fbpx

GroundSwell Privacy Policy

Effective January 1, 2021

GroundSwell SPC (“we,” “us” and/or “our”) is dedicated to protecting your personal information and informing you about how we use it. This privacy policy (the “Privacy Policy,” or the “Policy”) is intended to provide information to visitors to our websites and users of our mobile Application (“you” or “your”) about the Personal Information we collect, and how we source, use, disclose, and protect your information when you access or use (1) our websites located at https://www.groundswellworld.com/,  https://www.groundswellworld.com/, and all of our other websites to which this Privacy Policy is posted (collectively, the “Website”); (2) our mobile application(s) to which this Privacy Policy is posted (collectively, the “Application”); and (3) any services, content, communications, and product features relating to the Website and Application (together with the Website and the Application, the “Services”). This Privacy Policy covers the privacy practices of GroundSwell only. This Policy does not apply to the practices of third-party websites, services or applications, including third parties with which we partner. These third-party services are governed by each such third party’s privacy policy. GroundSwell is not responsible for the privacy policies and practices of websites other than that of GroundSwell, and GroundSwell is not responsible for the failure of unaffiliated third parties to honor their privacy obligations.

This Privacy Policy is organized as follows:

Table of Contents

A.  HOW WE COLLECT AND USE PERSONAL INFORMATION

B.  HOW TO OPT_OUT OF CERTAIN USES

C.  DISCLOSURE OF PERSONAL INFORMATION

D.  UPDATING YOUR PERSONAL INFORMATION AND INFORMATION RETENTION

E.  SECURITY OF YOUR PERSONAL INFORMATION

F.  LINKS TO THIRD-PARTY WEBSITES AND APPLICATIONS

G.  DO-NOT-TRACK SETTINGS

H.  CHILDREN UNDER 13

I.  YOUR CALIFORNIA PRIVACY RIGHTS

J.  CONSENT TO PROCESSING AND TRANSFER OF INFORMATION

K.  CHANGES TO THIS POLICY

L.  QUESTIONS ABOUT THIS PRIVACY POLICY

A. HOW WE COLLECT AND USE PERSONAL INFORMATION

In the course of providing you with the Services, GroundSwell collects certain Personal Information detailed under “What Personal Information Does GroundSwell Collect and How Does It Use It,” below. 

First, here’s an overview of Personal Information generally:

What is Personal Information?

Generally, “Personal Information” refers to any piece or combination of information that identifies, relates to, describes, or can reasonably be linked or associated with you or your household.

Personal Information includes, but is not limited to:

Any means of identification, whether traditional, digital, or otherwise. Traditional identifiers include your name, social security number, physical address, and telephone number. Digital identifiers include your device ID, IP address, cookies, and voice recordings when you contact GroundSwell Support Services.

Any information associated with your identity. This might include any information about how you use a GroundSwell Website; where you’re located when you login; what operating system you use; what GroundSwell products and services you use; your credit score; and your financial habits. Anything about you is your Personal Information.

Some information is NOT Personal Information:

Public Information. Information lawfully available from government records and used for a purpose consistent with its availability is not Personal Information.

De-identified information. Information delinked and disassociated from any identifying information is not Personal Information. To de-identify Personal Information, a business must implement processes to ensure the information will not be reidentified.

Aggregated information. If a set of Personal Information is sorted into conclusions about a group, and the individual consumer identities have been removed and are not linked or reasonably linkable to a consumer or household, it is not Personal Information.

What Personal Information Does GroundSwell Collect and How Does It Use It?

GroundSwell collects, uses, and discloses various types of Personal Information differently. GroundSwell has collected at least some information described in each category of Personal Information outlined below in the last twelve (12) months. For each category of information collected, we detail the categories of sources from which we get the information, our business purposes for collecting it, and the categories of third parties with whom we share that Personal Information.

A. Identifiers:

1. Traditional identifiers.

At Enrollment. GroundSwell collects the following identifiers from you during the enrollment process before you can use the Services: your name, social security number, date of birth, home address, email address, and phone number. If any traditional identifier you provide at enrollment is mistaken or otherwise unverifiable, GroundSwell may collect your correct Personal Information from an identity service and ask you to verify it.

