PRIVACY POLICY

Privacy Notice:

GrayHair Software, LLC (“GrayHair”) operates grayhairsoftware.com and may operate other websites. It is GrayHair’s policy to respect your privacy regarding any information we may collect. GrayHair may change this policy from time to time by updating this page. This policy is effective as of 02/24/2023.

Our Contact Information:

If you have any concerns or questions about anything in this Privacy Notice, please get in touch with us.

Physical address and principal place of business:

Grayhair Privacy Officer, 1 SE Ocean Blvd, Stuart, FL 34994-2214

You can contact us:

● By mail at the address above.

● By using our website contact form (www.grayhairsoftware.com)

● By telephone, at 856-727-9372

● By email, at privacy@grayhairsoftware.com

Types of Information We Collect:

GrayHair collects the below categories and specific pieces of personal information. GrayHair has collected the following categories and types of personal information about consumers within the last twelve (12) months:

Category and the Information We Collect

Identifiers – A real name, alias, postal address, email address, IP address.

Personal information categories listed in the California Customer Records statute – A name, address.

Internet or other similar network activity – Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Sources of Information

GrayHair collects only as much information as is necessary or appropriate to fulfill the purpose of the interaction with GrayHair.

GrayHair collects this information from the following sources:

Website Visitors

  • GrayHair collects information that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request.
  • GrayHair collects website information to better understand how GrayHair’s visitors use its website. From time to time, GrayHair may release website information in the aggregate, e.g., by publishing a report on trends in the usage of its website.
  • GrayHair also collects potentially personally identifying information like Internet Protocol (IP) addresses for logged in users and for users leaving comments on grayhairsoftware.com blogs/sites.
  • GrayHair will ask visitors who sign up at grayhairsoftware.com to provide a username and email address. Visitors can always refuse to supply personally identifying information, with the caveat that it may prevent them from engaging in certain website-related activities.

From Data Subjects

  • GrayHair collects data directly from data subjects who are utilizing GrayHair’s services.
  • GrayHair obtains the necessary personal and financial information required to process those transactions.
  • GrayHair collects data from applicants and employees to manage the employer-employee relationship.

Third Parties

  • GrayHair obtains information from third parties. Our third parties include our clients in the course of providing services to them. GrayHair also purchases information from third parties who are not our clients.
  • GrayHair obtains name and address information from public sources. This data is used to provide services to our clients.

Uses of Information

GrayHair uses this information in order to fulfill business activities, including to:

  • Improve the functionality, security, and usability of the website.
  • Conduct marketing and promotional activities.
  • Occasionally send registered users of a GrayHair website an email to describe new features, to solicit feedback or updates on what’s going on with GrayHair and our products.
  • Fulfill a contract with our clients or other third parties.
  • Provide mail tracking and address quality services to our clients.
  • Manage employee relationships including payroll, taxes, and benefits administration.
  • GrayHair only discloses logged in user and commenter IP addresses under the same circumstances that it uses and discloses personally identifying information as described below, except that commenter IP addresses and email addresses are visible and disclosed to the administrators of the blog/site where the comment was left.
  • Comply with applicable laws or regulations.

GrayHair will not use the personal information it collects for purposes other than those described above without providing you with notice first.

Information Disclosure

Sale of Information

  • GrayHair sells name and address data it obtains from public sources as part of its business services.

    GrayHair does not rent or sell potentially personally identifying information to anyone collected during the GrayHair Software login processes, applicant, or employee data.

Sharing of Information

GrayHair shares potentially personally-identifying and personally-identifying information only with those of its employees, contractors, and affiliated organizations that (i) need to know that information in order to process it on GrayHair’s behalf or to provide services available at GrayHair’s websites, and (ii) that have agreed not to disclose it to others.

GrayHair shares information for the following business purposes:

  • Auditing relating to a current interaction
  • Detecting security incidents
  • Debugging to identify and repair errors
  • Short-term, transient use, provided that personal information is not disclosed to another party andnot used to build a profile
  • Performing services on behalf of GrayHair or service provider (maintaining or servicing accounts, providing customer service, processing or fulfilling orders, processing payments, providing analytics, providing ads or marketing services)
  • Undertaking internal research

GrayHair may publish any request or question you send to us about our services or software (for example via email or via one of our feedback mechanisms) to help us clarify or respond to your request or to help us support other users.

GrayHair discloses personally-identifying information in response to a subpoena, court order or other governmental requests, or when GrayHair believes in good faith that disclosure is reasonably necessary to protect the property or rights of GrayHair, third parties, or the public at large. GrayHair will notify direct clients when compelled to disclose the personal data or personally identifiable information (PII) of data subjects to government actors or entities.

GrayHair has shared the following categories of personal information for a business purpose in the last twelve months:

Category and Examples:

Identifiers – A real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers.



Personal information categories listed in the California Customer Records statute – A name, address, telephone number.



Internet or other similar network activity – Browsing history, search history, information on a consumer’s interaction with GrayHair’s website, application, or advertisement.

Your Data Protection Rights

You may choose to restrict the use of your personal data in accordance with this privacy policy.

General Data Subject Rights

Consumer Rights Requests – You may submit consumer rights requests exercising the below rights by calling our number at (856) 727-9372, or by emailing us to submit your request at privacy@grayhairsoftware.com.

Right to request access to data – You have the right to ask for copies of your personal information.

Right to deletion – You have the right to request that we delete your data.

Right to opt-out of communications – You have the right to opt-out of marketing communications.

