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US State Specific Disclosures Policy

US STATE SPECIFIC DISCLOSURES POLICY

Last Revised: August 2023

OVERVIEW

This supplemental U.S. State-Specific Privacy Disclosures Policy (this “Supplemental Policy”) supplements and is expressly made part of the information contained in the Grit Capital Corporation Privacy Policy (the “Privacy Policy”) and relates to our collection and use of Personal Information of residents in California, Colorado, Connecticut, Utah, and Virginia, including where such use is governed by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CPRA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Protection Act (“CTDPA”), the Virginia Consumer Data Protection Act (“VCDPA”) and the Utah Consumer Privacy Act (“UCPA”), to the extent applicable. To the extent applicable, those laws will be referred to as the “applicable state laws” in this Supplemental Policy. References to “Grit Capital,” “we,” “us,” or “our” means and refers to Grit Capital Corporation, and other capitalized terms have the meaning set forth in the main Privacy Policy. Any terms defined in the applicable state laws have the same meaning when used in this Supplemental Policy.

1. PERSONAL INFORMATION WE COLLECT.

We collect, process, and retain various types of Personal Information, as defined and described in our Privacy Policy. Personal Information includes information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. It does not include de-identified or aggregate information, or public information lawfully available from government records. We retain Personal Information only for as long as it is necessary for the purpose(s) for which it was collected, as further explained in our Privacy Policy.

The following chart describes, by category, the types of Personal Information covered by this Supplemental Policy that we have collected from our consumers within the last 12 months.

Minors. We do not knowingly collect any Personal Information of minors. If you are an individual, by accessing or using the Platforms and/or Services you represent and warrant that you are of legal age to form a binding contract. If we learn that Personal Information of a minor has been inadvertently collected without parental or guardian consent, we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that a minor for which you are responsible has provided his or her Personal Information to us without your consent, then you may alert us by contacting us at [email protected], and request that we delete such person’s Personal Information from our systems.

2. ADDITIONAL INFORMATION ABOUT USE AND SHARING OF PERSONAL INFORMATION.

In addition to the sharing of Personal Information as reflected on the chart above, we may disclose any information, including Personal Information, as indicated in our Privacy Policy.

Payment Processing. Although you can submit credit card or other payment card information through the Platforms, we do not receive this information. All payment information is transmitted directly to our third-party payment processor “Stripe,” through an internet connection secured by industry-standard encryption technology. “Stripe” then communicates to us whether your payment has cleared, but does not provide any credit card or other payment card information to us.

3. HOW WE USE THE INFORMATION.

We may use the information you provide to:

To comply with applicable laws and regulations
To manage business risks
To provide our Services to you
To establish and enhance our relationship with you
To operate, maintain, enhance, and provide our Services
To respond to specific requests from you
To facilitate, complete, and confirm an order for Services that you have placed with us
To send you messages relating to the delivery of the Services
To help us better understand your use of the Serves
To administer the Services and protect the security of the Platforms and/or the Services when necessary
To contact you to discuss your feedback

Grit Capital collects and uses Users’ Personal Information to continually improve our Platforms and Services based on the information and feedback we receive from you. We also use applications provided by third parties, such as Google Analytics, to evaluate the usage of our Platforms and our provided Services. These tools help us to improve Users’ experience and performance of our Platforms and provided Services.

Aggregate information. We may aggregate and anonymize your Personal Information to the extent that any identifiable information has been irreversibly modified such that you can no longer be identified from the processed information, whether directly or indirectly, and that it is no longer subject to applicable privacy laws. We may use such aggregated and anonymized information for the purpose of improving the quality of our Services and/or Content, and to develop new Services or Content.

Marketing and Experience. We may use your Personal Information to provide you with information about our features, services and other offerings that may be of interest to you (including, but not limited to our merchandise referral program), to facilitate your participation in sweepstakes or contests, and to fulfill prizes. This information may be provided to you by mail or phone and/or, with your prior consent, by e-mail. We may also send information or offers to groups of Users on behalf of our third-party partners and advertisers. We may share your Personal Information with certain other websites that we link to, to the extent that you click on such links, in order to enhance your experience in connection with our Platforms and/or Services.

4. DISCLOSURE OF PERSONAL INFORMATION.

We may disclose Personal Information for the purposes outlined in our Privacy Policy.

Sales of Personal Information. As described in our Privacy Policy, we work with certain third parties, partners, and sources to show ads that are targeted to your interests. These activities may be considered “selling” or “sharing” of your Personal Information under California law. We currently do not sell Personal Information of our Users.

