This privacy policy (this "Privacy Policy") explains how personal information is collected, used, stored, and disclosed by Grain Technology, Inc. ("Grain," "we," "us," and "our"). This Privacy Policy applies to consumer users (individually referred to as "you") of our websites, applications, and other online services to which this Privacy Policy is posted (collectively, our "Services").This Privacy Policy is part of our Terms of Service and your Credit Agreement (collectively, "The Agreement"). By accessing or using our Services, you agree to this Privacy Policy the Agreements. The provisions contained in this Privacy Policy supersede all previous notices and statements regarding our privacy practices with respect to our Services. If you do not agree to every provision of this Privacy Policy and our Terms of Use, you may not access or use our Services.

Application of this Privacy Policy

This Privacy Policy applies to your use of our Services, regardless of means of access. You may access or use our Services through a desktop, laptop, mobile phone, tablet, or other consumer electronic device (each, a "Device").

Information We Collect

INFORMATION YOU PROVIDE US

In general, you can visit trygrain.com without telling us who you are or revealing any information about yourself. When you submit an inquiry via our Services or register for a Grain Account, we may collect personal information from you, which may include your name, email address, mobile phone number, banking information, and other information that identifies you (collectively, "Personal Information"). By providing your Personal Information to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy. Personal Information does not include Aggregated Data. Aggregated Data means any data related to use of our Services or any account information, from which all identifying information has been removed and aggregated with other use and account information so that your individual data or information cannot be reverse engineered to be associated with you without extraordinary effort. By providing your Personal Information to us, you expressly agree to our collection, use, storage, and disclosure of such information as described in this Privacy Policy.

We may also ask you to create login information for your Grain Account, such as a username and password. When you provide your mobile phone number, we may ask for your consent to receive text messages relating to our Services at that number. You may withdraw your consent by contacting us as indicated below or by replying with "STOP" to any text message we send you. Please note that if you withdraw your consent to receive text messages from us, you may not be able to use some of our Services. Your mobile carrier's standard text message and data charges may apply to text messages you receive from us, and you are responsible for any fees charged by your mobile carrier if we contact you.

From time to time, Grain may contact you via email for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from Grain or click on a link therein. If you would like to stop receiving marketing or promotional communications via email from Grain, you may opt out of such communications. Customers may unsubscribe from emails by "replying STOP" or "clicking on the UNSUBSCRIBE button.

If you would like to stop receiving marketing or promotional communications via email from Grain, you may opt out of such communications by Customers may unsubscribe from emails by "replying STOP" or "clicking on the UNSUBSCRIBE button.

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INFORMATION ABOUT YOUR TRANSACTIONS

We collect Personal Information about your transactions with us and others.

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INFORMATION FROM THIRD PARTIES

We also collect Personal Information about you from other companies. For instance, we may receive Personal Information about you from a consumer reporting agency.We use Plaid Technologies, Inc. (“Plaid”) to gather your data from financial institutions. By using our service, you grant us and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid Privacy Policy.

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INFORMATION AUTOMATICALLY COLLECTED

We (or our service providers acting on our behalf) may collect information about your use of our Services. This information may include Personal Information as well as statistical information that does not identify you ("Analytics"). Some Analytics may be correlated with Personal Information. When Analytics are, directly or indirectly, associated or combined with Personal Information, such Analytics will be considered Personal Information for purposes of this Privacy Policy.

Information that we automatically collect in connection with your access or use of our Services may include:

Device Information: We may collect Device-specific information (such as hardware model, operating system version, unique Device identifiers, and mobile network Information, including your mobile phone number). We may associate your Device identifiers or mobile phone number with your Grain account.

Log Information: We may record or log information from your Devices, their software, and your activity accessing or using our Services. This information may include:

• The Device's Internet Protocol ("IP") address
• Identification numbers associated with your Devices
• Device event information, such as crashes, system activity, and hardware settings
• Location preferencesDate and time stamps of transactions
• System configuration information
• Other interactions with our Services

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INFORMATION COLLECTED THROUGH COOKIES AND SIMILAR TECHNOLOGIES

We use cookies to personalize our Services for you and to collect aggregate information about usage of our Services. A cookie is a text file or other local storage identifier provided by your browser or associated applications. We use cookies for record-keeping purposes and to enhance the quality of your use of our Services. The cookies assign random, unique numbers to your Devices to enable our systems to recognize your Devices and to allow us to see how you use our Services. Additional general information about cookies and how they work is available at www.allaboutcookies.org.