California Consumer Privacy Rights

The California Consumer Privacy Act of 2018 (CCPA) provides broad privacy protections to California consumers and became effective January 1, 2020. If you are a California resident, you have the following rights under data protection law, including:

  • Right to deletion – You have the right to request the deletion of personal information collected by GrayHair, unless an exception applies. GrayHair will remove any non-publicly sourced data upon request. GrayHair may refuse to delete personal information for the following reasons:
    • If the personal information is needed to complete a contract or provide a good or service

      requested by you;
    • It is necessary for the detection of security incidents, to protect against malicious, deceptive, fraudulent, or illegal activity, or to prosecute those responsible for that activity, and to debug and repair errors that impair existing functionality;
    • It is necessary for compliance with GrayHair’s legal obligations;
    • It is collected and maintained for peer reviewed, scientific, historical, or statistical research;
    • Allowing for the exercise of free speech, ensuring the rights of other consumers to exercise free speech, or allowing the exercise of another right provided by law;
    • It is necessary to enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
  • Right to access– Right to request data collected about you over the past 12 months, including:
    • Categories of information collected about you
    • Categories of sources from which information is collected about you
    • Business or commercial purpose for collecting or selling personal information
    • Categories of third parties with whom GrayHair shares data
    • Specific pieces of information GrayHair has collected about you
    • Right to request what data is sold or shared, including:
      • Categories of information collected about you
      • Categories of personal information sold about you
      • Categories of third parties to whom personal information was sold, by category
      • Categories of personal information GrayHair discloses for a business purpose

These disclosures will be provided in a written, readily usable format for data portability and free of charge to the consumer after GrayHair receives a valid request. Consumers will receive their requested information either by consumer’s account (if they have one), electronically, or via mail.

Disclosures will identify the personal information collected in the previous 12 months. GrayHair will deliver the required information within 45 days of a verifiable request, and consumers will receive notification if GrayHair will need an additional 45 days to respond.

  • Right to opt-out– Right to opt-out of the sale of personal information
    • If you do not want your personal information to be sold, you may appoint another individual to opt out on your behalf. If you are using an authorized agent to submit the opt-out request on your behalf, we may request proof of authorization.
    • You have the right to opt-out of the sale of personal information by a third-party recipient of

      your information.
    • If you opt out of the sale of personal information, GrayHair will not request the

      authorization of the sale of personal information for 12 months after request.
    • GrayHair will not ask consumers making opt-out requests for more information than what is necessary to verify the consumer’s identity.
    • GrayHair will only use any personal information collected from you in connection with your opt-out request for the purpose of fulfilling that request
  • Right to use an authorized agent – You have the right to use an authorized agent to submit a request to access or a request to delete on your behalf. If you are using an authorized agent to submit the opt-out request on your behalf, we may require that you:
    • Provide the authorized agent written permission to do so; and
    • Verify your own identity directly with GrayHair.

GrayHair may deny a request from an agent that does not submit proof they have been authorized by you to act on their behalf.

If GrayHair cannot verify the identification of the individual making the request, GrayHair will not disclose any personal information to the requester and will inform you that we cannot verify your identity. GrayHair will not provide you with specific pieces of personal information if the disclosure would create a substantial, articulable, and reasonable risk to the security of your personal information, your account with the business, or the security of GrayHair’s systems or networks.

There may be circumstances where GrayHair must deny your verified request because of a conflict with state law, federal law, or an exception to CCPA. If GrayHair must deny a request accordingly, then you will be informed and given the basis for the denial. If the request is denied only in part, GrayHair will disclose the other information sought by you.

  • Right to non-discrimination – Consumers shall not be discriminated against for exercising any of these consumer privacy rights.
  • Do Not Sell My Personal Information – Please send an email to privacy@grayhairsoftware.com and you will receive a form that will enable you to halt an activity regarding your personal information. Additionally, you may also call 1-702-900-2272 and leave a detailed message with your contact information including your name and a valid email address and we will get in touch with you to complete the process.

Children

GrayHair’s services are not directed to persons under 13 years of age. We do not knowingly collect personal information from children under 13. If a parent or guardian becomes aware that their child has provided us with personal information without the parent’s consent, they should contact us at

privacy@grayhairsoftware.com. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete the information from our records.

Aggregated Statistics

GrayHair may collect statistics about the behavior of visitors to its websites. GrayHair may display this information publicly or provide it to others. However, GrayHair does not disclose personally-identifying information other than as described.

Security

GrayHair takes all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally identifying and personally identifying information.

Cookies

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Session cookies are cookies that disappear you’re your computer or browser when you turn off your computer. Persistent cookies stay on your

computer even after you’ve turned it off. GrayHair uses session cookies to help GrayHair identify and track visitors, their usage of GrayHair website, and their website access preferences. GrayHair visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before

using GrayHair’s websites, with the drawback that certain features of GrayHair’s websites may not function properly without the aid of cookies.

Business Transfers

If GrayHair, or substantially all of its assets, were acquired, or in the unlikely event that GrayHair goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of GrayHair may continue to use your personal information as set forth in this policy.

Ads

Ads appearing on any of our websites may be delivered to users by advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows

ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by GrayHair and does not cover the use of cookies by any advertisers.

Privacy Policy Changes

This Privacy Policy will be reviewed and updated at a minimum every 12 months and may change more frequently from time to time, and at GrayHair’s sole discretion. If we make changes, we’ll revise the “Effective” date at the top of this statement. GrayHair encourages visitors to frequently check this page for

any changes to its Privacy Policy as it is the visitors’ responsibility to check for any changes or updates. If you have a grayhairsoftware.com account, you might also receive an alert informing you of these changes. Your continued use of this site after any change in this Privacy Policy will constitute your acceptance of

such change.