Privacy Policy

Last Updated: October 5th, 2023


Grace Manning, and the affiliates and subsidiaries ("we", "us", or "our") are committed to protecting your privacy. Please read this Privacy Policy (the "Privacy Policy") carefully to understand our policies and practices regarding your information and how we will treat it. This Privacy Policy is intended to inform you about the kind of information, including personally identifiable information, that we may collect from you in connection with your use of the Services and how, and for what purpose, we use that information.


Who We Are

When we refer to or use "Grace Manning", "we", "us", or "our" throughout this Privacy Policy, it means the Grace Manning entity who is the controller of your data under this Privacy Policy, namely the Grace Manning entity with which you had, have, or will have a business relationship or that otherwise decides what data of yours is collected and how it is used.


How To Contact Us

Please feel free to contact us if you have any questions about this Privacy Policy or Grace Manning entities' information collection and security practices or to exercise any of your rights set out in this Privacy Policy by email at privacy@grace-manning.com.


When This Privacy Policy Applies (And When It Doesn't)

This Privacy Policy applies when you:

  • Visit or use the Grace Manning website, Cowculator app, or any other Grace Manning entities;
  • Contact our customer support;
  • Collaborate with us in a paid or unpaid partnership; or
  • Otherwise interact with us in your capacity as a customer.
Unless otherwise stated in this Privacy Policy, this Privacy Policy does not apply:
  • When you visit or use third party links and websites.
  • To information you share when you connect, integrate, or use our entities with third party applications, integrations, or services.


You Give Consent

By accessing or using the Services, or submitting information through the Services, you acknowledge and agree that by providing us Personal Information you (1) understand that you allow us to identify you; and (2) have read, understand, and agree to the terms of this Privacy Policy and you expressly consent to the collection, use, and disclosure of your Personal Information and Anonymous Information (as each term is defined below) in accordance with this Privacy Policy.
Some of the services we provide may be obstructed if you do not provide us the necessary Personal Information. If you do not agree with our policies and practicies, unless otherwise stated, your choice is not to use or access the services.


Defining "Personal Information"

Currently, Grace Manning entities do not collect data or information from you in connection with your use of the Services. However, please review the definitions of Personal Information and Anonymous Information.

"Personal Information" is information that allows someone to identify or contact you, as well as any other non-public information about you that is associated with or linked to any of the foregoing, and can include, for example, an individual's first and last name, address, phone number, e-mail address, IP address, location or other personally identifiable details. Personal Information does not include Anonymous Data.

"Anonymous Information" means aggregated and/or anonymized data that is not associated with or linked to your Personal Information. Anonymous Information does not, by itself, permit the identification of individual persons.


Protecting Your Privacy

We do not share, rent, or sell your account information to any third party, except as expressly set forth in this Privacy Policy. Please help us protect your privacy by keeping your account information safe.


Information We Collect and How We Use It

Depending on your interactions with us (for example, online, offline, etc.) we may process different data about you. We may collect your data, for example, when you visit or use the Grace Manning website or Cowculator app, contact our customer support, participate in our promotions, surveys, and marketing campaigns or otherwise interact with us.


Information You Provide Us

Direct Communications, Feedback, and Support
If you provide us Feedback or contact us via e-mail, or contact us for support related inquiries, we will collect your first and last name, e-mail address, and any other content included in the feedback or support inquiries you send to us. We may use Personal Information submitted in these communications to contact and respond to you and send you related services communications.

Surveys and Marketing Campaigns
If you participate in our surveys or marketing campaigns, we may collect your name, mailing address, email, images and/or videos from which you may be identified, pictures and any other information requested and/or required with respect to your participation in the surveys and marketing campaigns. We may use Personal Information submitted in connection with our surveys and marketing campaigns to carry out the surveys and marketing campaigns and provide related marketing communications that we may think are of interest to you.


Information Collected Automatically

When you visit or use the Grace Manning website, Cowculator, or other entities, we may collect information sent to us by your computer, mobile phone, or other access device, in addition to the information you provide to us directly.

This information is used to (i) provide you the Grace Manning website, Cowculator app, and other services requested by you, (ii) improve the Grace Manning website, Cowculator app, and other services, and (iii) notify users about updates to the Services.

For example, we may collect:

Device Information
Hardware model, IMEI number and other unique device identifiers, MAC address, IP address, operating system version, and settings of the device you use to access the Services.

Log File Information
Log file information, which may include your internet protocol (IP) address, URLs of referring/exit pages, information you search for, click stream data, which pages areas of the Services you visit or use, access times, time and duration of your use of the Services.

Cookies and Other Tracking Technologies
A cookie is a small piece of data (text file) that a website - when visited by a user - asks your browser to store on your computer or device in order to remember information about you, such as your language and/or currency preference or login information. We may use similar techniques, such as pixels, web beacons etc., which we will refer to collectively as “cookies”. Where required by applicable law, we will obtain your consent prior to setting cookies (except for strictly necessary cookies).

Google Analytics
We also utilize Google Analytics, a web analysis service provided by Google, to better understand your use of our Services. Google Analytics collects information such as how often users visit the Grace Manning website, what pages they visit, and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of our Services, to prepare reports on its activities and share them with other Google services.

Google may use the data collected on or through the Services to contextualize and personalize the ads of its own advertising network. Google's ability to use and share information collected by Google Analytics about your visits to the Grace Manning website and use of the Services is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Google offers an opt-out mechanism for the web, available here.


How Your Information Is Shared

We do not share your information with any third parties.


Third Party Links and Websites

The Grace Manning website contains links to other third party websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We are not responsible for the content, privacy and security practices, and policies of third-party sites or services to which links or access are provided through the Services. We encourage you to read the privacy policies or statements of the other websites you visit.


Your Responsibilities, Privacy Rights, and Choices

Your Responsibilities
While we are committed to protecting your privacy, it is your responsibility to ensure that to the best of your knowledge the information and data you provide us is accurate, complete and up-to-date. It is also your responsibility that in the event you share Personal Information of other people with us, you collect such Personal Information in compliance with local legal requirements and that you have the appropriate consent to share such Personal Information. At a minimum, you should inform any such people about this Privacy Policy and obtain their consent prior to sharing their Personal Information with Grace Manning entities.

Changes and Deletion of Your Data
To the extent we provide you with access to and control of your information (for example, to update modify or, to the extent legally permissible, delete it), we strongly encourage you to take control of your information.

In certain jurisdictions you have the right to request access and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or object to the processing of your Personal Information, to have the information blocked, anonymized or deleted, as appropriate, or to exercise your right to data portability to transfer your Personal Information to another company. Those rights may be limited in some circumstances by local law requirements. In addition to the above-mentioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.

If you would like to access, review, update, rectify, and delete any Personal Information we hold about you, or exercise any other data subject right available to you under applicable data protection laws and regulation, you can do so by submitting your request in writing by email at privacy@grace-manning.com.

We will do our best to address your request in time and free of charge, except where it would require a disproportionate effort. In certain cases, we may ask you to verify your identity before we can act on your request. If you are unsatisfied with the reply received, you may then refer your complaint to the relevant regulator in your jurisdiction.

Please note that we may still use Anonymous Information that does not identify any individual and that even if you have requested deletion of your information, we may retain such information to the extent permitted by applicable law as further described in the section titled "Data Deletion and Retention" below.

Cookies
You can accept or reject cookies by adjusting your web browser controls.

Services-Related Communications
If you have contacted us for support or for other reasons, you may not, despite your indicated e-mail preferences, "opt-out" of other services-related communications regarding your account, support requests, or any payments made, or to be collected, by you, including receiving notices of any updates to this Privacy Policy.

California Residents - Shine the Light Law
Residents of California are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: privacy@grace-manning.com.


Data Deletion and Retention

We keep your data for the period necessary to fulfill the purposes for which it has been collected (for details on these purposes, see section titled "Information We Collect and How We Use It" above). We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period.

When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations. In any event, we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Security

We employ technical and organizational measures designed to prevent against risks such as accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Information in our possession.

Please be aware that no security measures are perfect or impenetrable. We cannot guarantee that information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our administrative, physical, and electronic safeguards, subject to requirements under applicable law to ensure or warrant information security. You acknowledge and agree that you provide your Personal Information at your own risk.

We will make any legally-required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored Personal Information to you via email or conspicuous posting on our Site in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system , and any other disclosures that may be required under applicable law.


California and Delaware "Do Not Track" Disclosures

California and Delaware law require us to indicate whether it honors "Do Not Track" settings in your browser concerning targeted advertising. We adhere to the standards set out in this Privacy Policy and do not monitor or respond to Do Not Track browser requests.


Children

Grace Manning's website or other entities do not collect or maintain Personal Information from or about children under the age of thirteen (13) and the Services are not intended to be used by persons under thirteen (13). If you are under the age of thirteen (13), please do not use any of our Services at any time nor in any manner. If we learn that Personal Information of persons under thirteen (13) years of age has been collected on or through the Services, then we may make the user content inaccessible. If you find that we have Personal Information about anyone below thirteen (13) years of age, please inform us at privacy@grace-manning.com.


Changes To This Privacy Policy

This Privacy Policy may be amended by us from time to time. If we make material changes to this Privacy Policy, we will use all reasonable efforts to notify you of such changes by posting the revised Privacy Policy on the Grace Manning website. Your continued use of the Services after such notification of changes as described above will constitute your agreement to such changes. If you object to any change, your sole recourse shall be to immediately cease all access and use of the Services.


Questions and Additional Information

Please feel free to contact us at privacy@grace-manning.com if you have any questions about this Privacy Policy or our information collection and security practices.