Privacy Policy
LAST UPDATED: MAY 21, 2025
GrainChain, Inc. (“GrainChain”, “we”, “us”, or “our”) is committed to protecting your privacy. This
Privacy Policy applies to (i) the GrainChain Platform and GrainChain Software, (ii) the websites
owned and operated by us (the “GrainChain Website(s)”), and (iii) any services provided to you by us
in connection with the foregoing (clause (i) through (iii), collectively, the “GrainChain
Service”).For clarity, “GrainChain Service” has the same meaning as “Services” in our Terms of
Service. This Privacy Policy is a part of and incorporated into the GrainChain Terms of Service
Agreement (collectively, the “Terms”) entered into between GrainChain and you, or your employer, or
the entity that has provided you with credentials, or has otherwise authorized you, to access and
use the GrainChain Service. If any provision of this Privacy Policy conflicts with the Terms, this
Privacy Policy will control with respect to privacy and data-protection matters; the Terms will
control for all other matters.
Capitalized terms used in this Privacy Policy but not defined in this Privacy Policy have the
meanings given to them in the Terms. This Privacy Policy is intended to inform you about the kind of
information, including personally identifiable information, that we may collect from you in
connection with your use of the GrainChain Service and how, and for what purpose, we use that
information. Additional regional disclosures required by the California Consumer Privacy Act (as
amended by the CPRA), the EU/UK General Data Protection Regulation (“GDPR”), Virginia Consumer Data
Protection Act (“VCDPA”), and the Brazilian LGPD appear at the end of this notice.
YOU GIVE US CONSENT
Please read this Privacy 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, your
choice is not to use or access the GrainChain Service. By accessing or using the GrainChain Service,
or submitting information through the GrainChain Service, you agree to the terms of this Privacy
Policy and you expressly consent to the collection, use, and disclosure of your Personal Information
and Anonymous Information (as each term is defined below) in accordance with this Privacy Policy.
Where we rely on “consent” as a legal basis under GDPR Article 6(1)(a) (for example, for optional
marketing e-mails or geo-location), you may withdraw that consent at any time via the mechanisms
described below; withdrawal will not affect processing that has already occurred. You understand
that by providing us Personal Information, you allow us to identify you. Some of the services we
provide may be hampered if you do not provide us the necessary Personal Information.
DEFINING “INFORMATION” AND “USER DATA”
We collect Customer Data in connection with your use of the GrainChain Service, which includes both
Personal Information and Anonymous Information. “User Data” means content and information (including
Personal Information) submitted by users to, or through, the GrainChain Service. As further
explained below, User Data is controlled by the organization or other third party that entered into
the Terms with GrainChain (the “Customer”). When GrainChain collects or processes User Data, it does
so on behalf of the Customer. If you are using the GrainChain Service by invitation of a Customer,
whether that Customer is your employer, another organization, or an individual, that Customer
determines its own policies regarding storage, access, modification, deletion, sharing, and
retention of User Data which may apply to your use of the GrainChain Service. Please check with the
Customer about the policies and settings it has in place. “Personal Information” (sometimes called
“Personal Data” or “Personally Identifiable Information”) is information that allows someone to
identify or contact you, as well as any other non-public information about you that is associated
with or linked to any of the foregoing, and can include, for example, an individual's first and last
name, phone number, e-mail address and any unique online identifier such as an account ID, wallet
address, or Internet-Protocol (“IP”) address. “Anonymous Information” means data that is not
associated with or linked to your Personal Information; Anonymous Information does not, by itself,
permit the identification of individual persons. “Sensitive Personal Information” has the meaning
given in the CPRA and refers to data such as precise geolocation, Social Security number, and racial
or ethnic origin; we collect such data only as strictly necessary for regulatory compliance (e.g.,
Know-Your-Customer (“KYC”) checks) or where you expressly provide it.
PROTECTING YOUR PRIVACY
We do not share, rent or sell your account information to any third party, except as expressly set
forth in this Privacy Policy. Please help us protect your privacy by keeping your account
information safe. Do not disclose your account password or login information to anyone and keep
changing it periodically. We maintain appropriate administrative, technical, and physical safeguards
(see “Security” below).
Registration Information
When you register an account for the GrainChain Service, you are required to provide us Personal
Information. We collect and store the following Personal Information in connection with the
registration of an account: your email address and first and last name. If you register via a
federated-identity provider (Google, Microsoft, etc.), we will also receive the OAuth or OpenID
Connect token and any profile information that provider shares (for example, avatar URL or locale).
We may use the Personal Information you submit during the registration process to send you
services-related communications. In addition, we may also use such Personal Information to send you
electronic newsletters or promotional e-mails, unless you have requested not to receive such
promotional communications from us as described below. Legal bases (GDPR): (i) performance of a
contract Art. 6(1)(b), (ii) our legitimate interest in administering the Service Art. 6(1)(f), or
(iii) your consent Art. 6(1)(a) for marketing messages.
Payment and Transaction Information
When you submit information to establish your account for payment transactions in connection with
the GrainChain Service, our third-party payment processor (currently, Dwolla) will collect, on our
behalf, your name, billing address, and complete bank account information, that enables the
GrainChain Service to execute on the transaction. For certain regulated transactions we may also
collect government-issued identification numbers, date of birth, and a selfie image to satisfy
anti-money-laundering (“AML”) and know-your-customer (“KYC”) obligations. Our payment processing
service provider will retain this information to process your transactions in connection with the
use of the GrainChain Service. We do not have routine access to your full bank-card number; we store
only the last four digits and tokenized references supplied by the processor.
Services usage information; Geolocation Data
This is information about how you are accessing and using the Services, which may include
administrative and support communications with us, and what third party integrations you use (if
any). In addition, if you use the GrainChain Service, GrainChain may collect your geolocation data
(subject to your consent), and certain mobile device information, which includes: device/platform
type and version (iOS v4, Android, etc.). We collect precise geolocation only when you actively
choose features that require it (e.g., on-site commodity-drop verification). You may disable
location sharing in your device settings at any time; however, certain functionality may then be
unavailable.
Feedback and Communications
If you provide us Feedback or contact us via e-mail or through our “contact-us” forms, we will
collect your first and last name and e-mail address, any information requested in our Feedback or
contact-us forms, as well as any other content included in the e-mail, Feedback or contact-us forms
you send to us. Any Feedback you provide will be governed by the Terms. We may use Personal
Information submitted in your communications to contact and respond to you and otherwise in the same
manner as described above for registration information. We may also publish aggregated,
de-identified comments for marketing purposes (e.g., “95 % of users report faster settlement”), but
never in a manner that would identify you.
Log File Information
When you access or use the GrainChain Service, our service provider may collect, and share with us,
information such as your web request, IP address, access times, and other browsing information. This
information is used to (i) provide you the GrainChain Service and other services requested by you,
(ii) improve the GrainChain Service and other services provided to you by us, (iii) notify users
about updates to the GrainChain Service, and (iv) contact you for our own internal marketing
purposes. Log data is retained for up to 12 months for security-audit purposes and then either
deleted or fully anonymized.
Anonymous Information
We may create Anonymous Information records from Personal Information by excluding information (such
as your name) that would otherwise make such data personally identifiable to you. We may use
Anonymous Information at our discretion and for any purpose.
When we provide or use this information, we employ procedures so that the data does not identify you
and we contractually prohibit recipients of the data from manipulating the data in a way that would
re-identify it back to you. Aggregated statistics (e.g., throughput, price-feed latency) may be
published in white-papers, research, or marketing materials.
Financial Transactions Involving GrainChain
To make informed decisions on whether to participate in a transaction with you, through financing or
otherwise, GrainChain will review and analyze Customer Data we have collected from you, which may
include your name, address, email address, phone number, transaction history, inventory data,
customer contracts, and historical performance. We will use this data with utmost care and respect
for your privacy, and we will not share it with third parties without your explicit consent, except
(i) with regulated financing partners bound by confidentiality obligations, or (ii) as otherwise
required by law. We value the trust you have placed in us and will continue to work hard to protect
your personal information and use it responsibly. If you have any questions or concerns about our
privacy practices, please do not hesitate to contact us.
Other (Opt-In Communications)
We may provide certain additional services and/or communications if you select such additional
services and/or communications by opting-in to such additional services and/or communications using
certain buttons provided in the user interface of our services. We will collect your name, e-mail
address and telephone number (if provided) and any other information we specify in the user
interface of our services where you opt-in by clicking on such buttons. We may use such Personal
Information to send you the corresponding additional services and/or communications. You may
withdraw your consent at any time by using the unsubscribe link in the message or contacting us.
HOW WE SHARE YOUR INFORMATION
We will share your Personal Information with third parties only in the ways that are described in
this Privacy Policy. We consider this information to be a vital part of our relationship with you.
There are, however, certain circumstances in which we may share your Personal Information with
certain third parties without further notice to you, as set forth below.
Service Providers
We may provide your information to third-party service providers (such as, but not limited to,
cloud-hosting, analytics, communications, KYC verification, and logistics vendors) who need the
information to perform services for us. These third-party service providers are contractually
forbidden to use your Personal Information for any purpose other than to provide the services
requested by us and are bound by confidentiality obligations.
