Privacy policy

1. Do We Collect Information From Minors?

In Short: We do not knowingly collect data from or market to persons under the age of consent in their country.

We do not knowingly solicit data from or market to any person under the age of consent in their country. By using our Services, you represent that you are at least of the age of consent in your country or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users under the age of consent in their country has been collected without the consent of their parent or guardian, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from persons under the age of consent, please contact us at privacy@gippea.com.

2. What Information Do We Collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us such as your email address, your social connection details and your profile name.

We collect personal information that you voluntarily provide to us when registering to use our Services, expressing an interest in obtaining information about us or our Services, when participating in activities in our Services (such as sharing 'Experiences' in our online forums) or otherwise contacting us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the features you use. The personal information we COLLECT can include the following:

Contact Data. We collect your email address, social connection details and may collect your profile name.

Information automatically collected

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit and use our Services.

If you use our Services, we may also collect the following information:

• Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our services, to provide location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera, sensors, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

Information collected from other Sources

In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

We may obtain information about you from other sources, such as joint marketing partners, as well as from other third parties. Examples of the information we may receive from other sources include: your name, gender, birthday, email, current city, state and country and any other information that you choose to make public.

3. How Do We Use Your Information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual Purposes"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

• To facilitate account creation and logon process (with your Consent).
• To send administrative information to you for Business Purposes, Legal Reasons and/or possibly Contractual Purposes. We may use your personal information to send you Service and new feature information and/or information about changes to our terms, conditions, and policies.
• Deliver targeted advertising to you for our Business Purposes. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For more information, see our Cookie Policy.
• Request Feedback for our Business Purposes and/or with your Consent. We may use your information to request feedback and to contact you about your use of our Services.
• To protect our Services for Business Purposes and/or Legal Reasons. We may use your information as part of our efforts to keep our Services safe and secure (for example, for misrepresentation monitoring and prevention).
• To enable user-to-user communications with your consent. We may use your information in order to enable user-to-user communications with each user's consent.
• To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and/or possibly Contractual Purposes.
• To respond to legal requests and prevent harm for Legal Reasons. If we receive a court order or other legal request, we may need to inspect the data we hold to determine how to respond.
• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, marketing and your experience.

4. Will Your Information Be Shared With Anyone?

In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We only share and disclose your information in the following situations:

• Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, (including, but not limited to, in response to public authorities to meet national security or law enforcement requirements).
• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
• Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology in our Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you use the Services. These companies may use information about your usage of our Services and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookie Policy for further information.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
• With your Consent. We may disclose your personal information for any other purpose with your consent.
• Other Users. When you share personal information (for example, by posting your 'Experiences', comments, contributions or other content in the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly distributed outside the Services in perpetuity. If you interact with other users throughout our Services, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

5. Do We Use Cookies And Other Tracking Technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Policy.

6. Do We Use Google Maps?

In Short: Yes, we use Google Maps for the purpose of our map functionality in our Services.

Our Services use Google Maps APIs. You may find the Google Maps Terms of Service here https://maps.google.com/help/terms_maps/. To better understand Google's Privacy Policy, please refer to this link.

By using our Maps API Implementation, you agree to be bound by Google's Terms of Service. By using our implementation of the Google Maps APIs, you agree to allow us to gain access to information about you including personally identifiable information (such as email address) and non-personally identifiable information (such as location). We will be collecting the following information: "identifiers", "protected characteristics", "commercial information", "geolocation data", "internet or other electronic network activity information", and "audio, electronic, visual, or similar information", and "inferences drawn from any of the above information categories".

For a full list of what we use information for, please see the previous sections titled "How Do we Use Your Information" and "Will Your Information Be Shared With Anyone." You agree to allow us to obtain or cache your location. You may revoke your consent at anytime. We use information about location in conjunction with data from other data providers.

The Maps APIs that we use store and access cookies and other information on your devices. Please see our Cookie Policy here for more information.

7. Is Your Information Transferred Internationally?

In Short: We may transfer, store, and process your information in countries other than your own.

We operate internationally and provide our Services to Gippea users worldwide allowing them to share information and communicate with each other across the globe. That means that your personal information may need to be processed in countries where data protection and privacy regulations may not offer the same level of protection as in your home country. We store and process your personal information on our and our service providers' servers, which may be located all over the world, including but not limited to the United States, Asia, Europe (including Russia), Australia and Brazil. We have appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the safeguards in place, please contact us at the details below.