In General. At any time in the course of your use of the Services, you may correct or update your information. In certain circumstances, GroundSwell may require that you provide, in addition to the information above, the following identifying information: government-issued photo ID, such as a driver’s license or passport; photographs of you; and proof of address documentation, such as a utility bill. Additionally, if you contact GroundSwell via a social media platform, GroundSwell may collect your social media handle from the social network or from a social media analytics tool.

GroundSwell collects your traditional identifiers in order to provide the Services and send you related communications; analyze individual and aggregated behavior to improve and customize the Services; verify your identity; comply and support our bank partners’ compliance with applicable law, including anti-money laundering (“AML”) and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you; process and deliver promotional (including contests and sweepstakes) entries and rewards; collect fees and other amounts owed in connection with the Services; comply with obligations to tax authorities; diagnose and debug our technical systems; and log and store this information.

2. Digital Identifiers.

Whenever you visit the Website or use the Application, GroundSwell automatically collects certain digital identifiers, including device identifiers, internet protocol (“IP”) addresses, web beacons, and other session tracking information as applicable, as follows:

Device Identifiers. GroundSwell automatically collects information regarding the computer, mobile device, technology or other device (collectively “Device”) you use to access the Services, including your device’s manufacturer, model number, and mobile phone plan carrier. GroundSwell collects this information through your use of GroundSwell’s Website and Application, your mobile phone plan carrier, and its risk investigation and mitigation vendors. GroundSwell may also assign a unique ID number to your Device.

IP Addresses. GroundSwell automatically collects information regarding your IP address(es). GroundSwell collects your IP address from your internet service provider (“ISP”), who assigns it. Your IP address is subject to change, so GroundSwell may maintain a record of many ISPs associated with you or your devices over time. IP addresses are typically associated with a particular geographic area and can thus be used to estimate your location. GroundSwell therefore collects IP address information both for the purposes associated with digital identifiers generally and for the purposes for which it collects geolocation data (described below).

Web Beacons & Customized Links. When you use the GroundSwell Website, GroundSwell collects web beacons and customized link information (also known as “clear GIFs” or “pixel tags”). Web beacons are transparent graphic images placed on a web page or in an email to identify you. They can indicate that you have viewed a page or email; tell your browser to get content from another server; and measure traffic to or from, or use of, our online forms, tools or content items and related browsing behavior. Similarly, customized links and related technologies track hyperlinks that you click and associate that information with you in order to provide you with more relevant communication.

Cookies & Other Session Trackers. GroundSwell may also collect cookies, local shared objects and similar session-tracking technologies (“Session Trackers”) to identify you over the course of many sessions. Session Trackers help provide additional functionality to the Services, customize users’ experiences with the Services and help us analyze Services usage more accurately for research and product development purposes. GroundSwell (and third parties that we work with) may place session trackers on your Device for security purposes, to facilitate navigation of the Services, and to personalize your experience while using our Services. If you would prefer not to accept Session Trackers when using the Site, follow the instructions provided by your website or mobile browser (usually located within the “Help”, “Tools” or “Edit” facility) to modify your Session Tracker settings. Please note that if you disable Session Trackers, you may not be able to access certain parts of our Site and other parts of our Services may not work properly. As a result, we recommend that you leave Session Trackers turned on when accessing the Services because they allow you to take advantage of all of the Service’s features.

GroundSwell collects your digital identifiers in order to provide the Services and send you related communications; analyze individual and aggregated usage data to improve and customize the Services; verify your identity; comply with and support our bank partners’ compliance with applicable law, including AML and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you; diagnose and debug our technical systems; and log and store this information.

In order to accomplish the business purposes described above, GroundSwell may disclose your traditional and digital identifiers to the following categories of third-party service providers: our bank partners, payment processors, payment networks, card fulfillment vendors, mobile check deposit processing services, identity services, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and Application usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.

B. Financial Information:

Financial information includes your GroundSwell and other bank account numbers, debit card and credit card numbers, and transaction history. To the extent GroundSwell collects this information, it does so on behalf of Axiom Bank, N.A. (GroundSwell’s bank partner), pursuant to the Privacy Notice you received from the bank partner at the time of enrollment. You may review the Privacy Notice(s) applicable to your account(s) at any time at https://www.groundswellworld.com/policies/.

1. GroundSwell partner bank account numbers.

GroundSwell collects your account number from the bank partner who issued your debit card or virtual debit card account(s) (“Accounts”). GroundSwell collects this information in order to deliver promotional (including referral, contests and sweepstakes) entries and rewards, and collect fees and other amounts owed in connection with the Services. Additionally, GroundSwell collects this information for the purposes applicable to financial information generally (see below).

2. External bank account information.

Your use of certain features of the Services requires GroundSwell to collect account numbers, balances, and other information about your bank accounts unrelated to your relationship with GroundSwell. GroundSwell may collect this information through a payment processor that facilitates a transfer to a GroundSwell partner bank account or through a third-party secure access tool such as Plaid (https://plaid.com/overview-privacy/). GroundSwell collects this information in order to provide certain features of the Services, including surfacing your external bank account balance and facilitating transfers between your external and GroundSwell partner bank accounts. Additionally, GroundSwell collects this information for the purposes applicable to financial information generally (see below).

3. History of GroundSwell partner bank account transactions.

GroundSwell collects your GroundSwell account transaction history from its processor and bank partner. It collects this information in order to provide you with the Services, in particular preparing your statement, resolving errors and unauthorized transfers, and verifying your identity in certain circumstances. GroundSwell may use certain transaction information as applicable, most notably whether your spending history is above a minimum threshold to determine your eligibility for certain features or elements of the Services. Additionally, GroundSwell collects this information for the purposes applicable to financial information generally (see below).

In addition to the purposes for which GroundSwell collects each subcategory of financial information described above, GroundSwell collects your financial information generally for the following purposes, as applicable: to provide the Services and send you related communications; analyze individual and aggregated usage data to improve and customize the Services; verify your identity; to comply and support our bank partners’ compliance with applicable law, including AML and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; diagnose and debug our technical systems; and log and store this information.

In order to accomplish the business purposes described above, GroundSwell may disclose your financial information to the following categories of third-party service providers: our bank partners, payment processors, payment networks, card fulfillment vendors, mobile check deposit processing services, identity services, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and Application usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.

D. Protected Class Information:

GroundSwell does not generally collect information relating to your status as a member of a protected class under federal or California law. However, GroundSwell does collect and disclose your date of birth for the purposes applicable to traditional identifiers, described above. Your date of birth necessarily indicates whether you are a member of the protected class of persons age 40 or older, but GroundSwell does not use or share the fact that you belong to this group for any purpose.

E. Commercial Information:

Commercial information consists of information about your interest in a particular product or service, your purchasing, donating, or consuming tendencies, and/or receipts or records for donations, products or services.

GroundSwell collects this information from you whenever:

You make a purchase or donation with your GroundSwell debit card; or you produce a receipt in response to a fraud prevention, anti-money laundering, or security inquiry from GroundSwell.

GroundSwell may also collect information from a GroundSwell nonprofit or not-for-profit philanthropic organization partner (“Impact Partner”) indicating whether you donated or enrolled in the Impact Partner’s programs or services. The partner will share this information with GroundSwell so that GroundSwell can verify that the partner is compensated accurately pursuant to the agreement between GroundSwell and the Partner, and to provide the Services. 

GroundSwell collects your commercial information in order to provide the Services and send you related communications; analyze individual and aggregated usage data to improve and customize the Services; verify your identity; comply and support our bank partners’ compliance with applicable law, including AML and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you; process and deliver promotion (including referrals, contests, and sweepstakes) entries and rewards; collect fees and other amounts owed in connection with the Services; comply with obligations to tax authorities; diagnose and debug our technical systems; and log and store this information.

In order to accomplish the business purposes described above, GroundSwell may disclose your commercial information to the following categories of third-party service providers: our bank partners, payment processors, payment networks, card fulfillment vendors, mobile check deposit processing services, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and Application usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.

F. Biometric Information:

Except as described below, GroundSwell does not collect your physiological, biological, or behavioral characteristics that could be used to identify you (“Biometrics”).

