Privacy Policy

Last Updated: March 25, 2024

Your privacy is very important to us and we take your privacy very seriously. This Privacy Policy describes how GRT Financial Inc. (“Company”, “we”, “us”, or “our”) collects and uses the personal information you provide to us on our website and all other websites, mobile sites, applications, platforms and tools where this Privacy Policy appears or is linked (collectively the “Site”). It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. This Privacy Policy does not apply to personal information provided by you in connection with our provision of the services as a financial institution under federal law, which is covered by our Consumer Privacy Notice located at https://www.grtfinancial.com/GRT-Privacy-Policy.pdf. However, we may combine personal information received through our Site with personal information received in connection with our provision of the services as a financial institution under federal law. Such use, once combined, will be covered by our Consumer Privacy Notice.

By creating an account, providing information to us (by any means, whether in correspondence, via our Site, or otherwise), or continuing to use our services, you acknowledge that you have read, understood, and consent to be bound by this Privacy Policy.

If you do not agree with this PRIVACY Policy or our practices, you may not use our SITE. This PRIVACY Policy may change from time to time and your continued use of our SITE constitutes your acceptance of those changes. We encourage you to review this PRIVACY Policy periodically.

1. Personal Information We Collect About You

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”):

Category	Category Examples of Personal Information	Specific Types of Personal Information Collected
A. Identifiers	Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers	First name, last name, postal address, email address, and IP address.
B. Customer records information	Name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit or debit card number, other financial information, medical information, health insurance information	First name, last name, email address, and phone number. In requesting we contact you about our services, you may provide us with background information on your income and other financial information, such as the amount of your current unsecured debt and the identity of your creditors, your account balance, payment history and credit card usage, information about your mortgage, budget and other financial information, your credit history or employment status, and your Social Security number. However, this information is not required to contact us.
C. Characteristics of protected classifications under state or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	None.
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	None.
E. Biometric information	A retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry.	None.
F. Internet or other electronic network activity information	Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement.	Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement).
G. Geolocation data	Physical location or movements.	None.
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.	None.
I. Professional or employment-related information	Business contact details, job title, work history, and professional qualifications.	None.
J. Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA)	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	None.
K. Inferences drawn from collected personal information	Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	None.
L. Sensitive personal information	(1) Personal information that reveals: (A) A person’s social security, driver’s license, state identification card, or passport number; (B) A person’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) A person’s precise geolocation; (D) A person’s racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) The contents of a person’s mail, email, and text messages unless the business is the intended recipient of the communication; (F) A person’s genetic data; (2) the processing of biometric information for the purpose of uniquely identifying a consumer; (3) personal information collected and analyzed concerning a consumer’s health, or a personal information collected and analyzed concerning a consumer’s sex life or sexual orientation).	None.

This personal information is required to provide products and/or services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and/or services to you.

Please note, by submitting your request to us, you are consenting to being contacted by us or by our business partners, through any means, based on the information you provide to us, even if you have opted into the National Do Not Call List administered by the Federal Trade Commission, any state Do Not Call List or the Do Not Call List of any specific institution. If, after you are contacted by that product or service provider, you do not wish to be contacted by that person again you must make a specific request to the product or service provider, not to GRT Financial Inc.

2. Cookies and Other Tracking Technologies

Cookies

Cookies are small text files of information stored by the Internet browser on your computer’s hard drive. We may use these cookies to collect browsing data to keep track of your preferences and profile information and to collect general usage and volume statistical information. Our cookies do not collect personal or confidential information and are not spyware.

There are a number of different types of cookies, however, our Site uses:

Essential – These cookies are necessary to the core functionality of our Site and some of its features, such as access to secure areas.
Analytics and Customization –Our Company uses these cookies and technologies to analyze how the Site is accessed, used, or performing in order to improve your user experience and to maintain, operate and continually improve the Site. For example, we use Google Analytics on the Site to collect: page url/page title and user browser/system information, which includes browser type, referrer, language, java/flash support, IP address, and ad-serving data. For information on how Google Analytics collects and processes data, visit www.google.com/policies/privacy/partners/. To opt-out of Google Analytics, visit Google’s “How you can control the information collected by Google on these sites and apps” article available here. These cookies are nonessential to the use of our Site, however, without these cookies, certain functionality may become unavailable. These are first-party cookies.

