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1. What Information Do We Collect?

1.1. Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

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1.1.1. Personal Information Provided by You

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names

• email addresses

• usernames

• passwords

• debit/credit card numbers

• billing addresses

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1.1.2. Sensitive Information

We do not collect any special categories of sensitive personal data about you that are unrelated to the service (such as details on your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

The only sensitive information we may process with your explicit consent or as otherwise permitted by applicable law includes:

• Student Data, such as your school or university, year level, unit names, student number and assignment grades.

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Providing this information is entirely optional and is intended to benefit you by enabling features that help track your academic progress. This data also allows us to identify trends and improve our services, ensuring we can deliver a more personalized and effective experience. You are not required to provide this information to use our Services, and your choice to do so will not affect your access to or the functionality of our platform.

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1.1.3. Payment Data

We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. You may find their privacy notice link(s) here: https://stripe.com/au/privacy.

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1.1.4. Social Media Login Data

We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, google, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "How Do We Handle Your Social Logins?" below.

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All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

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1.2. Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, 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, and for our internal analytics and reporting purposes.

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Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Policy.

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The information we automatically collect includes:

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1.2.1. Log and Usage Data

Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which 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 and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

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1.2.2. 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.

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1.2.3. Location Data

We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect 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 tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

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1.3. User Content

We may collect user content, which consists of all the text and documents that you upload, enter, or otherwise transmit to us when you use our products. We process your user content and usage data to optimize your use of our service, for example we may take previous user content to personalize the marking and feedback given, optimizing the use and effectiveness of our Services.

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1.4. Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

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2. Responsibility with You

When you submit any Personal Information to us, you represent that you have the lawful right to submit the Personal Information and agree that you will not submit any information unless you are legally entitled to do so and that such Personal Information is true, complete, and accurate. You may not use a false email address or other identifying information to impersonate any person or entity, or otherwise mislead as to the origin of any content.

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Any improper collection or misuse of Personal Information is in violation of this Privacy Policy and of the applicable terms and conditions of use. You agree not to misuse any Personal Information available on our website or to gather it or use robots or other automated scripts, codes, or functionalities to do so. We may immediately suspend or terminate your access to our website without notice if we become aware that you are in breach of applicable terms or of this Privacy Policy.

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3. How Do We Make Money?

We offer free and paid products, and we make money from subscriptions of the paid products. GradeWise does not monetize data or use the content customers upload to our products for advertising purposes.

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4. Why Do We Process Your Information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.

• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "What Are Your Privacy Rights?" below.

• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

• To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.

• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

• To provide, deliver, and manage our products and services. We may process your information to support activities such as licenses, registrations, subscriptions, user access, billing, payments, and purchases.

• To customize your online experience. We may process your information to enhance the usability, performance, and personalization of our online services and platforms.

• To comply with legal obligations. We may process your information to comply with applicable laws and regulations, including tax, employment, and law enforcement reporting requirements.

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5. What Legal Bases Do We Rely on To Process Your Information?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located 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 we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

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5.1. Consent

We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time by contacting us using the contact details provided in the section “How Can You Contact Us About This Notice?”. 

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5.2. Legitimate Interests

We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Send users information about special offers and discounts on our products and services

• Analyze how our Services are used so we can improve them to engage and retain users

• Support our marketing activities

• Diagnose problems and/or prevent fraudulent activities

 

5.3. Legal Obligations

We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

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5.4. Vital Interests

We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

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If you are located in Canada, this section applies to you.

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We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

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We reserve the right to disclose your personal data as required by applicable law, in response to lawful requests by public authorities, including meeting national security or law enforcement requirements and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or other legal process served on us.

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In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• For business transactions provided certain conditions are met

• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

• For identifying injured, ill, or deceased persons and communicating with next of kin

• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

• If the collection is solely for journalistic, artistic, or literary purposes

• If the information is publicly available and is specified by the regulations

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6. When and With Whom Do We Share Your Personal Information?

6.1. Trusted Service Providers

We use service providers like Open AI to provide services that allow us to serve our users. These trusted service providers are bound by agreements that require them to follow data privacy and security requirements and only use your data in the way we tell them to.

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6.2. Government Agencies, Regulators, and Similar Authorities

We may disclose your information to governmental agencies, regulators, and other authorities or authorized parties if we determine that such disclosure is reasonably necessary to (a) comply with any applicable law, regulation, legal process, or appropriate governmental request or (b) protect ourselves, our users, or others from fraud, abuse, or other illegal or potentially harmful activities.