Voice Recordings

If you call GroundSwell’s member services over the phone, GroundSwell will collect from its customer service and communications platform vendors a record of the call, including your voice recording. GroundSwell collects this recording for customer service training and quality assurance, but GroundSwell may also use your voice recordings to verify your identity and prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services.

G. Application and Website Usage Information:

GroundSwell collects information about your interactions with the GroundSwell Services through the digital identifiers described above. When you perform an interaction such as visiting a particular webpage or Application screen, GroundSwell uses third party usage trackers, such as Segment and Google Analytics, to collect the particular digital identifiers associated with that interaction or series of interactions. If you choose to share your location with GroundSwell, we may also collect Geolocation Data associated with certain interactions (see Section H, below).

Additionally, GroundSwell collects the following information regarding your use of the Application and Website:

1.Referral information

At enrollment, GroundSwell collects information about how you came to GroundSwell. First GroundSwell automatically collects this information provided by marketers (e.g. Facebook and Google) and other websites on which GroundSwell advertises. GroundSwell may also collect information about how you were referred to GroundSwell based on the landing page you enrolled on, or from the link you followed to the Apple Application or Google Play store. Last, GroundSwell may collect information from you directly during enrollment, if you answer the optional question regarding how you came to GroundSwell.

2. Information you offer through customer service interactions

Whenever you interact with GroundSwell via the in-Application chat, email, phone, or Website, GroundSwell collects your communications. GroundSwell collects this information for customer service training and quality assurance, but may also use the information to investigate fraud or unusual activity relating to your account.

3. Information you provide about your experience with GroundSwell

If you give GroundSwell any information about your use of the Services; participate in user research by responding to a questionnaire, survey; or offer other feedback, including opinions about GroundSwell, GroundSwell may collect that information. GroundSwell collects your Application and Website usage information in order to provide the Services and send you related communications; analyze individual and aggregated usage data to improve and customize the Services; verify your identity; comply and support our bank partners’ compliance with applicable law, including AML and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you; diagnose and debug our technical systems; and log and store this information.

In order to accomplish the business purposes described above, GroundSwell may disclose your Application and Website usage information to the following categories of third-party service providers: our bank partners, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and application usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.

H. Geolocation data:

GroundSwell may collect information from your mobile Device about your location while you are accessing or using the Application and while you are not accessing or using the Application. We may use this information to provide targeted offers to you and notify you of nearby third-party locations where you may use the Services. You may opt out of the collection of location data at any time by changing your settings on your mobile Device. However, if you do so, certain features of the Services may not be available to you or the performance of certain features of the Services may be limited or not work at all.

GroundSwell collects your geolocation data in order to provide the Services and send you related communications; analyze individual and aggregated usage data to improve and customize the Services; verify your identity; comply and support our bank partners’ compliance with applicable law, including AML and sanctions screening rules; prevent, detect, and investigate fraud, hacking, infringement, or other suspected or actual misconduct, crime, or violation of an agreement involving the Services; send you announcements, newsletters, promotional materials, and other information about the Services and third-party products and services that we think may be of interest to you; diagnose and debug our technical systems; and log and store this information.

In order to accomplish the business purposes described above, GroundSwell may disclose your geolocation data to the following categories of third-party service providers: our bank partners, customer service vendors, communications platforms, risk investigation and mitigation tools, transaction dispute processing services, website and application usage trackers, data processors, modeling and analytics tools, and network infrastructure and data storage services. These third-party service providers are contractually obligated to secure and refrain from disclosing any Personal Information which we disclose or otherwise entrust to them.

B. HOW TO OPT-OUT OF CERTAIN USES

Email, Text and Social Media Communications.

We may use your Personal Information to provide you with marketing or other promotional communications via mail, email, text, social media. If, at any time, you would like to stop receiving these promotional communications, you may follow the opt-out instructions contained in any such communication or by contacting us as set out at the bottom of this policy. Please note that by opting out, you may prohibit GroundSwell from informing you of offerings that may be of interest to you. It may take up to ten (10) business days for us to process opt-out requests. You will continue to receive non-promotional emails about your relationship with us.

C. DISCLOSURE OF PERSONAL INFORMATION

A. GroundSwell Never Sells Your Personal Information

GroundSwell does not and will not sell anyone’s Personal Information to third parties.

B. Minors’ Personal Information

GroundSwell does not sell or disclose the Personal Information of minors under 16 years of age regardless of any affirmative authorization by that minor or their parent or guardian.

Get Started

C. Disclosure of Your Personal Information

In general, GroundSwell discloses each category of Personal Information for the same purpose it is collected. The information provided for each category described in Section 1, “How We Collect and Use Personal Information” therefore describes in detail the categories of Personal Information GroundSwell discloses, for what business purpose, and to whom. In addition, GroundSwell may disclose certain categories of your Personal Information in the circumstances described below:

Legal disclosures. GroundSwell may transfer and disclose information as applicable, including your Personal Information, information about how the Services are accessed and used, to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our User Agreement or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety or security of third parties, users of the Services, or the public.

Business transfers. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or our assets, Personal Information collected through the Services may be disclosed to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

With your permission. At your direction or request, we may share your Personal Information with specified third parties

D. UPDATING YOUR PERSONAL INFORMATION AND INFORMATION RETENTION

If you wish to modify, verify, correct, or update any of your Personal Information collected through the Services, you may do so by logging into your Account and updating your Account profile or by emailing us at support@groundswellcard.com. Please note that GroundSwell may continue to use your de-identified data after you delete any of your Personal Information.

E. SECURITY OF YOUR PERSONAL INFORMATION

GroundSwell has, and requires our Third-Party Service Providers to have, administrative, technical, and physical safeguards in place in our respective physical facilities and in our respective computer systems, databases, and communications networks that are reasonably designed to protect the information contained within such systems from loss, misuse, and alteration. We employ commercially reasonable website security and customer verification procedures to protect your data. The measures we use may include storing Personal Information on secured servers, transmitting Personal Information using encryption technologies, and auditing and reviewing our data collection and storage practices.

User passwords and other sensitive information are saved and encrypted to prevent unauthorized access or disclosure and accidental loss, alteration, or destruction. We regularly review our operational and business practices for compliance with corporate policies and procedures governing the security, confidentiality, and quality of our information. We require all of our employees, contractors, and other third parties to protect confidential information as a condition of doing business with, and our business practices limit the use and disclosure of such information, including personal information, to authorized persons, processes, and transactions. No method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee absolute security of your Personal Information. You also play a role in protecting your Personal Information. Please safeguard your username and password for your Account and do not share them with others. If we receive instructions using your Account log-in information, we will consider that you have authorized the instructions. You agree to notify us immediately of any unauthorized use of your Account or any other breach of security related to the Services. We reserve the right, in our sole discretion, to refuse to provide the Services, terminate your Account, and to remove or edit content

F. LINKS TO THIRD-PARTY WEBSITES AND APPLICATIONS

When you access or use the Services, you may be directed to other websites or applications that are beyond our control. We may also allow third-party websites or applications to link to the Services or use Session Trackers with the Services. For more information about how and why we share information including Session Trackers with third parties, please refer to Section I.A, above. We are not responsible for the privacy practices of any third parties or the content of linked websites and applications. We encourage you to read the applicable privacy policies and terms and conditions of such parties, websites, and applications. This Privacy Policy only applies to the Services.

G. DO-NOT-TRACK SETTINGS

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not use technology that recognizes DNT signals from your web browser and do not respond to such signals.

H. CHILDREN UNDER 13

The Site is not directed to children under 13 years of age and we do not knowingly collect, use, or disclose Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we will make reasonable efforts to delete such information from our files.

I. YOUR CALIFORNIA PRIVACY RIGHTS

A. California Consumer Privacy Act.

Beginning January 1, 2020, the California Consumer Privacy Act (“CCPA”) provides California consumers the right to request that a business disclose what Personal Information it collects, uses, discloses, and sells. Consumer may, for no fee, make the following verifiable requests to a business collecting their Personal Information: request to know categories of Personal Information collected and disclosed; request to know specific pieces of Personal Information collected; and request to delete their Personal Information. Upon verifying a consumer’s identity in response to a request to know, the business must disclose to the consumer, in a portable and readily usable form, the categories of Personal Information that the business has collected about the consumer, the categories of sources from which the information is collected, the business or commercial purposes for collecting the information as applicable, the categories of third parties with whom the information is shared, and/or the specific pieces of information collected about that consumer. Upon verifying a Consumer’s identity in response to a request to delete, the business must delete any Personal Information about the Consumer which it has collected. If a business does not produce the information or delete the consumer’s Personal Information as requested, it must provide an explanation in terms of the exemptions and exceptions provided in CCPA.

