Last Updated: December 21, 2023
This privacy policy ("Privacy Policy") explains how Grindery Inc. ("Company", "we", "our", or "us") collects, uses, processes, discloses, shares, and stores personal data of users of its websites, https://www.grindery.io/ https://t.me/GrinderyAIBot https://www.grindery.io/zapier, and https://www.grindery.io/safe-zapier (the "Sites"). This Privacy Policy applies to the Sites, applications, products, and services (collectively, "Services") on or in which it is posted, linked, or referenced.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By using our Sites or utilizing our Services, you acknowledge you have read and understood this Privacy Policy. For the purposes of applicable data protection laws, including the European Economic Area data protection law, the data controller is Grindery Inc., Via España, Delta Bank Tower, Floor 6, Suite 604D, Panama City, Republic of Panama.
By using the Services, you accept the terms of this Privacy Policy and our terms of use, and consent to our collection, use, disclosure, and retention of your information as described in this Privacy Policy. If you have not done so already, please also review our terms of use. The terms of use contain provisions that limit our liability to you and require you to resolve any dispute with us on an individual basis and not as part of any class or representative action. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.
This Privacy Policy forms part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions, including but not limited to the Grindery One (G1) Token – Terms and Conditions of Token Distribution and Usage (where applicable).
1. The Information We Collect
We collect and process personal data to provide and improve our products and services (as elaborated below). The information we collect may include:
Account Information: When you create an account, we may collect your name, email address, and age to ensure compliance with legal requirements.
Transaction Data: We securely store information related to your cryptocurrency transactions, including transaction history, amounts, and recipient details.
Interaction Information: Information about you that you give us directly when you interact with us.
Device Information: We gather information about the device you use to access our services, such as the type of device, operating system, and browser.
Usage Information: We may collect data about how you interact with our website and services, including the features you use and the pages you visit.
Telegram Information: When you create or sign up on your Grindery AI Wallet, we collect your Telegram ID number, your phone number associated with your Telegram account, and your Telegram Handle name.
Technical Information: Such as your Ethereum Virtual Machine (EVM) address, application programming interface (API)-key, and network information regarding transactions.
Financial Information: Such as a bank account number and bank routing number; financial assets holdings such as your credit card or other payment card details (and third parties who you provided through our bot as the On/Off Ramp services listed as available in our products.
Information Automatically Collected: We collect "Log Data," including information about how you use our Sites, such as your IP address, device and browser type, operating system, the pages or features you visit, the time spent on those pages or features, the frequency of use, search terms, and clicked links. This information is used to administer and improve the Service, expanding its features and tailoring it to user preferences.
Cookies and Similar Technologies: That our site(s) use to collect and store information. Most web browsers automatically accept cookies, but you can change your browser settings if you prefer. However, this may limit your use of our website. We use cookies and similar technologies based on their necessity for performance, legitimate interests, and legal requirements.
Further Information related to On / Off Ramp Services: Further information we collect from you in relation to our products and external financial services connected like the ramps could be:
- Additional personal details, such as your birth country, citizenship, social security number, birthplace, employer, and profession;
- Passport and/or photographic identification to verify your identity;
- Details necessary to comply with anti-money laundering (AML) regulations and know-your-customer (KYC) requirements, such as country of citizenship and birthplace;
- Origin of funds for participation in token launches; and
- Information provided by you regarding your token holdings, such as earnings derived from staking and the quantity of tokens in your wallet.
To the extent permitted by law, we may also obtain other information about you such as contact information, change of address or demographic information from commercially available sources
2. How We Use Your Information
We use your information for the following purposes:
- Provide Services: To create and manage your cryptocurrency wallet, process transactions, and enable access to additional features.
- Improve our Services: We analyze data to enhance and optimize our services, including developing new features and addressing issues.
- Communication: We may send you important updates, service notifications, and promotional materials based on your preferences.
- Presenting content from our Bot in the most effective manner for you and your device.
- Verifying and processing financial transactions related to payments.
- Legal Compliance: In order to meet our legal obligations, which include compliance with age restrictions, relevant laws such as anti-money laundering (AML) laws and know-your-customer (KYC) requirements, as well as responding to lawful requests and legal processes, such as subpoenas or requests from government authorities.
- Information Processing: Information you grant us access to when using our tools and services on our website, we process it for the purpose of fulfilling information processing.
3. Disclosure and sharing of personal data
We may from time to time and in compliance with all applicable laws on data privacy, share personal data with the following categories of third parties:
- Our third-party service providers: These may include financial institutions, credit card companies, and their respective service providers, agents, contractors or third party service providers who provide services to us such as telecommunications, information technology, payment, data processing, storage and archival services. The lawful basis we rely on for sharing personal data with these recipients is that it is necessary for our legitimate interests (namely the receipt of services to support our business and for us to provide the Services).
- Our professional advisers: These may include our legal advisors, auditors, accountants, consultants, and insurers. Our professional advisors will process personal data as necessary to provide their services to us. The lawful basis we rely on for sharing personal data with these recipients is that it is necessary for our legitimate interests (namely the receipt of professional services).
- Relevant authorities: These will include governmental authorities (including law enforcement and tax authorities) and regulators. These recipients will use your personal data in the performance of their regulatory and law enforcement duties. The lawful basis we rely on for sharing personal data with these recipients is that the processing is either necessary to comply with a legal obligation to which we are subject, or necessary for our, or a third-party's, legitimate interests, or where it is in the interests of the wider public to do so.
Please be assured that when we disclose your personal data to such parties, we will disclose only the personal information that is necessary to deliver the service required, and will also require them to ensure that any personal data disclosed to them are kept confidential and secure.
For more information about the third parties with whom we share your personal data, you may, where appropriate, wish to refer to the agreement(s) and/or terms and conditions that govern our relationship with you. You may also contact us for more information (please see section 14 below).
We wish to emphasize that we do not sell personal data to any third parties without your explicit consent, and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or any applicable law.
You are responsible for ensuring that the personal data you provide to us is accurate, complete, and not misleading and that such personal data is kept up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and services you have requested. To update your personal data, please contact us (please see section 14 below for contact details). Where you provide us with personal data concerning individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.
We may transfer, store, process and/or deal with your personal data in any jurisdiction, and accordingly such personal data may be transferred to computers, servers or hardware located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information (including without limitation the standard contractual clauses approved by the European Commission). Your consent to this Privacy Policy followed by your submission of such information represents your agreement to the transfer of personal data as described herein.
4. How We Protect Your Information
All information you provide to us is stored on our secure servers. All payment transactions will be encrypted using SSL technology.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Our Sites may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
5. How Long We Keep Your Information
We retain personal data for as long as you have an account with us and for a period during which you have expressed interest in our Services. This retention period allows us to fulfill our contractual obligations to you and resolve any legal proceedings. Additionally, we may retain aggregate information beyond this time for research purposes and to enhance our services. It's important to note that the information contained within the chats maintained with Grindery AI Bot by the user may also be stored, not only by us but also by third parties such as the Telegram messaging service. If you have any further questions, please contact us at legal@grindery.io.
6. Rights under European Union General Data Protection Regulation ("GDPR")
If you are an EU data subject, you have certain rights regarding the collection and processing of personal data. Subject to certain exemptions, you may be entitled to exercise the following rights under certain circumstances:
- Right of access: You may request to access: (i) information regarding whether your personal data is retained; and/or (ii) a copy of all personal data relating to you which we retain, including information on the purposes of the processing, the categories of personal data concerned, the data recipients as well as potential retention periods.
- Right to Rectification: You may request that we correct any incomplete or inaccurate personal data we hold about you.
- Right to Erasure: You may ask us to delete or erase your personal data. Please note that we may not always be able to comply with your request for deletion / erasure if there are specific legal reasons which apply.
- Right to withdraw consent: If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time, but provided always that this shall not affect the lawfulness of processing based on your prior consent.
- Right to Object: You may object to the processing of your personal data, including the right to object to marketing. If you wish to exercise this right, please provide us with information about your situation. After the assessment of the information about your situation as presented by you, we will either stop processing your personal data or present you with our compelling legitimate grounds for the ongoing processing.
- Right to Restriction of Processing: You may to request that we restrict the processing of your personal data for certain periods, such as the period where we are verifying or investigating the exercise of your right to rectification / right to object (as discussed above).
- Automated Decision-Making and Profiling: You have the right to be free from decisions based solely on automated processing of your personal data, including profiling, that affect you, unless such processing is necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent to such processing.
- Right to Data Portability: You may require that we: (i) send to you personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format; and/or (ii) transmit such data to another controller without hindrance. Where it is technically feasible, you shall have the right to require such data to be transmitted directly from us to another controller.
- Right to lodge complaints: While you have a right to lodge a complaint with a supervisory authority regarding any misuse of your personal data and/or any breaches of data protection laws, we would appreciate the opportunity to directly address any GDPR issues you may have. If you have any such issues or if you would like to exercise any of the rights listed above, please contact us at legal@grindery.io.
7. Cookies & other technologies
Our website uses cookies and similar technologies, such as pixel tags or web beacons, to collect and store information. These technologies involve pieces of information or code that are transferred to or accessed from your computer or mobile device to store and track information about you. They enable you to be remembered when interacting with websites and online services and can manage features, content, and personalized experiences. By using cookies and similar technologies, we distinguish you from other users and provide a better browsing and service experience. Most web browsers automatically accept these technologies, but you can change your browser settings if you prefer. However, this may limit your use of our website. Some cookies and technologies last for the duration of your session, while others remember you for longer. We use these technologies to fulfill our contract with you, pursue our legitimate interests, and comply with legal requirements. For more information, please refer to our Grindery Cookie Policy at the end of this document.
8. Our promotional updates and communications
With your consent or where permitted by law, we will use your personal information for marketing analysis and to send you promotional updates by email or Telegram message. You can opt out of further marketing at any time, by email requesting un-subscription, or by deactivating Telegram notifications from Grindery AI Wallet.
9. Age Restrictions
You must be aged 18 years or older (or 21 in jurisdictions where applicable) to use the Services. We take steps to verify the age of users during account creation.
10. Information never required and that we will not collect.
We will never require you to provide us with your private keys; be aware of that. Avoid and take as a scam if you receive any request for your private keys and/or seed words from any site / individuals purporting to be our customer service representatives.
11. Personal data and the Blockchain
Blockchain technology, also known as distributed ledger technology (DLT), is at the core of our business. Blockchains are decentralized and made up of digitally recorded data in a chain of packages called "blocks". The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed all over the world (across several "nodes" which usually replicate the ledger) this means there is no single person making decisions or otherwise administering the system (such as an operator of a cloud computing system), and that there is no centralized place where it is located either.
Accordingly, by design, a blockchain’s data cannot be changed or deleted and is said to be "immutable". This may affect your ability to exercise your rights such as your right to erasure ("right to be forgotten"), or your rights to object or restrict processing of your personal data. Data on the blockchain cannot be erased and cannot be changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted.
In certain circumstances, in order to comply with our contractual obligations to you (such as delivery of tokens or provision of other services) it will be necessary to collect certain personal data, such as your wallet address, onto the blockchain; this is done through a smart contract and requires you to execute such transactions using your wallet’s private key.
The ultimate decisions to (a) transact on the blockchain using your wallet address, as well as (b) share the public key relating to your wallet address with anyone (including us) rests with you. IF YOU WANT TO ENSURE YOUR PRIVACY RIGHTS ARE NOT AFFECTED IN ANY WAY, YOU SHOULD NOT TRANSACT ON BLOCKCHAINS AS CERTAIN RIGHTS MAY NOT BE FULLY AVAILABLE OR EXERCISABLE BY YOU OR US DUE TO THE TECHNOLOGICAL INFRASTRUCTURE OF THE BLOCKCHAIN. IN PARTICULAR THE BLOCKCHAIN IS AVAILABLE TO THE PUBLIC AND ANY PERSONAL DATA SHARED ON THE BLOCKCHAIN WILL BECOME PUBLICLY AVAILABLE.
Specifically, information regarding your digital wallet addresses (including transactions performed by said digital wallet addresses), public cryptographic key relating to digital wallet addresses on distributed ledger networks and/or similar information which you utilize to access the Website will be linked to your user account. By accessing our services, you provide your consent to our services reading and/or accessing information from such digital wallet addresses in order to verify ownership of any digital assets or tokens associated with such address (whether fungible or non-fungible). Users will have the ability to "add" their digital wallet address to access our services, as well as the ability to "remove" such stored wallets. All data obtained by us in connection with your digital wallet addresses shall be treated as personal data and dealt with in accordance with the provisions of this Privacy Policy.
12. Cookie Policy
A cookie is a small text file placed on your computer or mobile device when you visit a website or use an app, which may include an anonymous unique identifier. The Sites use the following categories of cookies.
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
Performance and Functional Cookies
These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. Also, enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages.
All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our site, and will not be able to monitor its performance.
13. Changes on this Privacy Policy
We reserve the right to amend this Privacy Policy to ensure that this Privacy Policy is consistent with any developments to the way we use your personal data or any changes to the laws and regulations applicable to us. Any changes we make to our Privacy Policy in the future will be posted on this page and, in relation to substantive changes, will be notified to you by Grindery AI Updates Channel on Telegram or directly by a direct message through Grindery AI Bot. The changes take effect immediately upon the posting of changes to this Privacy Policy on this page, and your continued use of the Sites following such update will be deemed as your acceptance of those changes. You are encouraged to review the Privacy Policy from time to time to ensure that you are well informed of our latest policies in relation to personal data protection. All communications, transactions, and dealings with us shall be subject to the latest version of this Privacy Policy in force at the time.
14. Contact Us
We will receive your comments, questions, or requirements related to this Privacy Policy at:
Grindery Inc
Via España, Delta Bank Tower, Floor 6, Suite 604D Panama City, Republic of Panama legal@grindery.io