Last Modified: September 23, 2024

We at Grade and our affiliates are committed to protecting your privacy.

This Privacy Policy applies to the information and data collected by Grade when you interact with our websites, product and services, and any other sites or services that link to this Privacy Policy. This includes when you:

• interact with us on our websites or through other channels (for example, by communicating with us);
• use our product and services (including the Grade Service); and
• when you use any other sites or services that link to this Privacy Policy.

This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data.
It also describes your choices and rights with respect to your Personal Data, including your rights of access and correction of your Personal Data.Last Modified: September 23, 2024

For the purposes of this Privacy Policy:

• “Personal Data” means any information relating to an identified or identifiable individual. If you do not agree with this Privacy Policy, you should not use our websites, product and services, or any other sites or services that link to this Privacy Policy. Grade customers and users may collect and manage Personal Data when using our product and services, or what we may refer to as the Subscription Service. It does not apply to information which has been anonymised.
• “Subscription Service” means all of our web-based applications, tools and platforms that you have subscribed to or that we otherwise make available to you, and are developed, operated, and maintained by us, accessible via grade.app or another designated URL, and any ancillary products and services. When you use the Subscription Service, Grade processes Personal Data as a processor under the direction of our customers. Our customers, as data controllers, are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obt aining consent prior to collecting their customers’, employees and/or contractor`s Personal Data using the Subscription Service.
• “Data Controller” means the organisation or person responsible for deciding how personal information is collected and stored and how it is used.
• “Data Processor” means another organisation or person to carry out certain tasks in relation to the personal information on behalf of, and on the written instructions of, the Data Controller.

We update this Privacy Policy from time to time and we encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email notification. Terms not otherwise defined in this Privacy Policy will have the meaning as set forth in the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”). If you have any questions about this Privacy Policy or our treatment of your Personal Data, or to exercise your rights to delete or modify your Personal Data, please use the following e-mail: info@grade.app.

1.What Information We Collect About You

a. Information You Provide to Grade

When you interact with us via our websites or any sites or services that link to this Privacy Policy or use the Subscription Service, we may collect Personal Data and other information from you, as further described below.

When You Visit Our Websites
We collect Personal Data from you when you submit web forms or interact with our websites, for example by subscribing to one of our services or requesting customer support. We may ask for your email address, first and last name, job title, and other similar business information. You are free to explore some of our website without providing any Personal Data about yourself.

Account and User Information
We collect Personal Data when you sign-up for Grade account, create or modify user information, set preferences, or provide any other related information to access or utilize our Subscription Service. When you register for Grade, we collect information such as name, address, phone number, email address, and company name. We use this information to communicate with you and in some cases facilitate your registration.

Payment Information
We collect payment and billing information when you register for paid products or services. For example, we may ask you to provide a billing address, or a billing contact for your Grade account. If you give us payment information, we use it solely as authorized by you in accordance with this Privacy Policy. You may also provide payment information, such as a credit card number or bank account numbers, when purchasing products or services or as a part of using of the Subscription Services. We use secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.

Customer Testimonials
We post customer testimonials and comments on our websites, which may contain Personal Data. We obtain each customer’s consent via email or through other agreements between customers and Grade prior to posting the customer’s name and testimonial.

b. Information We Process on behalf of customers When they Use the Subscription Service

Our product, or the Subscription Service, allows our customers to manage tasks, keep track of time, organize work with clients and leads in a single system. When customers use our product, they may collect Personal Data such as first and last name, email address, physical address, phone number, or other information about you. We call the information that our customers submit or collect via the product “Customer Data”.

We do not control the content of our customers’ webpages or the types of Personal Data that our customers may choose to collect or manage using the Subscription Service. We store our customers’ information on our service providers’ servers but process it as a processor under our customers’ instructions, which prohibit us from using the information except as necessary to provide and improve the Subscription Service and as required by law.

Our customers control and are responsible for correcting, deleting or updating the information they process using the Subscription Service and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to Grade for processing purposes. Depending on the circumstances, the organizations or people who we share your personal information with will be acting as either Data Processors or Data Controllers. Where we share your personal information with a Data Processor, we will ensure that we have in place contracts, which set out the responsibilities and obligations of us and them, including in respect of security of personal information.

c. Information We Collect and Process When You Use the Subscription Service Usage Data

We collect usage data when you or your users in your Grade account interact with the Subscription Service. Usage data includes metrics and information regarding your use and interaction with the Subscription Service such as what product features you use the most.

Mobile
When you access or use the Subscription Service via our mobile applications, we automatically collect information such as your device model and version, operating system, or device identifier.

Grade Partners
We may receive information about you or other users of your Grade account from our global network of partners. We may receive this data from our deal and lead registration process through our partners. We may also collect information about you through our partner co-marketing partnerships.

Third Parties
We may receive information from third party service providers, from related companies, and from our business and solution partners.

Personal Information from Different Sources
We may combine the personal information we collect from you with personal information we receive from other sources, such as third-party providers of business information and publicly available sources (like social media platforms). This may include physical mail addresses, job titles, email addresses, phone numbers, IP addresses, and social media profiles. This helps us to update and improve our records, identify new customers, create more personalized advertising, suggest products and services that may interest you, deliver personalized communications and promote events. The collection of your Personal Data by these other third-party providers is governed by the provider’s privacy policy.

Log Files
Like most websites and technology services delivered over the Internet, we automatically collect and store information about your computer hardware and software when you visit our websites, use our product and services, or visit other sites or services that link to this Privacy Policy. This information can include your IP address, browser type, domain names, internet service provider (ISP), and the files viewed on our websites (e.g., HTML pages, graphics, etc.), the files viewed on our website, your operating system, access times and referring website addresses. When you use the Subscription Service, we collect and store the categories of information listed above in logs in the following instances, subject to the customer’s implementation settings:
– When Grade user logs into their account and accesses tools in the Grade Platform;
– When an individual visits a customer’s corporate account.

2. How We Use Your Information

‍a. To Communicate with You About the Product and Services

We use the account information you provide to Grade when signing up for the Subscription Service to send you transactional emails or in-app notification about billing, account management, and other administrative matters. We may also send you updates regarding our customer terms of service or other legal agreements, and may also communicate with you about security incidents via email or in-app notification. We use your information to provide customer support, such as resolving technical issues you encounter and analyzing product outages or bugs.

b. To Provide the Subscription Service

We use your account information and Customer Data to provide the product and services to you. For example, we use the email address you provide when signing up for the product to create your user account, and we use your payment information to process payments for paid use of the Subscription Service and as a part of Subscription Service. We also use this information to authenticate you when you log in and to provide customer support.

c. To Improve and Develop Our Product and Services

We collect usage data about how you or your users interact with our product and services. We use this data to develop and improve our products and services. For example, we use usage data to assess trends and usage across the product to help us determine what new features or integrations our users may be interested in.

We use Customer Data in an anonymized manner for machine learning that supports certain product features and functionality with the Subscription Service.

We may publish data about how our product and services are being used across our customer base. When we share statistical information externally in this way, the data will be aggregated and we will not identify individual users or customers. For example, we may publish blog posts on trends or insights into how users are interacting with our product.

d. To Secure and Protect our Product and Grade Users

We use your account information to investigate and help prevent security incidents. We may also use this information to meet legal requirements. We use your information to verify user accounts, new product sign-ups, and to detect and prevent product abuse.

We use log files to provide general statistics regarding use of the websites by you, including how you use our website, what country you are logging in from (for analytics, export control and regulatory purposes) and to help improve the navigation experience. Your IP address is also collected and logged for security and debugging purposes, for example to track access patterns, investigate security events and incidents. For these purposes we do link this automatically-collected data to other personal data provided by you such as name, email address, address, and phone number.

e. To Market and Promote the Subscription Service

We use the information you provide to Grade to market and promote the products, services, and other offerings. We use this information to promote the use of our services to you and share promotional and information content with you in accordance with your communication preferences.

We receive information from third party service providers and other sources such as third-party providers of business information and publicly available sources. We may receive and use this information from these service providers and other sources in combination with other information we collect through other means described in this Privacy Policy for the purposes of providing you with updates and an improved Subscription Service, like personalized communications, and tailoring the website or product to improve user experience.

f. Other purposes if we obtain your consent

We share your data with third parties when you give us consent to do so.

g. Legal Basis for Processing Personal Data

Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, provide you with Subscribed Service, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you.

3. How We Share Information We Collect

We may need to share your personal information with other organizations or people. These organizations include:
Other companies in our group (who may might act as joint data controllers or as data processors on our behalf).
Third parties who are not part of our group. These may include:

• Suppliers: such as payment providers, administration providers, marketing agencies;
• Government bodies and regulatory bodies;
• Our advisors: such as lawyers, accountants, auditors, insurance companies;
• Our bankers;
• any organizations which propose to purchase our business and assets in which case we may disclose your personal information to the potential purchaser.

a. Third Party Service Providers

We use third party service providers to support our websites, products, and services. For example, we use service providers for data hosting, application development, and marketing. We may need to share your information with service providers to provide information about products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis on your use of the Subscription Service or interactions on our websites, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information in this way, we explicitly require the third-party service providers to acknowledge and adhere to our privacy and data protection policies and standards.

b. Partners

We may share data with trusted Grade partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide sales support, or provide customer support. Partners are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your data.

c. Corporate Events

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Grade on the websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.

d. Compelled Disclosure

We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process. If you use the Subscription Service, Customer Data is considered confidential information.

