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Privacy Policy

Effective Date: April 24, 2024

Grabango Co. (“Grabango,”“we,” or “us”) is a provider of an automated retail technology solution that uses computer vision and machine learning to make your shopping experience quicker, easier and more efficient. We recognize that your privacy is important, and that your choice to share information with us is a critical part of how we can try to improve everyday life. We’ve developed this Privacy Policy (“Policy”) to explain our technologies and to describe how and why we collect, use, and share your information both in stores and online.

Our Services: This Privacy Policy applies to our collection of personal information through our www.grabango.com website (“Website”), our Grabango mobile app (“App”), in stores where you can use our App (“Stores”) and from any other interactions you have with us (collectively, our “Services”).

Please note that this Policy does not apply to our processing of information about employees or contractors. Nor does the Policy apply to the data handling practices of any partners which link to our Website or App.

In some cases, you may be shopping in a store with our technology and not even know it. This Policy does not apply to your shopping experience unless you interact directly with us through our App, but we have included some information below about how our technology works that may be of interest to you.

  1. Information We Collect and Use
  2. How We Share and Disclose Personal Information
  3. Online Privacy Choices
  4. Data Privacy Framework
  5. Children’s Information
  6. Third-Party Websites and Services
  7. How to Contact Us
  8. Changes to Our Privacy Policy

1. INFORMATION WE COLLECT AND USE

Personal Information: When we use the term “personal information,” we mean any information that can relate to, either directly or indirectly, an identifiable person (meaning you). Note that information which cannot be related to you (for example aggregated information) is not Personal Information and is not subject to this Policy.

We collect information in a variety of different ways:

A. Information You Provide to Us.

We collect and use the following categories of personal information you provide in the following ways and for the following purposes:

  • Registration. If you register for an account with our Services, we may collect your name, account credentials, contact information, demographic information and billing information, including email and physical address, username, password and payment card information. We use this information to administer your account, provide you with the relevant Services and information, communicate with you regarding your account and your use of the Services, and for customer support purposes. Please note that we work with third-party payment processors for the collection and use of a payment card information and do not receive such data directly.
  • Communications. If you communicate with us through any paper or electronic form, we may collect your name, email address, mailing address, cell phone number, date of birth, or any other personal information you choose to provide to us. We use this information to investigate and respond to your inquiries, and to communicate with you, to enhance the services we offer to our users and to manage and grow our organization. If you register for our newsletters or updates, we will communicate with you by email. To unsubscribe from promotional messages, please follow the instructions within our messages and review the Online Privacy Choices section below. We may also send you transactional and Service-related messages by email, push notification, or– if you provide your phone number– by text message.
  • If you are a company or store interested in partnering with us, we will collect your name, company name, and email address. We collect this information to respond to any inquiries, to help facilitate a business relationship and to communicate with you.
  • Job Applications. If you apply for a job with Grabango, we will collect your name, contact information, demographic information, education and work history, work eligibility information and any other information you choose to provide. Eligible candidates may be asked to undergo a background check or other screening measures, which are facilitated by our third-party partners. We use this information to determine your eligibility for the role, facilitate your candidacy, make hiring decisions, and communicate with you through the hiring process.

B. Information We Collect Online Automatically.

We use various technologies to collect information about the device or browser you use to navigate our Website, App or from your use of our Services, including:

  • Web Logs. Like many websites, apps and email communications, we automatically collect certain information about your device automatically and store it in log files. Some of this information may be indirectly related to you, and some may not. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data. We use this information to analyze patterns on our Services, manage and administer the content, improve the performance of the Services, and for fraud protection, and to protect our rights and the rights and safety of individuals.
  • Geolocation Information. When you download our App, you will be prompted to give permission for Grabango to access your device’s precise geolocation. We will use this information to facilitate the Services, including your in store shopping. Giving permission is voluntary, although the denial of permission to access geolocation information may result in your inability to take full advantage of Grabango’s Services.
  • Cookies and Other Data Collection Technologies. We and our service providers use cookies, scripts and similar technologies to manage the Services and to collect information about you and your use of the Services. These technologies are used to help us to recognize you, customize or personalize your experience, advertise products or services to you, and analyze the use of our Services to make them more useful to you. These technologies may also allow us to collect demographic and statistical data and provide this information to our service providers to help deliver their services. Most internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences. Outside of the use of the cookie settings in your browser, there are also browser-specific settings like “Do Not Track” (“DNT”) or “Global Privacy Control” (“GPC”). While the DNT signal is not widely adopted and is not a finalized standard (and so we don’t respond to DNT signals), the GPC signal is responded to by our Website. Note that if you have agreed to the use of tracking technologies via a banner on our website, we will follow that choice instead of the more general GPC signal. For information on how to do this, access the “help” menu on your internet browser, or access http://www.aboutcookies.org/how-to-control-cookies. Please note, however, that disabling our cookies may mean that you will not be able to take full advantage of our Services.
  • Google Analytics. We use “Google Analytics” to collect information about your use of the Website. Google Analytics collects information such as how often users access the Services, what pages they access when they do so and what other sites they used prior to using the Services. Google uses the data collected to track and examine the use of the Services, to prepare reports on its activities and share them with other Google services. To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit the Google Analytics Opt-Out browser add-on page.