We have implemented Standard Contractual Clauses: Such measures implementing Standard Contractual Clauses for transfers of personal information between us and our third-party providers, which require all such recipients to protect personal information that they process in accordance with data protection laws. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

8. What Is Our Stance On Third-Party Websites?

In Short: We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our Services.

The Services may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites. You should review the policies of such third parties and contact them directly to respond to your questions.

9. How Long Do We Keep Your Information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us keeping your personal information for longer than a period of 2 years past the termination of your account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

10. How Do We Keep Your Information Safe?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

11. What Are Your Privacy Rights and Specific Location Practices: California, EEA residents?

In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

California Privacy Rights

Residents of the State of California can request a list of all third-parties to which our Services have disclosed certain personal information (as defined by California law) during the preceding year for those third-parties' direct marketing purposes. If you are a California resident and want such a list, please contact us at privacy@gippea.com. For all requests, please ensure you put the statement "Your California Privacy Rights" in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information to allow us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or are not sent properly, or that do not have complete information. Gippea does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

California Consumer Privacy Act (CCPA) requires disclosing the collection of personal information by reference to specific categories listed in the statute. The categories of information that we may collect directly from you include "identifiers" and "protected characteristics". The categories of information that we may automatically collect from you through the use of cookies and similar technologies include "identifiers", "geolocation data", "commercial information", "audio, electronic, visual, or similar information", and "internet or other electronic network activity information". For more details and the information that we may collect from other sources please see sections "What Information Do We Collect", "How Do We Use Your Information" and "Will Your Information Be Shared With Anyone" above.

We may also make the following processing which may amount to a sale of your personal information: we may transfer the advertising ID of your device to third party advertisers, along with your age (if we have it), IP address, device characteristics, for them to place tailored ads on our service. If you wish to avoid this you can simply send us a "Do Not Sell My Personal Information" request at any time by sending an email to privacy@gippea.com.

California residents may have the following rights under the CCPA: right to access your personal information, right to deletion, right to disclosure, right to opt out of sales, and right to be free from discrimination.

If you reside in California please contact us by email at privacy@gippea.com to exercise your rights. We may require additional information from you in order to honor your request and we may decline your request as permitted under applicable law.

EEA Privacy Rights

If you use our services from the EEA, you have certain rights regarding your personal information, subject to local law. These include the following rights to: access your personal information, rectify the information we hold about you, erase your personal information, restrict our use of your personal information, object to our use of your personal information, receive your personal information in a usable electronic format and transmit it to a third party (right to data portability), lodge a complaint with your local data protection authority. If you would like to exercise such rights, please contact us at privacy@gippea.com. We will contact you if we need additional information from you in order to honor your requests.

We must have a legal basis to process your personal information. In most cases the legal basis will be to fulfill our contractual obligations to you, for example:

1. to provide the Services,
2. where you have given your consent to the processing,
3. to comply with our legal obligations,
4. as explained above to meet our legitimate interests,
5. to understand how you use our Services and to enable us to derive knowledge from that (which allows us to develop new Services),
6. to personalise the service for you and the ads you see,
7. for fraud and spam prevention,
8. to protect the vital interests of the data subject or of another natural person,
9. the necessity for the performance of a task to be carried out in the public interest.

When we process personal information to meet our legitimate interests, we put in place safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

We may obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to Cookies and Tracking Technologies or when we process location data for purposes other than performing the service). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice or by changing the setting within your browser or App. We encourage you to contact us by email on privacy@gippea.com. Gippea Limited is the controller of data we collect and process according to this privacy policy. We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your data protection authority or to the UK's Information Commissioner's Office (ICO).

12. Do We Use Cookies And Similar Technologies?

In Short: Yes, most Web browsers and Apps are set to accept cookies by default.

If you prefer, you can usually choose to set your browser or Phone Settings to remove cookies and/or reject cookies. If you choose to remove cookies or reject cookies, this could affect how our Services operate. For further information, please see our Cookie Policy.

13. Do We Make Updates To This Policy?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

14. How Can You Contact Us About This Policy?

If you have questions or comments about this policy, email us at privacy@gippea.com or by post to: