The types of Personal Information we collect and our privacy practices depend on whether you are a customer, user, visitor to our Site or App (together, “Individuals”) and the requirements of applicable law.

Below are the ways we collect Personal Information and how we use it.

• Account Information.When you sign up for an Account with our Services, you will need to provide us with Personal Information. This may include your name, email, mailing address, phone number, date of birth, Social Security Number, company name, and other related information.
• Information Necessary for our Services.When you use our Services, we will need to collect and store Personal Information to assist you with and prepare your tax return. Some examples include, but are not limited to, financial information found on government issued tax forms, financial statements, information related to your employment and/or income, bills, expenses, and other related information.
• Transactional Information. We and our third-party service providers may Process your financial and payment card information in order to facilitate a transaction that you request.
• Import Services. The Services includes a feature that allows you to import, where applicable, certain Personal Information and other information from financial institutions, payroll processors, personal financial software, business financial software, and charitable deduction information. You are responsible for verifying the accuracy of the information that is imported.
• Communications with Us. We may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, request customer or technical support, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
• Interactive Features. We may offer interactive features such as chat services, forums, and social media pages. We may collect the information you submit or make available through these features. Any content you provide on the public sections of these channels will be considered “public” and will not be subject to the privacy protections referenced herein.
• Conferences and Trade Shows. We may attend conferences and trade shows where we collect Personal Information from Individuals who interact with or express an interest in Grid and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
• Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an App Store, a third-party login service, or a Social Networking Site (“SNS”), we may collect information about you from that third-party application that you have made available via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, email, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with the Services.

We Process Personal Information about Individuals for a variety of business purposes, including:

• Analyze information;
• Prepare forms;
• Advise customers;
• Benchmark Personal Information in a de-identified format;
• Manage Individual information and Accounts;
• Respond to questions, comments, and other requests;
• Provide access to certain areas, functionalities, and features of our Services; and
• Answer requests for customer or technical support.

• Measure interest and engagement in our Site and Services;
• Improve our products and Services;
• Develop new products and Services;
• Ensure internal quality control;
• Verify Individual identity;
• Secure our information and networks;
• Communicate with you about your account, activities on our Site and Services and policy changes;
• Process your financial information and other payment methods for products or Services purchased;
• Prevent potentially prohibited or illegal activities; and
• Enforce our Terms.

We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest to you. We may provide you with these materials by email, phone, and/or postal mail, as permitted by applicable law. You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as described below.

We may use Personal Information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, information about the computer or device from which you access our Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Site and Services. De-identified and aggregated information is not Personal Information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

Grid’s Services may offer various tools and functionalities. For example, Grid may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Grid or any other third parties for any other purpose.

Grid may use Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent.

We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Site and Services.

Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of such Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that allow you access to our Services that are required to identify irregular behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions;
• Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
• Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services, keeping track of your specified preferences or past pages viewed;
• Advertising or Targeting Related. We may use first party or third-party Technologies to develop and deliver content, including ads relevant to your interests, on our Services or on third-party sites.

We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.

Google Firebase. We may use Google Firebase analytics to collect usage statistics and to improve our Services. Information collected by Google Firebase can be accessed here: https://support.google.com/firebase/answer/6318039. Information related to the security and privacy of Google Firebase is available here: https://firebase.google.com/support/privacy/.

Session Replay Providers. We use FullStory and Smartlook for session replay analytics. These service providers allow us to record and replay an Individual’s interaction with the Services. This helps us understand our customer’s experience and how we can improve our Services.

FullStory’s privacy policy can be found at https://www.fullstory.com/legal/privacy/. You can opt out of FullStory’s collection of your information by visiting https://www.fullstory.com/optout/.

Smartlook’s privacy statement can be found at https://www.smartlook.com/help/privacy-statement/. You can opt out of Smartlook’s collection of your information by visiting https://www.smartlook.com/opt-out.

