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Grafiti Privacy Policy

Welcome to Grafiti! Pundit, Inc. (“grafiti”, “we”, “us”, or “our”) has prepared this Privacy Policy to describe to you our practices regarding the Personal Information (as defined below) we collect from users of our website, located at https://grafiti.code (the “Website”) and online services (“Services”), including our mobile application (“App”). We respect your privacy, value your relationship, and want you to have fun using our website, mobile application and services.

1. Introduction.

1.1 Privacy Policy. We are committed to safeguarding the privacy of our website visitors and respecting their right to data privacy. As such, this Privacy Policy (“Privacy Policy”) applies to information we collect or use on websites, including www.grafiti.co (the “Website”), the Grafiti mobile application (the “Grafiti App”), products, features, services, or any portion thereof (collectively, the “Service”), owned or controlled by Pundit, Inc., or its affiliated companies, which are entities that control, are controlled by or are under common control with us (“Affiliates”) (collectively, the “Company” or “we” or “our” or “us”).

1.2 Changes to Privacy Policy. Although most changes are likely to be minor, we may change our Privacy Policy from time to time, and in our sole discretion. We encourage visitors to frequently check this page for any changes to the Privacy Policy. Your continued use of the Service after any change in this Privacy Policy will constitute your acceptance the changes. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you and for periodically visiting this privacy policy to check for any changes.

1.3 Terms of Service. This Privacy Policy and our Terms of Service (the “Terms of Service”), which is incorporated herein by reference, are an agreement (collectively, this “Agreement”) between you (“You” or “your” or “you”), a user of the Service, and us. By using our website, you acknowledge and agree to this policy, and consent to our use of cookies in accordance with the terms of this Agreement.

1.4 Third-Party Links. The Service contains third party links to other websites or services. Please be aware that we are not responsible for the content or privacy practices of such other third- party websites or services. We encourage our users to be aware when they leave the Service and to read the privacy statements of any other site that collects personal information. When you use the Service or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

These third parties may use tracking technologies to collect information about you when you use the Service. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

2. Information We collect.

We may collect, store and use the following kinds of personal information:

2.2 We may collect, store and use information obtained by automated means through the Service such as, cookies, web beacons, web server logs, JavaScript and similar technologies, including technologies designed to obtain information regarding your use of the Service:

(a) “Cookies” are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages in the Service are visited and by how many people. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website The “Help” portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. We recommend that you leave the cookies activated because cookies allow you to use many features of the Service. For more information please refer to Section 5.2 of the Privacy Policy.

(b) "Web Beacons" ,” also known as Internet tags, pixel tags, single-pixel GIFS or clear GIFs, link web pages to web servers and their cookies. Web Beacons can be embedded in web pages, videos, or emails, to collect certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the content, the IP address of your computer, and the Uniform Resource Locator (URL ) of the web page from which the content was viewed. We may use this information to reduce or eliminate messages sent to a user.

(c) "Web Server Logs" including browser types, Internet service providers (ISPs), referring/exit pages, platform types, date/time stamps, number of clicks, and IP addresses. An IP address is a number that is automatically assigned to your computer whenever you access the Internet, which web servers use to identify where to send the information your computer requests. We may use IP addresses for a number of purposes, such as system administration, to report aggregate information to our business partners, or to audit the use of our Services.

(d) "Local Shared Objects" sometimes known as Flash cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalize your visit.

(e) "Ad IDs" and Other In-App Tracking Methods. There are a variety of tracking technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” to associate app user activity to a particular app.

(f) Google Analytics and DoubleClick We use Google Analytics (“Google Analytics”), a web analytics service provided by Google Inc. (“Google”). Google Analytics uses “cookies.” The information generated by the cookies about your use of the Service (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Service, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this, you may not be able to use the full functionality of the Service. More information about how you can opt-out is in Section 5 (Your Rights) below. By using the Service, you consent to the processing of data about you by Google in the manner and for the purposes set out above. We also use the services like Google DoubleClick in conjunction with Google AdSense on our service. To disable this cookie, visit Google’s webpage on the subject for further instructions: http://www.google.com/policies/privacy/ads/.

