Privacy Policy and
Online Privacy Notice

Grain Finance BV.

 

Privacy Policy Last Revised on December 23, 2025

 

This Privacy Policy (the “Privacy Policy”) is intended to describe Grain Finance BV., or any of its affiliates or subsidiaries (“Grain Finance”, “we”, “us” or the "Company ("our practices regarding the information we may collect from our Customers when using or accessing our AI-driven currency hedging and foreign exchange solution for businesses operating across currencies (“Grain Services”), the ways in which we may use such information, and the choices and rights available to its Customers. In addition, our websites located at https://www.grainfinance.co/ (the “Site”) offers visitors through the Site (“Visitors”), information on our Company, technology and information concerning our Grain Services, as well as demos and trials of our Grain Services (if such are made available) and additional information and content we may make available through our Site. The Site, together with the Grain Services and related services, except if specifically designated otherwise, shall be referred to herein as the “Services”. “Customer” shall include: (I) the Grain Services’ merchant (“Merchant”) and/or our bank partner (“Bank Partner”); (II) Merchant clients (“Merchant Client”); and (III) Visitors.

 

This Privacy Policy supplements and shall be read in conjunction with our Terms of Service as published in the Site (“Terms of Service”), https://www.grainfinance.co/terms-of-service, and may be supplemented by additional privacy statements, terms or notices provided to you. Capitalized terms which are not defined herein, shall have the meaning ascribed to them in our Terms of Service.

 

1. YOUR CONSENT

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PLEASE READ THIS PRIVACY POLICY BEFORE ACCESSING AND USING THE SERVICES AND/OR THE SITE. BY ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY, INCLUDING THE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION (AS DEFINED BELOW). IF YOU DISAGREE TO ANY TERM PROVIDED HEREIN, WE WILL NOT BE ABLE TO SUPPLY THE SERVICES, AND YOU MAY NOT ACCESS OR USE THE SERVICES.

 

Please note: you hereby acknowledge and agree that you are providing us with personal information at your own free will and that we may collect and use such personal information pursuant to this privacy policy and any applicable laws and regulations.

 

TO THE EXTENT THAT DURING THE ACCESS TO OUR SERVICES, ANY PERSONAL INFORMATION RELATED TO ANY THIRD PARTY OR ANY OTHER PERSON OR ENTITY WHICH IS NOT YOU IS PROVIDED BY YOU, YOU ARE SOLELY RESPONSIBLE TO RECEIVE THE CONSENT, AUTHORITY, PERMISSION AND APPROVAL OF SUCH PERSONS AND PROVIDED THEM WITH SUFFICIENT DISCLOSURES, TO ALLOW THE COMPANY TO ACCESS, STORE, COLLECT, ANALYZE AND PROCESS SUCH PERSONAL INFORMATION AS DETAILED HEREIN. BY ACCESSING THE SERVICES, YOU REPRESENT THAT YOU HAVE RECEIVED SUCH CONSENT, AUTHORITY, PERMISSION OR APPROVAL, AND THAT YOU SHALL HAVE SUCH CONSENT, AUTHORITY, PERMISSION OR APPROVAL AT ALL TIMES YOU USE THE SERVICES.

 

2. WHAT TYPES OF PERSONAL INFORMATION DO WE COLLECT?

 

Personal Information is information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of a private or sensitive nature relating to an identified or identifiable natural person. Identification of an individual also includes the association of such an individual with a persistent identifier such as a name, an identification number, etc. Personal Information does not include information that has been anonymized or aggregated and can no longer be used to identify a specific natural person.
 

Personal Information that is collected by us consists of the following types of Personal Information:

 

a. Grain registration information. When you sign up for an account with Grain Finance, we may collect and use your personal information such as name, address, email address, bank account details, and tax identification number (“TIN”) or social security number (“SSN”) on behalf of our Merchant Clients and/or our Bank Partner to facilitate the provision of Grain Services.

b. Usage Information (Automatically Collected Data). When you interact with our Services, Grain Finance automatically collects certain information relating to your use of the Sites and Services (“Usage Information”). This information is primarily technical and collected in the background to enable, secure, and improve the Services. Such Usage Information may include:

Details regarding your interactions with our Sites and Services (such as access dates and times, pages viewed, features used, and other activity data);

Device identifiers and related technical information (such as IP address, browser type, operating system, hardware model, and unique device identifiers);

Log data and diagnostic information (for example, performance metrics, crash data, and other system-level information);