(i) To track opt-outs,our session replay service providers use an opt-out cookie placed on your device. Please note that if you get a new device, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the opt-out cookie. Third Party Websites/Applications and Software Development Kits. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Site or other Services. These other domains and websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.

(j) Grid has relationships with certain service providers in order to provide its services to you. Grid has contracted with Synapse Financial Technologies, Inc. (“Synapse”), a backend technology service provider that owns or otherwise has relationships with, (i) Synapse Brokerage LLC, an SEC-registered broker-dealer and member of FINRA and SIPC; (ii) Synapse Credit LLC, a state-licensed lender; and (iii) certain banks and financial institutions and service providers (each of the foregoing being a “Partner Financial Institution”). Among other services, Synapse assists Grid with “Know Your Customer” requirements and other obligations. For purposes of satisfying “Know Your Customer” requirements, Grid asks for your identifying information, such as your name, email address, tax identification number, address, telephone number, date of birth, videos, and photographs that may contain images of your face, including your driver’s license or government-issued identification number or card. [Platform] will also collect information pertaining to your account transactions. Your personal information will be shared with Synapse and will be subject to the Synapse Privacy Policy. Synapse will share your information as necessary with its Partner Financial Institutions and other service providers in connection with providing their services. The privacy policies of Synapse, its affiliates and its Partner Financial Institutions can be found here.

(a) We Use Service Providers. We may share any Personal Information we receive about you with our third-party service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) the provision of the Services.

We use Mailchimp, Sendgrid and Drip to help us with our marketing and related email services.
You can read Mailchimp’s Privacy Policy here: https://mailchimp.com/legal/privacy
You can read Sendgrid’s Privacy Policy here: https://www.twilio.com/legal/privacy
You can read Drip’s Privacy Policy here: https://www.drip.com/privacy

We use Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using the Services, you grant Grid and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution to Grid and our third-party service providers. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy. You can find Plaid’s Privacy Policy here: https://plaid.com/legal/#consumers

(b) Disclosure to Tax Agencies. Once your taxes are complete and you have given us permission to do so, we will send your taxes (including direct deposit information) to the Internal Revenue Service and the applicable state tax agency.

(c) Electronically Filed Tax Returns. The applicable date for filing tax returns is available from the IRS. The IRS requires Grid to notify it, in connection with the electronic filing of your tax return, of the Internet Protocol address of the computer from which the return originated and whether the email address of the person electronically filing the return has been collected. By using the Services to prepare and submit your tax return, you consent to the disclosure to the IRS and any other tax or revenue authority of all information relating to your use of the Services for electronic filing of your return(s).

If you are filing one or more state tax returns, then by using a computer system and software to prepare and transmit return(s) electronically, you consent to the disclosure of all information pertaining to your use of the system and software to the States in which you are filing the returns, as applicable by law, and to the transmission of your tax return(s).

(d) Payment Processing. When you make a payment, the third-party payment processor receives your full payment information and we receive only a confirmation of payment.

(e) Business Partners. We may provide relevant Personal Information to business partners to provide you with a product or service you have requested. We may also provide relevant Personal Information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.

(f) Marketing – Interest-Based Advertising and Third -Party Marketing. Through our Services, Grid may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the Site and Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may follow the instructions below.

(g) Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) to collect amounts owed to us; (iv) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (v) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

(h) Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

You agree that all information Processed by us may be transferred, Processed, and stored anywhere in the world, including but not limited to, the European Union, the United States or other countries. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers.

For purposes of the California Consumer Privacy Act of 2018, we do not “sell” your Personal Information.

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are Processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by Grid, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, Grid will take steps to verify your identity before fulfilling your request.

We retain copies of your tax return information for seven years. In addition, we may retain the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

The Site and Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below. If we learn that we have collected any Personal Information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Except as otherwise provided in this Privacy Policy, Grid does not share Personal Information with third parties for their own marketing purposes.

If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.

We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use the Services after the new Privacy Policy takes effect.

This Privacy Policy is incorporated by reference into the Grid Terms of Service (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms.