Grass Foundation™ (“Grass Foundation”, “we”, “us”, or “our”) operates the website www.grassfoundation.io (the “Website”) and provides the communications and services available through Website (the “Services”).

The purpose of this Privacy Policy is to help you understand what types of personal information we collect, use, and disclose in connection with your access to and use of the Services.

This Privacy Policy covers the following topics, which you can access by clicking the links below:

• What is personal information?
• Personal information that we collect
• Use of your personal Information
• Promotional and transactional messages
• Disclosure of personal information
• Aggregated data
• Retention of personal information
• Security & protection of personal information
• Access to personal information;
• Consent; withdrawal of consent
• Links to third party resources
• Changes to this Privacy Policy
• Contact information

Unless you are based in the European Economic Area (EEA) or the United Kingdom (UK), by accessing or using the Website or Services, you agree to accept this Privacy Policy, including the terms and conditions of this Privacy Policy that relate to the ways that we collect, use, and disclose your personal information. If you are based in the EEA or the UK, please see below for our policies and procedures regarding how we process your personal data here.

You can withdraw your consent to our collection, use, or disclosure of your personal information by contacting our Privacy Officer using the contact information that is included in this Privacy Policy (see below). Please note that if you choose to withdraw your consent, we may not be able to provide you with certain services, products, communications, and opportunities, including access to and use of the Website and Services.

Personal information is any information about, relating to, or that identifies a specific individual. Under certain laws that may apply to you, personal information may also include information that identifies a specific household or device.

We may collect personal information from you based on the Services that you elect to access and use. The personal information that we collect from you in connection with your use of the Website and Services includes your digital wallet address, email address, and any other personal information that you choose to provide to us when you contact us for support, provide us with feedback, or otherwise communicate with us.

The types of personal information that we collect will depend on what personal information you choose to provide to us based on your interactions with us and the Website and Services.

We use the personal information that we collect to provide you with the functionality, features, and communications that are available on and through the Website or Services and to enable us to manage, maintain, and develop our operations. For example, we may use your personal information for the following purposes:

• establish, maintain, and manage our relationship with you;
• allow you to participate in, subscribe to, and receive information, news, updates, and promotional materials from us and third parties;
• comply with your requests and preferences regarding your use of the Services and the manner in which we communicate with you;
• understand your preferences and values so that we can tailor the Services and communications to you;
• protect us against error, fraud, theft, and damage to our Services, business, and property;
• conduct research, analysis, evaluation, and development activities to understand the way the Services are used and to improve the Services, and our general operations, including with respect to the development of new products, services, and opportunities;
• enable us to comply with applicable laws and regulatory purposes; and
• any other reasonable purpose to which we may notify you of, or to which you consent.

Unless you are based in the EEA or UK, by consenting to our collection, use, and disclosure of your personal information on and through the Website or Services you allow us to fulfill the purposes for which we collect and use your personal information as described above.

For more information about how we use your personal information if you are based in the EEA or UK, including the legal bases we may rely on to process your personal information as an alternative to obtaining your consent, please see the EEA and UK section of this Privacy Policy.

We will collect your consent prior to sending you promotional emails and other electronic messages (e.g., texts, direct messages), unless an exception to obtaining your consent applies under applicable laws. You will have an opportunity to opt-out or unsubscribe from receiving promotional messages from us at any time. Promotional messages may include, but are not limited to, our newsletter and updates about our and our partners businesses, products, and services.

By using the Services, you agree to receive transactional communications about your account and activities. You may not opt-out of receiving these transactional communications.

We may disclose your personal information and other information in the manner and for the purposes that are described in the sections below.

