Privacy Policy
Last updated 17th June, 2024
Introduction
We at Grand Teton Systems Inc. respect your concerns about privacy.
This Privacy Notice (the “Privacy Notice”) describes the types of personal information we collect, use, store, and disclose through your accessing and using the website and any services available at https://ftxcreditor.com (together referred to as the “Services”). The notice also describes the measures we take to safeguard personal information. In addition, we tell you how you can ask us to access, change, or delete personal information we maintain about you, as well as answer questions you may have about our privacy practices.
This Privacy Notice is not a contract and does not create any contractual rights or obligations.
If you are interested in how we use cookies and you can change your cookies choice, please go to section “Cookies and Automatically Collected Data.”
What Types of Personal Information We Collect
For purposes of this Privacy Notice, “Personal Information” means any information directly or indirectly relating to an identified or identifiable individual. Personal Information may not include de-identified or aggregate information, certain publicly available information, or information covered by other legal frameworks.
In providing the Services, we have collected the following types of personal information:
- Identifiers (such as name, postal address, date of birth, Internet Protocol (IP) address, email address, account name)
- Internet or other electronic network activity information (such as information regarding your interaction with the Services, IP address, device type, operating system, browser type, browser settings, language settings, dates and times of connecting to a website, technical communication information, username, password, cookies, usage data)
- Geolocation data
- Sensitive Personal Information (such as social security number, government-issued identification information, 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)
Additionally, we may collect any other information that you choose to share with us on the Services.
*When we process Special Categories of Personal Information, our legal basis is compliance with applicable law; detection and prevention of crime; establishment, exercise or defense of legal rights; to fulfill a contract; or explicit consent.
We do not sell any Personal Information to third parties, nor do we share Personal Information for targeted advertising with third parties (and have not done so in the preceding 12 months or otherwise).
How and Why We Collect and Use Personal Information
We collect Personal Information from a variety of sources, including:
- Directly from you when you provide it to us or to others through the Services. This includes information you enter into web forms or chatbots, information you provide in phone calls or virtual screen- sharing sessions, and contracts or other content you submit to the Services.
- Indirectly from you (such as interactions with the Services)
- From FTX claims management providers
- Publicly available sources.
We collect and use Personal Information for, among other reasons:
- Communicating with you
- Providing you with or otherwise facilitating the Services, or specific products or services requested through the Services
- Authenticating use, detecting potential fraudulent use, and otherwise maintaining the security of the Services
- Developing, testing, improving, and demonstrating the Services
- Carrying out our legal and contractual obligations and enforcing our rights, including tax preparation, billing and payment processing.
- Evaluating, purchasing, effectuating transfers of, and managing FTX claims, including conducting KYC diligence
- Managing business relationships and administering customer relationships, including billing, accounting, invoicing, payment, collections, and support services
- Providing information relating to our services either in response to specific requests or generally to develop our business
- Meeting our legal and regulatory obligations
- Preventing, detecting, and responding to fraud or potential fraud or other illegal activities
- Anonymizing and aggregating information for analytics and reporting
- Short-term transient use, as defined in the California Consumer Privacy Act
- Training and quality assurance
- For any other purpose with your consent
To Whom We Disclose Personal Information
We may retain other companies and individuals to perform functions on our behalf. Such third parties may be provided with access to Personal Information to perform the functions for which they have been retained. Our agreements with these third parties will describe the purpose of the processing, will not permit them to use Personal Information for any purposes other than as is required to perform the function for which they have been retained, and will commit them to comply with applicable data privacy standards. We also enter into data processing agreements and model clauses with our vendors and clients whenever required and appropriate.
Third parties to whom we disclose Personal Information may include, but are not limited to:
- FTX claims management providers
- Providers of data services such as website hosting, data hosting, and SaaS tools
- Outsourced IT
- Financial institutions
- Professional services providers
- Shipping or direct mail organization
- Auditors and professional advisers
- Insurers
- Regulators and public bodies, including in connection with tax and VAT payments, compliance with obligations relating to the prevention and reporting of financial crime and compliance with other applicable laws
We may also disclose any information, including Personal Information, as we deem necessary, in our sole discretion, to comply with a subpoena, any applicable law, regulation, legal process, or governmental request.