Payment and Transaction Processors
We may provide your banking and payment information to third-party service providers engaged on our
behalf, including payment and transaction processors, for the purposes of executing your
transactions, effecting payment and servicing your account. As part of mandatory
“know-your-customer” checks, we or our payment partners may be required by law to collect and verify
additional identity information (e.g., government-ID images) and to screen you against sanctions
lists.
Affiliates
To provide the GrainChain Service and related support we may share some or all of your Personal
Information with our parent company and any subsidiaries or joint ventures under common control with
GrainChain (collectively, “Affiliates”). When we do so, we require our Affiliates to handle your
information in a manner consistent with this Privacy Policy and applicable law.
Business Transfers
As we develop our business, we might sell or buy businesses or assets. In the event of a corporate
sale, merger, reorganisation, dissolution, or similar event, Personal Information may be part of the
transferred assets. You will be notified via e-mail and/or a prominent notice on our website of any
change in ownership or uses of your Personal Information, as well as any choices you may have
regarding your Personal Information.
Other Disclosures - Legal / Safety
Regardless of any choices you make regarding your Personal Information (as set forth below), we may
disclose your Personal Information (i) to respond to subpoenas, warrants, court orders, lawful
requests or legal process, (ii) to establish or exercise our legal rights or defend against legal
claims or protect other users, (iii) in order to investigate, prevent, or take action regarding
illegal activities, suspected fraud, security incidents, or as otherwise required by law, or (iv) to
investigate, prevent, or take action regarding any violation of this Privacy Policy or the Terms.
YOUR CHOICES
Changes and Deletion of your Data
If your Personal Information changes, or if you no longer desire to use or access the GrainChain
Service, you may correct, update, amend, delete or request deletion by making the change in your
registered account settings page, or by contacting us at [email protected]. We will retain your
information for as long as your account is active or as needed to provide you services, resolve
disputes, enforce agreements, and comply with legal obligations. GDPR / UK GDPR / CPRA Rights. See
“Regional Disclosures” below for additional rights (access, portability, restriction, objection,
non-discrimination, etc.).
Opting Out
We will periodically send you e-mails that directly promote the use of the GrainChain Service. Out
of respect for your privacy, you may choose to stop receiving our marketing emails and you will have
the opportunity to “opt-out” by following the unsubscribe instructions included in these emails or
you can contact us at [email protected].
Services-Related Communications
While you may “opt-out” of certain services-related communications by following the unsubscribe
instructions provided in the e-mail you receive or by contacting us at [email protected], you may
not, despite your indicated e-mail preferences, “opt-out” of other services-related communications
regarding your account or any payments made, or to be collected, by you, including receiving notices
of any updates to our Terms or this Privacy Policy, except by terminating your account.
SECURITY
GrainChain employs technical and administrative control and maintain the security of information
collected through the GrainChain Service. Although we follow generally accepted standards to protect
the Personal Information submitted to us, both during transmission and once we receive, no method of
transmission over the Internet, or method of electronic storage, is 100% secure and no company,
including GrainChain, can completely or effectively eliminate the risks connected to handling
information on the Internet. You acknowledge and agree that you provide your Personal Information at
your own risk. If you have any questions regarding our security measures please contact
[email protected].
CHILDREN
GrainChain does not knowingly collect or maintain Personal Information from or about children under
the age of 13 (or under 16 if you reside in the European Economic Area or the United Kingdom). If we
learn that Personal Information of persons under the applicable minimum age has been collected on or
through the GrainChain Service, then we may deactivate the account and/or make the user content
inaccessible. If you find that we have personal information about anyone below the relevant minimum
age, please inform us at [email protected].
CHANGES TO THIS PRIVACY POLICY
This Privacy Policy may be amended by us from time to time. If we make material changes to this
Privacy Policy, we will notify you by posting the revised Privacy Policy on the GrainChain Website
or through the user interface of the GrainChain Platform or by notifying you at the email you
designated upon registration of your account. Your continued use of the GrainChain Service after
such notification of changes as described above will constitute your agreement to such changes. If
you object to any change, your sole recourse shall be to immediately terminate your account and
cease using the GrainChain Service.
QUESTIONS AND ADDITIONAL INFORMATION.
Please feel free to contact GrainChain at [email protected] if you have any questions about
GrainChain’s Privacy Policy, our Data-Processing Addendum, or our list of sub-processors.
REGIONAL DISCLOSURES.
California Consumers – CPRA
We do not sell Personal Information and have not done so in the preceding 12 months.
We do not share Personal Information for cross-context behavioural advertising.
Categories of Personal Information collected, sources, purposes, and disclosures are as described
above.
You have the right to know, delete, correct, and limit use of sensitive Personal Information;
exercise these rights via [email protected].
Virginia / Colorado / Utah / Connecticut Residents – similar rights are available; please contact
[email protected].
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