Privacy Policy

Last Modified: Jun 7th, 2023

At Gruvv Inc. (“Gruvv,” “we,” “our,” or “us”), one of our main priorities is the privacy of our visitors. This Privacy Policy (the “Policy”) describes the types of information collected by us or on the Gruvv mobile application (the “Application”) and how we use it.

By using the Application, you agree to this Policy and our Terms of Use [ www.Gruvv.app ]. If you do not agree with this Policy, your choice is not to use the Application. Furthermore, if you have additional questions or require more information about our Policy, do not hesitate to contact us via email at [Support@gruvv.app].

If you are a California resident, please also see the below Appendix A “Privacy Information for California Residents” for supplemental California-specific privacy information.

TYPES OF INFORMATION WE COLLECT

Information You Directly Provide to Us. When you use the Application, there may be areas where you are asked to provide personal information such as your: name, payment information, billing/shipping address, telephone number, or email address or any other identifier by which you may be identified online or offline. For example, you may be asked to provide personal information when you, among other things, purchase a product or service directly from us, create an account, or sign up for email updates.

Information You Automatically Provide to Us. When you use the Application, we may collect certain information about you automatically such as IP address, GPS location, operating system, and date and time of visit by using various technologies such as [Note: modify these technologies as necessary] log files, cookies:

Log Files: The Application follows a standard procedure of using log files. These files log visitors when they visit websites. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the Application, tracking users’ use of the Application, and gathering demographic information.

Cookies: Like other applications, the Application uses ‘cookies’. These cookies are used to store information including users’ preferences, and the pages on the Application that the user accessed or visited. The information is used to optimize the users’ experience by customizing our Application content.

THIRD PARTY DATA COLLECTION

We may contract with third parties, to assist us with payment processing, advertising, and email marketing. These third parties may use various technologies, such as third party cookies, web beacons and pixels to collect information about you when you use the Application. We use the information collected by third parties for a variety of purposes, including learning which advertisements attracted you, to improve our content, and to help us analyze the Application’s effectiveness.

Advertising. Each of our prospective, and current advertising partners has their own privacy policy for their website, which we encourage you to review. Our advertising parties use certain technologies, such as cookies, to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit. Please note that we do not have access to or control over these cookies that are used by third-party advertisers.

Information from Emails. We may collect information on our email campaigns from our third party service providers, including whether you have read an email sent by us or on our behalf, forwarded an email, and when and how many times you have opened an email. We may use this information to improve our marketing, to understand our audience, and to improve the Application and our products and services. If you wish to opt-out of receiving emails from us, please see the “Opt-out” section, below.

HOW WE USE THE INFORMATION WE COLLECT

We use the information you provide to us for the following purposes:

To fulfill transactions placed by you;

To provide you with customer support;

To resolve problems with the Application;

To notify you about changes to the Application;

In our marketing efforts, including to send you email updates about our products and services;

For any other purpose for which you provide your consent; and

As generally permitted by applicable law.

We use information we collect automatically, which typically does not identify you, for various internal business purposes, including those described in this Policy. However, we may use information we collect automatically from your use of the Application that is not personal information and other information we collect or obtain that is otherwise de-identified, aggregated, or anonymous, for any purpose, including sharing it with third parties to improve the content and functionality of the Application, to better understand our customers and markets, and to improve our products and services.

DISCLOSURE OF YOUR INFORMATION

We may share your information, including your personal information:

With our subsidiaries and affiliates;

With our subcontractors, service providers, and other third parties we use to support our business and the Application, including our payment processors, maintenance providers, and marketing partners;

To a buyer or other successor in the event of or during a merger, divestiture, restructuring, dissolution, or other sale or transfer of some or all of Gruvv’s assets or equity, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Gruvv is among the assets transferred;

For any other purposes disclosed by us when you provide the information; or

With your consent.

We may also share your personal information to comply with any court order or legal obligation, including responding to any lawful government or regulatory request, or if we believe disclosure is necessary to enforce or protect our rights, property, or safety, or that of our users or third parties.