Targeted Advertising Partners. We disclose certain Personal Information (e.g., identifiers, commercial information, contact preference information, geolocation information, internet or other electronic network activity information and inferences) to and work with third-party companies, such as Facebook and Instagram on behalf of advertisers using their own social media accounts, that support our advertising and marketing efforts, including to serve interest-based advertisements across the internet and to track and categorize your activity, interests, and device(s) used over time on our Platforms and on third-party websites. The advertising networks and related providers gather this information to create individual profiles that are disclosed to us, which allows us the ability to match those individual customer profiles with advertisements we believe may be most relevant to a particular customer. You may opt-out of targeted advertising by emailing us at [email protected] with the SUBJECT LINE: “OPT OUT OF TARGETED ADVERTISING” For Virginia consumers, please see Section 10 “Virginia Privacy Rights” below for your opt-in consent procedures.

Third-Party Sites. Our websites may be linked to internet websites operated by other companies. You should consult the respective privacy policies of these third-party websites. Our Privacy Policy and this Supplemental Policy does not apply to, and we cannot control the activities of, such other third-party web sites. Please be aware that we do not warn you when you choose to follow a link through to another platform or service from our Platforms and/or Services.

5. NOTICE OF FINANCIAL INCENTIVE.

Grit Capital may offer discounts on Products by joining our email subscription list or other promotions. The availability of these promotions to you at any given time will vary. If and when we offer such programs, we may ask for your Personal Information (such as your name and email address) as a prerequisite to your participation in the program. You may withdraw from any program you enroll in by following the unsubscribe link at the bottom of any of our marketing emails.

While we do not assign a monetary value to the Personal Information that we collect from Grit Capital subscribers in exchange for the benefits that our subscription offers, we do receive value in the form of customer loyalty and increased purchase engagement. In determining the value to Grit Capital, we considered the revenue generated from activities related to the collection and retention of Grit Capital Users’ Personal Information less expenses related to the benefits offered. This value will vary by User depending on purchases made, which offer a User takes advantage of, and many other factors.

6. CALIFORNIA PRIVACY RIGHTS.

California residents have the right to receive certain disclosures regarding a business’s processing of Personal Information, as well as certain rights with respect to our processing of such Personal Information. To the extent that you are a resident of California, and we collect your Personal Information subject to applicable California law, you may have the following rights with respect to your Personal Information:

Right to Access

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. When we receive your request to know what Personal Information we have collected from you, we will disclose to you: (i) the categories of Personal Information we collected about you; (ii) the categories of sources from which that information was collected; (iii) our purpose for collecting or selling that Personal Information; (iv) the categories of third parties with whom we share that Personal Information; (v) the specific items of Personal Information that we collected about you; and (vi) if we sold or disclosed your Personal Information for a business purpose, we will identify for sales of information, the Personal Information categories that each category of recipient purchased; and, where we have disclosed your Personal Information for a business purpose, we will identify the Personal Information categories that each category of recipient obtained. You may request these disclosures twice within a 12-month period.

Right to Delete Personal Information

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request to delete your Personal Information, we will delete (and direct our service providers to delete) such information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CPRA. Accordingly, by way of example, 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; give 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.

We may, however, offer you certain financial incentives permitted by the CPRA that can result in different prices, rates, or quality levels provided that such incentive is reasonably related to the value of the Personal Information. We will not include you as a participant in any financial incentive program without your prior “opt-in” consent, which you may revoke at any time.

Right to Correct Inaccurate Information

You have the right to request that we correct any inaccuracies that appear in the Personal Information that we collect from you and retain. Once we receive and confirm your request to correct your Personal Information, we will correct such information in our records and will alert you to the changes that were made.

Right to Opt-Out of the Sale or Sharing of Data

You have the right to opt-out of the “sale” or “sharing” of your Personal Information. Where applicable, to opt-out from the sharing or sale of information described above, please email [email protected] with the subject “Do Not Sell or Share My Personal Information” provide us with your name and email address.

Right to Limit Use of Disclosure of Sensitive Personal Information (“SPI”)

You have the right to limit the use or disclosure of your SPI if we are using your SPI beyond what is reasonable and proportionate to provide access to the Platforms and/or use of the Services. SPI may include precise geolocation data that we collect. You can make a request for us to limit the use or disclosure of your SPI by emailing [email protected] with the subject “Do Not Sell or Share My Personal Information” provide us with your name and email address.