Geolocation data: data information about the precise or approximate location of your device, collected only with your explicit consent via your device or browser settings. We use this data solely for specific purposes such as fraud prevention, service optimization, and improving user experience

c. Information You Provide Through the Use of the Services. In addition to the information collected automatically, Grain Finance may collect and process personal data that you actively provide while using our Services or communicating with us (“User-Provided Information”). This may include:

Voice recordings, such as when you contact Grain Finance’s customer service;

Information provided during customer service interactions, including feedback about your experience with Grain Finance or responses to surveys conducted by the Company;

Contact information and communication content, such as your name, email address, and any other information you include when you contact us (e.g. via email or feedback forms);

d. Transaction information. When you conduct a transaction via the Platform, , we may collect information you provide, including as necessary to complete the transaction, including your name, legal address, last four digits of your SSN, and credit or debit card billing information;

e. Technical information. Needed to ensure safe and secure delivery of the Service, such as: IP address, UDID (Unique Device Identifier) or other persistent user and/or mobile device token, advertising ID, device type, browser and keyboard language, the User’s ‘click-stream’ and activities on the Services, the period of time the User used the App (as defined below), and/or related time stamps.

f. Verification information. we may need to verify your identity in order for you to use some aspects of the Service. For purposes of verification, we may also collect the following personal information from you: Valid government issued identification such as a passport or driver’s license and other identification documents as deemed appropriate. If requested for compliance reasons, providing this information is mandatory to use our Service.

g. Prospect Data. We collect name, organization, phone number, country, and business email address of enterprises representatives who are prospective Merchants and/or Partners of Grain Finance. This includes Personal Information provided to Grain Finance through the “Book a Demo” feature, and the “Message Us” feature, and Name, email address and any other personal data may be shared through the Site chatbot agent, interactions made through social media platforms, conferences and events and similar business interactions.

h. Employees and Candidates. We collect name, email, phone, CVs and related professional background information necessary for evaluation of candidates who are interested in working at Grain Finance. We collect names, email, address, phone, CVs, bank account details, and any personal data necessary to facilitate salaries for our employees.

For avoidance of doubt, we do not collect any Personal Information from you or related to you without your approval, which is obtained, inter alia, through your acceptance of this Privacy Policy.

This Privacy Policy applies to all Services offered by Grain Finance to consumers, except where a product or service has a separate privacy notice that does not incorporate this Privacy Policy. Certain individuals also may be provided with additional privacy notices as described below:

Federal law requires our Merchant Customer/Bank Partner to provide notice to certain consumers to explain what personal information they collect, how they share it, and how consumers may limit our Bank Partner’s sharing of the information. The privacy practices of our Bank Partner are subject to their privacy notice, which we strongly suggest you review. Grain Finance is not responsible for our Bank Partner’s information practices or privacy notices.

Notice to California Residents – If you are a resident of California, please see our California Consumer Privacy Statement.

3. HOW DO WE COLLECT INFORMATION FROM YOU?

We collect information through your use of the Services. In other words, we are aware of your usage of the Service and may gather, collect and record the information relating to such usage, as further detailed below.

We collect information that you provide us voluntarily. For example, we collect Personal Information that you voluntarily provide when you request to provide us with your name and email upon your initial registration for the Services or when you use registration forms on the Site, Book a Demo, or while interacting with our Chatbot.

For employees, we collect information provided directly through onboarding, HR systems, payroll forms, or internal platforms, and may also obtain data from background check providers, professional references, or public databases for employment administration, verification, and compliance purposes.

Information Collected from Other Sources. We may also collect information about you from third parties, such as marketing partners, identity verification services, anti-fraud services, and other service providers. We may also supplement the information we have about you with information received from other sources such as commercially available sources (e.g., data brokers and public databases). The information we receive may include demographic data such as age, gender, and income level, your interests and purchase data and other information that is necessary or useful to assist our marketing efforts or for user verification, authentication, fraud detection or to comply with regulatory requirements.

 

Social Networking

This website allows users to sign into and associate social media accounts, including but not limited to, Facebook and LinkedIn, with the Sites and Services. By using this functionality, you give Grain Finance permission to access all of the elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with Grain Finance and other connected applications and to manage the data that is shared through your account, including information about your activities using our Sites.

Grain Finance does not retain your username or password for social networking platforms for any longer than is necessary to complete an interaction. If you would like to disconnect a social media account from Grain Finance, please refer to the settings of that social media account and its provider.

