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The purpose of this privacy policy (this “Privacy Policy”) is to provide individuals with a description of the types of personal information we at Grax, Inc. (“we”, “us” or the “Company”), collect about individual persons through our Services (the “Service”) and through our website grax.com (the “Website”).

This Privacy Policy does not describe technical or other information collected or stored (such as services descriptions or specifications) which is not related to individual persons. In addition to the provisions of this Privacy Policy, information we collect is also governed by the terms of the website Terms of Service and/or service agreement to which you agreed regarding your use of the Website and Service.

Information We Collect
We collect personal information about you in various ways when you use our Website and Service.

INFORMATION YOU PROVIDE
When creating an account or requesting or receiving content or offers, we may ask you to provide us certain personal information. For example:​​​

 

  • We may collect personal information from you, such as your first and last name, email address, company name, job title and password when you create an account.
     

  • When you purchase services on our Website, we will collect all information necessary to complete the transaction, including your name and payment information.
     

  • If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply.
     

  • In certain circumstances, we may request that you provide us with photocopies of your ID and other related documents for fraud prevention purposes and to verify your identity.
     

  • When you participate in one of our surveys, we will collect the information you provide.
     

  • We may also collect personal information at other points on our Website that state that personal information is being collected.

INFORMATION COLLECTED VIA TECHNOLOGY
We collect certain information automatically via various technological means. For example:

 

  • Passive collection: information which is automatically collected, without your knowledge, while navigating through and interacting with the content on our Website and the content on each of our Website pages, as well as information on your device or computer (such as cookies).

    Our Website uses cookies to collect non-personal information including standard internet log information and details of your behavioral patterns upon visiting our Website pages.  We do this to provide you with a better experience, identify preferences, diagnose technical problems, analyze trends and to improve our Website.

    Cookies are small data files transferred onto computers or devices by websites for record-keeping purposes and to enhance functionality on the website.  We may also use cookies to record login details on your device or computer. This helps to determine whether a particular device previously visited our Website so that the login details would not have to be re-entered each time you visit our Website.

    Most browsers allow you to choose whether to accept cookies or not. If you do not wish to have cookies placed on your computer, please set your browser preferences to reject all cookies before accessing the Website. Please note that by doing so some features of the Website you visit may be unavailable.

    The purpose of passively collecting your information is to improve your experience when using our Website. The following information may be collected through your device and browser: your device’s IP address (collected and stored in an anonymized format); device screen size; device type (unique device identifiers) and browser information; geographic location; and preferred language used to display the webpage.

  • Log data: Our servers automatically record information which is created upon using our Service or Website.  Data includes: referring domain; pages visited; geographic location; preferred language used to display the webpage; and date and time when Website pages were accessed.
     

  • Third Party Services: We also use a variety of other services which may be hosted by third parties, such as Google Analytics.  These services may collect information sent by your browser as part of a web page request, such as cookies or your IP request.  For information on how Google Analytics collect and use your information, please refer to their privacy policies.  By using the Website and our Service, you consent to the processing of data by these third parties in accordance with their privacy policies.

  • Do Not Track Signals: Some web browsers may transmit “do not track” signals to our Website and the Service with which your web browser communicates.  There is no standard that governs what, if anything, websites should do when they receive these signals.  We currently do not take action in response to these signals.  If and when a standard is established, we may revise our policy on responding to these signals..

Use of Personal Information

GENERAL USE
In general, the personal information you submit to us is used either to respond to requests that you make, or to aid us in serving you better.  We use your personal information in the following ways:

 

  • Facilitate the creation of and securing your account for our Service;
     

  • Identify you as a user in our system;
     

  • Provide the Service;
     

  • Provide improved administration of our Website and Service;
     

  • Respond to your inquires and other requests;
     

  • For fraud protection and/or to verify your identity; and
     

  • Send newsletters, surveys, offers and other promotional materials related to our Service and for other marketing purposes.

USER TESTIMONIALS

We often receive testimonials and comments from users who have had positive experiences with our Service.  We occasionally publish such content.  When we publish this content, we may identify our users by their first and last name and may also indicate their home city.  We obtain the user’s consent prior to posting his or her name along with the testimonial.

CREATION OF ANONYMOUS DATA

We may create anonymous information records from your specifications and any personal information we collect by excluding information (such as your name) that makes the information personally identifiable to you. We use this anonymous information to analyze request and usage patterns so that we may enhance the content of our Website and improve our Service. We reserve the right to use anonymous information for any purpose and disclose anonymous information to third parties at our sole discretion.

Disclosure of Information
We disclose your personal information as described below and as described elsewhere in this Privacy Policy.

 

  • Third Party Service Providers. We may share your personal information with third party service providers to: provide you with the Service; to conduct quality assurance testing; to facilitate the creation of accounts; to provide technical support; and/or to provide other services to us.
     

  • Payments. If you register for an account that will permit you to make via the Website you will be required to register with our applicable payment processor, to provide certain information with the applicable payment processor to enable the use of their payment processing system, to agree to the terms and conditions of the applicable payment processor, which shall govern your relationship with such payment processor and your use of their payment processing system.
     

  • We do not otherwise share personally identifiable information to third parties who are not affiliates of the Company, except as described here. We may disclose personally identifiable information to appropriate affiliates of the Company, including strategic alliance affiliates and third-party service providers, to respond to a request for service or to provide information about available services. We are not limited in our use of non-personal information that does not permit direct association with any specific individual, or non-identifiable aggregate information about our users (such as the number of users of our Service, the geographic distribution of our users, the amount of information located and/or removed, etc.).
     