The cookies we use in connection with our Services include:

Session cookies: Session cookies are temporary cookies that expire and are automatically erased whenever you close your browser window. We use session cookies to grant users access to content and to enable actions they must be logged into their Grain account to perform.

Persistent cookies: Persistent cookies usually have an expiration date in the distant future and remain in your browser until they expire or you manually delete them. We use persistent cookies to better understand usage patterns so we can improve our Services. For example, we may use a persistent cookie to associate you with your Grain account or to remember your choices for our Services.

Third-party cookies: We permit certain third parties to place cookies through our Services to provide us with better insights into the use of our Services and user demographics and to advertise our Services to you. These third parties may collect information about your online activities over time and across different websites when you access or use our Services. For example, we utilize Google Analytics to analyze usage patterns for our Services. Google Analytics generates a cookie to capture information about your use of our Services, which Google uses to compile reports on website activity for us and to provide other related services. Google may use a portion of your IP address to identify its cookie, but this will not be associated with any other data held by Google. We may also permit third-party service providers to place cookies for our Services, as indicated above, to perform analytic or marketing functions where you are notified of them and you have consented to the usage. We do not control the use of such third-party cookies or the resulting information, and we are not responsible for any actions or policies of such third parties.

By accessing or using our Services, you consent to the placement of cookies on your Devices as described in this Privacy Policy. If you prefer not to receive cookies through our Services, you may control how your browser responds to cookies by adjusting the privacy and security settings of your web browser. Unless you set your browser settings to refuse all cookies, our system may issue cookies when you access or use our Services. If you set your browser settings to refuse all cookies, the performance of certain features of our Services may be limited or not work at all.

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DO-NOT-TRACK SIGNALS

Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser.

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How We Use Information

We may use Analytics as described elsewhere in this Privacy Policy and for research and commercial purposes, such as to improve our Services.

We may use Personal Information for the purposes described elsewhere in this Privacy Policy and internally for our general commercial purposes, including, among other things, to offer our products and services and products and services of third parties that we think you might find of interest, but only Grain and our third-party service providers involved in distributing the offers or providing the products or services will have access to your Personal Information. Our third-party service providers will only be permitted to use Personal Information for that intended purpose.

We may use your email address to respond to your inquiries and to provide you information about our Services. You may elect not to receive promotional emails from us either by "unsubscribing" to an email you receive from us or by contacting us as indicated below. If you unsubscribe from receiving emails from us, we may still send you non-promotional emails, such as emails about your Grain account or our ongoing business relations, unless you withdraw your consent to receive electronic communications as provided in our Terms of Service.

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How We Share Information

We may share your Personal Information with unaffiliated third parties or third party service providers: (1) if you request or authorize it; (2) if the information is provided to help complete a transaction for you; (3) if the information is provided to: (a) comply with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas; (b) enforce our Terms of Service or other agreements; or (c) protect our rights, property, or safety or the rights, property, or safety of our users or others (e.g., to a consumer reporting agency for fraud protection, etc.); (4) if the disclosure is done as part of a purchase, transfer, or sale of services or assets (e.g., in the event that substantially all of our assets are acquired by another party, your Personal Information may be one of the transferred assets); (5) if the information is provided to our third-party service providers to perform functions on our behalf (e.g., analyzing data, providing marketing assistance, providing customer service, processing orders, etc.); (6) for our everyday business purposes; or (7) as permitted by applicable law or otherwise described in this Privacy Policy. When you are no longer our customer, we continue to share your information as described in this Privacy Policy.

We may disclose Analytics with third parties as described elsewhere in this Privacy Policy and for our commercial purposes.