4. COOKIES

Like many companies, we use “cookies” on our Site. Cookies are pieces of code placed on your devices when you visit certain websites. We use cookies to tell us, for example, whether you have visited us before or if you are a new visitor, and to help us identify features of the Sites in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website.Most modern web browsers allow you to manage cookies, including stopping new cookies, receiving notifications about cookies, or deleting existing cookies. Please note, however, that disabling cookies may limit certain features or functionality of our Sites

Web Beacons

Certain pages on our website contain “web beacons” (also known as Internet tags, pixel tags, and clear GIFs). These web beacons allow third parties to obtain information, such as the IP address of the computer that downloaded the page on which the beacon appears; the URL of the page on which the beacon appears; the time the page containing the beacon was viewed; the type of browser used to view the page; and the information in cookies set by the third party.

Third-Party Analytics Services

We may use Google Analytics or similar analytics services to help analyze how users use our Services. These services may use cookies to collect information such as how often users visit our Sites, the pages they visit, and what other sites they used prior to coming to our Services. We use the information to improve our Sites, Application(s), and Services.

Learn more about your choices and how to opt-out of tracking technologies:

Our Site may embed third-party cookies that collect certain identifiers and associate them with other personal information obtained by such third parties from external sources or provided under your contractual relationships with them independently of Grain Finance. These third parties act as Independent Controllers under the EU General Data Protection Regulation (“GDPR”) and under the California Consumer Privacy Act (“CCPA”) – as “Third Parties”, determining the purposes and means of processing the personal data they collect, and are responsible for compliance with applicable privacy laws. Opting out of cookies on our website does not extend to these third parties' collection or processing of your personal information. In order to delete or block any tracking technologies, please refer to the “Help” area on your internet browser for further instructions, or You may also opt out of third party tracking technologies by following the instructions provided by each third party service provider in its privacy policy listed above or visiting www.youronlinechoices.eu or http://www.aboutads.info/choices/. Please note however that deleting any of our tracking technologies or disabling future tracking technologies may prevent you from accessing certain areas or features of our Sites, or may otherwise adversely affect your user experience. Our Sites do not collect personal information about your online activities over time and across third-party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our Sites, and we do not alter any of our data collection and use practices upon receipt of such a signal.

To learn more about our use of Cookies and other tracking technology that we use please see our Cookie Policy at https://www.grainfinance.com/cookie-policy. 

Collection of Data in Connection with Advertising

We may use third parties to serve ads on the Sites. In connection with the delivery of advertising, certain third parties may automatically collect information about your visits to this and other websites, your IP address, your ISP, and the browser you use to visit our Sites. They do this by using cookies, web beacons, or other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Sites and the other sites tracked by these third parties. This policy does not apply to, and we are not responsible for, Cookies or Pixel Tags in third party ads, and we encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of Cookies and other technologies.

5. WHY DO WE COLLECT AND PROCESS YOUR INFORMATION?

We may use your information that we collect and receive about you for the following purposes:

To provide access to the Services.

To provide, operate, customer support, and improve our Services and related offers, and to manage our business;

To provide our Users with a better user experience, more fitted to their specific needs.

To be able to contact Users who requested such contact to be made, for the purpose of providing them with further information on Grain Finance and its Services or otherwise to provide them;

To interact with Users via our chatbot, including booking a demo for Users. To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal activities, whether suspected or actual;

To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.

To be able to send Users our newsletters and information in connection with the Services, where Users registered to receive such messages or have otherwise provided us with their consent, or otherwise to provide important notices with respect to Services to which Users have registered;

To market our Services to Users or potential Users (including via our marketing service providers), and to be able to track and evaluate our marketing activities and their results and attribute different marketing achievements to the respective marketing efforts.

To act upon and comply with requests you may make pursuant to this Privacy Policy and the privacy laws that apply to you.

To perform functions or services as otherwise described to you at the time of collection;

6. WHAT ARE OUR LEGAL GROUNDS FOR COLLECTING YOUR PERSONAL INFORMATION

With your consent: We ask for your consent to collect and process your information for the specific purposes stated herein, and you have the right to withdraw your consent at any time. For example, we ask for your consent to connect your Business Applications accounts (which may contain Personal Information) to the Services, and you may at any time withdraw such consent.

In the scope of providing the Services: We collect and process your Personal Information in order to provide you with the Services, following your acceptance of this Privacy Policy and pursuant to the Term of Use.

