Mobile App and Website Privacy Policy
Last modified: March 30th, 2023
Introduction
Gravystack, Inc. (“Company” or “We“) respect your privacy and are
committed to protecting it through our compliance with this policy. This policy
describes our practices for collecting, using, maintaining, protecting, and
disclosing your personal information as well as the types of information we
may collect or that you may provide when you purchase, download, install,
register with, access, or use the Gravystack mobile application (the “App“) or
the Gravystack website (the “Website“). The App and the Website offer
financial services such as deposit accounts and debit cards. The accounts
and debit card is offered by Synapse Financial Technologies, Inc., and is
offered through the App and Website. All of the services, content, offers,
features, and products offered through the App and Website are referred to
herein as the “Gravystack Services.” By using the Gravystack Services, you are
accepting the terms of this Privacy Policy and are agreeing to the collection
and use of your personal information pursuant to this Privacy Policy.
This policy applies only to information we collect in the App or on the Website,
and in any email, text, and other electronic communications sent through or
in connection with the App or Website.
This policy DOES NOT apply to information that:
● We collect offline or on any other Company apps or websites, including
websites you may access through this App or Website.
● You provide to or is collected by any third party (see Third-Party
Information Collection).
These websites and apps have their own privacy policies, which we
encourage you to read before providing information on or through them.
Please read this policy carefully to understand our policies and practices
regarding your information and how we will treat it. If you do not agree with
our policies and practices, do not download, register with, or use the App and
Website. By downloading, registering with, or using the App or Website, you
agree to this privacy policy. This policy may change from time to time
(see Changes to Our Privacy Policy). Your continued use of the App or Website
after we revise this policy means you accept those changes, so please check
the policy periodically for updates.
This Privacy Policy should be read in conjunction with our Terms of Service,
which contain more details about the Gravystack Services. Any terms not
defined herein shall have the meanings given to them in the Terms of Service.
GravyStack, Inc. has relationships with certain service providers in order to
offer its services to you. GravyStack, Inc.has contracted with Synapse
Financial Technologies, Inc. (“Synapse”), a backend technology service
provider that owns or otherwise has relationships with (i) Synapse Brokerage
LLC, a 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 GravyStack, Inc.
with “Know Your Customer” requirements and other obligations. For purposes
of satisfying “Know Your Customer” requirements, GravyStack, Inc. asks for
your identifying information, such as your name, email address, tax
identification number, address, telephone number, date of birth, gender,
videos, and photographs that may contain images of your face, including
your driver’s license or government-issued identification number or card.
GravyStack, Inc. 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 [https://synapsefi.com/privacy]
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 [https://synapsefi.com/legal]
Children Under the Age of 13
Please see the section below entitled “Children’s Privacy Policy” to review our
privacy practices with regard to children under the age of 13. Any user
accounts for children under the age of 18 must be established by a parent or
legal guardian.
California residents under 16 years of age may have additional rights
regarding the collection and sale of their personal information. Please
see [Your California Privacy Rights] for more information.
Information We Collect and How We Collect It
We collect information from and about users of our App and Website:
● Directly from you when you provide it to us.
● Automatically when you use the App or Website.
Information You Provide to Us
When you download, register with, or use the App or Website, we may ask you
provide information:
● By which you may be personally identified, such as name, postal
address, email address, telephone number, social security number,
date of birth, or any other identifier by which you may be contacted
online or offline (“personal information“). We may also ask for photos
of your government issued identification, such as a driver’s license.
● That is about you but individually does not identify you, such as the
dates of birth, names and phone numbers of your family members.
This information includes:
● Information that you provide by filling in forms. This includes
information provided at the time of registering to use the App or
Website, purchasing our Services, posting material, and requesting
further services. We may also ask you for information when you enter a
contest or promotion sponsored by us, and when you report a problem
with the App or Website.
● Records and copies of your correspondence (including email
addresses and phone numbers), if you contact us.
● Your responses to surveys that we might ask you to complete for
research.
● Feedback given for marketing purposes, whether in a Beta version or
otherwise, including but not limited to feedback in pop-ups, posts on
your wall, or testimonials.
● Details of transactions you carry out through the App or Website and of
the fulfillment of your orders. You may be required to provide financial
information before placing an order through the App or Website.
