PRIVACY NOTICE

Last updated 2/26/2026

This Privacy Noticefor Graybill Technology, LLC ("we," "us," or"our"), describes how and why we might access, collect, store,use, and/or share ("process") your personal information whenyou use our services ("Services"), including when you:
Questions or concerns? Reading thisPrivacy 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 mark@graybill.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process?
When you visit, use, or navigate ourServices, we may process personal information depending on how you interactwith us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? 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 may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be100%secure, so we cannot promise or guarantee that hackers, cyber criminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights. How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us.We will consider and act upon any request in accordance with applicable data protection laws.Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

InShort:
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 orour products andServices, 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 theServices, the choices you make, and the products and features you use.The personal information we collect may include the following:names phone numbers email addresses mailing addresses job titles

SensitiveInformation. We do not process sensitive information.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like yourFacebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

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, andadministerour Services, communicate with you, for security and fraudprevention, andto comply with law. We process the personal information for thefollowingpurposes listed below. We may also process your information forotherpurposes only with your prior explicit consent.

We process your personal information fora variety of reasons, depending on how you interact with our Services, including:
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do sounder applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation(GDPR) and UK GDPR require usto explain the valid legal bases we rely on inorder to process your personalinformation. As such, we may rely on thefollowing legal bases to processyour personal information:‍
If you are located in Canada, this section applies to you.

We may process your information if youhave given us specific permission(i.e., express consent) to use your personalinformation for a specificpurpose, or in situations where your permission canbe inferred (i.e.,implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.We may need to share your personal information in the following situations:

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

OurServices offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this PrivacyNotice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. Were commend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill 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 (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives),then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

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

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safe guards and efforts to secure your information, no electronic transmission over theInternet or information storage technology can be guaranteed to be100%secure, so we cannot promise or guarantee that hackers, cyber criminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified bylaw in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under18years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at mark@graybill.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), UnitedKingdom(UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information,(ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.If you are located in the EEA or UK and you believe we are un lawfully processing your personal information, you also have the right to complain to your MemberState data protection authority orUK data protection authority.If you are located in Switzerland, you may contact the FederalDataProtection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOWCAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

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

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications 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 recognizing and implementing DNT signals has been finalized. 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. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California,Colorado, Connecticut,Delaware, Florida, Indiana, Iowa, Kentucky, Maryland,Minnesota,Montana, Nebraska, New Hampshire, New Jersey, Oregon, RhodeIsland,Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information.These rights may be limited in some circumstances by applicable law. More information is provided below.
Categories of Personal Information We Collect 

The information below shows the categories ofpersonal information we have collected in the past twelve (12) months. Thetable includes illustrative examples of each category and does not reflect thepersonal information we collect from you. For a comprehensive inventory of allpersonal information we process, please refer to the section "WHAT INFORMATIONDO WE COLLECT?"

Category: A. Identifiers
Examples: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
Collect? NO

Category: B. Personal information as defined in the California Customer Records statute
Examples: Name, contact information, education, employment, employment history, and financial information
Collect? NO

Category: C. Protected classification characteristics understate or federal law
Examples: Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data
Collect? NO

Category: D. Financial Information
Examples: Transaction information, purchase history, financial details, and paymentinformation
Collect? NO

Category: E. Biometric information
Examples: Fingerprints and voiceprints
Collect? NO

Category: F. Internet or other similar network activity
Examples: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements
Collect? NO

Category: G. Geolocation data
Examples: Device location
Collect? NO

Category: H. Audio, electronic, sensory, or similarinformation
Examples: Images and audio, video or call recordings created in connection withour business activities
Collect? NO

Category: I. Professional or employment-related information
Examples: Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
Collect? NO

Category: J. Education Information
Examples: Student records and directory information
Collect? NO

Category: K. Inferences drawn from collected personal information
Examples: Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
Collect? NO

Category: L. Sensitive personal Information
Examples: Medical or health information, sexual orientation, religious beliefs
Collect? NO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
Sources of Personal Information Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?" 

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?" 

Will your information be shared with anyone else? 

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider.Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?" 

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration.This is not considered to be "selling" of your personal information. 

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers. 

Your Rights 

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include: 
Depending upon the state where you live, youmay also have the following rights: 
How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at mark@graybill.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws. 

Request Verification 

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system.We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. 

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at mark@graybill.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general. 

California "Shine The Light" Law 

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update thisnotice as necessary to stay compliantwith relevant laws.Wemay update this Privacy Notice from time to time. The updated versionwill beindicated by an updated "Revised" date at the top of thisPrivacyNotice. If we make material changes to this Privacy Notice, we maynotifyyou either by prominently posting a notice of such changes or bydirectlysending you a notification. We encourage you to review this PrivacyNoticefrequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you havequestions or comments about this notice, you may email us at mark@graybill.com or contact us by post at:

Graybill Technology, LLC
5900 Balcones Drive STE 100
Austin, TX 78731

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, 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. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.

This Privacy Policy was created usingTermly's Privacy PolicyGenerator