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This Privacy Policy (“Privacy Policy”) explains how information is collected and used by GGtude Ltd. (“GGtude” or “we”, “us”, “our”).

This Privacy Policy applies to GGtude’s applications for mobile devices (the “App(s)”). By accepting this Privacy Policy, you give us informed consent to collect and process your personal data, and use it as explained in this Privacy Policy.

We are committed to protecting and respecting data privacy. Please read this Privacy Policy carefully.

KEY POINTS OF THE PRIVACY POLICY

The following key points are for your reading convenience and does not substitute the full Privacy Policy below.

  • You may use the App either with or without registering as a user. Upon your initial use of the App you will be asked to provide your age and your preferred username. You may also, at your sole discretion, provide us your gender.
  • Users who wish to register, may do so by using their Apple, Google or Facebook account. Registering with one of these accounts will allow us to collect your account profile information.
  • We will also collect your Device Data and other general data.
  • We will store and process the information we collect about you for the purposes of providing you with our App, developing our App and conducting our research (using aggregated and de-identified information). We will not process the data for other purposes not mentioned in this Privacy Policy without obtaining your prior consent.
  • Your information may be handled by our service providers for the purpose of maintaining the App. We may also share your information with other third-parties, if you chose to do so, and in the event of a merger or acquisition, or if we are required to do so by law or for other legal reasons.
  • We may process your personal information outside your jurisdiction. In such case, we will abide by data transfer rules applicable to these situations.
  • If you are an EU / UK resident, you have certain rights regarding your information, such as the right to access, rectify or delete it. You can exercise your rights by contacting us at privacy@3.78.134.37.
  • We may change this Privacy Policy from time to time, and will inform you of such changes. Your continued use of the App after being notified of the changes, indicates your consent to the new policy.

PERSONAL DATA PROCESSED

We collect and process your age and your preferred username on your initial use of the App. You may also, at your discretion, provide us your gender.

We refer to this as Initial Profile Information.

The App allows users to publicly share their statements or “thoughts” with other users, and to publicly share their progress and experiences through their social media accounts. If you choose to do so, we shall collect, process and share Your Content, via the App or the social media account you used and in accordance with to your preferences.

We refer to this as “Your Content”.

You may choose to register to the App or share Your Content through third party providers, such as Apple, Google, or Facebook (“Third Party Provider Account”). If you registered, logged in to, or shared Your Content through a Third Party Provider Account, we may process your full name, email address and user profile photo.

We refer to this as Registration Information.

Please note that once you register to the App, our system assigns a unique ID to your account, and your email address or name is detached from any other information we collect about you.

Registration is not mandatory. You may choose to use our App as without registering as a user. In that case, you will not be required to provide the above information. However, please note that if you delete the App from your phone and reinstall it, we will not be able to restore your account and the information we previously collected and processed about you.

When you wish to submit a payment for our App through third party providers such as Google Play or Apple App Store, we collect your user profile information on the device and your Account Manager information based on the third party provider’s policy.

We refer to this as Payment Related Information.

We collect general data of your device, such as your country and Unique Device ID (UDID). We collect this information from your device’s components, such as your WiFi, cellular and geolocation components, system clock and Audio/speaker settings.

We refer to this as Device Data.

You can provide us feedback or troubleshooting on social media channels, by posting on any of our online communities such as Facebook, by sending an e-mail to any of our designated addresses, leaving reviews in the app store or any other form of communication. We will process the data you choose to provide, which may include your name, email address and the content of your feedback.

We refer to this as “Feedback Information.

When you use the App, we record and collect through our own internal event tracking system statistical information, such as usage statistics, responses to on screen stimuli, self-assessments and mood tracking, including information about your sleep, level of activity and other related information provided by you.

We refer to this as “Statistical Information”.

HOW YOUR PERSONAL DATA IS USED

We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.

We store and use your Initial Profile Information, Registration Information, Device Data, Your Content, Analytics Information and Statistical Information in order to provide you the functionality of the App, such as allowing you to track your progress and improvements, add your own content or to share Your Content with third party providers if you decide to do so, including by methods of profiling and behavior tracking.

We process your Payment Related Information in order to provide you with additional services and features as purchased through third party providers, such as Google or Apple.

We process the Analytics Information and Feedback Information to assess the App performance, maintain and improve the App efficacy by selecting the best content, visual theme, learning pace and improving the personalization of the App, for quality assurance and for development and enhancement of the App.

We will also use the Analytics Information and Feedback Information to prevent fraud and abuse, resolve disputes, troubleshoot problems, assist with any investigations, and enforce our terms of use for the App.

We process your Statistical Information, which is aggregated and de-identified, to conduct our research, study the results and improve the app efficacy.

WHOM WE SHARE YOUR DATA WITH

We will not share your information with third parties, except in the events listed below or when you provide us your explicit and informed consent.