● Your search queries on the App or Website.
You may also provide information for publication or display (“Posted“) on
public areas of the App or Website (collectively, “User Contributions“). Your
User Contributions are Posted and transmitted to others at your own risk.
Although you may set certain privacy settings for such information by logging
into your account profile, please be aware that no security measures are
perfect or impenetrable. Additionally, we cannot control the actions of third
parties with whom you may choose to share your User Contributions.
Therefore, we cannot and do not guarantee that your User Contributions will
not be viewed by unauthorized persons.
Automatic Information Collection
When you download, access, and use the App or Website, it may use
technology to automatically collect:
● Usage Details. When you access and use the App or Website, we may
automatically collect certain details of your access to and use of the
App or Website, including traffic data, location data, logs, and other
communication data and the resources that you access and use on or
through the App or Website.
● Device Information. We may collect information about your mobile
device and internet connection, including the device’s unique device
identifier, IP address, operating system, browser type, mobile network
information, and the device’s telephone number.
● Stored Information and Files. The App or Website also may access
metadata and other information associated with other files stored on
your device. This may include, for example, photographs, audio and
video clips, personal contacts, and address book information.
● Location Information. This App and Website collect real-time
information about the location of your device.
If you do not want us to collect this information do not download the App,
delete it from your device and do not use the Website.
We also may use these technologies to collect information about your
activities over time and across third-party websites, apps, or other online
services (behavioral tracking). Contact us at info@gravystack.com for
information on how you can opt out of behavioral tracking on or through the
App or Website and how we respond to browser signals and other
mechanisms that enable consumers to exercise choice about behavioral
tracking.
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
● Cookies (or mobile cookies). A cookie is a small file placed on your
smartphone or computer. It may be possible to refuse to accept
cookies by activating the appropriate setting on your smartphone or
browser. However, if you select this setting you may be unable to
access certain parts of our App or Website.
● Web Beacons. Pages of the App, our emails and the Website may
contain small electronic files known as web beacons (also referred to
as clear gifs, pixel tags, and single-pixel gifs) that permit the Company,
for example, to count users who have visited those pages or opened an
email and for other related app statistics (for example, recording the
popularity of certain app content and verifying system and server
integrity).
Third-Party Information Collection
When you use the App or Website or their content, certain third parties may
use automatic information collection technologies to collect information
about you or your device. These third parties may include:
● Advertisers, ad networks, and ad servers.
● Analytics companies.
● Your mobile device manufacturer.
● Your mobile service provider.
These third parties may use tracking technologies to collect information
about you when you use the App or Website. The information they collect may
be associated with your personal information or they may collect information,
including personal information, about your online activities over time and
across different websites, apps, and other online services websites. They may
use this information to provide you with interest-based (behavioral)
advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may
be used. If you have any questions about an advertisement or other targeted
content, you should contact the responsible provider directly. For information
about how you can opt out of receiving targeted advertising from many
providers, see Your Choices About Our Collection, Use, and Disclosure of Your
Information.
How We Use Your Information
We use information that we collect about you or that you provide to us,
including any personal information, to:
● Provide you with the App and Website and their contents, and any other
information, products or services that you request from us.
● Fulfill any other purpose for which you provide it.
● Give you notices about your account, including expiration and renewal
notices.
● Carry out our obligations and enforce our rights arising from any
contracts entered into between you and us, including for billing and
collection.
● Notify you when App or Website updates are available, and of changes
to any products or services we offer or provide though it.
● Facilitate any and all functionality of the app and ecosystem
The usage information we collect helps us to improve our App and Website
and to deliver a better and more personalized experience by enabling us to:
● Estimate our audience size and usage patterns.
● Store information about your preferences, allowing us to customize our
App and Website according to your individual interests.
● Speed up your searches.
● Recognize you when you use the App or Website.
We use location information we collect to facilitate certain functionality of the
app and ecosystem.
We may also use your information to contact you about our own and third
parties’ goods and services that may be of interest to you. If you do not want
us to use your information in this way, please contact us at
info@gravystack.com. For more information, see Your Choices About Our
Collection, Use, and Disclosure of Your Information.