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Definitions:

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Opt-Out Rights

If you do not wish to receive offers or other notices from us in the future, you can "opt out" by contacting us as indicated at the end of this Privacy Policy or by following the "unsubscribe" instructions in any communication you receive from us. Please be aware that you are not able to opt out of receiving communications about your Grain account or related transactions with us.

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Accessing Your Information

You must notify us of any change in your Personal Information by updating your Grain Account profile through our Services. Any changes will affect only future uses of your Personal Information.

Subject to applicable law, which might, from time to time, oblige us to store your Personal Information for a certain period of time, we will respect your wishes to correct inaccurate information. Otherwise, we will hold your Personal Information for as long as we believe it will help us achieve our objectives as detailed in this Privacy Policy.

You can ask us whether we are storing your Personal Information and you can ask to receive a copy of that Personal Information. Before sending you any Personal Information, we will ask you to provide proof of your identity. If you are not able to provide proof of your identity, we reserve the right to refuse to send you any Personal Information. We will respond as quickly as we can to your requests for details of Personal Information we hold about you.

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Information You Share Socially

Our Services may allow you to connect and share your actions, comments, content, and information publicly or with friends. We are not responsible for maintaining the confidentiality of any information you share publicly or with friends.

Our Services may also allow you to connect with us on, share on, and use third-party websites, applications, and services. Please be mindful of your personal privacy needs and the privacy needs of others, as you choose whom to connect with and what to share and make public. We cannot control the privacy or security of information you choose to make public or share with others. We also do not control the privacy practices of third parties. Please contact those sites and services directly if you want to learn about their privacy practices.

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Security

We have, and require our third-party service providers that receive Personal Information from us to have, a comprehensive written information security program that contains administrative, technical, and physical safeguards for our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect information contained within such systems from loss, misuse, or alteration. When your bank account information is transmitted via our Services, it will be protected by encryption technology, such as Secure Sockets Layer (SSL) or Transport Layer Security (TLS).

No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Grain account and do not share them with others. If we receive instructions using your Grain account login information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Grain account or any other breach of security. We reserve the right, in our sole discretion, to refuse to provide our Services, terminate Grain accounts, and to remove or edit content.

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External Data Storage Sites

We may store your data on servers provided by third party hosting vendors with whom we have contracted. These data centers are compliant with the following industry standards:

ISO 27001

SOC 1 and SOC 2/SSAE 16/ISAE 3402 (Previously SAS 70 Type II)

PCI Level 1

FISMA Moderate

Sarbanes-Oxley (SOX)

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Protecting Children's Privacy

Our Services are not directed or intended to be attractive to children under the age of 18. We do not knowingly collect Personal Information from children under the age of 18. If you are under the age of 18, do not use our Services or submit any information to us.

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Links to Third-Party Websites

When you use our Services, you may be directed to other websites that are beyond our control. We may also allow third-party websites or applications to link to our Services. We are not responsible for the privacy practices of any third parties or the content of linked websites, but we do encourage you to read the applicable privacy policies and terms and conditions of such parties and websites. This Privacy Policy only applies to our Services.

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Changes to our Privacy Policy

Subject to applicable law, we may revise this Privacy Policy at any time and in our sole discretion. When we revise this Privacy Policy, we will post the revised version via our Services and will update the date at the top of this Privacy Policy. The revised Privacy Policy will be effective upon posting via our Services, unless otherwise set forth therein or as otherwise required by applicable law. You are free to decide whether or not to accept a revised version of this Privacy Policy, but accepting this Privacy Policy, as revised, is required for you to continue accessing or using our Services. If you do not agree to the terms of this Privacy Policy or any revised version of this Privacy Policy, your sole recourse is to terminate your access and use of our Services. Except as otherwise expressly stated by us, your access and use of our Services is subject to the version of this Privacy Policy in effect at the time of access or use.

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Contacting Us

If you have any questions regarding this Privacy Policy, or if you wish to ask us to delete, correct, or show you your Personal Information as provided above, please contact us at help@trygrain.com, with the subject line "Privacy Policy" or Grain Technology, Inc., 505 14th Street Suite 900, Oakland, California 94612.