Privacy Policy
This privacy policy for Grenke Wallet ("company", "we", "our", or "us") describes how and why we may collect, store, use, and/or share ("process") your information when you use our services ("services"), such as when you:
- Visit our website at https://grenag.com or any of our websites linked to this privacy policy.
- Communicate with us in any other way, including sales, marketing, or events.
Questions or concerns? Reading this privacy policy will help you understand your privacy rights and options. If you do not agree with our policies and practices, please do not use our services. However, if you still have questions or concerns, please contact us at info@grenag.com.
Summary of Key Points
This summary contains the main points of our privacy policy, but you can find more details on each of these
topics by clicking the link next to each key point or by using our table of contents below to find the
section you are looking for. You can also click here to go directly to our table of contents.
What
personal data do we process? When you visit, use, or browse our services, we may process personal data,
depending on your interaction with Grenke Wallet and the services, the decisions you make, and the
products and features you use. Click here to learn more.
Do we process sensitive personal data? We do
not process sensitive personal data.
Do we receive information from third parties? We do not receive
information from third parties.
How do we process your information? We process your information to
provide, improve, and manage our services, to communicate with you, for security and fraud prevention, and
to meet legal requirements. We may also process your information for other purposes, with your consent. We
only process your information if we have a valid legal basis for doing so. Click here to learn
more.
In what situations and with what types of parties do we share personal data? We may share
information in certain situations and with certain categories of third parties. Click here to learn
more.
How do we protect your information? We have implemented organizational and technical processes
and procedures to protect your personal information. However, no electronic transmission over the Internet
or information storage technology can guarantee that it is 100% secure. Therefore, we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to bypass our
security and collect, access, steal, or modify your information unauthorizedly. Click here to learn
more.
What are your rights? Depending on your geographical location, applicable data protection law
may mean that you have certain rights regarding your personal data. Click here to learn more.
How can
I exercise my rights? The easiest way to exercise your rights is to fill out our data request form available
here: https://grenag.com/pages/contact, or
to contact us. We will review and process each request in accordance with applicable data protection
laws.
1. What Information Do We Collect?
Personal Data Provided by YouSummary: We collect personal data that you provide to us.
We collect personal data that you voluntarily provide to us when you register for services, show interest in information about us or our products and services, engage in activities on the services, or otherwise contact us.
Personal Data Provided by You. The personal data we collect depends on the context of your interactions with us and the services, the decisions you make, and the products and features you use. The personal data we collect may include:
Sensitive Information. We do not process sensitive personal data.
Payment Data. We may collect data necessary for processing your payment when you make purchases, such as your payment instrument number (e.g., credit card number) and the security code of your payment instruments. All payment data is stored by Coinbase Commerce, PayPal, Amazon Pay, and Shopify Payments. You can find their privacy policy(ies) here: https://commerce.coinbase.com/legal/privacy-policy/, https://www.paypal.com/us/webapps/mpp/ua/privacy-full, https://pay.amazon.co.uk/help/82974, and https://www.shopify.com/legal/privacy.
All personal data you provide must be true, complete, and accurate, and you must inform us of any changes to such personal data.
Automatically Collected Information
Summary: Certain information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is automatically collected when you visit our services.
We automatically collect certain information when you visit, use, or browse the services. This information does not reveal your specific identity (such as your name or contact information) but may include data about devices and usage, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our services, and other technical information. This information is primarily needed to maintain the security and operation of our services, as well as for our internal analytics and reporting purposes.
Like many companies, we also collect information through cookies and similar technologies. For more information about this, please refer to our Cookie Notice: https://grenag.com/pages/cookie-policy.
The information we collect includes:
Log and Usage Data. Log and usage data are service-related, diagnostic, usage, and performance information that our servers automatically collect when you access or use our services and that we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, as well as information about your activities in the services (such as timestamps, pages and files viewed, search queries, and other actions such as feature usage). Device event information (such as system activity, error reports (sometimes called "crash reports"), and hardware settings) may also be included.
