PRIVACY AND DATA PROTECTION/RETENTION POLICY

Date of Last Revision: December 2023

Introduction

This Privacy and Data Retention/Protection Policy explains how we collect, use, disclose and protect your Personal Information when you visit our website or use our services.

“Personal Information” is an information that identifies or can be used to identify, contact or locate the person to whom such information pertains.

At Grapevine, we are fully committed to respecting privacy and to protecting any information that our clients provide. We prioritize your privacy and security and ensure that all the information you provide is protected.

We follow and comply with best practices and regulation in the sphere of privacy including but not limited to General Data Protection Regulations (GDPR).

By using our website, you consent to the practices described in this Privacy Policy. If you do not agree with our practices, please do not use our website or services.

Information We Collect

We may collect the following types of information when you use our website or services:

1.1. Personal Information: This includes information such as your name, email address, phone number and any other information you provide to us voluntarily.

1.2. Non-Personal Information:  We may collect non-personal information such as your IP address, browser type, operating system, and other technical details when you visit our website. This information is collected for analytical purposes and to improve our services

• Account and Profile Data: When you create an account and profile on the Grapevine Platform, we collect your name, email address, and other information you provide, such as topics that you know about or find interesting. You can choose to add your photo, country of residence, place of employment, education history, and any other information to your public-facing profile. Once you create a profile, others will be able to see certain information about your activity on the Grapevine Platform, such as the questions and answers you post, your followers and who you follow, topics of interest to you, and your credentials.
• Your Content: We collect the information and content that you post on the Grapevine Platform, including your questions, answers, comments, photos, and the edit history to your content. Unless you have posted certain content anonymously, your content, date and time stamps, and all associated comments are publicly viewable on the Grapevine Platform. Your content may be indexed by search engines and be republished elsewhere on the Internet in accordance with our Terms of Use.
• Communication Records: We maintain a record when you communicate with us via email, through the Grapevine Platform, or otherwise. The Grapevine Platform also provides a “Messages” feature that allows you to send direct messages through the Platform to other users. We store these communications and information related to these messages, such as the date of the communication and to whom it was sent.
• Third Party Application Login: You can log into your Grapevine account using third party applications (e.g., Facebook, Google, and Apple). When you log in using this method, you allow us to collect and process your name and email address associated with that third party application for authentication and identity verification purposes. You can also choose to import your contacts to your Grapevine account to connect with your friends on the Grapevine Platform. Note that your use of any third-party application and the personal data you provide them is governed by their terms of use, privacy policies, and other policies.
• Cookies and Similar Technologies: We and our third-party providers use cookies, log files, pixel tags, local storage objects, and other similar technologies to automatically collect information about your activities, such as your searches, page views, date and time of your visit, and other information about your use of the Grapevine Platform. We also collect information about your web browser or mobile device in connection with your use of the Grapevine Platform such as your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, and requested and referring URLs. We also receive information when you view content on or otherwise interact with the Grapevine Platform, even if you have not created an account. For more detailed information about these mechanisms refer to our Cookie Policy.
• Platform Engagement Data: We collect platform engagement and browsing information, such as IP address, date and time stamp, user agent, Grapevine cookie ID, URLs visited, unique advertising identifiers (including mobile device advertising identifiers) or content identifiers (if applicable), time zone, and other information about your activity on the Grapevine Platform. We may also receive these types of information about you from third parties, such as our partners (including ad partners) or Grapevine affiliates.
• Data From Advertisers: Third party advertisers who use our Ad Services may also provide us with information about you as part of their ad campaigns (e.g., email addresses) to create custom audiences for personalizing their ad campaigns or for measuring the effectiveness of their ads. To learn more, including about how to opt -out of certain Ad Services, refer to our Cookie Policy.

How We Use Your Information and Legal Basis for Processing

We process the information we collect for the following purposes, and under the following legal basis. You may decline to submit personal information through the Grapevine Platform, in which case we may not be able to provide certain services to you.

• Provide our Services: To provide you the services we offer on the Grapevine Platform and make the Grapevine Platform available to the public, communicate with you about your use of the Grapevine Platform, respond to your inquiries, provide troubleshooting, and for other customer service purposes. This is so we can comply with our contractual obligations to you.
• Personalization: To tailor the content and information that we or our third-party content publishers or advertisers may send or display to you in the Grapevine Platform. We also use your information to suggest followers and content, to help others find your profile, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Grapevine Platform. It is in our legitimate business interests to provide you with a customized experience.
• Advertising: To display interest-based, retargeted, contextual, and behavioral advertising to you in the Grapevine Platform. We also may use your information, to improve our advertising and measurement systems so we can show you relevant ads and to measure the effectiveness and reach of ads and services. It is in our legitimate business interests to provide advertising. Where necessary, we will obtain your consent before engaging in this processing.
• Marketing and Promotions: For marketing and promotional purposes, such as to send you news, special offers, promotions, or to otherwise contact you about products or information we think may interest you, including information about third-party products and services. It is in our legitimate interest to provide more relevant and interesting marketing and promotions messages. Where applicable, we obtain your consent before sending such marketing communications and you can unsubscribe anytime.
• Enable Communications: To facilitate communications, you send to us or to other users on the Grapevine Platform. We process information about who you have communicated with to better understand the use of our services. This processing is necessary to comply with our contractual obligations to you.
• Analytics: To gather analytics and metrics to better understand how users use the Grapevine Platform. We also use analytics data to evaluate and improve the Grapevine Platform, including the Ad Services and personalization, and to develop new products and services. It is in our legitimate business interests to make informed decisions about product development.
• Comply with Law: To comply with legal obligations, as part of our general business operations, and for other business administration purposes. This processing is necessary to comply with legal obligations and to serve our legitimate business interests in complying with the laws to which we are subject.
• Prevent Fraud and Misuse: To investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Use or this Privacy Policy. This processing is necessary to comply with legal obligations and to serve our legitimate interest in preventing misuse of the Grapevine platform, including through illegal activities and fraud.
• User Research: We may ask you to help us test new features or participate in surveys to help enhance your Grapevine experience. Your participation is voluntary, and we may use your personal information to communicate with you to seek your feedback.