We may use the information we collect to display advertisements to our
advertisers’ target audiences. Even though we do not disclose your personal
information for these purposes without your consent, if you click on or
otherwise interact with an advertisement, the advertiser may assume that
you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information
that does not identify any individual or device, without restriction.
In addition, we may disclose personal information that we collect or you
provide:
● To our subsidiaries and affiliates.
● To contractors, service providers, and other third parties we use to
support our business and who are bound by contractual obligations to
keep personal information confidential and use it only for the purposes
for which we disclose it to them.
● To a buyer or other successor in the event of a merger, divestiture,
restructuring, reorganization, dissolution, or other sale or transfer of
some or all of Gravystack, Inc.’s assets, whether as a going concern or
as part of bankruptcy, liquidation, or similar proceeding, in which
personal information held by Gravystack, Inc. about our App and
Website users is among the assets transferred.
● To third parties to market their products or services to you if you have
consented to these disclosures. We contractually require these third
parties to keep personal information confidential and use it only for the
purposes for which we disclose it to them. For more information,
see “CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION”.
● To fulfill the purpose for which you provide it.
● For any other purpose disclosed by us when you provide the
information.
● With your consent.
● To comply with any court order, law, or legal process, including to
respond to any government or regulatory request.
● To enforce our rights arising from any contracts entered into between
you and us, including the App EULA, terms of sale, Terms of Use, and for
billing and collection.
● If we believe disclosure is necessary or appropriate to protect the rights,
property, or safety of Gravystack, Inc., our customers or others. This
includes exchanging information with other companies and
organizations for the purposes of fraud protection and credit risk
reduction.
● We will use your feedback in pop-ups, posts on your wall, or
testimonials for our marketing purposes. When posting feedback, posts
or testimonials we will only disclose your first name, if provided.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the personal information you
provide to us. This section describes mechanisms we provide for you to
control certain uses and disclosures over your information.
● Tracking Technologies. You can set your browser to refuse all or some
browser cookies, or to alert you when cookies are being sent. You can
choose whether or not to allow the App or Website to collect
information through other tracking technologies via email. If you disable
or refuse cookies or block the use of other tracking technologies, some
parts of the App or Website may then be inaccessible or not function
properly.
● Location Information. You can choose whether or not to allow the App
or Website to collect and use real-time information about your device’s
location through the device’s privacy settings. If you block the use of
location information, some parts of the App or Website may become
inaccessible or not function properly.
● Promotion by the Company. If you do not want us to use your contact
information to promote our own or third parties’ products or services,
you can opt-out via email. You can also always opt-out by contacting
us at info@gravystack.com by checking or unchecking the relevant
boxes or by sending us an email or text message stating your request
to info@gravystack.com.
● Promotion by Feedback, Wall Posts or Testimonials. When we are
promoting our services by using your feedback in pop-ups, posts on
your wall, or testimonials, you will not be able to opt-out. However, if
opting-out is not available we will not disclose your contact information
in such posts, only your first name, if provided.
● Targeted Advertising by the Company. If you do not want us to use
information that we collect or that you provide to us to deliver
advertisements according to our advertisers’ target-audience
preferences, you can opt-out via email. You can also always adjust
your user advertising preferences by sending us an email stating your
request to info@gravystack.com.
● Disclosure of Your Information for Third-Party Advertising and
Marketing. If you do not want us to share your personal information
with unaffiliated or non-agent third parties for advertising and
marketing purposes, you can opt-out via email. You can also always
opt-out by logging into the App or Website and adjusting your user
preferences in your account profile by checking or unchecking the
relevant boxes or by sending us an email stating your request to
info@gravystack.com.
We do not control third parties’ collection or use of your information to serve
interest-based advertising. However, these third parties may provide you with
ways to choose not to have your information collected or used in this way.
You can opt out of receiving targeted ads from members of the Network
Advertising Initiative (“NAI“) on the NAI’s website.
California residents may have additional personal information rights and
choices. Please see [Your California Privacy Rights] for more information.
Accessing and Correcting Your Personal Information
You can review and change your personal information by logging into the
App or Website and visiting your account profile page.
You may also send us an email at info@gravystack.com to request access to,
correct, or delete any personal information that you have provided to us. We
cannot delete your personal information except by also deleting your user
account. We may not accommodate a request to change information if we
believe the change would violate any law or legal requirement or cause the
information to be incorrect.
If you delete your User Contributions from the App or Website, copies of your
User Contributions may remain viewable in cached and archived pages, or
might have been copied or stored by other App or Website users. Proper
access and use of information provided on the App or Website, including User
Contributions, is governed by our terms of use.
California residents may have additional personal information rights and
choices. Please see [Your California Privacy Rights] for more information.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional
rights regarding our use of your personal information. To learn more about
your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users
of our App or Website that are California residents to request certain
information regarding our disclosure of personal information to third parties
for their direct marketing purposes. To make such a request, please send an
email to info@gravystack.com[ or write to us at: 1 North 1st Street, Suite 790,
Phoenix, Arizona 85004.
Data Security
We have implemented measures designed to secure your personal
information from accidental loss and from unauthorized access, use,
alteration, and disclosure. All information you provide to us is stored on our
secure servers behind firewalls. Any payment transactions will be encrypted
using SSL technology.
The safety and security of your information also depends on you. Where we
have given you (or where you have chosen) a password for access to certain
parts of our App and Website, you are responsible for keeping this password
confidential. We ask you not to share your password with anyone. We urge
you to be careful about giving out information in public areas of the App and
Website like message boards. The information you share in public areas may
be viewed by any user of the App and Website.
Unfortunately, the transmission of information via the internet and mobile
platforms is not completely secure. Although we do our best to protect your
personal information, we cannot guarantee the security of your personal
information transmitted through our App and Website. Any transmission of
personal information is at your own risk. We are not responsible for
circumvention of any privacy settings or security measures we provide.
Children’s Privacy Policy
Gravystack, Inc.’s commitment to raising financially educated children runs
deep. This Children’s Privacy Policy demonstrates our unwavering
commitment to make sure that your child’s privacy is protected and that our
privacy practices comply with the Children’s Online Privacy Protection Act.
For any child under the age of 18, their parent or guardian must register the
child with us. We verify the status of the parent using photo identification, a
social security number, and/or other verification methods designed to
prevent anyone under the age of 18 from setting up an account on their
own. All consent to the collection or use of a child’s personal information
must come from the parent.
All child accounts must be established as a sub-account of the parent or
guardian’s account. Once the parent has set up the account and established
information use and collection parameters, the child may begin using the
App or Website.
Parents and guardians can access the personal information of their child
under 18 at any time through either the App or the Website. Parents and
guardians, as primary account holders, have access to all transaction details
in any of their sub-accounts. Sub-account holders cannot see the personal
information or transaction details of another sub-account without being
specifically authorized by the sub-account holder or the primary account
holder.
The primary account holder may provide access to their child’s personal
information to third parties in order to use our services for which we use
partners, such as banking and debit card services, fulfillment providers;
insurance providers, cloud hosting providers, and other service providers.
You should also be aware that your mobile carrier and/or internet service
provider may have access to any information transmitted through the App or
Website.
Parents and guardians may change, update or delete their child’s personal
information at any time. You may call 1 (213) 406-7621 or you may visit the
account settings page to change the privacy options. If you ask us to delete
any personal information we will delete as much as we are allowed to by
law. We will only retain any personal information as is necessary to close the
account, remove the personal information from the databases of our service
providers, resolve payment or other issues with the account, conduct a fraud
investigation, enforce our rights under any agreement such as the Terms of
Use of the App or Website, or take other actions permitted by law. There may
be regulatory recordkeeping obligations that keep us from deleting all
information related to a sub-account or primary account.
Changes to Our Privacy Policy
We may update our privacy policy from time to time. If we make material
changes to how we treat our users’ personal information, we will post the new
privacy policy on this page with a notice that the privacy policy has been
updated and notify you by a notice on the Website and an in-App alert the
first time you use the App after we make the change.
The date the privacy policy was last revised is identified at the top of the
page. You are responsible for ensuring we have an up-to-date active and
deliverable email address and/or phone number for you and for periodically
visiting this privacy policy to check for any changes.
