Privacy Policy

Little GRAPEVINETM Website Privacy Policy Last Updated: July 2, 2019 Summary Thank you for visiting the Little GRAPEVINETM website located at https://littlegrapevine.com (the “Site”).  The Site is an Internet property of Little GRAPEVINETM, LLC (“GRAPEVINE,” “we,” “our” or “us”).  The following GRAPEVINETM Website Privacy Policy (“Privacy Policy”) sets forth our policy with respect to the collection, storage and usage of your Personal Data.  For purposes of this Privacy Policy, “Personal Data” means any information concerning the personal or material circumstances of an identified or identifiable individual. This includes information such as your name, your address, your phone number and your email address.  Capitalized terms not defined herein shall have the meaning set forth in the GRAPEVINE™ Website Terms and Conditions (“Terms”). Legal Basis We collect Personal Data that you provide to us, e.g. during the email registration, to fulfill your request to receive additional information or for the purpose of handling the contractual relationship that you have with GRAPEVINE™.  We only use and store your Personal Data if we have a legal basis for doing so, including where you have given us your express consent, where we have a legitimate business interest or pursuant to the contractual relationship between you and GRAPEVINE™. Individual Rights: Deleting, Modifying and Updating Your Personal Data At your request, we will: (a) inform you of what Personal Data we have on file for you, in a machine readable format; (b) amend the Personal Data that we have on file for you; and/or (c) completely remove Personal Data that you have provided to us, or that we have collected, from: (i) our servers/databases; and (ii) the servers/databases of any third-party that we have provided your Personal Data to.  You may do so by e-mailing us at: support@littlegrapevine.com.  We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests. Please be advised that deleting your Personal Data may terminate your access to certain of the GRAPEVINE™ Offerings (as defined below).  If you wish to continue using the full complement of GRAPEVINE™ Offerings, you may not be able to delete all of the Personal Data that we have on file for you. Please be further advised that, after you delete your Personal Data, residual copies may take a period of time before they are deleted from our active servers and may remain in our backup systems. Background This Privacy Policy covers our treatment of Personal Data and other information that we collect when you: (a) access and/or use the Site; (b) access certain text, images, video, audio, testimonials, blog posts and other content and information relating to investment opportunities, financial data and analysis, as well as information relating to the GRAPEVINE™ Offerings, generally, as made available by: (i) GRAPEVINE™ (collectively, “GRAPEVINE™ Content”); (ii) VIP Members and/or Regular Members (as defined below) (“Member Content”); and (iii) other third-parties, including but not limited to, submitted or aggregated from sources outside GRAPEVINE articles, videos and podcasts (“Third-Party Content,” and together with the GRAPEVINE™ Content and Member Content, the “Content”); (c) access links to third-party websites and resources (“Third-Party Links”); (d) access, view and/or download the Executive Cast videos and virtual presentations featuring executives from third-party companies or their representatives, such as but not limited to Investor Relation Firms (“GRAPEVINE Videos”); (e) register, for a free, to establish a GRAPEVINE account (“Account”) as a VIP member (“Membership”) of the Site (“VIP Member”), which enables VIP Members to: (i) receive periodic VIP Member-only email newsletters delivered by GRAPEVINE  (“VIP Email”); (ii) receive exclusive email alerts delivered by GRAPEVINE from time-to-time (“Special Email,” and together with the “VIP Email”, the “GRAPEVINE Email”); and (iii) obtain access to the Site, which may contain compilations of GRAPEVINE Email and will contain other non-exclusive Content; (f) access certain message boards, comment sections, messaging functionality and other interactive features of the GRAPEVINE Offerings (“Interactive Services”); (g) register for the free email newsletter available to all Users (“Newsletter”) (h) access or use the site a if you have not registered with the GRAPEVINE (“Regular Member”)  (h) access links to the GRAPEVINE and/or User social media pages/accounts appearing on third-party social media websites (collectively, “Social Media Pages”), such as Facebook®, LinkedIn® and Twitter® (collectively, “Social Media Websites,” and together with the Site, Content, GRAPEVINE Email, Interactive Services, the “GRAPEVINE Offerings”); and/or (i) otherwise affirmatively consent to this Privacy Policy and/or the Agreement. IF YOU DO NOT AGREE TO TERMS OF THIS PRIVACY POLICY IN THEIR ENTIRETY, YOU MAY NOT ACCESS OR OTHERWISE USE THE GRAPEVINE™ OFFERINGS. Facebook® is a registered trademark of Facebook, Inc. (“Facebook”).  LinkedIn® is a registered trademark of LinkedIn Corporation (“LinkedIn”).  Twitter® is a registered trademark of Twitter, Inc. (“Twitter”).  Please be advised that Company is not in any way affiliated with Facebook, LinkedIn or Twitter, nor are the GRAPEVINE™ Offerings endorsed, administered or sponsored by any of the foregoing entities. Your California Privacy Rights GRAPEVINE™ will never share, sell, rent, exchange or barter your Personal Data to or with any third-party for financial gain or marketing purposes.  Nevertheless, we may, in certain limited instances, share your Personal Data with third parties who perform administrative functions on our behalf. If you are a resident of the State of California and would like to learn how your “personal information” (as defined in the Shine the Light Law, Cal. Civ. Code § 1798.83) is shared with third parties, what categories of personal information that we have shared with third parties in the preceding year, as well as the names and addresses of those third parties, please contact Little Grapevine (support@littlegrapevine.com, (954) 494-4276, 599 South West Second Avenue, Fort Lauderdale, FL 33301) Personal Data Collected We collect Personal Data when you access certain of the GRAPEVINE™ Offerings and complete the required information request Form and/or otherwise provide such information to us.  The information that you must supply on the applicable Form may include, without limitation: (a) your full name; (b) your mailing/billing address; (c) your e-mail address; (d) your telephone number; (e) your credit card information (where purchasing a Membership subscription); and/or (f) any other information requested by us on the applicable registration Form.  For purposes of this Privacy Policy, item (e) in the preceding sentence shall be considered “Sensitive Information.” Use of Personal Data GRAPEVINE™ will never share, sell, rent, exchange or barter your Personal Data to or with any third-party for financial gain or marketing purposes. By making your Personal Data available to GRAPEVINE™, you grant GRAPEVINE™ the right, subject to applicable law, to use that Personal Data (other than Sensitive Information) to contact you by telephone and email regarding your use of the GRAPEVINE™ Offerings (including in connection with the Newsletter and your VIP Membership).  In addition, where you provide your consent as required under the GDPR or we have another valid legal basis under the GDPR, we may use your Personal Data to contact you by telephone and email regarding certain GRAPEVINE™ products and/or services that we think may be of interest to you. If you wish to stop receiving future communications from us, please follow the instructions at the end of each such marketing message or see the “Opt-Out/Unsubscribe” section below. We will also use your Personal Data for customer service, to provide you with information that you may request, to customize your experience with the GRAPEVINE™ Offerings and/or to contact you when necessary in connection with your use of the GRAPEVINE™ Offerings.  We may also use your Personal Data for internal business purposes, such as analyzing and managing our service offerings including, without limitation, the GRAPEVINE™ Offerings. We may also employ other companies and individuals to perform certain functions on our behalf.  Examples include sending direct and electronic mail, removing duplicate information from User lists, analyzing data and providing marketing analysis.  The agents performing these limited functions on our behalf shall have access to our Users’ Personal Data solely as needed to perform these functions for us, but we do not permit them to use User Personal Data for other purposes. At times, we may want to contact you via telephone regarding your use of the GRAPEVINE™ Offerings. To enable us to contact you by telephone regarding your use of the GRAPEVINE™ Offerings, you agree that by submitting your Personal Data by and through the GRAPEVINE™ Offerings, and where you provide your consent as required under the GDPR or we have another valid legal basis under the GDPR, such act constitutes an inquiry and/or application for purposes of the Amended Telemarketing Sales Rule (16 CFR §310 et seq.), as amended from time to time (the “Rule”) and applicable state do-not-call regulations.  As such, notwithstanding that your telephone number may be listed on the Federal Trade Commission’s Do-Not-Call List, and/or on applicable state do-not-call lists, we retain the right to contact you via telemarketing in accordance with the Rule and applicable state do-not-call regulations. At times, we may want to contact you via your mobile device regarding your use of the GRAPEVINE™ Offerings. To enable us to contact your mobile device, you agree that, where you provide your consent as required under the GDPR or we have another valid legal basis under the GDPR, and where you have provided your “prior express written consent” within the meaning of the Telephone Consumer Protection Act (47 USC § 227), and its implementing regulations adopted by the Federal Communications Commission (47 CFR § 64.1200), as amended from time-to-time (“TCPA”), you consent to receive telephone calls, including artificial voice calls, pre-recorded messages and/or calls delivered via automated technology, to the telephone number(s) that you provided.  Please note that you are not required to provide this consent in order to obtain access to the GRAPEVINE™ Offerings, and your consent simply allows GRAPEVINE™ to contact you via these means.  Please be advised that by agreeing to this Privacy Policy, you are obligated to immediately inform us if and when the telephone number that you have previously provided to us changes.  Without limiting the foregoing, if you: (a) have your telephone number reassigned to another person or entity; (b) give up your telephone number so that it is no longer used by you; (c) port your telephone number to a landline or vice versa; or (d) otherwise stop using that telephone number for any reason (collectively “Phone Number Change”), you agree that you shall promptly notify GRAPEVINE™ of the Phone Number Change via e-mail at: support@littlegrapvine.com, or by using one of the methods set forth in the “Contact Us” section below. We reserve the right to release current or past Personal Data, including Sensitive Information: (i) in the event that we believe that the GRAPEVINE™ Offerings are being or have been used in material violation of the Terms or to commit unlawful acts; (ii) if the information is subpoenaed; provided, however, that, where permitted by applicable law, we shall provide you with e-mail notice, and opportunity to challenge the subpoena, prior to disclosure of any Personal Data pursuant to a subpoena; (iii) to comply with a legal obligation, including sharing your name/e-mail address with third-parties to assist you with your opt out requests in compliance with applicable law, including the GDPR and the CAN-SPAM Act of 2003, as amended from time-to-time; (iv) to protect and defend the rights or property of GRAPEVINE™ and/or its Users; (v) to act in urgent circumstances to protect the personal safety of our Users or the public; or (vi) if we are sold, merge with a third-party, are acquired or are the subject of bankruptcy proceedings; provided, however, that if GRAPEVINE™ is involved in a bankruptcy proceeding, merger, acquisition or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on the Site of any change in ownership or uses of your Personal Data, as well as any choices that you may have regarding your Personal Data. Social Media Websites If you engage in any interaction with GRAPEVINE™, other users or any third-party on any Social Media Pages, you should be aware that: (a) the personal information that you submit by and through such Social Media Pages can be read, collected and/or used by other users of these websites/services (depending on your privacy settings associated with your accounts with the applicable Social Media Websites), and could be used to send you unsolicited messages or otherwise to contact you without your consent or desire; and (b) where GRAPEVINE™ responds to any interaction on such Social Media Pages, your account name/handle may be viewable by any and all users of GRAPEVINE’s™ social media accounts.  We are not responsible for the personal information that you choose to submit on any Social Media Websites. Your interactions with the Social Media Pages are governed by the privacy policies of the applicable Social Media Websites.  We encourage you to review the privacy policies and settings of the Social Media Pages with which you interact to help you understand those Social Media Websites’ respective privacy practices.  If you have questions about the security and privacy settings of any Social Media Pages that you use, please refer to the applicable Social Media Website’s privacy notices or policies. Non-Personal Data Collection and Use IP Addresses/Browser Type We may collect certain non-personally identifiable information about you and your desktop computer and/or mobile device when you visit many of the pages of the Site.  