Privacy Policy

Last updated April 25, 2025

This Privacy Notice for The Grafter Ltd. ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:

• Visit our website at www.thegrafter.com, or any website of ours that links to this Privacy Notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@thegrafter.com.

Summary of Key Points

1. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you 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.

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
• Phone numbers
• Contact preferences

Sensitive Information. We do not process sensitive information.

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.

2. How Do We Process Your Information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law.

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

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• 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 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.

3. What Legal Bases Do We Rely On?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason to do so under applicable law.

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:

• Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations.
• 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.

4. When and With Whom Do We Share Your Information?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

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.

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

• Communication & Collaboration Tools
• Payment Processors
• Sales & Marketing Tools

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.

5. Do We Use Cookies and Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

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, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

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

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout.

6. Do We Offer AI-Based Products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

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.

Use of AI Technologies

We provide the AI Products through third-party service providers ('AI Service Providers'), including OpenAI. 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.

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process.

7. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

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.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational 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.

9. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services.

If you become aware of any data we may have collected from children under age 18, please contact us at hello@thegrafter.com.

10. What Are Your Privacy Rights?

In Short: In some regions, such as the EEA, UK, and Switzerland, you have rights that allow you greater access to and control over your personal information.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right:

• To request access and obtain a copy of your personal information
• To request rectification or erasure
• To restrict the processing of your personal information
• If applicable, to data portability
• Not to be subject to automated decision-making

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us.

Opting out of marketing communications: You can unsubscribe from our marketing and promotional communications at any time by replying 'STOP' or 'UNSUBSCRIBE' to the SMS messages that we send, or by contacting us.

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. For further information, please see our Cookie Notice.

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

11. Controls for Do-Not-Track Features

Most web browsers and some mobile operating systems 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 recognising and implementing DNT signals has been finalised. 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.

12. Do We Make Updates to This Notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

13. How Can You Contact Us?

If you have questions or comments about this notice, you may email us at hello@thegrafter.com or contact us by post at:

14. How Can You Review, Update, or Delete Your Data?

Based on the applicable laws of your country, you may 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.

To request to review, update, or delete your personal information, please contact us at hello@thegrafter.com.