2.3 In using some features of the Service, you may also be able to submit information about other people. Before you disclose to us the personal information of another person, you must obtain that person’s consent, and you hereby represent that you have obtained such consent from such person, to both the disclosure and the processing of that personal information in accordance with this Privacy Policy.

3. How We Use Your Information.

3.1 Personal information submitted to us through our website will be used for the purposes specified in this Privacy Policy or on the relevant pages of the Service.

3.2 We may use your personal information to:

(a) To provide, operate, maintain, improve, and promote the Service, and any other information, products or services that you request from us;

(b) To enable you to access and use the Service, including uploading, downloading, collaborating and sharing content, photos, images, videos and information, with other users or third parties;

(c) To process, verify, and complete transactions, and send you related information, including purchase confirmations and invoices, to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, collection and enforcement, and to build a user database;

(d) To send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; sending you technical notices, updates, security alerts, and support and administrative messages sending statements, invoices and payment reminders to you, and collecting payments from you; and, when we have location information, we use it to tailor our Service for you and others.

(e) To send promotional communications, such as providing you with information about services, features, newsletters, offers, promotions, contests, events and sending updates;

(f) To monitor and analyze trends, usage, and activities in connection with the Service and for marketing, advertising, administrative, analytical, research, optimization, and other purposes. For example, we may use statistical analyses of usage data in order to measure interest in the various areas of the Service, for development purposes and to inform advertisers and partners in aggregate and anonymous terms about consumers who click on their advertising or other messages. IP addresses are also used for systems administration and troubleshooting purposes.

(g) To investigate and prevent fraudulent transactions, unauthorized access to the Service, and other illegal activities;

(h) To personalize the Service’s content, features or advertisements;

(i) To deal with inquires and complaints made by or about you relating to the Service;

(j) To verify compliance with the terms and conditions governing the use of the Service; and

(k) To comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies.

3.3 If you submit personal information, including User Content, for publication on the Service, we will publish and otherwise use that information in accordance with the license you grant to us, and by submitting such information to us, you hereby grant us a worldwide, revocable, sublicensable and royalty-free license to use such personal information for our business purposes. You shall be solely responsible for your own User Content and the consequences of submitting and publishing your User Content on the Service. You further agree that you will not submit to the Service any User Content or other material that is contrary to this Privacy Policty or contrary to applicable local, national, and international laws and regulations.

4. Disclosing Personal Information.

4.1 Service Providers. We engage service providers to perform functions and provide services to us. We may share your private personal information with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions.

4.2 Authorized Personnel Our employees, agents, consultants, contractors, or other authorized personnel, including those of our contractors, service providers, subsidiaries and affiliates, may have access to user information as necessary in the normal course of our business.

4.3 Business Transfers. In some cases, we may choose to buy or sell assets, or have engaged in discussions with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about our Service users is among the assets transferred. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if the Service, the Company, or substantially all of its assets, were acquired, liquidated, or dissolved, personal information would be one of the assets that is transferred.

4.4 Government, Law Enforcement or Third Parties. We may disclose any information, including, without limitation, Personal Information that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We also may exchange information, including, without limitation, Personal Information, with other companies and organizations to protect the rights, property, or safety of the Company and its affiliates, personnel, users, third parties, or others. We reserve the right to disclose a user’s Personal Information if we believe, in good faith, that the user is in violation of the Terms of Service, even without a subpoena, warrant or other court order.

4.5 Social Media Networks. We may include applications or widgets from social media networks that allow interaction or content sharing by their users. These widgets, such as a Facebook “Share” or “Like” button, are visible to you on the web page you visit. Integration between the Service and social media networks such as Facebook, Twitter and others may allow social media networks in which you participate to collect information about you, even when you do not explicitly activate the network’s application or widget. Please visit the applicable social media network’s privacy policy to better understand their data collection practices and choices they make available to you. The privacy policy of the social media network controls the collection, use and disclosure of all personal information transmitted to that network.

Your Rights.

5.1 We will provide you with an opportunity to exercise certain controls and choices regarding our collection, use and sharing of your information through Opt-out options.