This non-personally identifiable information includes, without limitation, the type of browser that you use (e.g., Safari, Chrome, Internet Explorer), your IP address, the type of operating system that you use (e.g., Windows or iOS) and the domain name of your Internet service provider (e.g., Verizon, AT&T).  We use the non-personally identifiable information that we collect to improve the design and content of the GRAPEVINE™ Offerings and to enable us to personalize your Internet experience.  We also may use this information in the aggregate to analyze usage of the GRAPEVINE™ Offerings. Cookies When a User visits the Site, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to When a User visits the Site, and that User agrees to the terms of our cookie policy, we send one (1) or more cookies and/or gif files (collectively, “Cookies”) to assign a unique identifier to the applicable User’s computer.  To opt-out of allowing us to use Cookies in connection with your computer/mobile device, please e-mail us at: support@GRAPEVINE.com.  A Cookie is a piece of data stored on your hard drive containing non-personally identifiable information about you.  Cookies have many benefits to enhance your experience at the Site.  To find out more about Cookies, visit www.cookiecentral.com. We use Cookies to improve the quality of the GRAPEVINE™ Offerings, including for storing User preferences and tracking Site-User trends (such as pages opened and length of stay at the Site).  We do not use Cookies to track your Internet browsing activity, or to serve you advertisements. Most Internet browsers are initially set up to accept Cookies, but you can reset your browser to refuse all Cookies or to indicate when a Cookie is being sent.  To disable and reject certain Cookies, follow the instructions associated with your Internet browser.  Even in the case where a User rejects a Cookie, he or she may still use the GRAPEVINE™ Offerings; provided, however, that certain functions of the GRAPEVINE™ Offerings may be impaired or rendered inoperable if the use of Cookies is disabled. Behavioral Tracking Neither GRAPEVINE™, nor any third party, uses cookies, pixels or other tracking technology on the Site for purposes of tracking Users’ activities after they leave the Site. Nevertheless, most Internet browsers contain a “do-not-track” setting.  In general, when a “do-not-track” setting is active, the User’s Internet browser notifies other websites that the User does not want his/her Information and online behavior to be tracked and used, for example, for behavioral advertising. Cross Device Tracking GRAPEVINE™ tracks Users’ use of the GRAPEVINE™ Offerings across various devices, including User personal computers and mobile devices, in order to optimize and personalize the User GRAPEVINE™ Offerings experience.  GRAPEVINE™ may collect certain User Personal Data across various devices.  If you would like to opt-out of having your use of the GRAPEVINE™ Offerings tracked across multiple devices, please e-mail us at: support@littlegrapvine.com.  Please be advised that where you opt-out of having your use of the GRAPEVINE™ Offerings tracked across devices, you may need to upload certain information multiple times and/or input your log-in information multiple times. Aggregate Data GRAPEVINE™ does not track Users’ use of the GRAPEVINE™ Offerings across multiple devices, including personal computers and mobile devices. Third-Party Websites The Site may contain links to third-party owned and/or operated websites including, without limitation, the Third-Party Links and Social Media Websites.  GRAPEVINE™ is not responsible for the privacy practices or the content of such websites.  In some cases, Users may be able to make a purchase through one of these third-party websites.  In these instances, Users may be required to provide certain information, such as a credit card number, to register or complete a transaction at such website.  These third-party websites have separate privacy and data collection practices and GRAPEVINE™ has no responsibility or liability relating to them. Security We endeavor to safeguard and protect our Users’ Personal Data.  When Users make Personal Data available to us, their Personal Data is protected both online and offline (to the extent that we maintain any Personal Data offline).  Where our registration/application process prompts Users to enter Personal Data, and when we store and transmit such Personal Data, that information is encrypted with advanced TLS (Transport Layer Security). Access to your Personal Data is strictly limited, and we take reasonable measures to ensure that your Personal Data is not accessible to the public.  All of our Users’ Personal Data is restricted in our offices, as well as the offices of our third-party service providers.  