1. Introduction

KorGrid, LLC, an Arizona limited liability company, ("KorGrid," "we," "us," or "our") provides Infrastructure-as-a-Service solutions, including hosted hypervisors, high-performance storage, networking, and related infrastructure services ("Services"). We are based in Scottsdale, Arizona, and our Services are designed for business customers ("Customers," "you," or "your") and their authorized users ("Authorized Users").

This Privacy Policy explains how we collect, use, share, and protect personal information in connection with the Site, our Services, and related applications and offerings. It also outlines your rights and choices with respect to your personal information.

2. Changes to This Policy

KorGrid may update this Privacy Policy from time to time to reflect changes in business practices, technologies, or applicable legal requirements. The revised version will be posted on our website with a new effective date at the top of the page. All changes become effective when posted, unless otherwise stated.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect personal information. Your continued use of the Services after a revised Privacy Policy has been posted constitutes acceptance of the updated terms.

3. Privacy Officer Contact Information

KorGrid has appointed a Privacy Officer responsible for overseeing this Privacy Policy and ensuring compliance with applicable privacy laws. You may contact our Privacy Officer using the details below:

By Email:	[email protected]
By Mail:	KorGrid, LLC Attn: Privacy Officer 3370 N. Hayden Rd. Suite 123-428 Scottsdale, Arizona 85251

4. Scope and Applicability

This Privacy Policy applies to:

• Visitors to our Site(s) or persons or entities who contact us for information ("Visitors").
• Prospective customers engaging with us for sales or marketing.
• Customers who register for or contract with KorGrid for Services.
• Authorized Users designated by Customers to access the Services.
• Other individuals whose information we collect in the course of providing support, billing, or account management.

(a) Customer Data - This Privacy Policy does not apply to the data, files, or content that our Customers upload, transmit, or process through our Services ("Customer Data"). We handle Customer Data solely on behalf of our Customers, in accordance with our Terms of Service ("Terms") and Data Protection Addendum ("DPA"). Our Customers are responsible for the collection, use, and disclosure of Customer Data within their own environments.

(b) Third Party Services - Our Services may contain links to or integrate with third-party websites, applications, or services. This Privacy Policy does not govern the practices of those third-parties, which are subject to their own privacy policies. By using our Services or visiting our websites, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of information as described herein.

5. Information We Collect

KorGrid collects personal information in several ways, including when it is provided directly by you, when it is generated automatically through your use of our website or Services, and when it is obtained from third parties.

(a) Information You provide to KorGrid directly - We collect personal information that you provide us directly when you:

1. Register for an account or subscribe to our Services
2. Configure or administer your use of the Services
3. Contact us for support or customer service
4. Participate in a survey, marketing activity, or other communication
5. Engage in billing or payment activities

Information you provide directly may include:

• Identifiers such as your name, company name, job title, business email address, phone number, and mailing address.
• Account information such as usernames, passwords, and other authentication details
• Payment and billing details, which are processed securely through third-party providers
• Communications sent to us in the form of support requests, sales inquiries, or other correspondence

(b) Information Collected Automatically - Information collected automatically may include:

• Technical data such as Internet Protocol addresses, browser types, operating systems, and device identifiers.
• Usage data such as pages visited, features accessed, time stamps, and log-in attempts
• System performance and diagnostic information, including error reports and service metrics

Approximate geolocation inferred from Internet Protocol addresses.

(c) Information Received from Third Parties - Information from third parties may include:

• Business contact details obtained from marketing partners and lead generation providers
• Data about Authorized Users that is supplied by our customers
• Interaction information provided by analytics vendors and service providers assisting us in website operations
• Payment processors and financial institutions
• Public or Commercial Sources such as professional networking websites or data enrichment providers, consistent with applicable law

(d) Customer Data Processed on Behalf of Customers - We process Customer Data solely on behalf of Customers and in accordance with our Terms and DPA. We do not use Customer Data for our own marketing or analytics purposes. Customers act as the data controllers for such data under General Data Protection Regulation ("GDPR") and we act as their data processor.

(e) Sensitive Information - We do not intentionally collect or process special categories of personal data, such as health data, racial or ethnic origin, religious beliefs, or biometric data, unless required for specific, lawful, and disclosed purposes authorized by Customer.

In addition to the categories above, KorGrid may create aggregated or anonymized datasets for internal analysis and reporting. Such information does not identify individuals and is not treated as personal information. KorGrid does not intentionally collect sensitive categories of personal data, such as government identification numbers, health records, or biometric identifiers, and requests that customers do not provide such data unless expressly required by contractual terms.