Web Beacons

Our Site contains electronic images known as web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how our Site is used and may be used in some of our emails to let us know which emails and links have been opened by recipients. This allows us to gauge the effectiveness of our customer communications and marketing campaigns. We use a third party to gather information about how you and others use our Site. For example, we will know how many users access a specific page and which links they clicked on. We use this aggregated information to understand and optimize how our Site is used.

How to Manage Cookies.

You have the right to decide whether to accept or reject certain cookies. You can set your browser not to accept cookies and you can remove cookies from your browser. However, in a few cases, some of our Site features may not function as a result. Essential cookies cannot be rejected, as they are strictly necessary to provide you with our Site.

3. Do Not Track

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

4. Testimonials

If you submit a testimonial to us, we will ask for your permission to post your testimonial prior to any public use. We will post your name as given to us in your testimonial. We may post a photo of you or use a stock photo. Please be aware that any personal information you submit as a testimonial to be posted can be read, collected, or used by the general public, and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to include in any testimonial you choose to submit. If at any time you decide to remove your testimonial, please contact us via e-mail or postal mail.

5. Promotional Communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our services.

We will always treat your personal information with the utmost respect and never sell it to other organizations outside GRT Financial Inc.’s group companies for marketing purposes without your consent.

You have the right to opt out of receiving promotional communications at any time by:

Contacting us by using one of the methods listed in the “How to Contact Us” Section below; or
Using the “unsubscribe” link in emails or “STOP” number in texts.

We may ask you to confirm or update your preferences if you instruct us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. How Your Personal Information is Collected

We collect most of this personal information directly from you or your agent—in person, by telephone, text or email, from documents you provide us related to our services, and/or via our Site. However, we may also collect information:

From publicly accessible sources;
Directly from a third party (e.g., credit reporting agencies);
Third parties with your consent (e.g. your bank and credit card providers);
From cookies on our Site; and
Via our IT systems, including automated monitoring of our Site and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

7. How and Why We Use Your Personal Information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

To comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products and services to you, including to provide debt settlement activities and respond to your inquiries and fulfill your requests; To inform you about important information regarding the Site, products or services for which you apply or may be interested in applying for, or in which you are already enrolled, changes to terms, conditions, and policies and/or other administrative information; To allow you to apply for products or services and evaluate your eligibility for such products or services.	For the performance of our contract with you or to take steps at your request before entering into a contract.
To prevent and detect fraud against you or Company.	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you.
To verify your identity and/or location (or the identity or location of your representative or agent), including personal information collected through our social media pages and other online interactions and combining it with information collected from offline sources or information we already have, in order to allow access to your account, conduct online transactions and to maintain measures aimed at preventing fraud and protecting the security of account and personal information; Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business.	To comply with our legal and regulatory obligations.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.	For our legitimate interests, i.e. to make sure contacts are being adhered to so we can deliver the best service to you.
To assist you in identifying appropriate resources if we cannot serve you for any number of reasons including, but not limited to, inability to operate in the state of request or lack of eligible debt.	For our legitimate interests or those of a third party, i.e. to make sure we can deliver the best service for you.
Ensuring business policies are adhered to, e.g. policies covering security and internet use.	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you.
Ensuring the confidentiality of commercially sensitive information.	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information. To comply with our legal and regulatory obligations.
For business purposes, including data analysis, audits, developing and improving products and services, enhancing the Site, identifying usage trends and determining the effectiveness of promotional campaigns; Operational reasons, such as improving efficiency, training and quality control.	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you.
Updating customer records, including combining the personal information you provide through our website with personal information we may receive pursuant to our Consumer Privacy Notice.	For the performance of our contract with you or to take steps at your request before entering into a contract. To comply with our legal and regulatory obligations.
Marketing our services and those of our family of companies to: ¾ existing and former customers; ¾ third parties who have previously expressed an interest in our services; ¾ third parties with whom we have had no previous dealings. To provide you with email alerts, newsletters and other notices concerning our products or services, or events or news, that may be of interest to you; To provide a third party with qualified leads for a program that they may administer.	For our legitimate interests or those of a third party, i.e. to promote our business (and the business of select third parties) to existing and former customers.