Legitimate interests: We process your information to protect our legitimate interests while applying appropriate safeguards that protect your privacy. This means that we process your information for purposes like detecting, preventing or otherwise addressing fraud, abuse, security, usability, functionality or technical issues with our Services; protecting against harm to the rights, property or safety of our properties, our Users or the public as required or permitted by law; enforcing legal claims, including investigation of potential violations of this Privacy Policy; and in order to comply and/or fulfil our obligations under applicable laws, regulation, guidelines, industry standards and contractual requirements, legal process, subpoena or governmental request.

7. WHO DO WE SHARE YOUR INFORMATION WITH AND WHY?

We keep the information processed by us in strict confidence and we may only share information with third parties (or otherwise allow them access to it) in very limited circumstances and for very specific purposes, as described below:

Internally – We may share information with our family of companies, as well as our employees, for the purposes described in this Privacy Policy. In addition, should Grain Finance or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your information may be shared with the parties involved in such event under strict security conditions, for the purpose of evaluating such event and in accordance with the terms of this Privacy Policy. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have, either through a prominent notice on our Services or by contacting you directly through contact details you have provided us.

Protecting Rights and Safety – We may share your information to enforce this Privacy Policy and/or the Terms of Use or any other agreement between Grain Finance and you with respect to the Grain Services, including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security or technical issues; or otherwise, if we believe in good faith that this will help protect the rights, property or personal safety of any of our users, or any member of the general public.

Third Parties & Business Partners – We partner with certain third parties to provide selected services that are used to facilitate and enhance the Services and your use thereof (“Service Providers"). Such Service Providers may access or process personal information on our behalf only as needed to perform their services, such as hosting, data storage, or analytics. We keep a current list of our sub processors and will provide it to you upon request. We review our partners regularly to ensure they meet our privacy and security standards. If you have any questions about our use of third-party providers, please contact us at Privacy@grainfinance.co.

Law Enforcement – We may cooperate with government and law enforcement officials to enforce and comply with the law. We may therefore disclose any information to government or law enforcement officials as we believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and legal rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.

For avoidance of doubt, we may share anonymized/de-identified information with any other third party, at our sole discretion. 

For the avoidance of ambiguity, we will NOT sell (as “sell” is traditionally defined) your personal data. That is, we will not provide your name and email or other personally identifiable information to third parties in exchange for money. We may share anonymized or de-identified information with any other third party, at our sole discretion. However, under California law, certain cases of sharing information, such as for advertising purposes, may be considered a “sale” of personal information. However, to the extent applicable, including if a supervisory authority determines that our practices include the selling and/or sharing of your personal information (as such terms are defined under applicable US State Privacy Laws including the CCPA), and you would like to opt out of the “sale” or “sharing” of your personal information, please contact us at Privacy@grainfinance.co.

8. THIRD PARTY SOFTWARE/SERVICE

While using the Site you may encounter links to third party websites and/or services. Please be advised that such third party websites and/or services are independent from Grain Services, and may use cookies and other web-tracking technologies, not specified or otherwise handled in our Cookie Policy, to collect Non-Personal and/or Personal Information about you. We assume no responsibility or liability whatsoever with regard to privacy matters or any other legal matter with respect to such third party websites and/or services. We encourage you to carefully read the privacy policies and the terms of use of such third party websites and/or services, as their terms, not ours, will apply to any of your interactions with such third parties. Grain Finance has no control over the use of any information you provide to these third party services.

9. WHERE DO WE TRANSFER OR STORE YOUR PERSONAL INFORMATION?

Your information may be transferred to, maintained, processed and stored by us and our authorized affiliates and service providers in Israel, the EU or the United States. Please note that the data protection laws in the above jurisdictions may not be as comprehensive as those in your country of residence. Residents of certain countries may be subject to additional protections, as set forth below.

GDPR (EEA Users): This section applies only to natural persons residing in the European Union, EFTA States, or the United Kingdom (for the purpose of this section only, "you" or "your'' shall be limited accordingly). It is the Company's policy to comply with the GDPR throughout the EEA and the UK GDPR. In accordance with the GDPR, we may transfer your Personal Information from your home country to the U.S. and/or other countries, provided that the transferee has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available. Specifically, we may cause such transfer if we ensured that at least one of the following applies:

The country to which Personal Information has been transferred, has been determined by the EU Commission to be a country providing adequate protection to the privacy rights of EU residents. Application of Standard Contractual Clauses where appropriate.

Please know that we, our affiliates and our service providers that store or process your personal information on our behalf are each committed to keep it protected and secured, pursuant to this Privacy Policy and industry standards, regardless of any lesser legal requirements that may apply in their jurisdiction.

