Privacy Policies

PRIVACY POLICY

Last updated: January 20, 2022


This Privacy Policy sets forth how Personal information is used which we collect through our website located at www.grifin.com (the “Site”) and our mobile application (collectively, “Grifin Platform”). Unless otherwise indicated, this Privacy Policy only applies to personal information collected through the Grifin Platform by Interest Investments Inc., Grifin LLC, or any of their respective affiliates, including, without limit, Interest Investments, Inc., Interest Financial, LLC, and Bark Media, LLC (together, for purposes hereof, “Grifin”). By using the Grifin Platform, you agree to be bound by this Privacy Policy and our other privacy policies (collectively referred to as “Privacy Policies”) and our Terms of Use, as they may be amended from time to time in the future (see “Change to this Privacy Policy” below).


Please read this Privacy Policy carefully. Grifin is committed to maintaining the confidentiality, integrity and security of any personal information about our users. This Privacy Policy explains how we protect personal information provided through the Grifin Platform and how we use that information in connection with our service offered through the Grifin Platform (the “Service”). “Personal information” for purposes of this Privacy Policy means information that identifies you, such as your name, address, phone number, or email address.


Grifin stresses its privacy and security standards to guard against identity theft and provide security for your personal information. We regularly re-evaluate our privacy and security policies and adapt them as necessary to deal with new challenges.


Children under the Age of 13

 

The Grifin Platform does not knowingly collect or receive Personal Information from children under the age of 13 through the Platform and/or the Services. If you are under the age of 13, please do not provide any Personal Information through the Platform and/or the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Privacy Policy by instructing their children to never provide any Personal Information on the Platform, the Services, or any other website without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to the Grifin Platform through the Grifin Platform and/or the Services, please contact us at hello@grifin.com and we will endeavor to delete that information from our databases. 


If you establish an account with us that is governed by the Uniform Gifts to Minors Act or the Uniform Transfers to Minors Act that is for the benefit of a child under the age of 13, only the individual establishing the account provides Personal Information to us necessary to establish an account for the child under the age of 13. Subsequent to the creation of the account, we will only collect and use Personal Information related to the child for the limited purpose of providing the Services, and except as set forth in the Privacy Policies, such information will not be shared with third parties for any purpose not required or permitted by law, including marketing. 


 

Children over the Age of 13 and under the Age of 18

 

If you are 13 or older but under the age of 18, you should review the Privacy Policies with your parent or guardian to make sure that you and your parent or guardian understand it.

 


Collection and Use of Personal Information


We collect the following personal information from you:


  • contact information such as name, email address, mailing address, phone number;
  • financial information such as bank or brokerage account numbers, types of investments, investment experience, income, net worth;
  • Social Security number;
  • unique identifiers such as user name, account number, password;
  • preferences information such as product wish lists, order history, and marketing preferences; and
  • demographic information such as age, employment status, gender, interests, and zip code.


Your Social Security number or other Taxpayer Identification number is collected during the onboarding process by our Broker.  We do not maintain that number on our servers.


During the onboarding process, your bank account and credit card/debit card information may be accessed by one or more third party providers so that the Grifin Platform may work but we do not maintain that information on our servers. Each of such providers have their own Privacy Policies which may be accessed at the following links:


https://plaid.com/legal/

https://alpaca.markets/disclosures


When you download and use our Services, we automatically collect information on the type of device you use, operating system version, and the device identifier (or “UDID”). We also collect information on the city, state, and country where you are located; however, we do not collect your specific location-based information.


How we use your personal information


Grifin uses and discloses your personal information only as follows:


  • to analyze site usage and improve the Service;
  • to process your transactions, maintain your account(s), or respond to court orders and legal investigations;
  • to deliver to you any administrative notices, money alerts, and communications relevant to your use of the Service;
  • to fulfill your requests for certain products and services;
  • for market research, project planning, troubleshooting problems, and detecting and protecting against error, fraud, or other criminal activity;
  • to third-party contractors that provide services to Grifin and are bound by these same privacy restrictions;
  • to enforce Grifin’s Terms of Use; and as otherwise set forth in our Privacy Policies.