We may also anonymize, aggregate or de-identify personal information so the end-product does not identify you or any other individual. For example, we may use this information to generate norms by industry, geography, level, etc., enable us to understand where our services are being utilized, conduct ongoing validation studies, compile reports, and improve the services. Such aggregated, anonymized or de-identified information is not considered personal information for purposes of this Privacy Policy and we may use it for any purpose.

8. Who We Share Your Personal Information With

We may share or provide access to personal information with:

Service providers we use to help deliver our products and/or services to you, such as call center operators and corporate credit facility lenders;
Third parties we use to help us run our business, such as marketing agencies or website hosts;
Third parties approved by you, including social media sites you choose to link your account to and appropriate resources we recommend if we cannot serve you for any number of reasons including, but not limited to, inability to operate in the state of request or lack of eligible debt; and
Credit reporting agencies, creditors, credit card companies, collection agencies, banks, and other entities and individuals specifically necessary to effect, administer and perform our services.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you.

We may disclose and exchange information with law enforcement agencies, government agencies in response to subpoenas, court orders or other forms of legal process, and regulatory bodies to comply with our legal and regulatory obligations. We may elect to share information when, in our reasonable judgment, such sharing is necessary or appropriate for the investigation or prevention of illegal activities, including actual or suspected fraud, real or potential threats and for other legal reasons, such as to enforce our legal and contractual rights or to protect our rights, privacy, safety or property or that of our affiliates, you or others.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

9. How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing products or services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements

10. Children and our Site

Our Site is not directed to children, and you may not use our Site if you are under the age of 18. If you are under 18, do not use our services, access the Site, or provide any information about yourself including, without limitation, your name, address, email address or any screen name or user name you may use. If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, in compliance with the Children’s Online Privacy Protection Act, we will purge such information from our database and cancel the corresponding accounts. If you believe we may have any information from or about a child under 13, please see our “How to Contact Us” Section below. Please visit the FTC’s website at www.ftc.gov for tips on protecting children’s privacy online.

11. Keeping Your Personal Information Secure

We use reasonable and appropriate physical, technical, and administrative safeguards to protect your information from unauthorized use, access, loss, misuse, alteration, or destruction. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also require that third party service providers acting on our behalf or with whom we share your information also provide appropriate security measures in accordance with industry standards. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

However, no computer system or information can ever be fully protected against every possible hazard, including when information is transmitted over the internet. As such, COMPANY CANNOT GUARANTEE SECURITY. COMPANY ASSUMES NO RESPONSIBILITY OR LIABILITY FOR DISCLOSURE OF YOUR PERSONAL INFORMATION. WE DO NOT GUARANTEE THAT YOUR PERSONAL INFORMATION WILL NOT BE MISUSED BY THIRD PARTIES. WE ARE NOT RESPONSIBLE FOR CIRCUMVENTION OF ANY PRIVACY SETTINGS OR SECURITY FEATURES.

12. A Note to Users Outside of the United States

Information may be held at our offices and those of our family of companies, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Company is headquartered in the United States and utilizes service providers in the United States. The Site is not intended for Site visitors outside the United States. If you are a non-U.S. user of the Site, by visiting the Site and providing us with data, you acknowledge and agree that your personal information may be processed for the purposes identified in this Privacy Policy. If you choose to access our Site outside the United States, Company and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. In particular, you are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Where the laws of your country allow you to do so, by using the Site or the services or by providing your data, you consent and authorize Company to transfer, store, and use all such personal information in the United States of America (and any other country where we operate) which may not offer an equivalent level of protection to that required in the country where you reside and to the processing of that personal information by us on our servers located in the United States of America, as described in this Privacy Policy. If you do not want your personal information transferred to the United States of America and any other country where we operate, please do not submit any information to us or use our Site or the services.