We will process your Information with the assistance of our service providers, such as Amazon AWS and Google Firebase. Your personal information will be stored under your unique user ID.

These companies are authorized to use your personal information in this context only as necessary to provide you with the App and not for their own business purposes.

We will share your Analytics Information with third party providers, such as Google Analytics, Facebook Ads, and AppsFlyer for tracking and attributing installs of the App and reaching new target audiences. If you make purchases on the App, we will also share your Payment Related Information and Analytics Information with third party providers for tracking and attributing purchases to the App.

At your choice, and in according to your preferences, we may share Your Content via your chosen social media account (including Instagram, Facebook and twitter) and with other users within the App. 

If you have abused your rights to use the App, or violated any applicable law, we will share information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach.

We will share your information if we are required to do so by a judicial, governmental or regulatory authority.

If the operation of our business is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share information only as required to enable the structural change in the operation of the business.

SECURITY AND DATA RETENTION

We will retain your Information for the duration needed to conduct our research and support our ordinary business activities operating the App. Thereafter, we will still retain it as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.

We implement some measures to reduce the risks of damage, loss of information and unauthorized access or use of information, such as SSL and TSL encryption. In any event, these measures do not provide absolute information security. Therefore, although efforts are made to secure personal information, it is not guaranteed, and you cannot expect that the App will be immune from information security risks.

INTERNATIONAL DATA TRANSFERS

We will internationally transfer information in accordance with applicable data protection laws

If we transfer your personal data for processing at locations outside your jurisdiction, we will abide by data transfer rules applicable to these situations.

ADDITIONAL INFORMATION FOR INDIVIDUALS IN THE UK OR THE EUROPEAN ECONOMIC AREA

GGtude is the data controller of the personal information collected via our App

GGtude is the data controller for the purposes of the personal data we collect via the App. We determine the purposes and means of processing that data as part of our App:

GGtude’s contact information

Our contact information is:

GGtude Ltd.

30 Ibn Gvirol Street

Tel Aviv, Israel

Information we collect from you will be processed within Israel, the United States and the European Union.

Because we transfer your information from within Europe to other jurisdictions outside Europe, we will do so done using adequate safeguards consistent with those determined by the EU Commission and the UK Information Commissioner’s Office (ICO).

The legal basis for collecting and processing your Initial Profile Information, Registration Information, Payment Related Information, Your Content, Feedback Information and Statistical Information, is our legitimate interests in providing you with the App and tailoring the App to your preferences.

The legal basis for processing your Analytics Information, Statistical Information and Device Data, is our legitimate interest in providing, maintaining, developing, and enhancing the App.

The legal basis for processing your Statistical Information through our research is our legitimate interest in improving the App efficacy and our business development.

The legal basis for processing your Analytics Information and Registration Information for the purpose of handling instances of abusive use of the App is our legitimate interests in defending and enforcing against violations and breaches that are harmful to our business.

The legal basis for sharing your information with competent authorities, or other third parties, if you violated the law or abused your rights to use the App, is our legitimate interest in protecting our business from abuses and violation of law.

The legal basis for required disclosures of your information to a judicial, governmental, or regulatory authority is our legitimate interest in complying with mandatory legal requirements imposed on us.

The legal basis for us processing your data in the event of a change in our corporate structure is our legitimate interests in our business continuity.

If you are in the EU or the UK, you have the following rights under the GDPR:

Right to Access your personal data that we process and receive a copy of it.

Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.

Right to Withdraw your consent where processing your data is based on consent. Such withdrawal of consent will not impact the data processed on that basis before the withdrawal of your consent.

Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used, and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.

Right to Object,based on your particular situation,to using your personal data on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise of defense of legal claims.

Right to Restrict theprocessing your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the personal data and request instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defense relating to legal claims, or if you object to processing, pending the verification whether our legitimate grounds for processing override yours.

Right to be Forgotten. Under certain circumstances, such as when you object to us processing your data and we have no compelling legitimate grounds to override your objection, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation that we are subject to under laws in EU Member States or for the establishment, exercise or defense of legal claims.

If you wish to exercise any of these rights, contact us at privacy@3.78.134.37.

We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR. For a list of supervisory authorities in the EU, click here.

If you are in the UK, you can lodge a complaint to Information Commissioner’s Office (ICO) pursuant to the instructions provided here.

MINORS

The App is not directed to users under 13

The App is not directed to users under the age of 13. We do not knowingly collect information or data from children under the age of 13 or knowingly allow children under the age of 13 to use the App. Additional age restrictions may apply in your country.

CHANGES TO THIS PRIVACY POLICY

If we change this Privacy Policy, we will make efforts to proactively notify you of such changes

From time to time, we may change this Privacy Policy. If we do so, we will make efforts to proactively notify you of such changes. In any event, the latest version of the Privacy Policy will always be accessible at the bottom of the App screen. Your continued use of the App after being notified of the changes, indicates your consent to the new policy.

Last Update: May 2022.

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