Verifiable Consumer Requests

If you submit a request to us to disclose how we collect and use your Personal Information or to delete your Personal Information from our records, we must be able to verify your request. To be “verifiable,” you must provide sufficient information to allow us to reasonably verify that you are the person about whom we collected Personal Information or that you are an authorized representative of that person, and you must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it (a “verifiable consumer request”). Please indicate that you are making a request pursuant to your state privacy rights. You must provide us with the following information: (1) first and last name; (2) email address; (3) and zip code. We cannot respond to your request if it is not a verifiable consumer request. 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. You may also make a verifiable consumer request on behalf of your minor child. To make a verifiable consumer request for disclosure of our collection and use of your Personal Information or to delete your Personal Information, you can call us at our toll-free number: [insert phone number] or email us at [email protected].

We will try to respond to a verifiable consumer request within 45 days of its receipt. If we need more time (up to 90 days), we will let you know in writing, either by email or mail (or, if you have an account with us, through your account), why we need more time and when we will provide our response. There is no charge to you for us 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.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Security of Your Personal Information

Grit Capital takes reasonable precautions to protect the security of your Personal Information but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security. We follow generally accepted industry standards to safeguard your Personal Information from loss or theft, unauthorized access, disclosure, duplication, use or modification through security measures appropriate to the sensitivity of the information. These measures include internal reviews of our data collection, storage and processing practices and security measures which include appropriate encryption and physical security measures to guard against unauthorized access to systems where we store Personal Information.

We restrict access to your Personal Information to our employees, contractors, and suppliers who need to know that information in order to process it on our behalf or to provide our Services to you. Our employees, contractors, and suppliers are bound by confidentiality obligations and may not use the information for any unauthorized purpose. Our employees may be subject to discipline, including termination and criminal prosecution, if they fail to meet their obligations described in the Privacy Policy and this Supplemental Policy. Our suppliers and contractors are required to protect your Personal Information in a manner that is consistent with the Privacy Policy and this Supplemental Policy.

Other California Privacy Rights

Because we value your privacy, we will not provide personal identification information about you to third parties for their solicitation or marketing purposes.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits Users of our Platforms 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 send an email to [email protected].

7. COLORADO PRIVACY RIGHTS.

Colorado residents have the right to receive certain disclosures regarding a business’s processing of Personal Information, as well as certain rights with respect to our processing of such Personal Information. To the extent that you are a resident of Colorado, and we collect your Personal Information subject to the applicable Colorado law, you may have the following rights with respect to your Personal Information:

Right to Access

You have the right to confirm whether we are processing your Personal Information and to access such Personal Information, including: (i) the categories of Personal Information we collect about you; (ii) the categories of sources from which we collect such Personal Information; (iii) the business or commercial purpose for collecting, selling or sharing Personal Information about you; (iv) the categories of third parties with whom we shared or disclosed such Personal Information; and (v) the specific pieces of Personal Information we have collected about you.

Right to Correction

You have the right to correct inaccuracies in any Personal Information we have collected about you, taking into account the nature of the Personal Information and the purposes for processing your Personal Information.

Right to Deletion

You have the right to delete the Personal Information that has been provided to us by you.

Right to Data Portability

You have the right to obtain a copy of the Personal Information that you previously provided to us in a structured, commonly used, and machine-readable format, so that you can transfer it to another party, if you have given us permission to process your data and where the processing was carried out by automated means.

Right to Opt-Out of Sale, Targeted Advertising and Profiling

For purposes of Colorado law, a “sale” includes disclosing Personal Information to a third party in exchange for monetary compensation or other valuable consideration. Colorado residents have the right to opt-out of the processing of your Personal Information by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Information for such profiling. To opt out of targeted marketing, where applicable, please email [email protected] with the subject “Do Not Sell or Share My Personal Information” provide us with your name and email address.

Right to Appeal

If we decline to take action regarding your request, you have the right to appeal our decision. We will notify you providing our reasons and instructions for how you can appeal the decision. You have the right to contact the Colorado Attorney General if you have concerns about the result of the appeal.

8. CONNECTICUT PRIVACY RIGHTS.

Connecticut residents have the right to receive certain disclosures regarding a business’s processing of Personal Information, as well as certain rights with respect to our processing of such Personal Information. To the extent that you are a resident of Connecticut, and we collect your Personal Information subject to the applicable Connecticut law, you may have the following rights with respect to your Personal Information:

Right to Access

You have the right to confirm whether we are processing your Personal Information and to access such Personal Information.