  • We disclose information that we, in good faith, believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our service agreement or Terms of Service for our Website. For example, this means that if we conduct a fraud investigation and conclude that someone has engaged in deceptive practices, we can give that person or entity’s contact information to victims who request it. In addition, we reserve the right to disclose aggregate information and personally identifiable information to third parties as required or permitted by law and when we believe that disclosure is necessary to protect our rights.
     

  • We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process (“Legal Request”), including Legal Requests from private parties in a civil action, and in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
     

  • If the Legal Request seeks information about an identified user or limited group of users, we’ll make reasonable business efforts to contact the user(s) before providing information to the party that requests it. We cannot guarantee that we will be able to contact the user(s) in all cases, whether because of a time limit, court order, inability to effectively contact a user, or for any other reason. We may disclose information to an individual’s agent or legal representative (such as the holder of a power of attorney that an individual grants, or a guardian appointed for an individual).
     

  • We share information with companies that provide public relations and marketing services for us. Such information will only be shared by us to customize, measure and improve our services and advertising; it will not be shared with third parties for their marketing purposes. These third parties are obligated to protect information under equivalent terms to this Privacy Policy and are prohibited from using personally identifiable information for any other purpose.
     

  • As with any other business, it is possible that in the future we could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the information maintained by us, including customer account information, but would continue to be bound by this Privacy Policy unless and until it is amended.
     

  • We share information with our parent, subsidiaries and joint ventures to help coordinate the Service we provide, enforce our terms and conditions, and promote trust and safety. We may share aggregate truly anonymized (non-personally identifiable) information with certain third parties such as advertisers, national industry organizations, and prospective affiliates.
     

Data Security

We follow commercially accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. While we strive to use commercially acceptable means to protect personal information, no method of transmission over the Internet, or method of electronic storage, is 100% secure and we cannot guarantee its absolute security. In the event of an inadvertent disclosure of personal information we will take commercially reasonable steps to limit and remedy the disclosure as required by the applicable law. If you have any questions about security regarding our Service, you can contact us at privacy[at]grax.com.

Communications With You, Right of Opt-Out, Access and Correction

When you create an account, you will receive e-mail from us to verify ownership of the email address provided when your account was created.

We may use your e-mail address information to provide you with administrative email notifications, such as order status information and updates.


We may periodically send you emails or other materials that directly promote the use of our Website or Service.  We also may, from time to time, contact you on behalf of third-party businesses about a particular offering that may be of interest to you.  In those cases, we do not transfer your unique personal information to the third party.  When you receive promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below).  Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our service agreement, terms of use or Privacy Policy.

You can correct or update your personally identifiable information by using the profile settings feature of grax.com.

In addition, European data protection legislation gives individuals the right to access personally identifiable information held about them.  Individuals may ensure that such information is accurate and relevant for the purposes for which we collected it.  Individuals may review their own information and correct or remove any information that is incorrect, as permitted by applicable law. To request opt-out, review, modification or removal of personal data, you should submit a written request to us at {privacy[at]grax.com)
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Privacy and 3rd Party Links

This Privacy Policy applies solely to information collected by our Website and Service. In an attempt to provide you with increased value, we may include third-party links on our Website. These linked sites have separate and independent privacy policies, and we do not have control over and do not review these linked sites. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Website and welcome any feedback about these linked sites (including if a specific link does not work).

Governing Law

This Privacy Policy is governed by the laws of the Commonwealth of Massachusetts, U.S.A. without giving effect to any principles of conflict of law.

Age Limitation

The Service is not directed to person under the age of 18. If you become aware that a child has provided us with personal information, please contact us at [privacy@grax.com].  We do not knowingly collect or solicit information concerning persons under 18 years old. If we become aware that a person under 18 has provided us with personal information, we take steps to remove such information and terminate the person’s account.

Effective Date; Policy Changes

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your personal data, we may notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Website.

If you have registered as an account holder, or order or provide services through us, we may (as a part of any transaction relating to your account or order) require you to explicitly accept the changes as a condition to the continued provision of the Service to you.

Any changes to this Privacy Policy that make it less protective of your information will not apply to your information acquired by us prior to such change unless and until you consent as described above.

Please note that at all times you are responsible for updating your personal data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our e-mail to you containing such notice will nonetheless constitute effective notice of the changes described in the notice. If you do not wish to permit changes in our use of your personal data, you must notify us prior to the effective date of the changes that you wish to deactivate your account with us. Continued use of our Website or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

California Privacy Rights

Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have certain rights relating to collection, use, and sharing of their personal information for companies that do a minimum amount of business in or with California residents.

 

We do not meet the minimum necessary requirements to be subject to the CCPA. However, we also do not sell your personal information and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale if required by law. Similarly, we do not offer financial incentives associated with our collection, use, or disclosure of your personal information.

If you are a resident of California, you have the right to request to know what personal information has been collected about you, and to access that information. You also have the right to request deletion of your personal information, though exceptions under the CCPA may allow us to retain and use certain personal information notwithstanding your deletion request.

California Civil Code Section 1798.83 permits customers who are California residents and who have provided the Company with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes.

If you are a California resident with questions regarding your privacy rights, please contact us at (privacy[at]grax.com).

Contact Us

To contact us with your questions or comments regarding this Privacy Policy or the information collection and dissemination practices of the Service, please email us at [privacy@grax.com].  All trademarks, service marks, and other proprietary materials herein are the property of the Company or its affiliates.  All rights reserved.

 

CONTACT US

 

To contact us with your questions or comments regarding this Privacy Policy or the information collection and dissemination practices of the Service, please email us at [privacy@grax.com].

All trademarks, service marks, and other proprietary materials herein are the property of the Company or its affiliates. All rights reserved.

 
 
 
 
 
 
 
 
 

© GRAX 2020

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