6. How We Use Information

We use the information we collect for the following purposes, in each case, in accordance with applicable data protection laws, to:

(a) Provide and Operate the Services - We may use information to provide and operate the Services, in the following ways:

• To register and manage Customer accounts
• To deliver, maintain, and support the Services and related infrastructure
• To process transactions, billing, and payments
• To respond to inquiries, troubleshoot issues, and provide technical support
• To authenticate users and secure access to accounts and environments

(b) Maintain and Improve Infrastructure - We may use information to:

• Monitor performance, ensure reliability, and protect against outages or attacks
• Analyze usage patterns and optimize capacity planning
• Develop new products, features, or enhancements to existing Services using aggregated or de-identified data where feasible

(c) Communicate with You - We may use information to:

• Send important administrative or service-related notices, such as updates to our terms, security alerts, or account notifications
• Respond to support requests and customer feedback
• Provide information about new features or offerings where permitted by law. You can opt out of marketing communications at any time by following the unsubscribe instructions included in our messages

(d) Ensure Data Security Compliance and Prevent Misuse - We may use information to:

• Detect, investigate, and prevent fraud, abuse, or unauthorized access
• Comply with and enforce our Terms, Acceptable Use Policy, and other agreements
• Meet our legal obligations, such as responding to lawful requests from public authorities

(e) Support Business Operations - We may use information to:

• Manage our internal accounting, audits, and legal processes
• Exercise or defend legal claims
• Plan and conduct potential mergers, acquisitions, or business transfers, in which case appropriate safeguards will apply to personal data

7. Customer Data and Control

Customers remain the sole controllers of the workloads, virtual machines, and data they host on our infrastructure. Customer Data is entirely under the Customer's control. KorGrid does not access, monitor, or use Customer Data except as required to provide and maintain Services, meet contractual obligations, or comply with legal requirements. Customers are responsible for handling privacy requests regarding Customer Data.

8. Purposes and Legal Bases for Processing

KorGrid processes personal information only where a lawful basis exists. The principal purposes include fulfilling contracts, maintaining and securing Services, complying with legal obligations, and engaging in lawful marketing. We rely on contractual necessity when providing Services, managing accounts, and processing payments. We rely on legitimate interests when protecting infrastructure, detecting fraud, analyzing service performance, and improving customer experience. We rely on legal obligations when complying with tax, regulatory, or law enforcement requirements. We rely on consent where required for marketing and promotional communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

Where the GDPR or UK GDPR applies, we rely on the following legal bases for processing personal information:

• Performance of a contract to provide and manage the Services you requested
• Legitimate interests to secure and improve our Services, communicate with Customers, and prevent fraud or misuse
• Legal obligations to comply with applicable laws, such as tax and accounting rules

9. Sharing and Disclosure of Personal Information

KorGrid does not sell or rent personal information. We disclose information only in limited circumstances.

• We may share information with vetted service providers who act on our behalf, including hosting providers, payment processors, and support contractors
• We may share information with affiliates or subsidiaries to facilitate business operations
• We may disclose information to a customer about its own Authorized Users
• We may disclose information to regulators or law enforcement when legally required
• We may transfer information to an acquiring entity in the event of a merger, acquisition, or sale of assets
• We may disclose information when an individual provides consent or directs us to do so

All service providers are bound by confidentiality and contractual obligations to handle information securely.

10. Marketing and Communications

KorGrid may send marketing communications, including information about product updates, promotions, and events. Communications may be delivered by email or other permissible methods. Individuals may opt out at any time by following unsubscribe links or by contacting [email protected]. Customer Data is never used for marketing.

11. SMS Text Messaging

By opting in to or using KorGrid's text messaging service ("Text Message Service"), you agree to the following terms and conditions. This agreement is between you and KorGrid, LLC or one of its affiliates.

The term "Opting In" refers to requesting, joining, agreeing to, enrolling in, signing up for, acknowledging, responding to, or otherwise consenting to receive one or more text messages from KorGrid. The term "Text Message Service" refers to any arrangement in which we send one or more messages to your mobile phone number, including SMS, MMS, or successor protocols or technologies.

By providing your consent, you acknowledge that you have agreed to these terms and that your consent may be documented electronically. You may withdraw your consent at any time by replying "STOP" to a text message.

We respect your privacy in the operation of the Text Message Service. Information you provide will be used solely to transmit messages and to respond to your communications. This may include sharing your information with platform providers, carriers, and vendors that assist in message delivery. We do not sell, rent, trade, or otherwise transfer phone numbers or information collected through this service to third parties for profit. However, we reserve the right to disclose information as required by law, regulation, or governmental request, or to protect our rights and property. This SMS-specific privacy policy supplements the broader KorGrid Privacy Policy and applies only to the Text Message Service.

