Privacy Policy

Effective Date: 10/1/2025

Last Updated: 11/3/2025

The Privacy Policy describes how Groundswell Solutions, and its subsidiaries and affiliated entities (collectively, “Groundswell,” “we,” “our,” and “us”) process personal information about you. This Privacy Policy applies when you engage with us through the Groundswell website portal and mobile application (the “Application”). If you need to receive this Privacy Policy in a different format, please contact us at sales@groundswellsolution.com.

BY USING THE APPLICATION OR OTHERWISE PROVIDING US WITH YOUR PERSONAL INFORMATION, YOU ARE AGREEING TO THE PROCESSING OF INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. PLEASE READ IT CAREFULLY.

Categories of Personal Information We Collect

The types of information that we collect depends on your interaction and relationship with us. We collect the below categories and types of personal information with your consent or as otherwise required or permitted by law.

• Identifiers: We may collect full name, email address, address, telephone numbers, username and password, and other security information for authentication and access.
• Financial Information: We may collect tax identification number, financial or bank account information, tax-related information, wire instructions, and billing address.
• Commercial Information: We may collect records of products or services purchased and obtained.
• Internet or Electronic Usage Data: We may collect data related to network and website interaction history, device information, usage information such as access to and use of the Application, IP address, tracking technology information, and browsing time.
• Log Data: We may collect your device identifier, user settings, browser type, operating system, the web page that you were visiting before accessing the Application, and the pages or features of our Application that you access or use.
• Geolocation Data: We may collect geolocation data which is derived from a device and that is used or intended to be used to locate a consumer within a geographic area that is equal to or less than the area of a circle with a radius of 1,850 feet, except as prescribed in applicable regulations.
• Inferences: We may use information from the categories of personal information described above in order to create a profile about you, to reflect your preferences, characteristics, behavior, and attitude.

Sources Of Personal Information

We collect personal information in the following ways:

• Directly from you: We may collect identifiers, financial information, and commercial information that you provide directly to us, such as while you are using the Application.
• Passively from you: We may collect commercial information and internet or other electronic activity passively using tools like tracking technologies.
• Automatically: When you access the Application, we may collect identifiers, geolocation data, and internet or electronic usage data using tools like tracking technologies.
• From third parties, vendors and service providers: We may receive identifiers, financial information, and commercial information from our service providers, vendors, and other third-parties.

Purposes for Collecting Personal Information

We use your personal information for the following business and commercial purposes:

• Transactional: We may use identifiers, financial information, and commercial information to: (i) allow you to use the Application; (ii) purchase and receive products and services that we offer; (iii) communicate with you; (iv) provide you with customer assistance; and (v) provide services to you including, but not limited to, billing support services and insurance verification services.
• Operate Our Business: We may use identifiers, financial information, and commercial information to operate our business, including for billing, accounting, and improving our internal operations.
• Combination of Data: We may combine information we obtain from different sources with publicly available information, including to create inferences about you. For example, we may combine information that we have collected offline with information we collect online. We combine information that we have collected across other third-party sites or applications. We combine information across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have.
• Analytical: We may use identifiers, usage data, geolocation data, commercial information, and inferences to analyze preferences, trends, and statistics.
• Maintenance and Improvement of our Application and Systems: We may use identifiers, internet or electronic usage data, log data, and geolocation data to improve our Application and systems, to provide you with alerts or notifications, provide and maintain functionality on our Application and systems, and help us diagnose technical and service problems and administer our Application and systems.
• Develop and Improve Our Products and Services: We may use identifiers, financial information, commercial information, geolocation data, internet or electronic usage data, audio/visual data, log data, and inferences to help us develop new products and services and to improve and analyze our existing products and service offerings.
• Security and Fraud Prevention: We may use identifiers, financial information, commercial information, geolocation data, internet or electronic usage data, log data, and inferences to: (i) protect the Application, premises, assets, systems, products, services and intellectual property; (ii) protect us, our affiliated companies, our employees, our carriers and others from fraud, theft, and other misconduct; (iii) conduct vendor due diligence; and (iv) detect and prevent fraud, theft, and misconduct including by verifying the identity of those we are conducting business with.
• Legal: We may use identifiers, financial information, commercial information, geolocation data, internet or electronic usage data, log data, and inferences to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
• Corporate Transactions: If Groundswell is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer identifiers, financial information, commercial information, geolocation data, internet or electronic usage data, log data, and inferences, in connection with such transaction.
• Other Purposes: We may use identifiers, financial information, commercial information, geolocation data, internet or electronic usage data, log data, and inferences for other reasons we may describe to you.

How We Disclose Personal Information

We disclose personal information in the following circumstances:

• Service Providers: We may share personal information with vendors and service providers who support the operation of our services, application, website, and our business and who need access to such information to carry out their work for us (including, for example, cloud hosting providers, analytics, payment processing, background and credit checks, attorneys, accountants, order fulfillment, email delivery, marketing, insurance, internet service providers, operating systems and platforms, recruiting vendors, credit verification, maintenance and customer support services). In some cases, the vendor or service provider may directly collect the information from you on our behalf.
• Affiliates: We may share personal information with and among our parent company, subsidiaries, affiliates, or their successors or assigns.
• Government Entities: We share information with regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation. This includes cooperating with law enforcement when we think it is appropriate, obtaining legal remedies or limiting our damages, and to enforcing or protecting our contracts, legal rights or the rights of others, including by responding to claims asserted against us.
• Corporate Transaction Recipients: We may share information with potential investors, purchasers, merger partners, and their advisors in the event we: (i) sell or transfer, or are considering selling or transferring, all or a portion of our business or assets; or (ii) are considering or engaging in any reorganization, conversion, merger, sale, joint venture, assignment, transfer or disposition of all or any portion of our ownership interest, business or operations; or (iii) are soliciting or accepting investments.
• Other Reasons: We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.

How Long We Keep Personal Information

We will retain and use your information for as long as we need it to provide you services or products through the Application, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

• how long the information is needed to provide our services and operate our business;
• whether there are contractual or legal obligations that exist that require us to retain the information for period of time;
• whether any law, statute, or regulation allows for a specific retention period;
• whether an individual has agreed to a longer retention period;
• whether the data is considered to be sensitive in nature, and
• what the expectation for retention was at the time the data was provided to us.

Analytics and Other Tracking Technology

When you access the Application, we (and third-party companies we work with) may collect and store certain information by using technologies such as server logs, web beacons, clear gifs, tags, e-tags, log files, pixels, code, JavaScript packages, mobile advertising IDs, cross-device linking, and similar technologies. The information collected includes information about your activities on the Application, IP address, browser or operating system type and version, device IDs, and demographic or inferred-interest information, as well as information or communications you have submitted to us through the Application.

To the extent we collect information using the technologies describe above, we may use this information to understand general usage and volume statistics, how users navigate to and around the Application, what content is viewed or accessed, and which products and services have been obtained. We also use these technologies to keep track of your preferences and profile information. To learn more about interest-based advertising, tracking technologies, and how to opt out, please visit http://www.aboutads.info/choices.

Do Not Track Signals

Some browsers and devices have a “do not track” feature. It lets you tell websites or applications you visit that you do not want them to track your online activity. These features are not yet uniform across browsers. Our Application is not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.

Links to Websites or Applications

The Application may include links to websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or application that you use.

Security

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use applications and share information with caution. To the extent we share your personal information with vendors, services providers, affiliates, or other third parties as described above, we will require that such third parties agree to provide the same or equal protection of your personal information as set forth in this Privacy Policy.

If we become aware of a breach that affects the security of your personal information, we may provide you with notice as required by applicable law. To the extent permitted by applicable law, we may provide any such notice that we must provide to you under applicable law at your account’s email address. By using the services, you agree to accept notice electronically.

Your Choices

• Access: To the extent permitted by applicable law, you can request access to and copies of the personal information we process about you by contacting us in writing at sales@groundswellsolution.com. We may not be required to disclose some or all of your personal information.
• Correction: You can request correction of certain account information, such as email address or phone number associated with your account, by contacting us in writing at the addresses below. We are not required to correct information that is accurate or outside of our control.
• Deletion: If you would like to delete any personal information we have collected about you, or if you would like to revoke your consent to collection of your personal information (to the extent such consent is required), please contact us at sales@groundswellsolution.com to process such request, subject to certain limitations (e.g., where we need to keep your information to process a transaction). Also note that if we delete your personal information, the Application may not work the same.
• Opting Out: We may periodically send you text messages or e-mails that directly promote our Application and our services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (either through your account or by following the unsubscribe instructions provided in the e-mail or by emailing us at sales@groundswellsolution.com). We do need to send you certain communications regarding the Application and you will not be able to opt out of those communications (e.g., communications regarding updates to our Privacy Policy, communications related to transactions with you, communications to confirm your identity).

Our Application Is Not Intended for Children

We do not knowingly collect or store any personal information from anyone under the age of 16. If we become aware that we have collected or stored personal information from an individual under age 16, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to sales@groundswellsolution.com.

Notice for California Users and Residents

The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at sales@groundswellsolution.com and include “CA Shine the Light” in the subject line of your email.

Notice to Users Outside of the United States

Groundswell and our technical infrastructure are located in the United States. The personal information that you provide to us is stored on servers located in the United States. If you are located in another jurisdiction, you should be aware that in order to provide the Application to you, we must transfer your personal information to the United States where it will be stored and processed in accordance with this Privacy Policy. We may transfer your information outside the United States to service providers with operations in other countries. By using the Application, you consent to such collection, storage and processing in the United States and elsewhere, though the United States and other jurisdictions may not afford the same level of data protection as considered adequate in your own country. We will take reasonable steps to protect your personal information.

Contact Us

If you have any questions about this Policy or our data practices, please email us at sales@groundswellsolution.com.

Updates to Our Privacy Policy

From time to time we may change our privacy policy. We will notify you of any material changes to our privacy policy as required by law. We will also post an updated copy on the Application where this appears. Please check our Application periodically for updates. The “Last Updated” legend above indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Application.