GrayHair Software, LLC (“GrayHair”, “we”, “our”, or “us”) provides this privacy policy to describe how we collect, use, sell, and share information, including information collected through grayhairsoftware.com or other affiliate websites (collectively, the “Sites”), information received from third parties, and information processed through GrayHair’s mail tracking and address quality services (collectively, the “Services”).

Information Collection:

When using our Sites, you may provide information about yourself, including your real name, alias, phone number, job title, employer name, address, email address, financial information, and any other information you choose to provide. We collect information, for example, when you use our Services, when you create an account with us, contact us, or interact with us for any other purpose. We also collect information from applicants and employees to manage the employer-employee relationship.

We (and other entities) automatically collect information relating to your interactions with us and our Sites and Services or other websites or apps, including browser type, browsing history, IP address, pages visited and other activities on the Site, device type, language preference, referring site, time and date of visit, and other information we collect through the use of cookies and similar technology. See the “Digital Advertising & Analytics” section of this privacy policy to learn more about the use of this information and the choices available to you.

To provide our Services, we collect information from various companies and sources that collect and supply consumer data, including public sources, our clients, and our third-party marketing partners. From these sources, we may collect, for example, name, telephone number, and address information.

Information Use:

• GrayHair may use your information for any lawful purpose, including to:
• Respond to your requests for products, services, and information;
• Improve the functionality, security, and usability of the Sites and Services;
• Conduct internal research and marketing and promotional activities;
• Send registered users of our Sites an email to describe new features, to solicit feedback, or provide update with what’s going on with GrayHair and our products;
• Fulfill a contract with our clients or other third parties;
• Provide our Services to our clients;
• Perform auditing relating to a current interaction with our Sites or Services;
• Detect security incidents and help to ensure the security and integrity of the Sites and Services;
• Debug to identify and repair errors that impair existing intended functionality;
• Engage in short-term, transient use, of personal information;
• Maintain or service accounts, provide customer service, process or fulfill orders, process payments, provide analytics, or provide ads or marketing services;
• Manage employee relationships including payroll, taxes, and benefits administration;
• Associate visitation data from our Sites with other personal information we or others maintain about you,
• including email addresses, to send marketing messages for GrayHair products and services;
• Comply with applicable laws or regulations; or
• With your consent, or as otherwise disclosed at the time information is collected.

We may use information that has been de-identified or aggregated without limitation.

Information Sharing:

We may share the information we collect with other parties, including the following:

• With service providers who process information on our behalf, such as providers that maintain or service accounts, provide customer service, process or fulfill orders, process payments, provide analytics, provide ads or marketing services, or provide Services available at our Sites, or with our legal or business advisors;
• With customers, marketing partners, marketing services, and platforms to provide our Services;
• With any affiliates or joint venture partners that we may have in the future;
• As part of a corporate sale, merger, or acquisition, or other transfer of all or part of our assets, including as
• part of a bankruptcy proceeding;
• Pursuant to a subpoena, court order, governmental inquiry, or other legal process or as otherwise required
• by law, to protect our rights or the rights of third parties, or to protect the safety or security of any person or
• entity; and
• With your consent or as otherwise disclosed at the time of data collection or sharing.

We may share information that has been de-identified or aggregated without limitation.

GrayHair may also publish any request or question you send to us about our Services or software (for example via email or via one of our feedback mechanisms) to help us clarify or respond to your request or to help us support other users. Please note that if you disclose information as part of a request or question, this information may be viewed, collected, and used by others.

Digital Advertising & Analytics

To assist in marketing of GrayHair’s Services, we may partner with ad networks and other ad serving providers (“Advertising Providers”) that serve ads on behalf of us and others on non-affiliated platforms. Some of those ads may be personalized, meaning that they are intended to be relevant to you based on information Advertising Providers collect about your use of our Sites and other sites or apps over time, including information about relationships among different browsers and devices. This type of advertising is known as interest-based advertising.

You may visit the DAA Webchoices tool at http://www.aboutads.info to learn more about this type of advertising and how to opt out of this advertising on websites by companies participating in the DAA self-regulatory program. You can also exercise choices regarding interest-based advertising on your mobile device by downloading the appropriate version of the DAA’s AppChoices tool at https://youradchoices.com/appchoices.