We do not charge for the use of the Text Message Service, but message and data rates from your carrier may apply depending on your plan. The number of messages you receive will vary depending on how you use the service and whether you initiate further communications, such as by sending a "HELP" request.

If you no longer wish to receive text messages, you may opt out at any time by replying to a message with "STOP", "QUIT", "END", "REVOKE", "OPT OUT, "CANCEL", or "UNSUBSCRIBE". Because this is a conversational service between you and KorGrid representatives, opt-out requests are specific to each conversation and associated phone number. Once you opt out, you may receive a final confirmation message acknowledging your request.

12. Cookies and Similar Technologies

KorGrid and its partners use cookies, pixels, and related technologies to authenticate users, remember preferences, analyze traffic, and measure the effectiveness of our website. Some cookies are essential for the operation of Services, while others support analytics or limited remarketing. You may disable non-essential cookies through your browser or cookie banner preferences, though this may affect the availability of certain features.

13. Data Retention

Personal information is retained only for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations, to resolve disputes, and to enforce agreements. In most cases, personal information associated with a customer account is retained for seven years following termination of the relationship. Customer Data is retained for as long as the Customer's account is active or is needed to provide Services. Upon Termination, as described in our Terms, Customer Data is deleted or returned in accordance with contractual obligations. We may retain certain information if required by law or regulation, for example, to comply with record-keeping obligations, audit requirements, or government requests. In such cases, access to retained information is restricted to authorized personnel only.

For Customers residing in the European Economic Area ("EEA"), the United Kingdom, or another region granting deletion rights, you may request that we delete your personal data at any time, subject to our legal obligations. Customers acting as data controllers are responsible for managing and responding to such data subject requests concerning Customer Data. We may require reasonable authentication before fulfilling deletion requests to protect accounts from unauthorized access.

14. Data Security

KorGrid maintains administrative, technical, and physical safeguards to protect personal information. These measures include encryption of data at rest and in transit, multi-factor authentication for privileged access, segregated networks, continuous monitoring, and restricted access to facilities. While no method of storage or transmission is entirely secure, we continuously evaluate and improve our practices to reduce risks.

15. International Data Transfers

All personal information collected by KorGrid is processed and stored in the United States. Customers outside the United States acknowledge that their information will be transferred to the United States, which may have different data protection standards. Where legally required, KorGrid implements safeguards such as Standard Contractual Clauses.

16. Your Privacy Rights

We respect your privacy rights and provide you with meaningful control over your personal data. Depending on your location and applicable law, you may have certain rights regarding how your personal data is collected, used, and shared.

(a) Privacy Rights in the United States - Residents of certain states, including California, Virginia, and Colorado, may have rights to know what personal information is collected, request access or deletion, request correction of inaccuracies, and opt out of the sale or sharing of information. KorGrid does not sell personal information. We honor legally recognized opt-out signals, including Global Privacy Control.

(b) Privacy Rights in the EEA, United Kingdom, and Switzerland - If you reside in the EEA, the United Kingdom, or Switzerland, you may have rights under data protection laws, including GDPR. These rights include access to personal data, correction of inaccuracies, erasure, restriction of processing, objection to processing, portability of data, and withdrawal of consent. You may also lodge a complaint with a supervisory authority.

(c) Exercising Your Privacy Rights - Requests to exercise rights under this Privacy Policy should be submitted to [email protected]. We may request verification of your identity before fulfilling such requests. We will respond within the timeframes required by law, typically thirty to forty-five days, subject to extensions where necessary. KorGrid will not discriminate against individuals who choose to exercise their rights.

(d) Complaints - If you believe we have not handled your personal data appropriately, you may contact us at any time to seek resolution. If you are located in the EEA or UK, you also have the right to lodge a complaint with your local Data Protection Authority or the UK Information Commissioner's Office.

17. Social Media and Third-Party Links

Our website may include links or plugins that connect to third-party platforms including social media platforms. Interactions with those platforms are subject to their own privacy policies.

18. External Websites

The KorGrid website may contain links to other websites not controlled by us. We are not responsible for the privacy practices of such websites, and we encourage visitors to review the policies of third parties when leaving our website.

19. Incident Notification

If a data breach occurs that affects personal information, KorGrid will notify affected Customers and, where required, regulatory authorities within the legally prescribed timeframes. Such notifications will describe the nature of the incident, actions taken, and steps customers can take to protect themselves.