This Privacy Policy (“Policy”) covers Grind 24 Inc. and certain of its affiliates and subsidiaries. These entities are collectively referred toas “Grind”, “affiliated companies,” “we,” “us,” and “our” throughout thisPolicy.

Privacy Principals

Grind is committed to maintaining the confidentiality, integrity, and security of personal information about our current, past and prospective customers. In the course of offering and providing financial products and services, we collect and maintain certain personal information.This Policy explains what personal information we collect and how we use and share any such personal information. It also explains what you can do to limit the use and sharing of your personal information.

Please take a moment to read this Policy carefully. 

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Types of information we Collect or Receive:

When you visit our website or mobile application (each and collectively the “Site”) or download and use our services to apply, open, or maintain an account with us, you signify acceptance to the terms of this Policy and consent to the collection, use, and disclosure of your personal information as described below. If you do not agree with or you are not comfortable with any aspect of this Policy, you should immediately discontinue access or use of our services.

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The Personal Information We Collect:

Personal information is data that can be used to identify you directly or indirectly, or to contact you (“Personal Information”). Our Policy covers all Personal Information that you voluntarily submit to us, that is collected from other sources including our partners, and that we obtain automatically. It includes:

• Personal Information you provide online and on applications or other forms, or mail to us, such as your name, address, email address, phone number, social     security number, driver’s license number, passport, date of birth.
• Personal Information about your transactions with or through us, such as your account balance, trading activity, loan amount, and account history, if     applicable.
• Personal Information from consumer reporting agencies (for example, to assess your creditworthiness for lending products)
• Personal Information about you for account authentication and identity verification and for use with fraud prevention technologies.
• Personal Information you provide to us about your external financial accounts; such as bank account number, so that we may provide you with special service     features.
• Technical, navigational and other information transferred when visiting our Site, including: IP address, mobile device IDs, device type, cookies, browsing     activity, location and browser type.

In addition, we may compile aggregate, anonymous, or de-identified data from various sources, including but not limited to accounts and transactions. This data, which we may use for our business purposes consistent with applicable law, does not identify individual customers.

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The Personal Information We Collect:

Grind does not sell any Personal Information to any third party.

Grind will not purchase consent, or sell, rent, or share consent to opt-in to our mobile SMS/texting program

We may disclose Personal Information we collect, such as the categories described above, to improve and make our financial products and services available to you. We may also use and disclose Personal Information with your consent. If you decide to withhold certain information, it may limit our ability to provide you with the services or products you request or that may be of interest to you. 

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Disclosure Information:

We may disclose your Personal Information to the following entities:

• Our affiliated and subsidiary companies (please see below to learn how you may limit the sharing of some of this information for marketing purposes by our affiliated companies).
• Non-affiliated third parties that perform services, such as marketing or market research, on our behalf (for example, we may provide your name, address, phone number, or email address to third parties that send email or regular mail on our behalf).
• Non-affiliated third parties under contract that service, maintain, or process your transactions and accounts (for example, companies that provide     administrative, telecommunications, payment, and transaction confirmations and other services in connection with the operation of our business).
• Non-affiliated     third parties as permitted or required by law to defend our rights or     enforce a contract, or to cooperate with government agencies or     regulators, (including for tax purposes), self-regulatory bodies (such as     FINRA) and law enforcement officials (for example, for reporting     suspicious activity or transactions, complying with a subpoena).
• Non-affiliated third parties to protect against actual or potential fraud or unauthorized transactions, and to protect the security of our records and systems, unless prohibited by law.
• Non-affiliated third parties at your direction or for which you provide your express consent (for example, banking or financial institutions and professional     service providers).

Our service providers are obligated to keep the PersonalInformation we share with them confidential and use it only to provide services specified by Grind.

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How We Protect Personal Information About You:

Grind considers the protection of Personal Information to be a foundation of customer trust and a sound business practice. We maintain reasonable physical, administrative, and technical safeguards to protect yourPersonal Information and we regularly adapt these controls to respond to changing requirements and advances in technology.

We take steps to ensure that your information is treated securely and in accordance with this Policy. Unfortunately, we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

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Collection and Use of Information Collected Automatically:

We receive and store certain types of information automatically, such as when you visit our Site or download and use our services. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, operating system version, or web-browser software. For example, we may use data collection and tracking tools such as cookies, web beacons, pixel tags, and other similar tracking techniques that may be downloaded to your personal computer, tablet, mobile phone or other device when you visit or interact with our Site.

A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,”also known as an internet tag, pixel tag or clear GIF, links web pages to web servers and cookies and may be used to transmit information collected through cookies back to a web server. The information we collect in this manner may include your device IP address, unique device identifier, web browser characteristics, device characteristics, operating system, language preferences, referring URLs, clickstream data, and dates and times of website visits.

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Access and Update Your Personal Information:

As a customer, you may access and update your PersonalInformation. You will find more information at our Help Center or through the Grind mobile application by clicking on your profile picture in the top left then select“personal information” from the main menu and click on the arrow next toPersonal Information you wish to update.

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Limit the Sharing of Your Personal Information:

We offer you certain choices in connection with the personal information we collect from you.  To update your preferences, limit the communications you receive from us, or submit a request, please email us at support@grind24.co

You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails.

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Notice to California Residents:

California Consumer Privacy Act ("CCPA"):

Effective January 1, 2020, the California Consumer Privacy Act(CCPA) allows California residents, upon a verifiable consumer request and subject to applicable exemptions, to request that we give you access, and (if technically feasible) in readily usable form, to the specific pieces and categories of Personal Information that we have collected or shared about you.California residents also have the right to submit a request for deletion ofPersonal Information under certain circumstances that Grind is not otherwise entitled to maintain. 

Consistent with California law, Grind will not discriminate against those who exercise their rights. Specifically, if you exercise your rights, we will not deny you services, charge you different prices for services or provide you with a different level or quality of services based on this exercise of your rights. 

To submit a data request, please follow the instructions in the“Contact Us” section below. For your protection, we will need to verify your identity using the information associated with your account, including email address, or date of birth. Government identification may be required. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law, which may take up to 45 days following verification of your identity. We will inform you if additional time is needed to verify your information.

Please note that the Gramm-Leach-Bliley Act, Bank Secrecy Act, and the CCPA and other applicable laws allows us to keep certain forms of data for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. In addition, there may be certain data that we may not allow you to review for legal, security, or other reasons.

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Updates to this Policy:

We may update this Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

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Contact Us:

If you have any questions about our Policy, please contact Grind Customer Service at support@grind24.co

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Last Updated: January 2022