How We Share Your Information

We share your information as outlined below, and where users have asked us to do so or otherwise consented:

• Service Providers: We share your information with third-party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, customer service providers, as well as service providers who assist us in providing the Ad Services. 
• Grapevine Affiliates: The information collected about you may be accessed by or shared with affiliates of Grapevine, Inc., whose use and disclosure of your personal information is subject to this Privacy Policy.
• Business Transfers: We may disclose or transfer your information as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event.
• Protection of Rights and When Legally Required: We may disclose information where we are required to do so by law, where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property, or safety of Grapevine, its users, or others.
• Your Content and Public Information: Your content, including your name, profile picture, profile information, and certain associated activity information is available to other users of the Grapevine Platform and may also be viewed publicly by non-users. Public viewing includes availability to non-registered visitors and users may share your content across other sites. In addition, your content may be indexed by search engines. 
• Platform Engagement Information: We share with our advertisers and publisher’s aggregate statistics, metrics, and reports about the performance of their ads in the Grapevine Platform. This aggregated data may include the number of unique user views, demographics about the users who saw their ads or content, and conversion rates. Certain features allow you to share your personal information with advertisers on our platform if you choose.
• Research: We share aggregated or anonymized information with third parties for market research, reporting, and analytics. The information we share in this context cannot be used to identify individual users.
• Protection of Assets: To protect your assets, we may use information to identify you and the assets belonging to you in order to secure access to your accounts and to prevent the fraud. Information about your transaction allows us to monitor suspicious activity and protect you from fraud and scam activity.
• To resolve disputes and enforce our agreements to the extent necessary and sufficient for protecting your interests or interests of other users. 
• To send periodic e-mails:  we may use the information we collect from you when you register or use certain other site features. This might be for security reasons, to ask your opinion about the website, or it may be to keep you updated on any changes to the services provided on the Website and our Services. We may also send periodic emails with news and Services updates, or use this information to follow up with you following live chat or email.

Your Rights to Your Information

There are significant number of rights related to your Personal Information, such as:

• The right to access and amend the personal information we hold about you: you have a right to request a copy of the personal information we hold about you. Also, you have the right to correct or update your Personal information at any time.
• The right to delete the Personal Information: you may request to remove the personal data if you do not want to use our Services or want your data to be erased, you can request us to remove your account permanently. Your requests could be fulfilled by erasing the personal data, to the extent permissible by the applicable law and regulations. In certain cases, we are obliged to store your information to be legally compliant. 
• The right to restrict processing: you have the right to ask us to restrict the processing of your Personal Information. When processing is restricted, we can still store your information, but will not use it further.
• The right to data portability: you have the right to receive Personal Information you provide to us, in a “commonly used machine-readable format’. This allows you to obtain and reuse your information for your own purposes across different services.
• The right to object to the processing of your data: you have a right to object to our use of your Personal Information for our own purpose at any time. In other words, you can withdraw your consent to processing your Personal Information by us. If you want to exercise this right, you may contact us. 

Data Retention

We will retain your information only for as long as is necessary for the purposes set out in this policy. We will retain your information just to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

The User may request the removal of his/her personal data. If that happens, the user request could be fulfilled by erasing the personal data, to the extent permissible by applicable law and regulations. In certain cases, we are obliged to store your information to be legally compliant.

Data Security

We take reasonable measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. However, no data transmission over the internet can be guaranteed as completely secure.

Cookie Policy

Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from the Website and stored on your computer’s hard drive. We use Cookies to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes, including:

• Recognizing you when you sign-in-to use our services
  
• Preventing fraudulent activity
• Improving security.
• Reporting: this allows us to measure and analyze the performance of our services.

You can manage browser cookies through your browser settings. The “Help” feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, how to disable cookies, and when cookies will expire. If you do this, however, you may have to manually adjust some preferences every time you visit a website and some features and services may not work.

Your Choices

You have the right to:

• Access, correct, or update your personal information by contacting us.
• Opt-out of receiving promotional communications from us by following the instructions in those communications or contacting us.

Third-Party Links

Our website may contain links to third-party websites or services. We are not responsible for the privacy practices or content of these third-party sites. Please review their privacy policies before using their services.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our practices or for other operational, legal, or regulatory reasons. Any changes will be posted on this page, and the effective date will be updated accordingly.

Contact Us

If you have any questions or concerns about this Privacy and Cookies Policy, kindly contact us at info@grapevine.com