Cookies and Automatically Collected Data
As you navigate through and interact with our website and the Services, we may ask your consent to use cookies, which are small files placed on the hard drive of your computer or mobile device, and web beacons, which are small electronic files located on pages of the website, to collect certain information about your equipment, browsing actions, and patterns. The data automatically collected from cookies and web beacons may include information from your web browser (such as browser type and browser language) and details of your visits to our website, including traffic data, location data and logs, page views, length of visit and website navigation paths as well as information about your device and internet connection, including your IP address and how you interact with the Services. We collect this data in order to help us improve our website and the Services. The information we collect automatically may also include statistical and performance information arising from your use of our Services and website. This type of data will only be used by us in an aggregated and anonymized manner. You can disable/delete the cookies set by our website; please find the appropriate instructions by following these links on how to implement the deletion in different browsers:
- For Google Chrome browser please refer to this instructions
- For Firefox browser please look up here
- For Safari browser please visit
- For Internet Explorer browser please refer here
How to Manage Your Personal Information
You may manage your Personal Information by making certain choices. If you believe that any Personal Information you have provided to us is out-of-date or inaccurate, you may review and correct such information if it is within your online account by logging in at any time or Contact Us. You may also have additional rights detailed below depending on where you live. As a security precaution, we may need to request information from you to help us confirm your identity when exercising a right related to your Personal Information.
Children Under 16
Our Services are not intended for children under 16 years of age, and we do not knowingly collect Personal Information from children under 16. If you are under 16, do not use or provide any information on the Services, register, or make any purchases. If we learn we have collected or received Personal Information from a child under 16 without verification of parental consent, we will delete it. If you believe we might have any information from or about a child under 16, please Contact Us using one of the methods specified below.
Jurisdiction Specific Notices
Additional Notice to California Residents
We collect the Personal Information identified in Section 1, which falls into the following categories of Personal Information according to the California Consumer Privacy Act:
- Identifiers
- Internet or other electronic network activity information
- Geolocation data
- Sensitive Personal Information
As described in more detail in Section 2, we collect Personal Information from the following categories of sources:
- Directly and indirectly from you
- Service providers
- Companies with public websites
- Government entities
We disclose the following categories of Personal Information for the business or commercial purposes identified above in Sections 2 and 3 with the following categories of third parties in the 12 months preceding the date this Global Privacy notice was last modified:
Here is the information from the table converted into a bulleted list:
-
Identifiers
- Service providers
- Other parties directly involved in any transactions related to your use of the Services
- Operating systems and platforms
-
Internet or other electronic network activity information
- Service providers
- Operating systems and platforms
- Other parties directly involved in any transactions related to your use of the Services
-
Geolocation data
- Service providers
- Other parties directly involved in any transactions related to your use of the Services
-
Sensitive Personal Information
- Service providers
- Other parties directly involved in any transactions related to your use of the Services
We do not sell any Personal Information to third parties, nor do we share Personal Information for targeted advertising with third parties (and have not done so in the preceding 12 months or otherwise).
If you are a resident of California, you have the right to: (1) request that we disclose what Personal Information we collect, use, disclose, and sell; (2) request deletion of Personal Information, subject to certain exceptions; (3) request that we correct inaccurate or incomplete Personal Information; (4) opt-out of the sale of Personal Information; (5) opt-out of the “sharing,” or disclosing Personal Information for the purposes of cross-context behavioral advertising, and (6) not receive discriminatory treatment by us for exercising these rights.
Requests to Know
You have the right to request that we disclose the following information:
- Specific pieces of Personal Information we have collected about you;
- Categories of Personal Information we have collected about you, disclosed about you for a business purpose, or sold;
- Categories of sources from which the Personal Information is collected;
- Categories of third parties with whom we share or to whom we sell Personal Information; and
- The business or commercial purpose for collecting, selling, and sharing Personal Information.
We do not have actual knowledge that we sell or share the Personal Information of consumers under the age of 16.
We do not use or disclose sensitive personal information for purposes other than those specified in Cal. Civ Code § 1798.121.
Exercising Your Rights
To make such a request, please follow the instructions in Section "Exercising Your Rights" below.
“Shine the Light” Request
California residents may also have the right to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please Contact Us.
Additional Notice to Certain Other U.S. Residents
following rights. Specifically, these states include Nevada, Virginia, Colorado, Connecticut, Utah, and Iowa. These rights are based on verifiable residency status, and we reserve the right to honor your request to exercise these rights based on your residency. You may have the right to request the following: (1) that we disclose and provide a copy of what Personal Information we collect, use, disclose, and sell; (2) that we delete your Personal Information, subject to certain exceptions; (3) that we correct inaccurate or incomplete Personal Information; (4) opt-out of the sale of Personal Information; (5) opt-out of targeted advertising; (6) opt out of profiling in furtherance of decisions that produce legal or similarly significant effects about you, and (7) not receive discriminatory treatment by us for exercising these rights.
To make such a request, please follow the instructions in Section "Exercising Your Rights" below.
If you are appealing our decision, please email us following the instructions in the below section, Contact Us, and reference and/or attach information to identify your original request. In order to verify your request, we may require you to provide additional information to confirm your identity.
Additional Notice to European Economic Area (EEA) and United Kingdom Residents
Where we need to collect Personal Information by law or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but will notify you first.