If you delete your cookies or use a different browser or mobile device, you may need to renew your opt-out choices exercised through the DAA Webchoices tool. Note that electing to opt out will not stop advertising from appearing in your browser or applications. It may make the ads you see less relevant to your interests.

We may also work with third parties that collect data about your use of the Sites and other sites or apps over time for non-advertising purposes. GrayHair uses Google Analytics and other third-party services to improve the performance of our Sites and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our Sites, visit http://www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit http://tools.google.com/dlpage/gaoptout.

Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our Sites may not function as intended.

Third-Party Links and Tools

Our Sites may provide links to third-party websites or apps. We do not control the privacy practices of those websites or apps, and they are not covered by this privacy policy. You should review the privacy policies of other websites or apps that you use to learn about their data practices.

The Sites also includes integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal information or you otherwise interact with these features on the Sites, those companies may collect information about you and may use and share such information in accordance with your account settings, including by sharing such information with the general public.

Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use.

State Privacy Rights

Specific U.S. States grant individuals certain rights under state privacy laws with respect to personal information we collect. If you are subject to the privacy laws of such states, this section of the privacy policy contains disclosures required by law and explains rights that may be available to you.

Personal Information We Collect and Disclose

• In the preceding 12 months, GrayHair has collected and disclosed the following categories of personal information:
• Personal and online Identifiers (such as real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers);
• Personal information categories listed in the California Customer Records statute (such as name, address, telephone number);
• Internet or other electronic network activity information (such as browsing history, search history, interactions with GrayHair’s website, application, or advertisement);
• Inferences drawn from the above information about your predicted characteristics and preferences; and
• Other information about you that is linked to the personal information above.

GrayHair sells and shares personal information as part of its Services. GrayHair also sells and shares personal information for its own marketing purposes and for targeted advertising. Specifically, in the past 12 months, we have sold and/or shared the following categories of personal information :

• Personal and online identifiers (such as a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers);
• Personal information categories listed in the California Customer Records statute (such as a name, address, telephone number);
• Internet or other similar network activity information (such as browsing history, search history, interactions with GrayHair’s website, application, or advertisement); and
• Inferences drawn from other personal information (excluding any information that may be considered sensitive under applicable state laws ).
• GrayHair does not knowingly sell or share personal information of individuals under 16.
• We do not use or disclose “sensitive personal information,” as defined under California law.

Categories of Sources

We collect personal information from the following categories of sources:

• You;
• Public records;
• Our affiliates and joint venture partners;
• Our clients;
• Our business partners;
• Our service providers;
• Business-to-business companies;
• Data brokers; data compilers; and consumer data resellers; and
• Advertising companies and networks.

Our Purposes for Processing Personal Information

We use and disclose the personal information we collect for our commercial and business purposes, as furtherdescribed above in the “Information Use” section of this privacy policy.

We may use and share aggregated and de-identified information to the extent permitted by applicable law. When we use de-identified information, we maintain and use the information in de-identified form and do not attempt to re-identify it, except to check whether our deidentification processes satisfy the requirements of applicable law.

Recipients of Personal Information

We disclose the categories of personal information designated above to the categories of third parties listed above in the “Information Sharing” section of this privacy policy for commercial and business purposes.

Your Rights:

Residents of certain states have rights with respect to the personal information collected by GrayHair. You may be able to exercise the following rights regarding personal information, subject to certain exceptions and limitations:

