GRID's Privacy Policy

• Introduction

• Our values

• Why we process personal data

• What personal data we process

• Your rights about your personal data

• How we protect your personal data

• How we use cookies and other tracking technologies

• How to reach us

Introduction

In our mission to make infrastructure better for everyone at GRID, we collect and use information about you, our:

• "partners," who develop apps for sellers to use, build stores on behalf of sellers, refer potential entrepreneurs to GRID or otherwise help sellers run or improve their GRID business
• "merchants," who use GRID to expand and boost their business
• "customers" who store at a GRID-powered company
• "users",of GRID apps and services
• "visitors," of GRID's websites, or anyone who contacts GRID's support.

This privacy policy helps you better understand how we collect, use and share your personal information. If we change our privacy practices, we may update this privacy policy. If there are significant changes, we will let you know (for example, by e-mail).

Our values

Trust is the foundation of the GRID platform, and that includes trusting us to do the right thing with your information. Three key values guide us as we develop our products and services. These values help you better understand how we think about your information and privacy.

Your information is yours

We carefully analyze what personal data we need to provide our services, and we try to limit the information we collect to what is necessary. Whenever possible, we delete or anonymize your personal data when we no longer need it. As we build and improve our products, our engineers work closely with colleagues with privacy or legal backgrounds to build with privacy in mind. In all of this work, our guiding principle is that your information belongs to you, and we strive to use your information only for your benefit.

We protect your information from others

If a third party requests your personal information, we refuse to share it unless you give us permission or we are required by law to share that personal information. If we are legally required to share your personal information, we will notify you in advance, unless we are prohibited from doing so by law.

We help merchants and partners meet their privacy obligations

Many of the merchants and partners who use GRID do not have a dedicated privacy team, and it is important for us to help them meet their privacy obligations. That's why we try to build our products and services so that they can easily be used in a privacy-friendly way.

Why we process personal data

We generally process your personal data when we need to do so to fulfill a contractual obligation (for example, to process your (subscription) payments for using the GRID platform) or when we or someone we work with needs to use your personal data for a reason related to their business (for example, to provide you with a service). European law calls these reasons "legitimate interests." These legitimate interests include:

• preventing risk and fraud
• Answer questions or provide other forms of support
• helping retailers find and use apps through the GRID App Store
• Providing and improving our products and services
• reporting and analysis
• testing of features or additional services
• Assist with marketing, advertising or other communications

We process personal information only for these legitimate interests after considering the potential risks to your privacy - for example, by providing clear transparency in our privacy procedures, providing you with control over your personal information where appropriate, limiting the information we hold, limiting what we do with your information, to whom we send your information, how long we keep your information, or the technical measures we use to protect your information.

One of the ways we can help merchants with GRID is by using techniques such as "machine learning" (called "automated decision making" in European law) to help us improve our services. When we use machine learning at GRID: (1) a human is still involved in the process (and so it is not fully automated); or (2) we use machine learning in ways that do not have significant privacy implications (e.g., reordering how apps are displayed when you visit the GRID App Store).

We may process your personal data where you have given your consent. In particular, this consent is necessary where we cannot invoke an alternative legal basis for processing, where your data has been obtained and consent has already been given, or where we are required by law to seek your consent as part of some of our sales and marketing activities. You have the right to withdraw your consent at any time by changing your communication choices, opting out of our communications, or by contacting us.

What personal data we process

What personal data is collected and processed depends on the relationship between you and GRID. More information is available in the terms and conditions applicable to the GRID platform and GRID App Store or in the agreement between you and GRID.

Your rights about your personal data

We believe you should be able to access and control your personal information no matter where you live. Depending on how you use GRID, you have the right to request access to your personal data, correct it (or have it corrected), amend it (or have it deleted), transfer it to another service provider, limit it or object to certain uses of your personal data (for example, direct marketing). We will not charge you anything or provide a different level of service if you exercise any of these rights.

If you buy something from a merchant that offers its products and/or services through GRID, you must contact this third-party merchant directly with whom you have the agreement. We are only a platform for them and cannot decide how personal data is processed at this merchant. We will, of course, help our merchants fulfill these requests by providing them with the tools to do so and answering their questions.

If you are a merchant, partner, employee of GRID or any other person with whom GRID has a direct relationship, you may make your request regarding the data at legal@grid.com. Please note that if you send us a request regarding your personal data, we must be sure it is you before we can respond. To that end, we may request your identity information or use a third party to collect and verify identification documents.

If you are not happy with our response to a request, you can contact us to resolve the issue. You also have the right to contact your local data protection or privacy authority at any time.

Finally, because there is no common understanding about what a "Do Not Track" signal is supposed to mean, we don't respond to those signals in any particular way.

Where we send your personal data

We are a Dutch company, but we work with and process personal data of individuals around the world. To run our business, we may send your personal data outside your country, including to the United States. This data may be subject to the laws of the countries to which we send it. When we send your data abroad, we take measures to protect your data, and we try to send your data only to countries with strict data protection laws.

Shipping outside Europe and Switzerland

If you are located in Europe, your personal information may be sent to other GRID locations and to service providers outside Europe. When we send your personal information outside of Europe, we do so in accordance with European law.

When we send your personal information to countries or regions outside of Europe, we do so only if the European Commission has determined that those countries or regions adequately protect your information. If we then send this personal information, it will be protected by contractual undertakings similar to those in the Standard Contractual Clauses.

Finally, although we do what we can to protect your information, we may sometimes be required by law to disclose your personal information (for example, if we receive a valid court order).

How we protect your personal data

Our teams work tirelessly to protect your information and ensure the security and integrity of our platform. However, we all know that no method of transmission over the Internet and no method of electronic storage can be 100% secure. This means that we cannot guarantee the absolute security of your personal information.

How we use "cookies" and other tracking technologies

We use cookies and similar tracking technologies on our website and in providing our services. For more information about how we use these technologies, including a list of other companies that place cookies on our sites, a list of cookies we place when we boost a merchant's store through GRID, and an explanation of how to opt out of certain types of cookies, see our Cookie Policy.

How to reach us

If you would like to ask questions about, make a request regarding, or complain about the way we process your personal data, please contact GRID Support or email us at any of the addresses below.

GRID.com B.V.

Radarweg 29

1043 NX Amsterdam

The Netherlands

legal@grid.com

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