How to Make a Request

To make a request to know categories or specific pieces of Personal Information we have collected about you, or to make a request to have your Personal Information deleted, please email privacy@groundswellcard.com. GroundSwell must verify your identity before it will fulfill your request. As part of this process, GroundSwell may require government-issued identification documents and a recent photograph to verify your name and identity. Depending on your existing relationship with GroundSwell, GroundSwell may ask you to provide identifying information you previously provided to GroundSwell, including your Social Security number. You will also be required to verify your email address. Before GroundSwell can produce any specific pieces of Personal Information, you must submit a signed declaration attesting to your identity under penalty of perjury. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued

identification. Consistent with California law, GroundSwell may not deny Services, provide different quality of Services, offer its products at a different price, limit your eligibility for products, or otherwise discriminate against you because you exercise any rights conferred by the CCPA. GroundSwell does not and will not sell Personal Information to third parties. In the past 12 months, GroundSwell has both used third parties to collect Personal Information and has disclosed Personal Information to third parties to accomplish the business purposes described above. See Sections 1 (Collection Statement) and 2 (Disclosure Statement) for more details.

For more information about GroundSwell’s privacy policies and practices, please email privacy@groundswellcard.com.

B. Shine the Light

California law provides California residents the right to request from GroundSwell: (i) a list of the categories of Personal Information that we have disclosed to third parties for direct marketing purposes; and (ii) the names and addresses of all such third parties. We do not share your Personal Identifying Information with third parties for the third parties’ own and independent direct marketing purposes unless we receive your permission.

J. CONSENT TO PROCESSING AND TRANSFER OF INFORMATION

The Services are governed by and operated in, and in accordance with the laws of, the United States, and are intended for the enjoyment of residents of the United States. If you use the Services, or otherwise provide us with data, from outside the United States, you acknowledge and agree that your Personal Information may be transmitted outside your resident jurisdiction. In particular, please note that your Personal Information may be stored and processed in the United States. The laws pertaining to the collection, use, disclosure and protection of Personal Information in the United States may be more or less stringent than the laws of other countries. By using the Services, you (a) acknowledge that the Services is subject to the laws of the United States; (b) consent to your Personal Information being stored and processed in the United States and handled as described in this Policy; and (c) waive any claims that may arise under the laws of the country where you reside, are a citizen, and/or from where you access the Services.

K. CHANGES TO THIS POLICY

This Policy is the sole authorized statement of GroundSwell’s practices with respect to the collection of Personal Information and the subsequent use and disclosure of such information. GroundSwell may revise this Policy from time to time without prior notice to you, and any changes will be effective immediately upon the posting of the revised Privacy Policy on the Services. You should bookmark and periodically review this page to ensure that you are familiar with the most current version of this Policy. You can determine when this Policy was last revised by checking the “Last Updated” legend at the top of the Policy.

L. QUESTIONS ABOUT THIS PRIVACY POLICY

If you have any questions or concerns about this Policy, please contact us at: 

GroundSwell SPC

1700 Main Street, Suite 203

Washougal, WA 98671

Email: privacy@groundswellcard.com

¹ This definition of Personal Information and the subsequent explanatory examples are designed to convey a meaningful understanding of the definition of Personal Information found in the California Consumer Privacy Act (“CCPA”). See Cal. Civ. Code § 1798.140(o). It is GroundSwell’s intention to treat all members’ Personal Information, as that term is defined in CCPA, in accordance with this Privacy Policy. For more information about the rights CCPA confers on California residents, please see section 9A, “Your California Privacy Rights,” above.

² Such a request will be considered a request to know also how each such category is collected, the business or commercial purposes for which it is used, and to whom it is disclosed.