Only employees or third-party agents who need the Personal Data to perform a specific job are granted access to Personal Data.  Our employees are dedicated to ensuring the security and privacy of all User Personal Data.  Employees not adhering to our firm policies are subject to disciplinary action.  The servers that we store Personal Data on are kept in a secure physical environment.  We also have security measures in place to protect the loss, misuse and alteration of Personal Data under our control. Please be advised, however, that while we take every reasonable precaution available to protect your data, no storage facility, technology, software, security protocols or data transmission over the Internet or via wireless networks can be guaranteed to be 100% secure.  Computer hackers that circumvent our security measures may gain access to certain portions of your Personal Data, and technological bugs, errors and glitches may cause inadvertent disclosures of your Personal Data; provided, however, that any attempt to breach the security of the network, our servers, databases or other hardware or software may constitute a crime punishable by law.  For the reasons mentioned above, we cannot warrant that your Personal Data will be absolutely secure.  Any transmission of data at or through the Site, other GRAPEVINE™ Offerings or otherwise via the Internet or wireless network, is done at your own risk. In compliance with applicable federal and state laws, we shall notify you and any applicable regulatory agencies in the event that we learn of an information security breach with respect to your Personal Data.  You will be notified via e-mail in the event of such a breach.  Please be advised that notice may be delayed in order to address the needs of law enforcement, determine the scope of network damage, and to engage in remedial measures. Minors Visitors under eighteen (18) years of age are not permitted to use and/or submit their Personal Data at the Site.  GRAPEVINE™ does not knowingly solicit or collect information from visitors under eighteen (18) years of age.  GRAPEVINE™ encourages parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children. Opt-Out/Unsubscribe To opt-out of receiving e-mail communications from us, you can follow the instructions at the end of the applicable e-mail message or e-mail us at: support@littlegrapevine.com.  To restrict the processing of your Personal Data, please e-mail us at: support@littlegrapevine.com. Notwithstanding the foregoing, we may continue to contact you for the purpose of communicating information relating to: (a) the fulfillment of our contractual relationship (including in connection with your Membership); (b) your request for GRAPEVINE™ Offerings; and (c) to respond to any inquiry or request made by you.  To opt-out of receiving GRAPEVINE™ Offerings-related and/or inquiry response-related messages from GRAPEVINE™, you must cease requesting and/or utilizing the GRAPEVINE™ Offerings and/or cease submitting inquiries to GRAPEVINE™, as applicable. Transfer of Personal Data Internationally If you are visiting the Site from a country other than the country in which our servers are located, your communications with us may, solely where permitted by applicable law, including the GDPR, result in the transfer of information across international boundaries. By visiting the Site and/or otherwise communicating electronically with us, you consent to such transfers where permitted by applicable law.  Even if your jurisdiction does not have the same privacy laws as the jurisdiction where our servers are located, we will treat your information as subject to the protections described in this Privacy Policy. Changes to this Privacy Policy GRAPEVINE™ reserves the right to change or update this Privacy Policy at any time by posting a notice on the Site that we are changing our Privacy Policy.  If the manner in which we use Personal Data changes, GRAPEVINE™ will notify Users by: (a) sending the modified policy to our Users via email; and/or (b) by any other reasonable means acceptable under applicable state and federal law.  You will have a choice as to whether or not we use your information in this different manner and we will only use your information in this different manner where you opt-in to such use. Contact Us If you have any questions about this Privacy Policy, you can utilize the options made available on the Site’s “Contact Us” page, or e-mail us at: support@littlegrapevine.com; call us at: (800) 891-1526; or send us mail to: 599 South West Second Avenue, Fort Lauderdale 33301. Filing a Complaint with the Federal Trade Commission To file a complaint regarding our privacy practices, please Click Here.