Specifically, each of our Third Party Service Providers which store or process your Personal Information either: (i) assured us that they provide adequate safeguards to protect your rights to privacy including where applicable, by undertaking to comply with the EU Standard Contractual Clauses; (ii)  where applicable, hold and process such information on our behalf in jurisdictions which have been determined to ensure an adequate level protection by the EU Commission; (iii) perform such processing pursuant to your consent and acceptance of their privacy policy as further detailed in this Privacy Policy.

By providing your information, you expressly consent to the place of storage and transfer described above, including transfers outside of the jurisdiction in which the information was provided

10. WHAT ARE MY RIGHTS?

If applicable to you under your country’s jurisdiction, you may have certain rights in connection with your Personal Information and how we handle it. You can exercise your rights at any time by contacting us via support@grainfinance.co. Those rights may include, but are not limited to, the following:

Right of access.

You may have a right to know what information we hold about you and, in some cases, to have the information communicated to you. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.

Right to correct Personal Information.

We endeavor to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know and we will use our best efforts to correct it as soon as we can.

Data deletion.

In some circumstances and under certain laws and regulations, you may have a right to request that some portions of the Personal Information that we hold about you be deleted or otherwise anonymized/de-identified.Data portability. In some circumstances and under certain laws and regulations, you may have the right to request that data which you have provided to us is provided to you, so you can transfer or port it elsewhere.

Restriction of processing.

In some cases, you may have the right to request restriction of the processing of your Personal Information, such as when you are disputing the accuracy of your information held by us.

Grain Finance may refuse requests to exercise data subject rights if there is a legitimate reason, such as if we cannot authenticate your identity, if the request could violate the rights of a third party or applicable law, or prevent us from delivering a service you requested.

11. HOW DO WE PROTECT PERSONAL INFORMATION?

We take great care in implementing and maintaining the security of the Services and of your Personal Information. We have implemented administrative, technical and physical safeguards to help prevent unauthorized access, use or disclosure of your Personal Information. Your information is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees, third party service providers or partners on a “need to know” basis, and strictly in order to enable us to perform the agreement between you and us.

Despite these measures, Grain Finance cannot provide absolute information security or eliminate all risks associated with Personal Information, and security breaches may happen. If there are any questions about security, please contact us at support@grainfinance.co.

12. HOW LONG WILL WE RETAIN YOUR INFORMATION?

Grain Finance will retain your Personal Information only for as long as necessary to achieve the purposes for collection and processing set forth above. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. If you withdraw your consent to our processing of your Personal Information, we will delete your Personal Information from our systems (except to the extent retaining such data in whole or in part is necessary to comply with any applicable rule or regulation and/or to respond to or defend against legal proceedings brought against us or our affiliates).If you would like to update your contact information or preferences, have your information removed from our mailing lists, or no longer receive marketing emails that we may send based on information collected via product registration cards or other sources, you may do so by:

Adjusting the settings in an account you created through the Sites; or

Unsubscribing via the links contained in emails from us.

13. HOW DO YOU PROTECT THE PRIVACY OF CHILDREN?

To use our Services, Users must be over the age of eighteen (18). Therefore, we do not knowingly collect Personal Information from individuals under the age of eighteen (18) and we do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that individuals under the age of eighteen are not using the Services. If you believe that we might have any information from or about an individual under the age of eighteen (18), please contact us at support@grainfinance.co In the event that it comes to our attention that a person under the age of eighteen (18) is using the Services, we may prohibit and block such User from using the Services and will make all efforts to promptly delete any Personal Information with respect to such User

If you are submitting to the Services any Personal Information pertaining to any minor child, you hereby represent and warrant that you have received all the necessary legal consents or approvals or that you are the parent or legal guardian and have the actual authority and legal right to upload, submit, disclose or otherwise share such Personal Information and/or any other form of sensitive information, on the minor’s behalf.

14. HOW DO WE USE THE INFORMATION OF JOB CANDIDATES?

We welcome qualified candidates to apply to any of the open positions posted on our Services by sending us your contact details and CV or resume (“Candidate Information”). Since privacy and discretion are very important to our candidates, we are committed to keeping Candidate Information private and will use it solely for our internal recruitment purposes (including for identifying candidates, evaluating their applications, making hiring and employment decisions, and contacting candidates by phone or in writing).

Please note that we may retain Candidate Information submitted to us even after the applied position has been filled or closed. This is done so we can reconsider candidates for other suitable positions and opportunities at Grain Finance; so we can use the Candidate Information as a reference for future applications; and in case the candidate is hired, for additional employment and business purposes related to their employment with us.

