which you have provided it, which may include:
- to operate, maintain, and improve the Services;
- to manage your account, including to communicate with you regarding your account;
- to operate and administer any proposals, events, or promotions you participate in on any site or application;
- to respond to your comments and questions and to provide customer service;
- to send information including technical notices, updates, security alerts, and support and administrative messages;
- with your consent, to send you marketing e-mails about new proposals, opportunities, upcoming events, and other news, including information about products and services offered by us and our affiliates. You may opt-out of receiving such information at any time: such marketing emails tell you how to “opt-out.” Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;
- to process payments you make via the Services; and
- as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.
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 firstname.lastname@example.org anytime for any other questions you may have about your personally identifiable information and our use of it.
b. 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. 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.
4. 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 Policy.
5. How Does A User Change Or Update Information?
6. 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@example.com.
7. Changes to This Policy
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