In the event that you access the Service as brought to you by one of our co-brand partners, through a co-branded URL, your email address used for registration on the Service may be provided to that co-brand partner.


In addition, we may, from time to time, offer promotions with various businesses, websites, mobile applications or third parties, which may include opportunities for you to earn rewards or deposits within your Grifin account. Each such promotion will be subject to and governed by our Terms of Use, our Privacy Policies, and any applicable rules or terms and conditions we may post online, post in our mobile application, include within email or other communications, or otherwise make available to you. To the extent you elect to participate in any such promotion or otherwise make any purchase subject to a promotion, we may share personal information such as name, email address, purchase dates, and other related information with the applicable third party for the limited purpose of allowing the parties to make the promotion available and track participation within such promotion.


We may use information you provide to connect you with people you may already know. For example, through our mobile application we may identify contacts within your address book as potential new users of Grifin. We may match the contact information you provide to the information provided by other users to improve the Service, including making it easier to find contacts you may refer to Grifin that are not already customers.


We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.


If Grifin is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.


User Access and Choice


If the personal information on file for you changes you may correct or update it by making the change on your profile page in the Grifin App.


We will retain and use your information as necessary to comply with our legal and/or regulatory obligations, resolve disputes, and enforce our agreements. Please note that Interest Financial, LLC, as the registered investment adviser for the Grifin Platform, is  subject to the rules and regulations of the Investment Advisers Act of 1940, as amended. As such, we are required to retain certain information about you and your account while you are using our advisory services and for a period of time after you terminate our services. Therefore this required information cannot be deleted.


If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails.


Cookies / Tracking Technologies


A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on the Site. We do not link the information we store in cookies to any personally identifiable information you submit while on the Site.


We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory.


If you reject cookies, you may still use the Site, but your ability to use some areas of the Site, such as contests or surveys, may be limited.


The use of cookies by our partners, affiliates, tracking utility companies, and/or service providers are not covered by our Privacy Policies. We do not have access or control over these cookies. Our partners, affiliates, tracking utility companies, and/or service providers use session ID cookies to make it easier for you to navigate the Site.


We employ (and/or our third-party advertising partner employs) a software technology called clear gifs (sometimes known as web beacons or web bugs), that help us better manage content on the Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.


Third Party Sites and Services


The Grifin Platform, including websites, products, applications, and services may contain links to third-party websites, products, and services. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.


Security


The security of your personal information is important to us. When you enter sensitive information, such as financial information, on our forms, we encrypt the transmission of that information using secure socket layer technology (SSL).


We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on the Site, please contact us.

GRIFIN MAKES NO REPRESENTATIONS OR WARRANTIES WITH REGARD TO THE SUFFICIENCY OF THESE SECURITY MEASURES. GRIFIN SHALL NOT BE RESPONSIBLE FOR ANY ACTUAL OR CONSEQUENTIAL DAMAGES (OR ANY OTHER DAMAGES OR LIABILITY OF ANY KIND WHATSOEVER, WHETHER AS A RESULT OF NEGLIGENCE OR OTHERWISE) THAT RESULT FROM A LAPSE IN COMPLIANCE WITH THIS PRIVACY POLICY BECAUSE OF A SECURITY BREACH OR TECHNICAL MALFUNCTION.



Photos, Videos, Audios, Comments and Reviews


            You hereby grant permission to use photographs, videos and/or audios of yourself taken, comments or reviews which you have posted, all of which may be used in publications, news releases, online, and in other communications related to the Grifin Platform.



Changes to this Privacy Policy


We may update our Privacy Policies to reflect changes to our information practices. If we make any material changes we will notify you by email or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.


Contact Us


If you have any questions about our Privacy Policy, for purposes of the Grifin Platform, please contact Grifin Customer Service at: hello@grifin.com.  If you have any questions regarding the requirement to maintain certain information  as required by law  please contact us at hello@interestfinancial.com