We rely on the following lawful bases to process your Personal Information for these non-exhaustive purposes:
- Consent. We may obtain your consent to process your Personal Information in certain circumstances, which may include when you seek to transfer an FTX claim, you elect to receive information from us, or you Contact Us to register an interest in our Services or company.
- Performance of a Contract. We rely on this lawful processing ground when we process your Personal Information to perform a contract which we have with you, or when we take steps in anticipation of entering into a contract with you, for example in connection within the provision of our Services to you and the management of our relationships with third parties.
- Compliance with a Legal Obligation. We rely on this lawful processing ground when we process your Personal Information to meet legal and regulatory obligations which apply to us.
- Legitimate Interests. We rely on this lawful processing ground when we process your Personal Information to provide our Services, to respond to specific requests, to manage our business operations, to manage our relationships with you and with third parties in connection with our business, and when we provide you with information in relation to our Services which we believe may interest you.
If you wish to have more information regarding the legitimate interests assessments we have conducted in order to reach these conclusions, please Contact Us.
For information about how users based in the EEA and United Kingdom can object to our automated decision-making, see Manage Your Personal Information. For more information, please Contact Us.
If you live in the EEA or United Kingdom, we may transfer Personal Information to countries for which adequacy decisions have been issued, and use contractual protections for the transfer of Personal Information to third parties, such as an intra-company agreement or the European Commission’s Standard Contractual Clauses or their equivalent under applicable law.
You may Contact Us to obtain a copy of the safeguards we use to transfer Personal Information outside of the EEA or United Kingdom.
If you live in the EEA or United Kingdom, you may have the right to (1) request access to, rectification, or erasure of your Personal Information or restrict the processing of your Personal Information; (2) object to processing; (3) data portability (receive and transfer your Personal Information); (4) lodge a complaint with a supervisory authority; and, (5) where processing of your Personal Information is based on consent, withdraw your consent at any time without affecting the lawfulness of the processing of Personal Information that occurred before you withdraw consent.
To make such a request, please follow the instructions in Section "Exercising Your Rights" below.
Additional Notice to Canada Residents
We may use service providers located outside of Canada, including, without limitation, in the United States of America, to process Personal Information, and may transfer your Personal Information to such service providers for this purpose. When your Personal Information is processed outside of Canada, it will be subject to the laws of the countries where the information is processed and may be accessible to law enforcement and national security authorities of those countries in accordance with their laws.
You may Contact Us to obtain information about our policies and practices regarding the use of service providers located outside of Canada.
If you live in Canada, in addition to the other rights you may have hereunder, you may have the right to (1) request access to, review and to correct inaccuracies or omissions in your Personal Information; (2) to withdraw consent for collection, use or disclosure of, or to request deletion of, your Personal Information (provided that, if you do so, we may no longer be able to provide services to you that rely on such Personal Information); (3) to ask questions about our policies and practices, and to lodge complaints about our compliance with them with us or with regulatory authorities; and (4) for Quebec residents, to request an electronic copy of the Personal Information you have provided to us in a structured and commonly used technological format.
To make such a request, please follow the instructions in Section "Exercising Your Rights" below.
Exercising Your Rights
To make a request, please Contact Us by email, or submit the request through your account with us. In order to verify your request, we may require you to provide additional information to confirm your identity.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. To make a request on your behalf, an authorized agent may Contact Us by email with proof of your written and signed permission to do so. Note that we may also require you to verify your identity and confirm that you gave permission.
How We Protect and Retain Personal Information
We have appropriate physical, technical, and administrative safeguards in place to protect information you provide to us in connection with the Services from loss, misuse, unauthorized access, disclosure, alteration, or destruction. You should keep in mind, however, that no Internet transmission is ever 100% secure or error-free. While we do take steps to protect your information, we encourage you to also take precautions to protect your personal information. For example, please be careful when sending us personal information by email, as email is not always a secure means of transferring information. Moreover, where you use passwords, ID numbers, or other special access features to access our website, it is your responsibility to safeguard them.
We retain your personal information for only as long as we need it to provide the Services, operate our business, and comply with our legal obligations. When we decide how long to keep your personal information, we keep in mind the nature and sensitivity of the information, the potential harm from unauthorized use, the reasons we collected the personal information, and our legal obligations.
Changes In Our Privacy Practices
We are always improving, and as a result, our policies and practices will continue to evolve. As we implement new practices and services that impact this notice, we will update it, and any changes will take effect upon posting. We encourage you to refer to this page on an ongoing basis for our most current notice and practices. If the changes are material, we will make an effort to notify you before those changes take place.
Contacts and Requests
If you have any questions about our Privacy Notice or applicable rights, please feel free to contact us using one of the following methods:
Grand Teton Systems Inc
125 S King Street,
Suite 2A,
Jackson WY 83001-1045
PO BOX 1045 Jackson,
WY 83001,
USA
Email: claims@ftxcreditor.com