• The right to confirm whether we are processing personal information about you.
• The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell about you; the categories of sources from which we collected personal information about you; our purposes for collecting or selling personal information about you; the categories of personal information about you that we have sold or disclosed for a business purpose; and the categories of third parties with which we have shared personal information.
• Depending on your state law, the right to receive a portable and readily usable copy of the personal information we have collected about you, to the extent feasible.
• he right to correct inaccuracies in the personal information we have collected about you.
• The right to request that we delete the personal information we have collected about you.Unless an exception applies, GrayHair will remove any non-publicly sourced data upon request. GrayHair may refuse to delete personal information for the following reasons:
  • If the personal information is needed to complete a contract or provide a good or service requested by you;
  • It is necessary for the detection of security incidents, to protect against malicious, deceptive, fraudulent, or illegal activity, or to prosecute those responsible for that activity, and to debug and repair errors that impair existing functionality;
  • It is necessary for compliance with GrayHair’s legal obligations;
  • It is collected and maintained for peer reviewed, scientific, historical, or statistical research;
  • Allowing for the exercise of free speech, ensuring the rights of other consumers to exercise free speech, or allowing the exercise of another right provided by law;
  • It is necessary to enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
  • Any other exception applies under applicable state laws.
• The right to opt-out of (i) the sharing or processing of personal information for targeted advertising; (ii) the sale of personal information; or (iii) profiling for decisions that have significant effects. Please note that if you opt out of certain practices, we may be unable to provide you with some services.
• The right not to receive discriminatory treatment for the exercise of the above privacy rights.

You may submit consumer rights requests exercising the above rights by calling our number at (856) 727-9372, or by emailing us to submit your request at privacy@grayhairsoftware.com.

Additionally, for individuals subject to certain state laws, if you have submitted a request that we have not reasonably fulfilled, you may contact us to appeal our decision by sending an email to privacy@grayhairsoftware.com.

Verification Process and Required Information

Note that we may need to request additional information from you to verify your identity or understand the scope of your request. You will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, basic contact information like your name and email address.

If GrayHair cannot verify the identification of the individual making the request, GrayHair will not disclose any personal information to the requester and will inform you that we cannot verify your identity. GrayHair will not provide you with specific pieces of personal information if the disclosure would create a substantial, articulable, and reasonable risk to the security of your personal information, your account with the business, or the security of GrayHair’s systems or networks.

There may be circumstances where GrayHair must deny your verified request because of a conflict with state law, federal law, or an exception to your state’s privacy laws. If GrayHair must deny a request accordingly, then you will be informed and given the basis for the denial. If the request is denied only in part, GrayHair will disclose the other information sought by you.

Authorized Agent

Depending on your state law, you may also designate an authorized agent to submit requests to access or a request to delete on your behalf. If you are using an authorized agent to submit the opt-out request on your behalf, we may require that you:

(i) Provide the authorized agent written permission to do so; and

(ii) verify your own identity directly with GrayHair.

GrayHair may deny a request from an agent that does not submit proof they have been authorized by you to act on their behalf.

Retention

We retain personal information in identifiable form only for as long as necessary to fulfill the purposes for which the personal information was provided to us or, if longer, to comply with legal obligations, to resolve disputes, to enforce agreements, or to satisfy and similar essential purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements. Once the retention period expires and if not otherwise required to retain information by law, we will delete or de-identify personal information.

Annual User Rights Request Metrics

California law requires certain businesses to compile and disclose metrics on an annual basis regarding their compliance with consumer rights requests. During the previous calendar year, GrayHair facilitated the following requests from California residents:

 

The mean number of days within which GrayHair substantively responded to requests to delete, requests to correct, requests to know, and requests to opt-out of sale/sharing is 3 days.

Your Choices

To opt out of our email marketing, you can use the link provided at the bottom of each marketing message. If you opt out of our email marketing, we will still send you messages related to our transactions and relationship with you, such as order confirmations.

For choices with respect to third-party interest-based advertising activities, please see the “Digital Advertising & Analytics” section above.

Privacy Policy Changes

If our information practices change, we will post these changes on this page and we’ll revise the “Effective” date atthe top of the privacy statement. GrayHair encourages you to periodically visit this page to learn of any updates.

Contact Us

If you have any concerns or questions about anything in this policy, or regarding GrayHair’s services, please get intouch with us.

Physical address and principal place of business:

GrayHair Software, LLC

Attn: GrayHair Privacy Officer

1 SE Ocean Blvd, Stuart, FL 34994-2214

You can contact us:

• By mail at the address above,
• By using our website contact form (www.grayhairsoftware.com)
• By telephone, at 856-727-9372
• By email, at privacy@grayhairsoftware.com