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This Privacy Policy (the “Policy“) describes the types of information that GGtude Ltd. (“GGtude“, “we”, “us”, “our”) collects and processes through the websites: www.ggtude.com and www.ocd.app (the “Website(s)”), and the rights and options available to users of our Website with respect to their personal data.

PERSONAL DATA PROCESSED

You can submit an inquiry through our online contact forms or by other methods provided on the Website. When you submit an inquiry on our Website, you will be asked to provide information such as your name, email address, inquiry type and related app, your device type and the content of your message. The mandatory fields for completion in the form will be marked as such (“Inquiry Information”).

You are not legally obligated to provide any of the above mentioned information; however, if you choose not to provide this information, we may not be able to respond to your inquiry.

If you’d like, you may share your feedback with us, in order to help us improve our platform and services. When you submit your feedback, you will be asked to provide information such as your name, email address, the content of your feedback (“Feedback”).

If you’d like, you may share your statements or “thoughts” with us, in order to support and inspire other users of our Apps. When you submit your thoughts on our “Suggest your own thoughts” page, you will be asked to provide information such as your email address, the topic of Your Content and the suggested thoughts that you want to share (“Your Content”).

You may take, at your sole discretion our OCD self-assessment test in which you shall provide us with your information, such as how much distressed or bothered you are regarding statements that refer to experiences that many people have in their everyday lives, by filing our OCD self-assessment test, in order to examine the possibility of having OCD symptoms (“OCD Test Information”).

When you use the Website, we record and collect certain information about your interaction with the Website, including the IP address from which you access the Website, time and date of access, type of browser used, language used, links clicked, and actions taken while using the Website (“Analytics Information“).

HOW WE PROCESS PERSONAL DATA

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 use your Inquiry Information to contact you about your inquiry and handle and respond to your inquiry.

We will use the Analytics Information for development and enhancement of the Website. We will use the Analytics Information collected via our Website to improve the Website, and the products and services we offer to customers. We also use the Analytics Information to adapt the Websites, their content, our services, and our email communications to users’ preferences. Finally, we will use the Analytics Information to understand the market in which GGtude operates in and for managerial reporting, business planning, expanding the reach of our product offerings and performing audience segmentation.

We may use your Feedback in order to improve our platform and enhance the efficiency and the quality of our services, to understand the market in which GGtude operates in, and expanding the reach of our product offerings and performing audience segmentation.

If you would like, you may choose to share Your Content with other users within the App. If you choose to do so, we shall process Your Content in order to publicly display it within our Apps.

We will use your information to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce this Policy and take other actions otherwise permitted by law.

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 share your personal information with our service providers who assist us with the internal operations of our business and the Website. These companies are authorized to use your personal information in this context only as strictly necessary to provide these services to us and not for their own business purposes. We do not sell your personal information to third parties.

If you have abused your rights to use the Website, or violated any applicable law, we may share your 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 may share Your Content with other users within our Apps if you choose to provide such content at our “Suggest your own thoughts” page. 

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

If the operation of the Website or the 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 your information only as required to enable the structural change in the operation of the Website and the business.

COOKIES

Cookies are text files, comprised of small amount of data, that are saved on your computer or other device (e.g. smartphone, tablet, etc.) when you use the internet and visit various website.

The information that the cookies maintain is read by the Website you visit, during the session of your visit to the Website (these are called ‘session’ cookies), and when you return to visit it again (these are called ‘persistent’ cookies). We also use techniques called web beacons and web pixels for purposes similar to the use of cookies.

We use a cookie control mechanism to provide you with more detailed information about the cookies we use (including their origin, purpose, and expiration dates) on our Websites. It also enables you to control the use of cookies. Click on the Cookies manager button on the bottom of this screen to manage your cookies preferences.

Our Website uses cookies for a number of purposes, as briefly explained below. We allow third parties to place cookies on our Website. These third party cookies are subject to their own terms and policies, not ours. You can review additional information about the specific cookies used in relation to each purpose, through the add-on https://cookiebot.com/

Necessary. Cookies that are strictly necessary for the functioning of the Website. The Website cannot operate properly without these cookies. You can set your browser to block or alert you about these cookies, but some parts of the Website may not function properly.

Statistics. Cookies that help us understand how you and other users interact with our Website by collecting data that does not directly identify you, including third party cookies such as Google Analytics, that track and monitor your use of our Website.

Marketing. Cookies that track your use of the Website and allow a third party to tailor content, both on and off the Website, that it believes is relevant to you.

Other than using the cookies control mechanism, you can always delete the cookies saved on your device through the settings of your computer browser or device. You can also disable cookies for future use through the settings of your computer browser or device.

SECURITY AND DATA RETENTION

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

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

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

GGtude is the data controller

GGtude Ltd. is the data controller for the purposes of the personal data we process via the Website. 

Our physical address is at:

30 Ibn Gvirol Street

Tel Aviv

Israel

Email: privacy@3.78.134.37

The legal basis for collecting and processing your Inquiry Information is our legitimate business interests in responding to your inquiry and developing our customer leads.

The legal basis for collecting and processing your Feedback is our legitimate business interests in improving our platform and the services being provided to you in accordance with the thoughts and feedback you provided.

The legal basis for collecting and processing your OCD Test Information and Your Content is our legitimate interests in providing you the functionality of the Website and the service you asked for.

The legal basis for processing your Analytics information for Website development, enhancement, managerial reporting, business planning, expanding the reach of our product offerings and performing audience segmentation, is our legitimate interest in managing the Website and, business development, planning and expanding the reach our products to new audiences.

The legal basis for processing your Analytics Information and Inquiry Information for the purpose of handling instances of abusive use of the Website 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 Website, 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 sharing your information in the event of a change in our corporate structure is our legitimate interests in our business continuity.

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 using adequate safeguards consistent with those determined by the EU Commission and the UK Information Commissioner’s Office (ICO).

You have the following rights:

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 use 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. You may also object at any time to the use of your personal data for direct marketing purposes.

Right to Restrict theprocessing of 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 Privacy 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, 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, please 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 the 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. You can file a complaint with the supervisory authority, in particular in the Member State of your residence, place of work or place of an alleged infringement of the GDPR. For a list of supervisory authorities in the European Economic Area, 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 Website is not directed to users under 13

The Website 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 Website. 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 Policy. If we do so, we will make efforts to proactively notify you of such changes. In any event, the latest version of the Policy will always be accessible on the Website at http://3.78.134.37/website-privacy-policy/

Last Update: May 2022.

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