·         You

    o   When you provide such information directly to us.

        §  When you create an account or use our interactive tools and Services.

        §  When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.

        §  When you send us an email or otherwise contact us. 

    o   When you use the Services and such information is collected automatically.

        §  Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).

        §  If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.

        §  If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

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·         Public Records

    o   From the government or other sources.

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·         Third Parties

    o   Vendors

        §  We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

        §  We may use vendors to obtain information to generate leads and create user profiles.

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    o   Advertising Partners

        §  We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.

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    o   Social Networks

        §  If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.

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Our Commercial or Business Purposes for Collecting Personal Data

 

·         Providing, Customizing and Improving the Services

    o   Creating and managing your account or other user profiles.

    o   Processing orders or other transactions; billing.

    o   Providing you with the products, services or information you request.

    o   Meeting or fulfilling the reason you provided the information to us.

    o   Providing support and assistance for the Services.

    o   Improving the Services, including testing, research, internal analytics and product development.

    o   Personalizing the Services, website content and communications based on your preferences.

    o   Doing fraud protection, security and debugging.

    o   Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

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·         Marketing the Services

    o   Marketing and selling the Services.

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·         Corresponding with You

    o   Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Granthika or the Services.

    o   Sending emails and other communications according to your preferences or that display content that we think will interest you.

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·         Meeting Legal Requirements and Enforcing Legal Terms

    o   Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

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How We Share Your Personal Data

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o   Protecting the rights, property or safety of you, Granthika or another party.

o   Enforcing any agreements with you.

o   Responding to claims that any posting or other content violates third-party rights.

o   Resolving disputes.

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 We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

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We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

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• Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include:

  • Hosting, technology and communication providers.

  • Analytics providers.

  • Payment processors.

    • Our payment processing partner Paddle.com Market Limited (“Paddle”) collects your voluntarily-provided payment card information necessary to process your payment.

       

    • Please see Paddle’s terms of service and privacy policy for information on its use and storage of your Personal Data.

       

• Advertising Partners. These parties help us market our services and provide you with other offers that may be of interest to you. They include ad networks.

• Business Partners. These parties partner with us in offering various services. They include:

  • Businesses that you have a relationship with.

  • Companies that we partner with to offer joint promotional offers or opportunities.

• Parties You Authorize, Access or Authenticate

  • Third parties you access through the services.

  • Social media services.

  • Other users.

  • ​

 

Legal Obligations

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We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

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Business Transfers

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All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

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Data that is Not Personal Data

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Tracking Tools and Opt-Out

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We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

   

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

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For more information about our use of Cookies, please see our Cookie Policy.



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Data Security and Retention

 

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

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We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.



Personal Data of Children

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As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16  years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at support@granthika.co .



California Resident Rights

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If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

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If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at support@granthika.co .

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Access

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You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:

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·         The categories of Personal Data that we have collected about you.

·         The categories of sources from which that Personal Data was collected.

·         The business or commercial purpose for collecting or selling your Personal Data.

·         The categories of third parties with whom we have shared your Personal Data.

·         The specific pieces of Personal Data that we have collected about you.

 

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

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Deletion

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You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

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Exercising Your Rights

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To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information, such as your email address or invoice number, to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

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We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

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You may submit a Valid Request using the following methods:

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·         Email us at: support@granthika.co

·         Submit a form at this address: https://granthika.co/connect

 

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.

 

Personal Data Sales Opt-Out and Opt-In

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The CCPA sets forth certain obligations for businesses that “sell” Personal Data. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity. We do share certain information as set forth in this Privacy Policy and allow third parties to collect certain information about your activity, for example through Cookies, as explained in our Cookie Policy. For more information on how you can control or opt out of these Cookies, please see the Cookie Policy.

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We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

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We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.



Other State Law Privacy Rights

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California Resident Rights

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Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at support@granthika.co .

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Nevada Resident Rights

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If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at support@granthika.co with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.



European Union Data Subject Rights

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EU Residents

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If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below. 

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For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Granthika will be the controller of your Personal Data processed in connection with the Services.

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If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at support@granthika.co . Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

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Personal Data We Collect

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The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

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Personal Data Use and Processing Grounds

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The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

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We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

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·         Contractual Necessity:  We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

o   Profile or Contact Data

o   Payment Data

o   Professional or Employment-Related Data

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·         Legitimate Interest:  We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:

o   Profile or Contact Data

o   Payment Data

o   Professional or Employment-Related Data

o   We may also de-identify or anonymize Personal Data to further our legitimate interests.

Examples of these legitimate interests include (as described in more detail above):

o   Providing, customizing and improving the Services.

o   Marketing the Services.

o   Corresponding with you.

o   Meeting legal requirements and enforcing legal terms.

o   Completing corporate transactions.

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·         Consent:  In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

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·         Other Processing Grounds:  From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

 

Sharing Personal Data

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The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

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EU Data Subject Rights

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You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at support@granthika.co or submit a form at https://granthika.co/connect. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. 

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• Access:  You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by emailing us at support@granthika.co or submitting a form at https://granthika.co/connect.

• Rectification:  If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by emailing us at support@granthika.co or submitting a form at

  https://granthika.co/connect.

  .

• Erasure:  You can request that we erase some or all of your Personal Data from our systems. 

• Withdrawal of Consent:  If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.

• Portability:  You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.

• Objection:  You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.

• Restriction of Processing:  You can ask us to restrict further processing of your Personal Data.

• Right to File Complaint:  You have the right to lodge a complaint about Granthika's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

 

Transfers of Personal Data

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The Services are hosted and operated in the United States (“U.S.”) through Granthika and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Granthika in the U.S. and will be hosted on U.S. servers, and you authorize Granthika to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to: (i) a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission.



Changes to this Privacy Policy

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We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Granthika website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.



Contact Information

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If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

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• https://granthika.co/

• support@granthika.co

• 3559 MT Diablo Blvd Suite 370, Lafayette, CA 94549, USA

 

For data subjects in the EU or the UK:

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We value your data subject rights under GDPR and GDPR-UK and therefore have appointed https://prighter.com/ as representative according to Article 27 GDPR and have provided you with an easy way to submit privacy-related request like a request to access or erase your personal data.

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If you want to make use of your data subject rights, please visit:

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https://prighter.com/q/11870547.

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Contact Prighter at:

Prighter
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o Granthika Co.
Schellinggasse 3/10, 1010 Vienna, Austria

Please add the following subject to all correspondence: GDPR-REP ID: 1187054.