Privacy Policy

This Privacy Policy (“Privacy Policy” or “Policy”) describes the types of information gathered by
GRA ENTERPRISES (“GRA ENTERPRISES ”, “us” or “we”) in the process of providing this
website, services, information, tools, functionality, updates and similar materials (collectively, the
“Services”), how we use it, with whom the information may be shared, what choices are
available to you regarding collection, use and distribution of information and our efforts to
protect the information you provide to us through the Services. By using the Services, you
hereby consent to allow us to process information in accordance with this Policy.

This Policy is subject to change. If our information retention or usage practices change, we will
let you know by posting the Privacy Policy changes on the Services and/or otherwise making
you aware of the changes. Please refer to the “Effective Date” above to see when this Policy
was last updated.

Territoriality

Regardless of where our servers are located, your personal data may be processed by us in the
United States, where data protection and privacy regulations may or may not be to the same
level of protection as in other parts of the world. BY VISITING THE WEBSITE AND USING THE
SERVICES, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE
COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION
COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND THAT
U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

Information Collected

We collect two types of information about and from persons who use the Services: Personal
Information and Anonymous Information.

“Personal Information” is information that is personally identifiable to you, such as your name,
address, email address or phone number, as well as other non-public information that is
associated with the foregoing. Anything you publicly post or that is available publicly will not be
considered Personal Information, and will be outside the restrictions of this policy.

“Anonymous Information” means information that is not associated with or linked to your
Personal Information. We may create Anonymous Information from (i) automatically gathered
information or (ii) Personal Information by excluding information (such as name) that may make
the information personally identifiable to you.

Personal Information Collected

We collect certain Personal Information about you or about those you identify, which may be
supplied when you interact with the Services, complete a survey, make a purchase, when you
request services or otherwise when you submit such information. The information collected may
include one or more of the following:

Name;
Address;
Phone number;
Email;
Username;

Information from your activities on the Services;Although the Services may appear to
collect payment card information, such information is collected directly by our credit card
processing vendor, and we do not have possession of such information.
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Anonymous Information

Anonymous Information is collected about you when you use the Services, including but not
limited to enrolment history, the type of device you used and its operating system, the pages
accessed most frequently, how pages are used, search terms entered, and similar data.
Automatically Tracking Internet Protocol (IP) addresses is one method of automatically
collecting information about your activities online and information volunteered by you. An IP
address is a number that is automatically assigned to your device whenever you surf the
internet. Further, the Services may utilize web beacons, pixel tags, cookies, embedded links,
and other commonly used information-gathering tools.

Although it may be possible to turn off the collection of cookies through your device, that may
interfere with your use of the Services.

Use of Information

Internal Use of Information by Us

We accept and gather Personal Information and Anonymous Information in an effort to provide
the Services to you. We may also use this information to help us develop and improve our
Services, fulfill your requests, send materials to you, inform you about our offers and those of
others, tailor our Services to meet your interests, and for other purposes permitted by law.
We may use Anonymous Information or non-Personal Information for any business purpose.

Sharing Collected Information

We may share Personal Information and Anonymous Information with our business associates,
consultants, service providers, advisors and affiliates in order for them to provide services to us,
to you, and to enable us to provide the Services. For example, our host and internet service
provider may have access to this information.

We may also share Personal Information and Anonymous Information with third-parties for
marketing and analytics, when marketing our Products and Services, and for other purposes
permitted by law. The use of information by third-parties will be governed by their own policies,
and may be broader than the uses outlined in this Policy.

Further, we may disclose collected information, including Personal Information and Anonymous
Information, to the extent we believe it necessary to comply with the law, such as in response to
a subpoena or court order, to defend a legal claim or establish or protect our legal rights or
otherwise as permitted by applicable law. We may disclose any information in our possession in
the event that we believe it necessary or appropriate to prevent criminal activity, personal injury,
property damage or bodily harm.

Additionally, we may transfer your information to a successor in interest, which may include but
may not be limited to a third-party in the event of an acquisition, sale, asset sale, merger or
bankruptcy. The policies applicable to your information thereafter may be determined by the
transferee.

Links

The Services may contain links to other websites. We are not responsible for the privacy
practices of such other sites. When you leave our Service to visit another website or application,
please read the privacy statements of websites that may collect personally identifiable
information. This Privacy Policy applies solely to information collected by us through the
Services.

Security

We employ procedural and technical safeguards to secure your personal information against
loss, theft, alteration, and unauthorized access, use and disclosure. We also employ security
procedures to protect your information from unauthorized access by users inside and outside
the company.
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Regardless of the precautions we take, no transmission of data over the internet is guaranteed
to be completely secure. It may be possible for third parties not under our control to intercept or
access transmissions or private communications unlawfully. While we strive to protect personal
information, we cannot ensure or warrant the security of any information you transmit to us.

E-Mail and Electronic Newsletters 

We may offer electronic newsletters and e-mails concerning available properties, as well as new
products and services, or may provide other marketing materials as a service to our users.
Users may receive newsletters and e-mails concerning promotions and marketing of ours or of
our business partners, after registering with the Services or after engaging with us in person or
through our agents.

If you have received a message from us, and you no longer wish to receive such materials, you
may opt- out by following the unsubscribe instructions included in each electronic newsletter
and e-mail.

Please note that you may be required to separately opt out of any e-mails sent by our business
associates.

Children and Privacy

We do not knowingly permit users to use our Services if they are under 13 years old, and
therefore do not request personally identifiable information from anyone under the age of 13.
If we become aware that a user or customer is under the age of 13 and has registered without
verifiable parental consent, we will remove his or her personally identifiable registration
information from our files. If you are the parent or guardian of a person under the age of 13 who
has provided personally identifiable information to us without your approval, please inform us by
contacting us at the e-mail address below and we will remove such information from our
database.

Do Not Track

At present, the Services do not specifically respond to browser do-not-track signals.

California Privacy Rights

California law allows California residents to request information regarding our disclosures in the
prior calendar year, if any, of their personally identifiable information to third parties. To make
such a request, please contact us at Gerard@gerardadams.com with “Request for Privacy
Information” in the subject line. Please include enough detail for us to locate your file; at a
minimum, your name, email, and username, if any. We will attempt to provide you with the
requested information within thirty (30) days of receipt. We reserve our right not to respond to
requests sent more than once in a calendar year, or requests submitted in a form other than as
prescribed in this notice. Please note that this law does not cover all information sharing. Our
disclosure only includes information covered by the law.

Contact Information

If you have any questions or suggestions regarding our Privacy Policy, please contact us via
e-mail at Gerard@gerardadams.com

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