Contact Information
To ask questions or comment about this privacy policy and our privacy
practices, contact us at:
1 North 1st Street, Suite 790
Phoenix, Arizona 85004
or via phone:
1 (213) 406-7621
To register a complaint or concern, please contact us
at info@gravystack.com
Privacy Policy for California Residents
This Privacy Policy for California Residents supplements the information
contained in Gravystack, Inc.’s Mobile App and Website Privacy Policy and
applies solely to all visitors, users, and others who reside in the State of
California (“consumers” or “you”). We adopt this notice to comply with the
California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the
CCPA have the same meaning when used in this Policy.
Where noted in this Policy, the CCPA temporarily exempts personal
information reflecting a written or verbal business-to-business
communication (“B2B personal information“) from some of its requirements.
Information We Collect
We collect information that identifies, relates to, describes, references, is
reasonably capable of being associated with, or could reasonably be linked,
directly or indirectly, with a particular consumer, household, or device
(“personal information“). Personal information does not include:
● Publicly available information from government records.
● Deidentified or aggregated consumer information.
● Information excluded from the CCPA’s scope, like:
o health or medical information covered by the Health Insurance
Portability and Accountability Act of 1996 (HIPAA) and the
California Confidentiality of Medical Information Act (CMIA),
clinical trial data, or other qualifying research data;
o personal information covered by certain sector-specific privacy
laws, including the Fair Credit Reporting Act (FCRA), the Gramm-
Leach-Bliley Act (GLBA) or California Financial Information Privacy
Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
In particular, we have collected the following categories of personal
information from consumers within the last twelve (12) months:
Category
Examples
Collected
A. Identifiers.
A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address,
email address, account name, Social Security number,
driver’s license number, passport number, or other
similar identifiers.
YES
B. Personal
information
categories
listed in the
California
Customer
Records statute
(Cal. Civ. Code
§ 1798.80(e)).
A name, signature, Social Security number, physical
characteristics or description, address, telephone
number, passport number, driver’s license or state
identification card number, insurance policy number,
education, employment, employment history, bank
account number, credit card number, debit card
number, or any other financial information, medical
information, or health insurance information.
Some personal information included in this category
may overlap with other categories.
YES
C. Protected
classification
characteristics
under
California or
federal law.
Age (40 years or older), race, color, ancestry, national
origin, citizenship, religion or creed, marital status,
medical condition, physical or mental disability, sex
(including gender, gender identity, gender expression,
pregnancy or childbirth and related medical
conditions), sexual orientation, veteran or military
status, genetic information (including familial genetic
information).
YES
D. Commercial
information.
Records of personal property, products or services
purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies.
YES
E. Biometric
information.
Genetic, physiological, behavioral, and biological
characteristics, or activity patterns used to extract a
template or other identifier or identifying information,
such as, fingerprints, faceprints, and voiceprints, iris or
retina scans, keystroke, gait, or other physical patterns,
and sleep, health, or exercise data.
NO
F. Internet or
other similar
network
activity.
Browsing history, search history, information on a
consumer’s interaction with a website, application, or
advertisement.
YES
G. Geolocation
data.
Physical location or movements.
YES
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar
information.
NO
I. Professional or
employment-
related
information.
Current or past job history or performance evaluations.
NO
J. Non-public
education
information
(per the Family
Educational
Education records directly related to a student
maintained by an educational institution or party acting
on its behalf, such as grades, transcripts, class lists,
NO
Rights and
Privacy Act (20
U.S.C. Section
1232g, 34 C.F.R.
Part 99)).
student schedules, student identification codes, student
financial information, or student disciplinary records.
K. Inferences
drawn from
other personal
information.
Profile reflecting a person’s preferences, characteristics,
psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes.
NO
We obtain the categories of personal information listed above from the
following categories of sources:
● Directly from you. For example, from forms you complete or products
and services you purchase.
● Indirectly from you. For example, from observing your actions on our
App or Website.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of
the following purposes:
● To fulfill or meet the reason you provided the information. For example,
if you share your name and contact information to request a price
quote or ask a question about our products or services, we will use that
personal information to respond to your inquiry. If you provide your
personal information to purchase a product or service, we will use that
information to process your payment and facilitate delivery. We may
also save your information to facilitate new product orders or process
returns.
● To provide, support, personalize, and develop our App or Website,
products, and services.
● To create, maintain, customize, and secure your account with us.
● To process your requests, purchases, transactions, and payments and
prevent transactional fraud.
