Grey, Inc. (the “Company”, “Grey”, “we”, “us” or “our”) provides money transmitter services in connection with the Company’s “Grey Token” stablecoin platform (the “Services”).  This Privacy Policy (the “Policy”) applies to Grey and all of its employees. In addition, to the extent necessary we will verify that all third parties engaged by us have written policies and procedures in place to comply with this Policy prior to performing any customer-related services on behalf of Grey.  This Policy shall apply to Grey’s operations within the United States.


This Policy describes how we collect, uses and shares information generated from you, by visiting our site or using our services.  This Policy also aims to provide our users with the information necessary to understand their privacy choices when using our website and Services.


By using, applying and/or signing up for Grey’s Services, including through a computer or mobile device, you accept the terms of our service and the terms of this Policy.  By doing so you consent to our collection, use, disclosure and retention of your information for the purposes described in this document as well as for the purposes permitted under applicable personal information privacy statues, credit bureau reporting rules, anti-spam legislation and consumer protection laws.  This Policy does not apply to websites and services we do not own or control, including websites or services of other Grey users and members of the Grey Network.

Policy Statement

It is Grey’s policy to provide clear and conspicuous disclosures that accurately reflect our privacy policies and practices.  Furthermore, it is our policy to not share nonpublic personal information of our customers to nonaffiliated third parties, unless it is permitted by law.  Within this guiding principle, it is the policy of Grey to comply with all requirements of the Privacy of Consumer’s Financial Information Rules, or Regulation P.  Specifically, Grey will give initial and annual privacy notices to those of its customers who are covered by the regulation. Furthermore, we will ensure that our privacy notices meet the required notice contents and that our privacy notices are provided in a clear and conspicuous manner, accurately reflecting this Policy.

A. Collection of Information – Types of Information We Collect

1. Information You Provide to Us to Provide Services Requested.

We collect information you provide when you apply or sign up for a Grey user account and information you provide for our customer due diligence and identity verification programs.  This information includes:

• Identification information, such as your name, email address, mailing address, phone number, photograph, birthdate, passport number, driver’s license number, Social Security number, Taxpayer Identification number, or other government-issued identification number;

• Financial information, including bank account information, issuing bank information, other financial documents;

• Tax information, including withholding allowances and tax filing status;

• Business documents, including operating agreement, by-laws and management agreement;

• Regulatory information, industry license identifiers and employee personal information;

• Transaction information, including baseline sales data and point-of-sale records; and

• Other historical and contact information.

2. Information We Collect When You Use Our Services.

When you and users authorized under you, use our Services we collect activity information that is generated. The activity information we collect includes:

Use Information.  Information about how you use our Services, including your access time, “log-in” and “log-out” information, browser type and language, country and language setting on your device, Internet Protocol (“IP”) address, the domain name of your Internet service provider, other attributes about your browser, mobile device and operating system, any specific page you visit on our platform, content you view, features you use, the date and time of your visit to or use of the Services, your search terms, the website you visited before you visited or used the Services, data about how you interact with our Services, and other clickstream data.

Geolocation Information.  The location of your device while using our services.

Device Information.  Information about your device, including hardware model, operating system and version, device name, unique device identifier, mobile network information and information about the device’s interaction with our services.

Business Information.  Information about products you sell including inventory, pricing and other data, and information about your business operation including, staffing hours and activity, employee information, employee management information, payroll and contact information.

Transactional Information. Information about transactional frequency, volume, and type.

Customer Information. Information you collect form your customers, including email addresses, phone numbers, payment information, or other information.

We also collect information from your devices including mobile devices and applications you or your users use to access and use any of our websites, applications or services (for example, we may collect the device identification number and type, location information, and connection information, such as statistics on page views, traffic to and from the sites, referral URL, advertisement data, your IP address, your browsing history and your web log information) and will ask for your permission before we do so.  We may do this using cookies or similar technologies (as described below).

3. How We Collect Your Information.

To the extent permissible under applicable law, we collect information about you and users authorized under you when you:

• Provide us with information upon applying for our service.

• Use Grey’s application and Services.

• Connect the Grey application to the Internet.

• Perform deposits, transfers, and withdrawals (fiat-to-token, token-to-token, token-to-fiat).

• Complete forms on our applications or interact with the user interface.

• Provide your contact information when contacting customer support through our application.

We may enhance personal information we collect from you with information we obtain from third parties that are entitled to share that information; for example, information from credit agencies, search information providers or public sources (e.g., for customer due diligence purposes), but in each case as permitted by applicable laws.

If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Notice.

We use cookies and similar tracking technologies to track the activity on our Services and hold certain information.

Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our services.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.  However, if you do not accept cookies, you may not be able to use some portions of our services.

Examples of Cookies we use:

• Session Cookies.  We use session cookies to operate our services.

• Preference Cookies.  We use preference cookies to remember your preferences and various settings.

• Security Cookies.  We use security cookies for security purposes.

B. How We Use the Information We Collect

To the extent permissible under applicable law, we use your information to:

• Compare information for accuracy and verify it with 3rd party service providers;

• Provide any information and services that you have requested or ordered;

• Measure, improve, and protect our applications, website, and services to provide an exceptional user experience;

• Provide you with any information that we are required to provide you with in order to comply with our regulatory and legal obligations;

• Perform statistical analysis, provided that in such circumstances it is on an aggregated basis which will not be linked back to you or any living individual;

• Perform internal testing of our applications, website, or infrastructure;

• To provide and maintain our services;

• To notify you about changes to our services;

• To allow you to participate in interactive features or our services when you choose to do so;

• To provide customer care and support;

• To provide analysis or valuable information so that we can improve our services;

• To monitor the usage of our services; and

• To detect, prevent and address technical issues.

C. How We Share Your Information

We may share your information as follows:

• With vendors, consultants and other service providers (including third party analytics services) who need access to such information to carry out work on our behalf;

• In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation;

• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of us or any third party;

• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company;

• With your consent or at your direction; and

• We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

D. Transfer of Data

Your information, including personal data, may be transferred to and maintained on computers located outside of your state, province, country or other government jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal data, to United States and process it there.

Your consent to this Policy followed by your submission of such information represents your agreement to the transfer described above.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

E. Third-Party Links

Our site and services may contain links to third-party websites.  Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites.  We are not responsible for the information practices of such third party websites.

F. Disclosure of Data – Legal Requirements

Grey may disclose your personal data in good faith belief that such action is necessary to:

• Comply with a legal obligation;

• Protect and defend the rights or property of Grey;

• Prevent or investigate possible wrongdoing in connection with the service;

• Protect the personal safety of users of the service or the public; and

• Protect against legal liability.

G. Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer or electronic device, choosing a robust password that no one else knows or can be easily guessed, and keeping your log-in and password private.  We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

H. Children’s Privacy

Our services do not address anyone under the age of 18 (“Children”).  We do not knowingly collect personally identifiable information from anyone under the age of 18.  If you are a parent or guardian and you are aware that your Children has provided us with personal data, please contact us. If we become aware that we have collected personal data from Children without verification of personal consent, we will take steps to remove that information from our servers and systems.

I. Changes to Privacy Policy

We may update our Privacy Policy from time to time.  We will notify you of any changes by posting the new Privacy Policy on this page of our website.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Policy.

You are advised to review this Policy periodically for any changes.  Changes to this Policy are effective when they are posted on this page.

J. Contact Us

If you have questions about the privacy aspects of our services or would like to make a complaint, please contact us at or 1601 Elm Street, Suite 4420, Dallas, Texas 75201.