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Biometric Data Privacy Notice

Last Updated: August 10, 2026

Grain Inc. (“Grain,” “we,” “us,” or “our”) has established this Biometric Data Privacy Notice (“Notice”) to describe how we treat the photos and/or video images of your face, including scans of facial geometry extracted from those images, which may be considered “biometric identifiers,” “biometric information,” or “biometric data” under applicable law in some jurisdictions (collectively, “Biometric Data”).

We use a third-party vendor to provide identity verification and fraud prevention services. As part of the identity verification process, we and/or our identity verification vendor will collect a photograph or video image of your face and an identity document (e.g., driver’s license or passport) that contains your image. Where we collect your identity document or image directly, we may submit that information to our identity verification vendor for the purposes described in this Notice. Our vendor may derive a scan of your facial geometry using facial recognition or similar technology to facilitate identity verification and fraud prevention.

Purposes for Collection and Processing

Any Biometric Data collected and/or processed by us and/or our vendor(s) will be used solely for purposes of identity verification, customer identification, Know Your Customer (“KYC”) and anti-money laundering (“AML”) compliance, sanctions screening, fraud prevention and detection, account security, and compliance with our respective legal and regulatory obligations.

Disclosures

We may disclose Biometric Data to our third-party service providers and vendors that process Biometric Data on our behalf for the purposes described in this Notice, including identity verification, KYC/AML compliance, sanctions screening, fraud prevention and detection, account security, and compliance with legal and regulatory obligations.

We will not otherwise disclose or redisclose Biometric Data unless:

  • You or your legally authorized representative consents to the disclosure;
  • The disclosure is required by applicable law or regulation; or
  • The disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.

We do not sell, lease, trade, or otherwise profit from Biometric Data.

Retention and Destruction

In circumstances where we retain Biometric Data, we will retain such Biometric Data until the initial purpose for collecting or obtaining it has been satisfied or within three (3) years of your last interaction with us, whichever occurs first, unless a valid warrant, subpoena, or directly applicable legal requirement requires retention for a longer period. Upon expiration of the applicable retention period, we will permanently destroy the Biometric Data in accordance with applicable law.

This Notice constitutes Grain’s publicly available written policy establishing its retention schedule and guidelines for permanently destroying Biometric Data.

Contact Us

Questions regarding this Notice may be directed to:

Privacy Team
Grain Inc.
Email: [email protected]

For more information about how Grain processes personal information, please review our Privacy Policy.