Device Data. We collect device data, such as information about your computer, phone, tablet, or other device you use to access the services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data, such as information about the location of your device, which may be precise or imprecise. The volume of information collected depends on the type and settings of the device you use to access the services. For example, we may use GPS and other technologies to collect geolocation data that indicates your current location (based on your IP address). You can choose to refuse us from collecting this information by denying access to information or by disabling location settings on your device. However, if you choose to do so, certain features of the services may not be available.
2. How Do We Process Your Information?
In brief: We process your information to provide, improve, and manage our services, communicate with you, ensure security and prevent fraud, as well as to comply with laws. We may also process your information for other purposes if you consent to it.We process your personal information for various reasons, depending on how you interact with our services, including:
To facilitate the creation and authentication of user accounts and otherwise manage user accounts. We may process your information to enable you to create and log into your account, as well as to maintain account functionality.
To facilitate the delivery and performance of services to the user. We may process your information to provide you with the requested service.
To respond to user requests/provide user support. We may process your information to respond to your requests and resolve any issues you may encounter with the requested service.
To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the services.
To request returns. We may process your information as necessary to request returns and contact you regarding your use of our services.
To send you marketing and advertising communications. We may process the personal information you provide to us for marketing purposes if it aligns with your marketing preferences. You can unsubscribe from our marketing emails at any time. For more information, see "WHAT ARE YOUR DATA PROTECTION RIGHTS?" below).
To provide you with targeted advertising. We may process your information to develop and display personalized and relevant advertising content to you, based on your interests, location, and more. For more information, see our Cookie Policy: https://grenag.com/pages/cookie-policy.
To protect our services. We may process your information as part of our efforts to maintain the safety and security of our services, including monitoring and preventing fraud.
To identify usage trends. We may process information about how you use our services to better understand their usage and to improve them.
To determine the effectiveness of our marketing and advertising campaigns. We may process your information to better understand how to provide marketing and advertising campaigns that are most relevant to you.
To save or protect the life or vital interests of a person. We may process your information as necessary to save or protect the life or vital interests of a person, such as to prevent harm.
3. What Legal Bases Do We Rely On to Process Your Information?
In brief: We only process your personal data if we believe it is necessary and if we have a valid legal basis under applicable law, such as your consent, to comply with laws, provide you with services, fulfill contractual obligations, or protect your rights, or to satisfy our legitimate business interests.If you are in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases on which we rely to process your personal data. Therefore, we may rely on the following legal bases to process your personal data:
Consent. We may process your data if you have given us permission (i.e., your consent) to use your personal data for specific purposes. You can withdraw your consent at any time. Click here to learn more.
Contract Performance. We may process your personal data if we believe it is necessary to fulfill our contractual obligations to you, including providing our services or at your request before concluding a contract with you.
Legitimate Interests. We may process your data if we believe it is reasonably necessary to achieve our legitimate business interests, and those interests do not outweigh your fundamental interests and rights. For example, we may process your personal data for some of the purposes described in order to:
Send users information about special offers and discounts on our products and services
Develop and display personalized and relevant advertising content to our users
Analyze how our services are used to improve them and engage and retain users
Support our marketing activities
Diagnose problems and/or prevent fraudulent activities
Understand how our users use our products and services to improve the user experience
Legal Obligations. We may process your data if we believe it is necessary to comply with our legal obligations, such as cooperating with a law enforcement or supervisory authority, exercising or defending our legal rights, or disclosing your information as evidence in a legal proceeding in which we are a party.
Vital Interests. We may process your data if we believe it is necessary to protect your vital interests or those of a third party, such as in situations involving potential threats to a person's security.
If you are in Luxembourg, this section applies to you.
We may process your information if you have expressly given us your permission (i.e., your explicit consent) to use your personal data for specific purposes, or in situations where your consent can be inferred (i.e., implied consent). You can withdraw your consent at any time. Click here to learn more.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including:
When the collection is clearly in the interest of a person and no timely consent can be obtained
For investigations and detection and prevention of fraud
For business transactions under certain conditions.