15. UPDATES TO THIS PRIVACY POLICY

This Privacy Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our Services (as reflected in the “Last Revised” heading). You are advised to check for updates regularly. We will provide notice of substantial changes of this Privacy Policy on the homepage of the Services and/or we will send you an e-mail regarding such changes to the e-mail address that you may have provided us. Such substantial changes will take effect seven (7) days after such notice was provided on our Services or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised” date and your continued use of the Services after the Last Revised date will constitute acceptance of, and agreement to be bound by, those changes.

16. DIRECT MARKETING

Email communications.

We may, from time to time, send you an email regarding our products and services, or products and services we think you may enjoy. Only We (or our vendors or service providers operating on our behalf) will send you these emails. You can choose not to receive these emails by clicking the unsubscribe link in any email. Please note that you are not permitted to unsubscribe or opt-out of non-promotional messages regarding your account, such as account verification, changes or updates to features of the App, or technical or security notices

Interest based on advertising.

We do not display any targeted advertising in the Services. We do not permit third parties to collect information about your use of the Services for the purpose of sending you targeted advertisements on other websites or applications. Although we are unable to recognize Do Not Track signals set by your browser, we do not engage in activities which track our users across other websites or mobile apps over time. However, outside of the mobile app (“App”), we may engage in interest-based advertising to deliver online advertisements about our app, and may use third party advertising companies to serve targeted advertisements on other websites, apps or services, including on Facebook and other social networks. These advertisements are not based on the personal data we collect from you or on your activities on our App, though you may see one of these advertisements based on your activities on other websites or services (for instance, if you type “Embedded Hedging” into an online search engine, you may see an advertisement for Grain Finance). To learn about interest-based advertising and your choices, you may wish to visit the Network Advertising Initiative’s online resources here, and/or the DAA’s resources here.

17. GENERAL INFORMATION

This Privacy Policy, its interpretation, and any claims and disputes related hereto, shall be governed by the laws of England and Wales, without respect to its conflict of law principles. Any and all such claims and disputes shall be brought in, and you hereby consent to them being litigated in and decided exclusively by a court of competent jurisdiction located in London, England.

This Privacy Policy was written in English and may be translated into other languages for your convenience. If a translated (non-English) version of this Privacy Policy conflicts in any way with the English version, the provisions of the English version shall prevail.

18. HOW TO CONTACT US

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the details provided below: support@grainfinance.co

CALIFORNIA CONSUMER PRIVACY STATEMENT

This California Consumer Privacy Statement (“Statement”) supplements the Grain Finance Privacy Policy and applies solely to California consumers. This Statement does not apply to Grain Finance personnel or job applicants.

This Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

NOTICE OF COLLECTION AND USE OF PERSONAL INFORMATION

We may collect the following categories of personal information about you:
Identifiers:

identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers.

Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number, credit card number, debit card number, and other financial information.

Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, age, sex, gender, marital status, citizenship status, and military and veteran status.

Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.

Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements.

Geolocation Data.

Sensory Information: audio, electronic, visual, and similar information.

Employment Information: professional or employment-related information.Inferences:

inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

.We may use your personal information for the purposes described in our Grain Finance Privacy Policy and for the following business purposes specified in the CCPA:

Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services;

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;

Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction;

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;

Debugging to identify and repair errors that impair existing intended functionality;

Undertaking internal research for technological development and demonstration; and/or

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us.

SALE OF PERSONAL INFORMATION

We do not “sell” personal information (as such term is defined in the CCPA).

CALIFORNIA CONSUMER PRIVACY RIGHTS

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed, and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and, (2) the identity of those third parties.

How to Submit a Request

To submit an access or deletion request, please email support@grainfinance.co a request through our webform. To submit a Shine the Light request, email us at support@grainfinance.co. If you designate an authorized agent to make an access or deletion request on your behalf using one of the channels described above, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us (as described below). For questions or concerns about our privacy policies and practices, please contact us as described in the How to Contact Us section of our Privacy Policy.

Verifying Requests

To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: your name, date of birth, the last four digits of your Social Security number, the email and physical addresses associated with your Grain Finance account, one or more recent transactions, and the last four digits of one or more Grain Finance-branded cards associated with your account. If you have never had an account with us and you request access to or deletion of your personal information, there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA. The reason for this is that Grain Finance does not maintain information about non-account holders in a way that is linked to named actual persons (and historically has not linked IP addresses, device identifiers or other information collected by automated means to named actual persons). In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. 


Additional Information

If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.