C. Information We Collect in Stores Automatically.

When you walk into a store that uses our technology, we use cameras to collect information about your visit, including information about your movement around the store and the items you interact with and purchase. Please note that we do not control the information collected in stores owned and operated by our third-party partners. See the Third-Party Websites and Services section below for more information.

There are two different types of user experience:

Grabango Checkout-Ready Service: If you enter a Store and do not have our App installed on your phone or an active Grabango account, our technology does not try to associate your image with any personal information. Instead, if your image is collected by our cameras, it’s used for the purpose of completing your payment transaction in the store. Our technology associates your image with the products you pick up to build a virtual cart. Then, when you are ready to check out, your virtual cart is presented without the need to manually scan your selected items. The payment transaction will then be completed by the cashier using your payment method of choice.

Grabango will not receive sensitive information about any payment card you use or about your payment method of choice. After the payment transaction is completed, we may retain the certain information collected through our cameras and related technologies, but we do not try to identify you or track your visits over time or across different stores. However, we do transfer this information to the Stores for their own purposes, subject to their own privacy policies.

Grabango Checkout-Free Service: If you do have our App and a registered account, the information we collect about your visit will be identifiable to you as personal information, including:

  • Device Information. As is true of most mobile apps, we may automatically collect information whenever the shopper uses the App. This information may include device and application identification numbers, your username or other Grabango account identifier, browser type, mobile carrier, operating system and system configuration information, date/time stamps associated with your usage and any other unique identifier offered by your phone (“Device Information”). Device Information is used to associate your visit with your Grabango account and to analyze your visits and shopping patterns to help us improve our Services and to provide the stores with analytics and insights.
  • Visits and Purchases. When you walk into a store that uses our technology, we or our third-party partners collect information about your visit, including information about your movement around the store and the items you interact with to create a virtual cart. We will associate this information with your Device Information to identify your Grabango account so you can walk out of the store with the products in your virtual cart and we can complete your payment transaction for you using your payment information and ID card information on file. We also use this information for internal reporting and analytics, to track our payment transactions and to facilitate any customer service inquiries. We may transfer information from our cameras and related technologies to the Stores for their own purposes, subject to their own privacy policies.

D. Information from Third-Party Sources.

We may receive personal information about you from other users or our business partners and service providers and combine this information with other information we have.

  • Single Sign-On. We use single sign-on to allow a user to enter login information from a third-party platform to access the Services. If you create or log into your account through a third-party social media site, such as Facebook, we may receive access to certain data and information from that site, such as your name, email address, profile picture and other information the social media site may provide to us. We use this personal information to authenticate you to our Website or App. Further, we use this personal information to ensure that the actions you take via the Website and App are your actions and not someone else’s. To learn more about the use of data collection technologies by social media sites, please visit each site’s privacy policy.
  • Referrals. We may obtain your name and contact information about you from other users who think you may be interested in the Services. We use this category of personal information to reach out to you with information about our Services.
  • Background Check Information. For job candidates, we may obtain information about you from references or our third-party background check partners. We will use this category of personal information to determine your eligibility for the role and make hiring decisions.
  • Stores. If you have a Grabango account, third-party stores may send us information about your loyalty membership, purchases or visits to their stores. We use this category of information to analyze trends, improve our business and advise the stores on potential business improvements.
  • Payment Processors. If you make a purchase through the App, we will receive confirmation about the transaction from the applicable payment processor. We will not receive any payment card information or account numbers. We use this category of personal information to complete transactions, to provide receipt information to you, for record keeping purposes, to prevent fraud or to protect our rights or the rights of others.