Right to Correction

Right to Deletion

You have the right to delete the Personal Information that has been provided to us by you.

Right to Data Portability

Right to Opt-Out of Sale, Targeted Advertising and Profiling

For purposes of Connecticut law, a “sale” includes disclosing Personal Information to a third party in exchange for monetary compensation or other valuable consideration. Connecticut residents have the right to opt-out of the processing of your Personal Information by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Information for such profiling. To opt out of targeted marketing, where applicable, please email [email protected] with the subject “Do Not Sell or Share My Personal Information” provide us with your name and email address.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your rights under the CTDPA. Accordingly, by way of example, 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; give 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.

Right to Appeal

If we decline to take action regarding your request, you have the right to appeal our decision. We will notify you providing our reasons and instructions for how you can appeal the decision. If the appeal is denied, we will provide a way for you to contact the Connecticut Attorney General to submit a complaint.

9. UTAH PRIVACY RIGHTS.

Utah residents have the right to receive certain disclosures regarding a business’s processing of Personal Information, as well as certain rights with respect to our processing of such Personal Information. To the extent that you are a resident of Utah, and we collect your Personal Information subject to the applicable Utah law, you may have the following rights with respect to your Personal Information:

Right to Access

You have the right to confirm whether we are processing your Personal Information and to access such Personal Information.

Right to Correction

Right to Deletion

You have the right to delete the Personal Information that has been provided to us by you.

Right to Data Portability

Right to Opt-Out of Sale, Targeted Advertising and Profiling

For purposes of Utah law, a “sale” includes disclosing Personal Information to a third party in exchange for monetary compensation. We do not “sell” Personal Information under this definition. Utah residents have the right to opt out of the processing of your Personal Information by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Information for such profiling. To opt out of targeted marketing, where applicable, please email [email protected] with the subject “Do Not Sell or Share My Personal Information” provide us with your name and email address.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your rights under the UCPA. Accordingly, by way of example, 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; give 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.

10. VIRGINIA PRIVACY RIGHTS.

Virginia residents have the right to receive certain disclosures regarding a business’s processing of Personal Information, as well as certain rights with respect to our processing of such Personal Information. To the extent that you are a resident of Virginia, and we collect Personal Information subject to the applicable Virginia law, you may have the following rights with respect to your Personal Information:

Right to Access

You have the right to confirm whether we are processing your Personal Information and to access such Personal Information.

Right to Correction

Right to Deletion

You have the right to delete the Personal Information that has been provided to us by you.

Right to Data Portability

Right to Opt-Out of Sale, Targeted Advertising and Profiling

For purposes of Virginia law, a “sale” includes disclosing Personal Information to a third party in exchange for money. We do not “sell” Personal Information under this definition. Virginia residents have the right to opt out of the processing of your Personal Information by us for decisions that produce legal or similarly significant effects concerning you. We do not process Personal Information for such profiling. To opt out of targeted marketing, where applicable, please email us at [email protected] with Subject Line “Do Not Sell or Share My Personal Information” and share your name and email.

We may collect or process Personal Information considered “sensitive” that is subject to the VCDPA, such as precise geolocation data. The VCDPA requires that businesses obtain opt-in consent to collect or process Personal Information that is considered sensitive data. Prior to processing such Personal Information that is considered sensitive, we will request your affirmative opt-in consent.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your rights under the VCDPA. Accordingly, by way of example, 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; give 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.

We may, however, offer you certain financial incentives permitted by the VCDPA that can result in different prices, rates, or quality levels provided that such incentive is reasonably related to the value of the Personal Information. We will not include you as a participant in any financial incentive program without your prior opt-in consent, which you may revoke at any time.

Right to Appeal

If we decline to take action regarding your request, you have the right to appeal our decision. We will notify you providing our reasons and instructions for how you can appeal the decision. You have the right to contact the Virginia Attorney General if you have concerns about the result of the appeal.

11. CHANGES TO THIS SUPPLEMENTAL POLICY.

We reserve the right to change this Supplemental Policy at any time at our sole discretion. We will inform you of any such change by posting a new Supplemental Policy on our website and clearly marking the date of any such change or revision to this Supplemental Policy. Your continued use of the Services after the posting of changes constitutes your binding acceptance of such changes.

12. CONTACT INFORMATION.

If you have any questions or comments about this Supplemental Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California, Colorado, Connecticut, Utah or Virginia law, please do not hesitate to contact us at:

Email: [email protected]