● To provide you with support and to respond to your inquiries, including
to investigate and address your concerns and monitor and improve our
responses.
● To personalize your App or Website experience and to deliver content
and product and service offerings relevant to your interests, including
targeted offers and ads through our Website, third-party sites, and via
email or text message (with your consent, where required by law).
● To help maintain the safety, security, and integrity of our App or
Website, products and services, databases and other technology
assets, and business.
● For testing, research, analysis, and product development, including to
develop and improve our App or Website, products, and services.
● To respond to law enforcement requests and as required by applicable
law, court order, or governmental regulations.
● As described to you when collecting your personal information or as
otherwise set forth in the CCPA.
● To evaluate or conduct a merger, divestiture, restructuring,
reorganization, dissolution, or other sale or transfer of some or all of our
assets, whether as a going concern or as part of bankruptcy,
liquidation, or similar proceeding, in which personal information held by
us about our consumers is among the assets transferred.
We will not collect additional categories of personal information or use the
personal information we collected for materially different, unrelated, or
incompatible purposes without providing you notice.
Sharing Personal Information
We may share your personal information by disclosing it to a third party for a
business purpose. We only make these business purpose disclosures under
written contracts that describe the purposes, require the recipient to keep the
personal information confidential, and prohibit using the disclosed
information for any purpose except performing the contract. In the preceding
twelve (12) months, Company has disclosed personal information for a
business purpose to the categories of third parties indicated in the chart
below.
We do not sell personal information in exchange for money, but we may share
your personal information with third parties for marketing purposes, and such
sharing may be considered a “sale” under California law. The following
information may be shared with third parties for marketing purposes: your
name, a unique username you would like to go by, a phone number and/or
your email address. Our personal information sales do not include
information about individuals we know are under age 16. In the preceding
twelve (12) months, Company has sold the following categories of personal
information to the categories of third parties indicated in the chart below. For
more on your personal information sale rights, see Personal Information Sales
Opt-Out and Opt-In Rights.
Personal Information
Category
Category of Third-Party Recipients
Business Purpose Disclosures
Sales
A: Identifiers.
Marketing partners and
banking partners
Marketing partners
B: California Customer
Records personal
information categories.
Marketing partners and
banking partners
Marketing Partners
C: Protected classification
characteristics under
California or federal law.
None
None
D: Commercial information.
None
None
E: Biometric information.
None
None
F: Internet or other similar
network activity.
None
None
G: Geolocation data.
None
None
H: Sensory data.
None
None
I: Professional or
employment-related
information.
None
None
J: Non-public education
information.
None
None
K: Inferences drawn from
other personal information.
None
None
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights
regarding their personal information. This section describes your CCPA rights
and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you
about our collection and use of your personal information over the past 12
months (the “right to know”). Once we receive your request and confirm your
identity (see Exercising Your Rights to Know or Delete), we will disclose to you:
● The categories of personal information we collected about you.
● The categories of sources for the personal information we collected
about you.
● Our business or commercial purpose for collecting or selling that
personal information.
● The categories of third parties with whom we share that personal
information.
● If we sold or disclosed your personal information for a business purpose,
two separate lists disclosing:
o sales, identifying the personal information categories that each
category of recipient purchased; and
o disclosures for a business purpose, identifying the personal
information categories that each category of recipient obtained.
● The specific pieces of personal information we collected about you
(also called a data portability request).
We do not provide a right to know or data portability disclosure for B2B
personal information.
Right to Delete
You have the right to request that we delete any of your personal information
that we collected from you and retained, subject to certain exceptions (the
“right to delete”). Once we receive your request and confirm your identity
(see Exercising Your Rights to Know or Delete), we will review your request to
see if an exception allowing us to retain the information applies. We may deny
your deletion request if retaining the information is necessary for us or our
service provider(s) to:
1. Complete the transaction for which we collected the personal
information, provide a good or service that you requested, take actions
reasonably anticipated within the context of our ongoing business
relationship with you, fulfill the terms of a written warranty or product
recall conducted in accordance with federal law, or otherwise perform
our contract with you.
2. Detect security incidents, protect against malicious, deceptive,
fraudulent, or illegal activity, or prosecute those responsible for such
activities.
3. Debug products to identify and repair errors that impair existing
intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise
their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal.
Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical
research in the public interest that adheres to all other applicable
ethics and privacy laws, when the information’s deletion may likely
render impossible or seriously impair the research’s achievement, if you
previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer
expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are
compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these
exceptions from our records and will direct our service providers to take
similar action.
We do not provide these deletion rights for B2B personal information.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a
request by either:
● Calling us at: (213) 406-7621
● Emailing us at info@gravystack.com.
● Visiting www.gravystack.com
● Changing your account settings on the App.
Only you, or someone legally authorized to act on your behalf, may make a
request to know or delete related to your personal information.
You may also make a request to know or delete on behalf of your child by any
of the above methods.
You may only submit a request to know twice within a 12-month period. Your
request to know or delete must:
● Provide sufficient information that allows us to reasonably verify you are
the person about whom we collected personal information or an
authorized representative, which may include providing photo ID or a
social security number.
● Describe your request with sufficient detail that allows us to properly
understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information
if we cannot verify your identity or authority to make the request and confirm
the personal information relates to you.
You do not need to create an account with us to submit a request to know or
delete. However, we do consider requests made through your password
protected account sufficiently verified when the request relates to personal
information associated with that specific account.
We will only use personal information provided in the request to verify the
requestor’s identity or authority to make it.
For instructions on exercising your sale opt-out or opt-in rights, see Personal
Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do
not receive confirmation within the 10-day timeframe, please contact
info@gravystack.com.
We endeavor to substantively respond to a verifiable consumer request within
forty-five (45) days of its receipt. If we require more time (up to another 45
days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that
account. If you do not have an account with us, we will deliver our written
response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our
receipt of your request. The response we provide will also explain the reasons
we cannot comply with a request, if applicable. For data portability requests,
we will select a format to provide your personal information that is readily
useable and should allow you to transmit the information from one entity to
another entity without hindrance, specifically .xlsx file.
We do not charge a fee to process or respond to your verifiable consumer
request unless it is excessive, repetitive, or manifestly unfounded. If we
determine that the request warrants a fee, we will tell you why we made that
decision and provide you with a cost estimate before completing your
request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are age 16 or older, you have the right to direct us to not sell your
personal information at any time (the “right to opt-out”). We do not sell the
personal information of consumers we actually know are less than 16 years
old, unless we receive affirmative authorization (the “right to opt-in”) from
either the consumer who is between 13 and 15 years old, or the parent or
guardian of a consumer less than 13 years old. Consumers who opt-in to
personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may
submit a request to us via email at info@gravystack.com
Once you make an opt-out request, we will wait at least twelve (12) months
before asking you to reauthorize personal information sales. However, you
may change your mind and opt back in to personal information sales at any
time by emailing us at info@gravystack.com
You do not need to create an account with us to exercise your opt-out rights.
We will only use personal information provided in an opt-out request to
review and comply with the request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights.
Unless permitted by the CCPA, we will not:
● Deny you goods or services.
● Charge you different prices or rates for goods or services, including
through granting discounts or other benefits, or imposing penalties.
● Provide you a different level or quality of goods or services.
● Suggest that you may receive a different price or rate for goods or
services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA
that can result in different prices, rates, or quality levels. Any CCPA-permitted
financial incentive we offer will reasonably relate to your personal
information’s value and contain written terms that describe the program’s
material aspects. Participation in a financial incentive program requires your
prior opt-in consent, which you may revoke at any time.
Changes to Our Privacy Policy
We reserve the right to amend this privacy policy at our discretion and at any
time. When we make changes to this privacy policy, we will post the updated
notice on the Website and App and update the notice’s effective date. Your
continued use of our Website or App following the posting of changes
constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which
Gravystack, Inc. collects and uses your information described here and in
the Privacy Policy, your choices and rights regarding such use, or wish to
exercise your rights under California law, please do not hesitate to contact us
at:
Phone: tel:+1(213) 406-7621
Website: www.gravystack.com
Email: info@gravystack.com
Postal Address:
GravyStack, Inc.
Attn: Customer Success
1 North 1st Street, Suite 790, Phoenix, Arizona 85004
If you need to access this Policy in an alternative format due to having a
disability, please contact info@gravystack.com or 1 (213) 406-7621.