YOUR CHOICES ABOUT OUR COLLECTION, USE, AND DISCLOSURE

You have choices regarding the information you provide to us and that we collect, including:

Cookies. If you do not want us to collect cookies, you may set your browser to refuse some cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of the Application may then be inaccessible or may not function properly. Information on deleting or controlling cookies can be found at www.aboutcookies.org. Furthermore, visitors may choose to decline the use of DART cookies by visiting the Google ad and content network Privacy Policy at the following URL – http://www.google.com/privacy_ads.html.

E-mail Opt-Out. You may opt-out of receiving future communications from us by clicking on the “unsubscribe” link at the bottom of any email from us (or sent on our behalf).

If you are a California resident, please also see the below Appendix A titled “Privacy Information for California Residents” for further supplemental information about additional rights you may exercise.

EXTERNAL WEBSITES

Third Party Links. Our Application contains links to websites operated and maintained by third parties. We have no control over and are not responsible for the privacy policies or content on those websites, and any links to third party websites do not imply an affiliation between Gruvv and the website owner, or any endorsement, approval, or verification of any content contained on those websites. Privacy policies on third party websites and mobile applications may be different from our Policy. You access such links at your own risk. You should always read the privacy policy of a website or mobile application before disclosing any of your information.

Social Media. If you use any functionality of the Application allowing you interact with social media platforms such as Facebook® or otherwise interact with us on social media, generally, then please be aware that: (a) we may display your email address and/or social media handle (e.g., username) to other users; (b) we may use information you provide about yourself or other users to facilitate communications; (c) we may collect information about interactions with us and receive information from social media platforms about you; and (d) display pictures on our Application.

Purchasing Products or Services on the Application. When you purchase a product or service directly from Gruvv, your payment information may be collected by a third party payment provider. The third party payment provider will collect information on our behalf in order to fulfill the order placed by you.

DO NOT TRACK

The Application does not respond to “do not track” requests. All traffic is treated as equal and processed the same. If you desire to have your browsing be private, we suggest that you use your web browser’s private or incognito function, or a similar option.

CHILDREN UNDER THE AGE OF 18

The Application will not collect any data on children under the age of 18, and we do not knowingly collect personal information from children under 18. In the event that we learn that we have collected personal information from a child under the age of 18 without parental consent, we will delete that information and otherwise comply with the requirements of any applicable law including the Children’s Online Privacy Protection Act. If you believe that we might have any information from or about a child under the age of 18, please contact us at [Support@gruvv.app].

SECURITY

We strive to use reasonable means to secure your personal information while you are using the Application. However, please keep in mind that the transmission of information over the Internet and on mobile platforms is not always secure, which means we cannot and do not guarantee the security or confidentiality of any personal information your provide to us. Given this reality, your use of the Application, and your decision to provide personal information to us, is at your own risk.

CHANGES TO THIS POLICY

The effective date of this Policy is the date next to the words “Last Modified” at the top of this Policy. We may update this Policy at any time, in our sole discretion, if we make material changes to the way we handle your personal information, or if material changes are necessary due to law. Any changes we make to this Policy will be effective immediately upon the posting of the updated Policy. As such, we encourage you to review this Policy regularly. Your continued use of the Application after we make changes will constitute your acceptance of any such changes.

If you have questions or comments about this Policy or our Terms of Use, wish to remove or change your contact information in our database, or do not want to receive future mailings or other communications, as well as other inquiries, just contact us at any time using one of the options below:

Via e-mail: [Support@gruvv.app]

Appendix A

Privacy Information for California Residents

Effective Date: June 7th, 2023

This Appendix applies solely to individuals who reside in the State of California (“consumers” or “you”). This Appendix complies with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Appendix. This Appendix does not apply to personal information outside the scope of the CCPA.

Disclosures

The below chart lists the categories of personal information that we may collect and have collected in the past 12 months and how we use such information.

Categories of Personal Information

Categories of Sources from which the Personal Information is Collected

How We Use the Personal Information (Business Purposes)

Categories of Services Providers and Third Parties with whom Personal Information is Shared

Identifiers. This may include a real name, alias, address, email address, phone number, Social Security Number, driver’s license number, online identifier, IP address, account username and password, job title, or other similar identifiers.

You or your agents; our other customers; service providers; ad networks; data analytics providers; our affiliates; social media networks; and online third party marketplaces.