When included in a testament and the collection is necessary to assess, process, or settle an insurance claim
To identify injured, sick, or deceased persons and communicate with relatives
When we have reasonable grounds to believe that a person has been a victim of financial abuse, is or may be
When it is reasonable to believe that the collection and use with consent would impair the availability or accuracy of information and collection is reasonable for purposes related to the examination of a breach of an agreement or violation of Luxembourg laws or provincial laws
When disclosure is necessary to comply with a subpoena, search warrant, court order, or court rules regarding the production of documents
When created by a person in the course of his employment, business, or profession and the collection corresponds to the purposes for which the information was created
When the collection is carried out solely for journalistic, artistic, or literary purposes
When the information is publicly accessible and regulated by the provisions.
4. When and With Whom Do We Share Your Personal Information?
In brief: We may share information in specific situations described in this section and/or with the following categories of third parties.Suppliers, Consultants, and Other Service Providers. We may share your data with third-party service providers, subcontractors, or agents ("third parties") who provide services on our behalf and need access to this information to perform this work. We have contracts with our third parties to protect your personal information. This means they cannot do anything with your personal information unless we have authorized them to do so. They also will not share your personal information with any organization other than ours. They also commit to protecting the data held for our account and retaining it for the period we specify. The categories of third parties with whom we may share personal information include:
We also must share your personal information in the following situations:
Business Transfers. We may share your information as part of negotiations or in the event of a merger, sale of company assets, financing, or acquisition of all or part of our business by another company.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
5. Do We Use Cookies and Other Tracking Technologies?
In brief: We may use cookies and other tracking technologies to collect and store your information.We may use cookies and similar tracking technologies (such as web beacons and pixels) to access information or store it. Specific information about how we use such technologies and how to opt out of certain cookies is available in our Cookie Policy: https://grenag.com/pages/cookie-policy.
6. How Long Do We Retain Your Information?
In brief: We retain your information for as long as necessary to achieve the purposes outlined in this privacy policy, unless otherwise required by law.We will only retain your personal information for as long as necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this statement will require us to keep your personal information for longer than the period in which users have an account with us.
If we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If this is not possible (for example, if your personal information is stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. How Do We Protect Your Information?
In brief: We strive to protect your personal information through a system of organizational and technical security measures.We have implemented appropriate and reasonable technical and organizational security measures to protect the security of the personal information we process. Despite our protection measures and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed 100% secure. Therefore, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to circumvent our security measures and collect, access, steal, or modify your information without authorization. While we do our best to protect your personal information, the transmission of personal information to and from our services is at your own risk. You should only access the services in a secure environment.
8. What Are Your Data Protection Rights?
In brief: In certain regions such as the European Economic Area (EEA), the United Kingdom (UK), and Luxembourg, you have rights that allow you greater access to and control over your personal information. You can access, modify, or terminate your account at any time.In certain regions (such as the EEA, UK, and Luxembourg), you have certain rights under applicable data protection laws. These may include the right (i) to access your personal information and obtain a copy, (ii) to correct or delete it, (iii) to limit the processing of your personal information, and (iv) potentially, data portability. In certain situations, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us at the contact information provided below.
We will review each request in accordance with applicable data protection laws and respond to it.
If you are in the EEA or UK and believe that we are processing your personal information unlawfully, you also have the right to lodge a complaint with your local data protection authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are in Switzerland, contact details for data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawal of Your Consent: If we rely on your consent to process your personal information, which may be explicit and/or implied under applicable law, you have the right to withdraw your consent at any time. You can revoke your consent at any time by contacting us at the contact information provided below.
Please note, however, that this does not affect the legality of processing carried out before your withdrawal, and if permitted by applicable law, the processing of your personal information based on legitimate grounds other than consent will not be affected.
Unsubscribing from Marketing and Advertising Communications: You can unsubscribe from our marketing and advertising communications at any time by clicking the unsubscribe link in the emails we send or by contacting us using the contact information provided in the "How to Contact Us About This Notice" section below. You will then be removed from marketing lists. However, we may continue to communicate with you, for example, to send you service-related messages necessary for the management and use of your account, to respond to service requests, or for other non-advertising purposes.