• Working with third parties.We may work with third parties that provide services to us that help us facilitate one or more aspects of the products, services, communications, or features that we offer to you on and through our website and Services. We may provide these third parties with your personal information directly or they may collect your personal information from you on our behalf.
• Opportunity to receive rewards. We may disclose your personal information to third parties in connection with your opportunity to receive rewards.
• Business transactions.Your personal information may also be disclosed to a third party in connection with a business transaction, including a change of ownership of Grass Foundation or its affiliates, the sale of all or certain of our assets, or the grant of a security interest. We will take reasonable steps to ensure that the third party that receives your personal information is bound by appropriate agreements that require that your personal information is handled in a manner that is consistent with this Privacy Policy (or, if you are based in the EEA/UK, where we may notify you otherwise).
• Legal requirements. Your personal information may also be disclosed:
  • as permitted or required by applicable law or regulatory requirements;
  • to comply with valid legal processes such as a search warrant, subpoena, or court order; and
  • during emergency situations or where necessary to protect the safety of a person or a group of persons; and
  • for additional purposes for which we have obtained your consent to disclose your personal information (or, if you are based in EEA/UK, where we may notify you otherwise).

Since we may disclose your personal information to third parties (including our service providers) as described in this Privacy Policy, your personal information may be collected, used, disclosed, and otherwise processed outside of your jurisdiction of residence. As such, your personal information may potentially be accessible to law enforcement and national security authorities of another jurisdiction where local laws provide for a different level of protection for personal information. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security agencies in those other countries may be entitled to access your personal information.

If you would like further information about our policies and practices regarding the transfer and storage of your personal information, including disclosures to third parties such as our service providers, please contact our Privacy Officer using the contact details below.

Unless you are based in the EEA or UK, by providing your personal information to us, you consent to our disclosure of this information to our service providers (and other third parties) as described in this Privacy Policy, including those that may be located outside of your jurisdiction of residence.

We may disclose aggregated non-personal information and related usage information, which does not contain personal information that can identify you, with third parties, including our customers, clients, partners, advertisers, service providers, vendors, suppliers, and content providers.

We do not keep your personal information forever. We will retain your personal information for as long as is reasonably necessary for us to complete our dealings with you, or as may be required by law, whichever is longer.

We endeavour to maintain commercially reasonable physical, technological, and procedural safeguards that are appropriate based on the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction.

Please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of your personal information that is relevant to your use of the Website or the Services.

You can ask to access the personal information that we have about you. If you want to review, verify, delete or correct your personal information, please contact our Privacy Officer. We may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. If you require assistance in preparing your request, please contact our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are situations where applicable law allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, your personal information may have been destroyed, erased or made anonymous in accordance with our record retention practices. In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.

If you are based in the EEA or the UK, you have other rights with respect to your access to and correction of the personal information we hold about you. Please see below for our policy on how we process your personal data.

Unless you are based in the EEA or UK or you advise us otherwise, through the access and use of our Website and Services, you have consented to the collection, use and disclosure of your personal information as explained in this Privacy Policy. For further information about how we process your personal information if you are based in the EEA or UK, including the legal bases we may rely on to process your personal information as an alternative to obtaining your consent, please see the EEA and UK section of this Privacy Policy.

The Website and Services may contain links to other websites that may be subject to less stringent privacy standards. These links are provided for your convenience only and you assume all risk for clicking these links to other websites. We cannot assume any responsibility for the privacy practices, policies or actions of the third parties that operate these websites. We are not responsible for how such third parties collect, use or disclose your personal information. You should review the privacy policies of these websites before providing them with personal information.

We may make changes to this Privacy Policy from time to time. These changes may be made as a result of changes to our legal obligations or the ways in which we collect, use, disclose, or otherwise process your personal information.

We will post an updated version of our Privacy Policy on our website when we make changes and may also notify you of the changes we have made if we are required to do so by applicable law. We encourage you to check this Privacy Policy for updates on a regular basis.

You agree that by continuing to use the Website or Services after an update to our Privacy Policy, you agree to accept and consent to the collection, use, and disclosure of your personal information as described in the updated version of the Privacy Policy.

If you have any questions or concerns regarding this Privacy Policy, you should contact our Privacy Officer at privacy@grassfoundation.io.

**If you choose to communicate with us via email, please be aware that email is not a 100% secure medium for sending any personal or confidential information to us. **