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6.3. Advertising Partners

We engage other companies to provide analytics services, serve advertisements promoting Grammarly across the web and in other companies’ mobile apps, and perform related services. We do not make user content available to these advertising partners. These companies may use cookies, web beacons, pixels, and other technologies to collect limited information about your interactions with our marketing websites, such as a cookie ID or device identifier and a link you click or page you visit on our website. In addition, we may work with advertising partners to translate other identifiers, such as your email address, into a unique identifier (called a hashed value) that such partners can then use to show ads promoting GradeWise on other websites and online services. These disclosures of hashed identifiers and information disclosed through advertising cookies and similar technologies may constitute “targeted advertising,” “sharing,” or “selling” under certain privacy laws, and you may opt out at any time. See the “Opting out of marketing and promotional communications” section for information about how to opt out of these disclosures.

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6.4. Vendors, Consultants, and Other Third-Party Service Providers

We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. These trusted third-party service providers are bound by agreements that require them to follow data privacy and security requirements, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The third parties we may share personal information with are as follows: 

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Advertising, Direct Marketing, and Lead Generation

• Google AdSense

AI Service Providers

• OpenAI

Allow Users to Connect to Their Third-Party Accounts

• Google account

Cloud Computing Services

• Google Cloud Platform

Data Backup and Security

• Google Drive Backup

Functionality and Infrastructure Optimization

• Google Cloud Storage

Invoice and Billing

• Stripe

Retargeting Platforms

• Google Analytics Remarketing

Social Media Sharing and Advertising

• Facebook advertising

Web and Mobile Analytics

• Google Analytics

Website Performance Monitoring

• Crashlytics

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We also may need to share your personal information in the following situations:

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6.5. Business Transfers

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

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6.6. Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

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6.7. Business Partners

We may share your information with our business partners to offer you certain products, services, or promotions.

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7. Do We Use Cookies and Other Tracking Technologies?

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

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We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, or to tailor advertisements to your interests (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

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To the extent these online tracking technologies are deemed to be a "sale"/"sharing" (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section “Do United States Residents Have Specific Privacy Rights?”.

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Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

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7.1. Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page at: https://policies.google.com/privacy.

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8. Do We Use Artificial Intelligence Based Products?

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

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8.1. Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including OpenAI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in “What Legal Bases Do We Rely on to Process Your Personal Information?”. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

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8.2. Our AI Products

Our AI Products are designed for the following functions:

• Text analysis

• AI insights

• Image analysis

• AI generated feedback

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8.3. How We Process Your Data Using AI

The only information processed by these AI Service Providers will be the files you upload to use our Service. These files will typically be assignment related files such as your draft, rubric, and task sheet.

All personal information processed using our AI Products is handled in line with our Privacy Notice and the Privacy Policies in place with these AI Service Providers. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety. Learn more about the Privacy Policy of our AI Service Providers in the “When and With Whom Do We Share Your Personal Information?” section.

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9. How Do We Handle Your Social Logins?

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

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10. Is Your Information Transferred Internationally?

Our servers are located in Australia. If you are accessing our Services from outside Australia, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see "When and With Whom Do We Share Your Personal Information?" above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law. This Privacy Policy shall apply even if we transfer Personal Information to countries outside your country.

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11. How Long Do We Keep Your Information?

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than twelve (12) months past the termination of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

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12. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Our website may contain links to other websites, including without limitation those websites of our affiliates. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the said websites. We are not responsible for the privacy practices, nor do we accept any liability about the content of such websites including those of our group companies that have their own privacy policies tailored for the business practices and sectors in which they operate.

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13. Testimonials & Public Forums

We post on our website customer testimonials/comments/reviews that may contain Personal Information. Prior to posting the testimonial, we obtain the customer’s consent to post their name along with their testimonial. If you want your testimonial removed, please contact us.

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Our website may offer publicly accessible blogs, community forums, or discussion board posts. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. You agree and acknowledge that the use of such information is not confidential, does not constitute Personal Information, and is not subject to protection under our Privacy Policy.

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14. What Are Your Privacy Rights?

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “How Can You Contact Us About This Notice?” below.

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We will consider and act upon any request in accordance with applicable data protection laws.

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If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

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If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

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14.1. Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “How Can You Contact Us About This Notice?” below or updating your preferences.