13.Your Rights and Choices

If you are a resident of California, Colorado, Connecticut, Iowa, Nevada, Vermont, Virginia, or Utah please go to our Privacy Notice Addendum to learn about additional rights you may have under applicable data protection laws.

14. Third Party Websites

If, in your interactions with the Site, you are linked or directed to, or click on, a third party website, including those of our family of companies, we cannot control what information you may provide to that party or on that website, and we are not responsible for how that party may use or disclose any information you may provide to them. This is not as an endorsement by us of any third party website, content that may be offered on such third party website, or of any products or services provided by such third party. We do not control, nor are we responsible for, such third party website, product or service offerings. As such, we urge that you exercise caution before providing them with your personal information and to review the third party’s privacy policy for information on its data processing practice.

You should contact the site administrator for such third party website if you have any complaints, claims, concerns or questions regarding such third party website or its privacy practices.

15. Changes to This Privacy Notice

This Privacy Policy was published on the date “Last Updated” above.

We may change this Privacy Policy from time to time. Changes to this Privacy Policy will be made by updating this page. Please visit this Privacy Policy regularly to read the current version.

16.How to Contact Us

Please contact us by post, email or telephone if you have any questions about this Privacy Policy or the information we hold about you.

If by e-mail: info@GRTFinancial.com

If in writing:

GRT Financial Inc.
26711 Northwestern Hwy., Ste. 375,
Southfield, MI 48033

Privacy Notice Addendum

This Privacy Notice Addendum (“Notice”) supplements the information contained in the above Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California, Colorado, Connecticut, Iowa, Nevada, Vermont, Virginia, or Utah (“consumers” or “you”). We adopt this Notice to comply with the California Shine the Lights law, the California Consumer Privacy Act of 2018 (CCPA), the California Privacy Rights Act of 2020 (CPRA), the Colorado Privacy Act of 2021, the Connecticut Data Privacy Act of 2022, the Iowa Consumer Data Protection Act of 2023, the Nevada Telecommunication Solicitation Act, the Utah Consumer Privacy Act of 2022, the Vermont Fair Credit Reporting Act, the Virginia Consumer Data Protection Act of 2023, and certain other privacy and data protection laws, as applicable (collectively, the “Statutes”). Any terms defined in the Statutes will have the same meaning when used in this Notice. Any terms used in this Notice but undefined herein shall have the meaning provided in the Privacy Policy.

As further set forth in our Privacy Policy, we may collect certain information that is (i) linked or reasonably linkable to an identified or identifiable individual or natural person, or (ii) that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer or household, or (iii) as further defined in the Statutes as “Personal Data” or “Personal Information,” as further set forth below:

1. Notice to Nevada Residents.

We are providing you this notice pursuant to Nevada state law. You may be placed on our internal Do Not Call List by requesting that we cease calling you by contacting us directly and making such request in writing at info@grtfinancial.com. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; Phone number: 702-486-3132; e-mail: BCPINFO@ag.state.nv.us

2. Notices to Vermont Residents.

In accordance with The Vermont Fair Credit Reporting Act, we will not share information we collect about Vermont residents with companies who are not affiliates, except as permitted by law, such as with your consent or to service your accounts. We will not share information about your creditworthiness with our affiliates without your authorization or consent but we may share information about your transactions or experiences with our affiliates without your consent.