Account Information: If you wish to access or modify your account information or terminate your account at any time, you can:
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with investigations, enforce our Terms of Use, and/or comply with applicable legal requirements.
Cookies and Similar Technologies: Most web browsers are set by default to accept cookies. However, you can usually choose to set your browser to delete and refuse cookies. If you choose to delete or refuse cookies, it may affect certain features or services of our services. To opt out of advertiser interest-based advertising on our services, visit http://www.aboutads.info/choices/. For more information, see our cookie policy: https://grenag.com/pages/cookie-policy.
If you have any questions or comments about your data protection rights, you can contact us at info@grenag.com.
9. Do Not Track Browser Feature
Most web browsers as well as some mobile operating systems and mobile applications have a Do Not Track feature or setting that you can activate to indicate your privacy preferences and that your online browsing activities should not be monitored or collected. Currently, there is no uniform standard for how to detect and implement Do Not Track signals. For this reason, we do not currently respond to Do Not Track signals sent by browsers or to other mechanisms that automatically transmit your choice not to be tracked online. If an online tracking standard were to be established in the future that we must comply with, we will inform you of this practice in a revised version of this privacy notice.10. Do California Residents Have Specific Privacy Rights?
In brief: Yes, if you are a resident of California, you have specific rights regarding access to your
personal information.
The California Civil Code Section 1798.83, also known as the "Shine The Light"
Law, allows our users residing in California to request, once per year and free of charge, information about
the categories of personal information (if available) that we have disclosed to third parties for direct
marketing purposes during the preceding calendar year, as well as the names and addresses of all third
parties with which we have shared personal information. If you are a California resident and would like to
make such a request, please send us your request in writing using the contact information provided
below.
If you are under 18 years of age, reside in California, and have a registered account with the
Services, you have the right to request the deletion of data you have publicly posted on the Services. To
request the deletion of such data, please contact us using the contact information provided below and
provide the email address associated with your account along with a statement indicating that you reside in
California. We will ensure that the data is not publicly displayed on the Services, but please note that the
data may not be entirely or completely deleted from all our systems (e.g., backups, etc.).
CCPA
Privacy Notice
The California Code of Regulations defines a "resident" as follows:
(1) any
person who is not merely passing through or temporarily in the state of California, and
(2) any
person who is domiciled in California and who is temporarily or temporarily outside the state of
California
All other persons are defined as "non-residents".
If this definition of "resident"
applies to you, we must comply with certain rights and obligations regarding your personal
information.
What categories of personal information do we collect?
What data have we
collected and not collected over the past 12 months:
A. Identifiers - Yes
Contact information
such as real name, alias, postal address, telephone or mobile phone number, unique personal identifier,
online identifier, IP address, email address, and account name
B. Categories of personal information
covered by the California Customer Records Act - Yes
Name, contact information, education,
employment, employment history, and financial information
C. Characteristics protected under
California or federal law - No
Gender and date of birth
D. Commercial information -
No
Transaction information, purchase history, financial details, and payment information
E.
Biometric information - No
Fingerprints and voiceprints
F. Internet or other similar network
activity - No
Browsing history, search history, online behavior, interest data, and interactions with
our websites and other websites, applications, systems, and advertisements
G. Geolocation data -
Yes
Device location
H. Audio, electronic, visual, thermal, olfactory, or similar information -
No
Images and audio, video, or call recordings created as part of our business activities
I.
Professional or employment-related information - No
Professional contact details to provide our
services at a professional level, or professional title, employment history, and professional qualifications
if you apply to us
J. Educational information - No
Student data and directory
information
K. Inferences drawn from other personal information - No
From the collected
personal information listed above, inferences can be drawn to create a profile or summary of a person's
preferences and characteristics, for example.
We may also collect other personal information outside
of these categories when you interact with us personally, online, by phone, or by mail, as part of:
-
Obtaining assistance via our customer support channels;
- Participating in customer surveys or contests;
and
- Assisting in the provision of our services and responding to your requests.
How do we use
and share your personal information?
Grenke Wallet collects and shares your personal information
via:
- Targeted cookies/marketing cookies
Social media cookies
- Tags/pixels
For more
information on our data collection and sharing practices, please consult this privacy notice and our cookie
notice: https://grenag.com/pages/cookie-policy.
You
can contact us via email at info@grenag.com or use the contact details provided at the bottom of
this document.
If you are using an authorized agent to exercise your right to opt-out, we may deny a
request if the authorized agent does not provide proof that they have been legally authorized to act on your
behalf.
Are your information shared with others?
We may disclose your personal information
pursuant to a written contract between us and each service provider. Each service provider is a for-profit
entity that processes information on our behalf.
We may use your personal information for internal
business purposes, such as internal research for technological development and demonstration. This is not
considered a "sale" of your personal information.
Grenke Wallet has not sold personal data to third
parties for business or marketing purposes in the last twelve (12) months. Grenke Wallet has disclosed the
following categories of personal information to third parties for business or marketing purposes in the last
twelve (12) months:
- Category A. Identifiers such as coordinates like your real name, alias, postal
address, landline or mobile phone number, unique personal identifier, online identifier, IP address, email
address, and account name.
- Category B. Personal information as defined in the California Customer
Records Law, such as your name, coordinates, education, employment, employment history, and financial
information.
- Category G. Geolocation data such as device location.
You can find the categories
of third parties with whom we share personal information for business or marketing purposes in the section
"WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"
Your rights regarding your personal
data
Right to deletion of data - Deletion request
You can request the deletion of your
personal information. If you ask us to delete your personal information, we will honor your request and
delete your personal information, subject to certain legal exceptions, such as (but not limited to) the
exercise of freedom of expression rights by another consumer, our legal compliance requirements, or any
processing necessary to combat illegal activities.
Right to information - Information
request
Depending on the circumstances, you have the right to know:
- if we collect and use
your personal information;
- the categories of personal information we collect;
- the purposes for
which collected personal information is used;
- if we sell your personal information to third
parties;
- the categories of personal information we have sold or disclosed for business purposes;
-
the categories of third parties to whom personal information has been sold or disclosed for business
purposes; and
- the commercial or business purpose of collecting or selling personal
information.
Under applicable law, we are not required to delete or provide information to consumers
that have been de-identified in response to a consumer request, nor to re-identify individual data to verify
a consumer request.
Right to non-discrimination in the exercise of consumer privacy rights
We
will not discriminate against you if you exercise your privacy rights.
Verification
process
Upon receipt of your request, we must verify your identity to determine if you are the same
person from whom we have information in our system. These verification efforts require us to ask you for
information so that we can compare it with the information you have previously provided to us. Depending on
the type of request you have submitted, we may ask you to provide certain information so that we can compare
the information you have provided with what we already have, or we may contact you through a mode of
communication (e.g., telephone or email) that you have already provided to us. We may also use other
verification methods depending on the circumstances.
We will only use the personal information
provided in your request to verify your identity or authorization to make the request. To the extent
possible, we will avoid asking for additional information for verification purposes. However, if we cannot
verify your identity using the information we already manage, we may ask you to provide additional
information to verify your identity and for security or fraud prevention purposes. We will delete this
additional information provided as soon as we have completed the verification.
Other privacy
rights
You can object to the processing of your personal information
You can request
correction of your personal data if it is incorrect or no longer relevant, or request limitation of
information processing.
You can designate an authorized representative to make a request on your
behalf in accordance with the CCPA. We may deny a request made by an authorized representative who does not
provide proof that they have been legally authorized to act on your behalf in accordance with the
CCPA.
You can request that your personal information not be sold to third parties. Upon receipt of a
withdrawal request, we will process the request as soon as possible, but no later than fifteen (15) days
from the date of receipt of the request.
To exercise these rights, you can contact us via email at
info@grenag.com or use the contact details provided below. If you have a complaint about how we
handle your data, we would like to hear from you.
11. Will we update this notice?
In short: Yes, we will update this notice as necessary to remain compliant with relevant laws.We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revision" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may inform you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to regularly check this privacy notice to stay informed about how we are protecting your information.