To provide you with information, products, or services; to advertise or market to you; and for our own legal obligations and business needs.

Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates; ad networks; data analytics providers; prospective purchasers of our business; outside auditors and lawyers; and social networks.

Internet and network information. This may include information on your interaction with a website, application, or advertisement, such as browsing history and how you use your account.

You; service providers; ad networks; data analytics providers; our affiliates; social media networks; and online third party marketplaces.

To provide you with information, products, or services; to advertise or market to you; to improve our services and products; for our own business needs; and to secure our websites.

Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates; ad networks; data analytics providers; and social networks.

Device information. This may include the operating system of your device, device identifier, the type of device you are using, or your geolocation information.

You; service providers; ad networks; data analytics providers; our affiliates; social media networks; and online third party marketplaces.

To provide you with information, products, or services; to advertise or market to you; to improve our services and products; to secure our websites; and for our own business needs.

Entities that we are required to share with pursuant to law or for legal proceedings; service providers; ad networks; data analytics providers; and social networks.

Order information. This may include information about what you order, shipping, returns, product complaints, or warranties.

You or your agents; service providers; ad networks; data analytics providers; our affiliates; social media networks; and online third party marketplaces.

To provide you with information, products, or services; to advertise or market to you; for our own legal obligations and business needs; and to improve our services and products.

Payment and credit information. This may include your credit or debit card information, banking information, information about your payment transaction, or other financial information you provide us.

You or your agents; service providers; our affiliates; and online third party marketplaces.

To provide you with information, products, or services and for our own legal obligations and business needs.

Entities that we are required to share with pursuant to law or for legal proceedings; service providers; and our affiliates.

Other information you submit to us or our partners. This may include requests or communications you submit to us, including emails, ratings, or customer service call recording.

You; service providers; our affiliates; social media networks; online third party marketplaces; and our other customers.

To provide you with information, products, or services; to advertise or market to you; to improve our products and services; and for our own legal obligations and business needs.

Entities that we are required to share with pursuant to law or for legal proceedings; service providers; our affiliates; outside auditors, insurers, and lawyers; and social networks.

Inferences we draw about you. This may include information about your preferences, characteristics, predispositions, behavior, or other trends that help us identify which products you may be interested in.

You; service providers; our affiliates; social media networks; data analytics providers; and ad networks.

To provide you with information, products, or services; to advertise or market to you; to improve our products or services; and for our own business needs.

Service providers; our affiliates; ad networks; data analytics providers; and social networks.

Sale of Personal Information

In the past 12 months, we have not sold any personal information.

California Residents’ Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information, described below. Below are your CCPA rights and how to exercise those rights.

Access to Specific Information and Data Portability Rights (“Right to Know”)

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. You could request:

The categories of personal information we collected about you;

The categories of sources of the personal information we collected about you;

Our business or commercial purpose for collecting that personal information;

The categories of third parties with whom we share that personal information; or

The specific pieces of personal information we collected about you.

Our employees and employees of our business partners and service providers do not have a Right to Know.

Deletion Request Rights

You have the right to request that we delete some or all of the personal information that we have collected from you and retained, subject to a number of exceptions. We are not required to delete personal information that is: (a) necessary to complete a transaction with you or for warranty or product recalls; (b) used for security purposes, to prevent fraud, to fix errors, or to comply with law; (c) reasonable for us to use for internal purposes given our relationship with you; or (d) compatible with the context in which you provided the information. The list of exceptions above is not exhaustive, and we may also deny a deletion request as otherwise permitted by law.

Our employees and employees of our business partners and service providers do not have a Right to Deletion.

c. Exercising Your Rights

To exercise your rights described above, please submit a verifiable consumer request to us by either:

Emailing us at (Support@gruvv.app].

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. If you are making a request on behalf of another person, you must provide written legal documentation that you are authorized to act on behalf of that individual.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may not be able to fulfill your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. To verify your identity, we may request up to up to three pieces of personal information about you, and we reserve the right to take additional steps as necessary to verify your identity if we have reason to believe a request is fraudulent.

d. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the date we receive your verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

e. Non-Discrimination

You have the right to not be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services;

Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

Provide you a different level or quality of goods or services; or

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services

4. Other California rights

California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us through the information provided above.