5.2 In accordance with local law, your controls and choices may include:

5.3 Opt Out We have created the following mechanisms to provide you with control over certain uses and disclosures of your information:

5.4 Accessing and Correcting Your Information.

If you have an account, you can help ensure that your contact information and preferences are accurate, complete, and up to date by logging into your account or by emailing us at privacy@grafiti.co. For other personal information we hold, we will provide you with access for any purpose including requesting that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to his/her personal information records. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

If you delete your User Content from the Service, copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other Service users. Proper access and use of information provided on the Service, including User Content, is governed by our terms of use www.grafiti.co/terms

6. Notice to California Residents.

6.1 California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content. To make any such requests, please email us at privacy@grafiti.co or contact us at the address below.

6.2 California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. We do not currently take action to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

7. Children Under Age of 13.

The Service is not intended for children or directed at any individual under 13 years of Age. We do not knowingly collect or knowingly solicit any information from anyone under the age of 13 or knowingly allow people under the age of 13 to register for the Service. In the event that we learn that we have collected personal information, as defined by the Children’s Online Privacy Protection Act ("COPPA"), of a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at privacy@grafiti.co.

8. Retaining Personal Information

8.1 This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.

8.2 Personal information that we process for any purpose or purposes may be maintained.

8.3 Notwithstanding the other provisions of this Section, we will retain documents (including electronic documents) containing personal data:

9. Security of Personal Information.

9.1 We will take reasonable administrative, technical, organizational and physical precautions to safeguard against the loss, misuse or alteration of your personal information. These safeguards vary based on the sensitivity of the information that we collect and store. For example, when processing sensitive personal data (such as data about ethnic or racial origin, political opinions/union membership, data concerning health, sex life or sexual orientation, genetic data, or biometric data) or data that reveals sensitive personal data, especially when using data profiling extra safeguards will be added.

9.2 We will store all the personal information you provide on our secure password- and firewall-protected servers.

9.3 We will notify consumers and regulatory authorities in case of breach without undue delay.

You acknowledge that the transmission of information over the internet is inherently insecure, and any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that information will never be disclosed, altered or destroyed in a manner that is inconsistent with this Privacy Policy.

9.5 You acknowledge that the safety and security of your information also depends on you. You are responsible for keeping the password you use for accessing the Service confidential; we will not ask you for your password (except when you log in to our Service).

10. Users from Other Jurisdictions

10.1 The Service is controlled and operated by us from the United States. If you are not a resident of the United States or you are located outside the United States and choose to use the Service or provide information to us, please note that we will transfer the information, including personal information, to the United States and process it there.

10.2 We do not represent or warrant that the Service, or any portion thereof, are appropriate or available for use in any particular jurisdiction. Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America.

10.3 Those who choose to access the Service do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations, and are subject to United States export controls in connection with your use of the Service and are responsible for any violations of such controls, including, without limitation, any United States embargoes or other federal rules and regulations restricting exports.

10.4 We may limit the availability of the Service, in whole or in part, to any person, geographic area or jurisdiction that we choose, at any time and in our sole discretion.

10.5 Personal information that you publish on the Service or submit for publication on our Website or Grafiti App may be available, via the Internet, around the world. We cannot prevent the use or misuse of such information by others.

10.6 You expressly agree to the transfers of personal information described in this Section.

11. Notice to Users in The European Union.

If you are a user in the European Union, you should know that we are the controller of your personal information. Here is some additional information we would like to bring to your attention:

11.1 Bases for using your information: Your country only allows us to use your personal information when certain conditions apply. These conditions are called “legal bases” and we typically rely on one of four:

11.2 Your rights in regards to your personal information.

11.3 We may collect your personal information from, transfer it to, and store and process it in the United States and other countries outside of where you live. Whenever we share information of EU users outside the EU we make sure an adequate transfer mechanism is in place, including data processing agreements based on the EU/EEA Standard Contractual Clauses.

11.4 When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

11.5 By using our Services, you consent to us transferring information about you to these countries.

12. Our Contact Information.

12.1 If you have any questions, feedback or to report a violation regarding the Privacy Policy, you may email us at privacy@grafiti.co or you may send a letter to:

12575 Beatrice St., Ofc. Q
Los Angeles, CA 90066