3. Personal Information We Sold or Disclosed for a Business Purpose.

In the preceding 12 months, we have not sold for a business purpose to one or more third parties any categories of personal information

In the preceding 12 months, we have disclosed to one or more third parties the following categories of personal information:

Category A – Identifiers
Category B – Customer records information
Category F – Internet or other electronic network activity information

4. Shine the Light Law.

California Civil Code Section 1798.83, also known as the “Shine The Light” law permits individuals who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

5. Your Rights Under the CCPA and CPRA.

The California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA) provides consumers who are California residents with specific rights regarding their Personal Information. This section describes your rights under the CCPA and CPRA and explains how to exercise those rights.:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold, Shared, Disclosed, or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here: https://www.grtfinancial.com/do-not-sell-my-information/.
Right to Limit Use and Disclosure of Sensitive Personal Information.	You have the right to opt-out of the use and disclosure of your sensitive personal information for anything other than supplying requested goods or services. We do not use your personal information for anything other than supplying the requested goods or services.
Right to Correction	You have the right to request correction of inaccurate personal information maintained by us about you. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.
Right to Deletion	Subject to certain exceptions, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

6. Your Rights Under Other State Privacy Laws

Colorado, Connecticut, Iowa, Utah, and Virgina also provide consumers who are residents of these states with certain rights regarding their Personal Data. This section describes the rights you may have under these state privacy laws, under certain circumstances and subject to certain exceptions. Please contacts us if you have any questions about your rights under these state privacy laws.

	Colorado	Connecticut	Iowa	Utah	Virginia
Right to Opt-Out	X	X	X	X	X
Right of Access	X	X	X	X	X
Right to Correction	X	X			X
Right to Deletion	X	X	X	X	X
Right to Data Portability	X	X	X	X	X
Right to Appeal	X	X	X		X

The Right to Opt-Out	You may have the right to opt out of the processing of Personal Data concerning you for the purposes of: Targeted Advertising; The Sale of Personal Data; or Profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. We do not sell Personal Data.
The Right of Access	You may have the right to confirm whether we are processing Personal Data concerning you and to access your Personal Data. Please note, there may be restrictions on how often you may exercise this right.
The Right to Correction	You may have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.
The Right to Deletion	You may have the right to delete Personal Data concerning you or to request that we delete Personal Data provided by, or obtained about, you.
The Right to Data Portability	You may have the right to obtain a copy of your Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. Please note, there may be restrictions on how often you may exercise this right.
The Right to Appeal	We hope that we can resolve any query or concern you raise about our use of your Personal Data. However, if we do not take action on your request to exercise any of your rights, we will inform you without undue delay after the receipt of the request for not taking action. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision. The Colorado Privacy Act also gives you right to contact the Colorado Attorney General if you have concerns about the results of your appeal. The Iowa Consumer Data Protection Act of 2023 also gives you right to contact the Iowa Attorney General if you have concerns about the results of your appeal. The Virginia Consumer Data Protection Act of 2023 also gives you right to contact the Virginia Attorney General if you have concerns about the results of your appeal.

7. How to Exercise Your Rights.

If you would like to exercise any of your rights as described in this Privacy Policy, please:

Complete a data subject request form available on our Site at: https://www.grtfinancial.com/do-not-sell-my-information/
Call us, toll-free, at (800) 811-5721; or
Email or write to us at:
GRT Financial Inc.
26711 Northwestern Hwy., Ste. 375,
Southfield, MI 48033
info@GRTFinancial.com

Please note that there may be restrictions on the number of related data access or data portability disclosure you may request within a 12-month period.

If you choose to contact us to exercise your rights, we will take steps to verify your identity before granting you access to your personal information or complying with your request. In order to help protect your privacy and maintain security, you will need to provide us with:

Enough information to identify you (e.g., your full name, address, email address, telephone number, birth date, or customer or matter reference number));
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

In addition, if you ask us to provide you with specific pieces of personal information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

You may use a representative, called an “authorized agent,” to submit a request to us. An authorized agent means a natural person, or a business entity registered with the California Secretary of State, that you have authorized to act on your behalf.

In order to protect your privacy, Company requires you to confirm that you have provided the authorized agent permission to submit the request and you must provide the authorized agent with signed permission. “Signed” means that the written attestation, declaration, or permission has either been physically signed or provided electronically pursuant to the Uniform Electronic Transactions Act. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but in such cases, consumer verification will not be required. Company may deny a request from an authorized agent that does not submit proof that they have been authorized to act on your behalf. Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.