Privacy Policy

EFFECTIVE: September, 2018


GrainChain, Inc. (“GrainChain”, “we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Policy applies to (i) the GrainChain Platform and GrainChain Software, (ii) the websites owned and operated by us (the “GrainChain Website(s)”), and (iii) any services provided to you by us in connection with the foregoing (clause (i) through (iii), collectively, the “GrainChain Service”).

This Privacy Policy is a part of and incorporated into the GrainChain terms of service or other customer agreement (collectively, the “Terms”) entered into between GrainChain and you, or your employer, or the entity that has provided you with credentials, or has otherwise authorized you, to and use access the GrainChain Service. If any provision of this Privacy Policy is inconsistent or conflicts with any provision in the Terms, this Privacy Policy will control with respect to the subject matter hereof. Capitalized terms used in this Privacy Policy but not defined in this Privacy Policy have the meanings given to them in the Terms.

This Privacy Policy is intended to inform you about the kind of information, including personally identifiable information, that we may collect from you in connection with your use of the GrainChain Service and how, and for what purpose, we use that information.



YOU GIVE US CONSENT


Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use or access the GrainChain Service. By accessing or using the GrainChain Service, or submitting information through the GrainChain Service, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use, and disclosure of your Personal Information and Anonymous Information (as each term is defined below) in accordance with this Privacy Policy. You understand that by providing us Personal Information, you allow us to identify you. Some of the services we provide may be hampered if you do not provide us the necessary Personal Information.



DEFINING “INFORMATION” AND “USER DATA”


We collect Customer Data in connection with your use of the GrainChain Service, which includes both Personal Information and Anonymous Information.

“User Data” means content and information (including Personal Information) submitted by users to, or through, the GrainChain Service. As further explained below, User Data is controlled by the organization or other third party that entered into the Terms with GrainChain (the “Customer”). When GrainChain collects or processes User Data, it does so on behalf of the Customer. If you are using the GrainChain Service by invitation of a Customer, whether that Customer is your employer, another organization, or an individual, that Customer determines its own policies regarding storage, access, modification, deletion, sharing, and retention of User Data which may apply to your use of the GrainChain Service. Please check with the Customer about the policies and settings it has in place.

“Personal Information” is information that allows someone to identify or contact you, as well as any other non-public information about you that is associated with or linked to any of the foregoing, and can include, for example, an individual's first and last name, phone number, and e-mail address.

“Anonymous Information” means data that is not associated with or linked to your Personal Information; Anonymous Information does not, by itself, permit the identification of individual persons.



PROTECTING YOUR PRIVACY


We do not share, rent or sell your account information to any third party, except as expressly set forth in this Privacy Policy. Please help us protect your privacy by keeping your account information safe. Do not disclose your account password or login information to anyone and keep changing it periodically.



Registration Information

When you register an account for the GrainChain Service, you are required to provide us Personal Information. We collect and store the following Personal Information in connection with the registration of an account: your email address and first and last name.

We may use the Personal Information you submit during the registration process to send you services-related communications. In addition, we may also use such Personal Information to send you electronic newsletters or promotional e-mails, unless you have requested not to receive such promotional communications from us as described below.



Payment and Transaction Information

When you submit information to establish your account for payment transactions in connection with the GrainChain Service our third party payment processor (currently, Dwolla) will collect, on our behalf, your name, billing address, and complete bank account information, that enables the GrainChain Service to execute on the transaction.

Our payment processing service provider will retain this information to process your transactions in connection with the use of the GrainChain Service.



Services usage information; Geolocation Data

This is information about how you are accessing and using the Services, which may include administrative and support communications with us, and what third party integrations you use (if any).

In addition, if you use the GrainChain Service, GrainChain may collect your geolocation data (subject to your consent), and certain mobile device information, which includes: device/platform type and version (iOS v4, Android, etc.).



Feedback and Communications

If you provide us Feedback or contact us via e-mail or through our “contact-us” forms, we will collect your first and last name and e-mail address, any information requested in our Feedback or contact-us forms, as well as any other content included in the e-mail, Feedback or contact-us forms you send to us. Any Feedback you provide will be governed by the Terms.

We may use Personal Information submitted in your communications to contact and respond to you and otherwise in the same manner as described above for registration information.



Log File Information

When you access or use the GrainChain Service, our service provider may collect, and share with us, information such as your web request, IP address, access times, and other browsing information.

This information is used to (i) provide you the GrainChain Service and other services requested by you, (ii) improve the GrainChain Service and other services provided to you by us, (iii) notify user about updates to the GrainChain Service, and (iv) contact you for our own internal marketing purposes.



Anonymous Information

We may create Anonymous Information records from Personal Information by excluding information (such as your name) that would otherwise make such data personally identifiable to you. We may use Anonymous Information at our discretion and for any purpose. When we provide or use this information, we employ procedures so that the data does not identify you and we contractually prohibit recipients of the data from manipulating the data in a way that would re-identify it back to you.