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However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

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14.2. Opting out of marketing and promotional communications

You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “How Can You Contact Us About This Notice?” below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

14.3. Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Log in to your account settings and update your user account.

• Contact us using the contact information provided.

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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 any investigations, enforce our legal terms and/or comply with applicable legal requirements.

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14.4. Cookies and similar technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. For further information, please see our Cookie Notice.

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If you have questions or comments about your privacy rights, you may email us at legal@gradewiseai.com.

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15. Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

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California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

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16. Do United States Residents Have Specific Privacy Rights?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

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16.1. Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

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​16.2. Sources of Personal Information

Learn more about the sources of personal information we collect in "What Information Do We Collect?"

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16.3. How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "Why Do We Process Your Information?"

We collect and share your personal information through: 

• Targeting cookies/Marketing cookies

• Social media cookies

 

16.4. Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "When and With Whom Do We Share Your Personal Information?".

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We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information. We do not make money by selling or monetizing your personal information or content.

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We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

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The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under " When and With Whom Do We Share Your Personal Information?"

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16.5. Your Rights 

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data

• Right to access your personal data

• Right to correct inaccuracies in your personal data

• Right to request the deletion of your personal data

• Right to obtain a copy of the personal data you previously shared with us

• Right to non-discrimination for exercising your rights

• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

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Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota’s privacy law)

• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law)

• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota’s and Oregon’s privacy law)

• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota’s privacy law)

• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)

• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

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16.6. How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at legal@gradewiseai.com, or by referring to the contact details at the bottom of this document.

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You can opt out from the selling of your personal information, targeted advertising, or profiling by disabling cookies. See our Cookie Policy for more information.

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We will honor your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser.

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Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

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16.7. Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

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16.8. Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at legal@gradewiseai.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

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16.9. California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “How Can You Contact Us About This Notice?”.

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17. Do Other Regions Have Specific Privacy Rights?

17.1. Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act).

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This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

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If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

• Offer you the products or services that you want

• Respond to or help with your requests

• Manage your account with us

• Confirm your identity and protect your account

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At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "How Can You Review, Update, Or Delete the Data We Collect from You?"

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If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner and a breach of New Zealand’s Privacy Principles to the Office of New Zealand Privacy Commissioner.

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17.2. Republic of South Africa

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section " How Can You Review, Update, Or Delete the Data We Collect from You?".

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If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:

• The Information Regulator (South Africa) HYPERLINK - https://inforegulator.org.za/

• General enquiries: enquiries@inforegulator.org.za

• Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za

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18. Do We Make Updates to This Notice?

We reserve the right to modify or replace these Privacy Policy at any time. We may revise this Policy to, for example, reflect changes to the law, new regulations, and changes to our products. If an update significantly negatively affects your use of our products or your legal rights as a user of our products, we’ll notify you before the update’s effective date by sending an email to the email address associated with your account or via an in-product notification. We will give you at least 30 days after that notice before the update takes effect. We may also update this Policy in ways that won’t significantly negatively affect your rights. For example, we may change the feature or product names or change the email address you can use to contact us. In those cases, we will post the change to our website. If you don’t agree to the updates we make, you must cancel your account before they become effective. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. By using or accessing the products after the updates come into effect, you agree to be bound by the revised terms.

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19. How Can You Review, Update, Or Delete the Data We Collect from You?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request via email to legal@gradewiseai.com including the following content:

• Make the subject of the email – “Data Subject Access Request”

• Your Name (First and Last)

• What email address do you use to access GradeWise?

• Who you are submitting this request as? (Either A. The person, or parent / guardian of the person whose details you have entered. Or B. An agent authorized by the consumer to make this request on their behalf.)

• Under the rights of which law are you making this request? (For example, GDPR, CCPA, CPA, CTDPA, UCPA, VCDPA, or other)

• Why are you submitting this request? (For example, Know what information is being collected from me, Have my information deleted, Access my personal information, Fix inaccurate information, Receive a copy of my personal information, Opt out of having my data shared for cross-context behavioral advertising, Limit the use and disclosure of my sensitive personal information, or other)

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By submitting a data subject access request via email, you confirm that:

• Under penalty of perjury, I declare all the above information to be true and accurate.

• I understand that the deletion or restriction of my personal data is irreversible and may result in the termination of services with GradeWise.

• I understand that I may be required to validate my request by email, and I may be contacted in order to complete the request.

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20. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at legal@gradewiseai.com.

By using the GradeWise service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy and any other agreements or policies referenced herein.