E. Other Uses of Personal Information.

In addition to the uses described above, we may collect and use personal information for the following purposes:

  • To create, maintain, improve, and operate the App, Website and Services.
  • To personalize your user experience.
  • To communicate with you to provide technical or administrative support.
  • To conduct, manage, and grow our organization.
  • To analyze, research, investigate and improve the use of our Services and interactions with stores.
  • To prevent, investigate, and provide fraud notifications, unlawful or criminal activity, unauthorized access to or use of personal information, our data system services, and to meet governmental and institutional policy obligations.
  • To investigate and resolve disputes and security issues and to enforce our Terms of Service.
  • To evaluate, negotiate, and execute business transactions which include the sale of some of all of the assets of Grabango, either in bankruptcy or in a normal merger or acquisition scenario (see “Business Transfers” below).
  • To protect the rights of Grabango, as well as other third parties.

2. HOW WE SHARE AND DISCLOSE PERSONAL INFORMATION

We may share your personal information in the following ways:

  • Service Providers. We share personal information with third-party service providers who perform services on our behalf, such as technology providers (including web and mobile platforms and hosting providers, email communications providers, analytics providers and data storage providers) and our payment providers for any orders you may make.
  • Stores. We operate our in-store Services on behalf of the Stores that use our technologies to facilitate their operations and transactions. Accordingly, we may share the information we process about your in-store interactions and transactions with these Stores. Please review the privacy policy of the Store you are shopping at for more information about their use of your personal information.
  • Regulatory or Legal Requirements, Safety and Terms Enforcement. We may disclose personal information to governmental regulatory authorities as required by law, including for tax or accounting purposes, in response to their requests for such information or to assist in investigations. We may also disclose personal information to third-parties in connection with claims, disputes or litigation; when otherwise required by law; if we determine its disclosure is necessary to protect the health and safety of you or any other person; to protect against fraud or credit risk; or to establish, enforce, or defend our legal rights or contractual commitments.
  • Business Transfers. We may disclose personal information as part of an organizational business transaction, such as a merger, acquisition, joint venture, financing, or sale of organizational assets and may transfer personal information to a third-party as one of the business assets in such a transaction. We may also disclose personal information in the event of insolvency, bankruptcy, or receivership.
  • Publicly. At your direction, we may make your information publicly available, such as if you post public comments on our sites or provide product testimonials.

When we disclose personal information to third parties as disclosed in this Policy, we do so via a contract which provides that such information may only be processed for limited and specified purposes consistent with the requirements of this Policy and those third parties provide the same level of protection as this Policy.

3. ONLINE PRIVACY CHOICES

A. Online Advertising.

We support the self-regulatory principles of the Digital Advertising Alliance (“DAA”). We work with advertisers, advertising networks, advertising servers, and analytics companies (“Ad Partners”) that use data collection technologies to understand how our Website, App and Services are being used and to analyze your browsing history in order to deliver advertising relevant to your interests, as well as to provide advertising-related insights. These advertisements may appear on other websites or services, including through social media networks. These Ad Partners may be able to associate devices across third-party websites or services over time and link various devices used by the same individual.

For more information about how Ad Partners use the information collected by these technologies and your options for restricting cookies placed by some of these Ad Partners, please visit the DAA’s opt-out page. The DAA’s opt-outs are device- and browser-specific and may not work on all devices. If you choose to opt-out through the DAA’s tools it does not mean you will cease to see advertising. Rather, the ads you see will be based on the website you are visiting and not your interests.

B. Privacy Preferences.

You have some choices regarding how we use your personal information, including the following:

  • Accessing your Personal Information. You may request that we provide you the specific pieces of personal information that Grabango has about you; categories of personal information we have collected about you; categories of sources from which the personal information is collected; categories of personal information that we have sold or disclosed for a business purpose about you;categories of third parties to whom the personal information was sold or disclosed for a business purpose; and the business or commercial purpose for collecting or selling personal information. Please note that much of the information you can make a request for is already contained in this Policy. If you would like to request deletion or correction of your personal information, please see the section below entitled “Exercising Your State Privacy Rights”. If you do not have an account with Grabango, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.
  • Modifying or Deleting Your Information. While some state privacy laws provide a right to correct or delete personal information about you, those rights are fairly limited. As such, we may not be able to change or delete your information in all circumstances. For example, we retain personal information as necessary to: complete the transaction for which the personal information was collected, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality of our online properties; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with Grabango; comply with a legal obligation; or otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which your provided the information. If you would like to request deletion or correction of your personal information, please see the section below entitled “Exercising Your State Privacy Rights”. If you are inquiring about information collected in store by one of our store partners, please contact our store partner for more information.
  • How to Control Your Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in the email. You may not opt-out of Service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Website, technical and security notices).
  • Opting Out of Selling or Sharing of Personal Information. You may choose to opt-out of the sharing of your personal information with third parties for cross-contextual behavioral advertising purposes. You may also choose to opt-out of the sale of your personal information. You may do so at any time by submitting a request via the mechanisms noted in “Exercising Your State Privacy Rights”. Please note that this opt-out does not prohibit disclosure made for non-marketing purposes or to service providers as provided for under applicable law.
  • How to Control Use of Sensitive Geolocation Information. You can restrict the Grabango App from accessing specific location information (i.e. precise geolocation information) by changing your permissions in your mobile device’s settings menu. Please note that the withdrawal of permission to access this information may result in an inability to take full advantage of our Services.
  • Exercising Your Privacy Rights. If you are a resident of a state with applicable privacy law, and would like to exercise any of your rights you may do so by going to our website at https://www.grabango.com/contact/ or calling +1 (800) 952-5210. You may also contact us by using the contact particulars noted in the “Contact Us” section below.
  • Designating an Authorized Agent. Some state law permits their residents to designate an agent to manage their rights under the relevant state privacy law. If you would like to designate an agent to manage your privacy preferences, you may do so using the mechanisms noted above under “Exercising Your State Privacy Rights”. Note that If you do not have an account with Grabango, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request. We will also need sufficient Personal Information about your authorized agent to be able to identify them. As part of this process, you must have permission from your authorized agent to disclose their Personal Information to us for the purpose of acting as your agent.
  • Appeals. Should we deny your request for Access, Correction, or Deletion, you may appeal that decision through the use of our third-party dispute resolution service noted elsewhere in this Policy.
  • Non-discrimination. Some state laws do not permit us to discriminate against you because you exercised any your rights under this title, including, but not limited to, by: denying you access to goods or services; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services; suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

4. DATA PRIVACY FRAMEWORK

Grabango complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Grabango has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom (and Gibraltar) in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Grabango has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

The Federal Trade Commission has jurisdiction over Grabango’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF, Grabango commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.

For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.

For a full discussion of the information we collect and use and purposes, please see Section 1. INFORMATION WE COLLECT AND USE.

We may disclose an individual’s personal information where required and to the extent necessary to meet a legal obligation in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We sometimes provide personal information to third parties to perform services on our behalf. If we transfer personal information received under the Data Privacy Framework to a third party, the third party’s access, use, and disclosure of the personal information must also be in compliance with our Data PrivacyFramework obligations, and we will remain liable under the Data Privacy Framework for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage. We offer a full discussion of how we share personal information in Section 2. HOW WE SHARE AND DISCLOSE PERSONAL INFORMATION.

Individuals may contact us to correct, amend or delete such personal information if it is inaccurate or has been processed in violation of the DPF Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated). Individuals may also have the right to limit the use and disclosure of their personal information (opt out) under certain circumstances, such as marketing. Requests to access, correct, amend, delete, or limit the use and disclosure of personal information (opt out) may be submitted by going to our website at https://www.grabango.com/contact/ or calling +1 (800) 952-5210. You may also contact us by using the contact particulars noted in the “Contact Us” section below. With our Data Privacy Framework self-certification, we are committed to respecting those rights.

5. CHILDREN’S INFORMATION

We do not knowingly collect or solicit personal information from children under the age of thirteen (13), nor is this website targeted towards children under the age of thirteen. In the event we learn that we have inadvertently collected personal information from a child under age thirteen, we will delete that information as quickly as possible. If you believe that we might have received information from a child under 13, please contact us at privacy@grabango.com.

6. THIRD-PARTY WEBSITES AND SERVICES

Our technologies may be in use by unaffiliated third-party stores. Similarly, the Services may contain integrations or links to third-party websites or services, including those of our business partners. By interacting with these third parties or shopping in their stores, you are providing information directly to the third party and not Grabango. Please note that Grabango is not responsible for the privacy practices of these third parties or any entity that it does not own or control. We encourage you to review the privacy policies and online terms of those third parties to learn more about how they handle your personal information.

7. HOW TO CONTACT US

If you have any questions about this Policy or the services, please contact us at:

Email: privacy@grabango.com

8. CHANGES TO OUR PRIVACY POLICY

This Privacy Policy is subject to occasional revisions. Grabango will update this Policy in a timely manner if anything is updated or changed and will repost the notice on the Website and App with an updated effective date at the top. We encourage you to check this page periodically to stay informed about how we are processing personal information.