Other

We may provide certain additional services and/or communications if you select such additional services and/or communications by opting-in to such additional services and/or communications using certain buttons provided in the user interface of our services. We will collect your name, e-mail address and telephone number (if provided) and any other information we specify in the user interface of our services where you opt-in by clicking on such buttons. We may use such Personal Information to send you the corresponding additional services and/or communications.



HOW WE SHARE YOUR INFORMATION


We will share your Personal Information with third parties only in the ways that are described in this Privacy Policy. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Information with certain third parties without further notice to you, as set forth below.



Service Providers

We may provide your information to third party service providers (such as, but not limited to, our cloud service provider) who may need the information to perform services for us. These third party service providers are required not to use your Personal Information other than to provide the services requested by us.



Payment and Transaction Processors

We may provide your banking and payment information to third party service providers engaged on our behalf, including payment and transaction processors, for the purposes of executing your transactions, effecting payment and servicing your account. In addition, in order to set up payment transactions, we may collect the following information as required by applicable law: first and last name, address, date of birth, email, phone, social security numbers, and/or driver’s license number.



Affiliates

To provide the GrainChain Service and provide various services to you, we may use the efforts of our parent company, and any subsidiaries, joint ventures, or other companies, existing or formed in the future, under a common control (collectively, “Affiliates”). We may share some or all of your Personal Information with our Affiliates in which case we will require our Affiliates to comply with this Privacy Policy.



Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event we are acquired by or merged with a third party, we reserve the right to transfer or assign the information we have collected from our users as a part of such merger, acquisition, sale, or other change of control. In an event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors’ rights generally, your Personal Information may be transferred by the trustee. If GrainChain or any of its Affiliates is acquired by or merged with a third party, that third party will possess the Personal Information in GrainChain’s or its Affiliate’s possession and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.



Other Disclosures

Regardless of any choices you make regarding your Personal Information (as set forth below), we may disclose your Personal Information (i) to respond to subpoenas, warrants, court orders, lawful requests or legal process, (ii) to establish or exercise our legal rights or defend against legal claims or protect other users, (iii) in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, or as otherwise required by law, or (iv) to investigate, prevent, or take action regarding any violation of this Privacy Policy or the Terms.



YOUR CHOICES


Changes and Deletion of your Data

If your Personal Information changes, or if you no longer desire to use or access the GrainChain Service, you may correct, update, amend, delete or request deletion by making the change in your registered account settings page, or by contacting us at [email protected] We will retain your information for as long as your account is active or as needed to provide you services.

Please note that even if you have asked us to delete your account or any associated data as described above, we may be required to keep certain information of yours and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. In any event, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements



Opting Out

We will periodically send you e-mails that directly promote the use of the GrainChain Service. Out of respect for your privacy, you may choose to stop receiving our marketing emails and you will have the opportunity to “opt-out” by following the unsubscribe instructions included in these emails or you can contact us at [email protected]



Services-Related Communications

While you may “opt-out” of certain services-related communications by following the unsubscribe instructions provided in the e-mail you receive or by contacting us at [email protected], you may not, despite your indicated e-mail preferences, “opt-out” of other services-related communications regarding your account or any payments made, or to be collected, by you, including receiving notices of any updates to our Terms or this Privacy Policy, except by terminating your account.



SECURITY


GrainChain employs technical and administrative control and maintain the security of information collected through the GrainChain Service. Although we follow generally accepted standards to protect the Personal Information submitted to us, both during transmission and once we receive, no method of transmission over the Internet, or method of electronic storage, is 100% secure and no company, including GrainChain, can completely or effectively eliminate the risks connected to handling information on the Internet. You acknowledge and agree that you provide your Personal Information at your own risk. If you have any questions regarding our security measures please contact [email protected]



CHILDREN


GrainChain does not knowingly collect or maintain Personal Information from or about children under the age of thirteen (13) and the GrainChain Service is not intended to be used by persons under thirteen (13). If you are under the age of thirteen (13), please do not use the GrainChain Service at any time nor in any manner If we learn that Personal Information of persons under thirteen (13) years of age has been collected on or through the GrainChain Service, then we may deactivate the account and/or make the user content inaccessible. If you find that we have personal information about anyone below thirteen (13) years of age, please inform us at [email protected]



CHANGES TO THIS PRIVACY POLICY


This Privacy Policy may be amended by us from time to time. If we make material changes to this Privacy Policy, we will notify you by posting the revised Privacy Policy on the GrainChain Website or through the user interface of the GrainChain Platform or by notifying you at the email you designated upon registration of your account. Your continued use of the GrainChain Service after such notification of changes as described above will constitute your agreement to such changes. If you object to any change, your sole recourse shall be to immediately terminate your account and cease using the GrainChain Service.



QUESTIONS AND ADDITIONAL INFORMATION


Please feel free to contact us at [email protected] if you have any questions about GrainChain’s Privacy Policy or GrainChain’s information collection and security practices.