е. Google Analytics.

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

‍4. How We Transfer Data We Collect Internationally

a. International Transfers within the Grade

To facilitate our global operations, we may transfer information to other Grade Affiliates where we have operations for the purposes described in this policy.

This Privacy Policy will apply even if we transfer Personal Data to other countries. We have taken appropriate safeguards to require that your Personal Data will remain protected wherever it is transferred. When we share Personal Data of individuals in the European Economic Area (“EEA”), within and among Grade’s Affiliates, we use the corresponding agreements on the processing of personal data and as well as additional safeguards where appropriate.

b. International transfers to third parties

Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share Personal Data of individuals with third parties, we make use of a variety of legal mechanisms to safeguard the transfer including the European Commission-approved standard contractual clauses, as well as additional safeguards where appropriate.

5. How We Store and Secure Your Information

a. Data Storage and Security

We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures.

b. Retention of Personal Data

How long we keep information we collect about you depends on the type of information and how we collect and store it. After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request.

We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

6. Cookies and Similar Technologies

a. Cookies

We may collect personal information about you use and access our website. While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as pages you visit, the time and date of your visit and Internet protocol address assigned to your computer. We may also use ‘cookies’ or other similar technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookies on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your Internet browser but our websites may not work as intended for you if you do so.

Our cookies are used for the following purposes:

 

Strictly necessary/Technical.
These cookies are necessary to allow us to operate our Subscribed Service and/or products so you may access to them as requested. These also include cookies, which allow us to remember your previous actions within the same browsing session, and to secure the Subscribed Service and/or products.

Analytical/Performance.
These cookies are used by us or a third-party service provider to analyse how the Subscribed Service and/or products are used and their performance. For example, they track the most visited pages, and where the visitors come from.

Functional
These cookies are used to tailor your experience. For instance, cookies permit our Subscribed Service and/or products to remember the details you’ve provided when filling in forms – so that you don’t have to enter the same information multiple times.

Most web browsers automatically accept cookies. However, you do not have to accept cookies and you can reject or block the use of cookies and delete all cookies currently stored on your device. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu.

When you access our website, a so-called “cookie banner” appears, with which we ask you for your consent to set cookies. We use cookies to store your preferences when using our website, to statistically analyze your usage behavior, and to display personalized advertising on third-party websites or social media. This data may be used by us and our partners to enrich usage profiles.

When making your decision, please bear in mind that your personal data stored to the respective cookie may be transferred to countries outside the EU in which no level of data protection comparable to that in the EU is guaranteed. By selecting the relevant cookies, you consent to such a third-country data transfer.

b. Third Party Tracking Technologies

The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy.

7. How to Access & Control Your Personal Data

a. Reviewing, Correcting and Removing Your Personal Data

Under data protection laws you have certain rights in relation to your personal information, as follows:

• Right to request access: This is the right to obtain from us a copy of the personal information which we hold about you. We must also provide you with certain other information in response to these requests to help you understand how your personal information is being used.
• Right to correction: this is the right to request that any incorrect personal data is corrected and that any incomplete personal data is completed. Right to erasure: (this is often called the “right to be forgotten”). This right only applies in certain circumstances. Where it does apply, you have the right to request us to erase all of your personal information.
• Right to restrict processing: this right only applies in certain circumstances. Where it does apply, you have the right to request us to restrict the processing of your personal information. Right to data portability: this right allows you to request us to transfer your personal information to someone else.
• Right to object: you have the right to object to us processing your personal information for direct marketing purposes. You also have the right to object to us processing personal information where our legal reason for doing so is the Legitimate Interests Reason and there is something about your particular situation which means that you want to object to us processing your personal information. In certain circumstances you have the right to object to processing where such processing consists of profiling.

To exercise any of these rights please contact us at info@grade.app. We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of the action we have taken.

If you are a customer, prospect, or otherwise interact with Grade customer that uses our Subscription Service and would like to access, correct, amend or delete your data controlled by the customer, please contact the relevant customer directly. Grade acts as a processor for our customers and will work with our customers to fulfill these requests when applicable. Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service.

b. No automated single decision

As far as this is not exceptionally necessary for the conclusion of a contract or permitted by law (as in the case of age verification) we do not use your personal data for automated individual decisions.

d. To Unsubscribe from Our Customers’ Communications

Our customers are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. If you are a customer, prospect, or otherwise interact with Grade customer, you can unsubscribe from our customers’ marketing communications by clicking on the “unsubscribe” link located on the bottom of their emails, or by contacting them directly.