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- OUR APPROACH TO PRIVACY
- GG Technologies Inc. ("StayTouch", "we", "our", or "us") is committed to protecting your privacy. This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies.
- StayTouch operates a service which enables users to effortlessly share business and personal contact and related information with one another via our website at www.staytouch.com and/or mobile applications that we make available from time to time (the "Service").
- This Privacy Policy applies to the Service. Terms used in this Privacy Policy have the same meaning as in our Terms of Use, unless otherwise defined in this Privacy Policy.
- Before accessing or using the Service, please ensure that you have read and understood our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.
- StayTouch is the data controller of the personal information we hold about you.
- PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT
- We collect personal information about you when you voluntarily submit information directly to us when you use the Service. This can include information you provide to us when you register for an account, create or edit your profile on the Service, use a feature or other functionality of the Service that requires us to collect personal information, send messages using the Service, correspond with us by e-mail or otherwise, subscribe to our mailing lists, newsletters or other forms of marketing communications, or respond to a survey or enter a promotion. We may also collect personal information from third parties.
- If you choose not to provide personal information, we may not be able to provide the Service to you or respond to your other requests.
- The table below sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
- We also automatically collect personal information about you indirectly about how you access and use the Service and information about the device you use to access the Service. We typically collect this information through cookies and similar tracking technologies. For more information on cookies and similar technologies we use, please see section 8.
- The table below sets out the categories of personal information collected about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
- We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
- We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Service and developing new products and features. We may also share such anonymised information with others.
Category of information How we use it Legal basis for processing Basic personal details, contact and account information. Such as your name, mobile number, account password and email address. We use this information to allow you to register for an account on the Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely the Terms of Use). We use this information to provide to you the features and functionality of the Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely the Terms of Use). We use this information to send you Service-related emails and messages (for example, account verification, updates to features of the Service, technical and security notices). This processing is necessary for our legitimate interests, namely, administering the Service and communicating with you in connection with the Service. We use this information to send you promotional messages, including email messages and push notifications, from us and from our partners. We will only process your personal information in this way to the extent you have given us consent to do so. Profile information. This is information you choose to put in your profile such as photo, education, work experience, skills, contact information (for example email, phone number or mailing address), and links to social media accounts. We use this information to allow you to populate your profile with relevant information. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely the Terms of Use). We use this information to provide to you the features and functionality of the Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely the Terms of Use). Information collected from or via your device. Such as voice recordings and information contained in your address book and calendar information. With your permission, we: • collect voice notes and request access to the microphone on your mobile device to facilitate the voice notes for the Service; and
• may request access to your contacts or calendar information available on your device or through your email accounts and import or sync contact and calendar information with the Service.
We will only process your personal information in this way to the extent you have given us consent to do so. Information collected from other sources. We may receive information about you from third parties and other users. We may combine this information with the information we collect from you directly. We use this information to enhance or supplement our existing user information, to send you advertising or promotional materials or to personalize the Service, and to better understand the demographics of our users. The processing is necessary for our legitimate interests, namely to tailor the Service to the user and to improve the Service generally. Information received from social networks. If you interact with the Service through a social network, we may receive information from the social network such as your name, profile information, and any other information you permit the social network to share with third parties. The data we receive is dependent on your privacy settings with the social networks. We use this information to authenticate you and allow you to access the Service, as well as to populate your profile with your contact information (such as your name and email address). The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely the Terms of Use). Subscription information. Such as whether you have subscribed for any premium features on our Services.. We use this information to give you access to the premium features you have subscribed for within the Service. The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely the Terms of Use). Chat, photos and videos that you upload to the Service when you use the chat functionality of the Service. We use this information to allow you to share photos, videos and text through the chat functionality on the Service. The processing is necessary for the performance of a contract (namely the Terms of Use). Comments, and opinions. When you contact us directly, for example, by email, phone, mail or by completing an online form, we will record your comments and opinions.. To address your questions, issues and concerns and resolve your customer service issues. The processing is necessary for our legitimate interests, namely communicating with you effectively for the purposes of resolving your issues. Category of information How we use it Legal basis for processing Information about your device and its software, such as your IP address, browser type, Internet service provider,device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier , IDFA or Google AdID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modelling tools, which permit us to recognize and contact you across multiple devices. We use this information to present the Service to you on your device and to enhance and personalize your experience using the Service. The processing is necessary for our legitimate interests, namely to tailor the Service to you. We use this information to monitor and improve the Service, assess the effectiveness of our advertising and/or referral campaigns, and for other internal purposes The processing is necessary for our legitimate interests, namely to improve the Service generally, to monitor and resolve issues, to monitor our advertising campaigns and for other internal purposes. Information about the way you access and use the Service, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take when using the Service. We use this information to present the Service to you on your device and to enhance and personalize your experience using the Service. The processing is necessary for our legitimate interests, namely to tailor the Service to you. We use this information to determine news, alerts and other products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing. We use this information to monitor and improve the Service, assess the effectiveness of our advertising and/or referral campaigns and for other internal purposes The processing is necessary for our legitimate interests, namely to improve the Service generally, to monitor and resolve issues, to monitor our advertising campaigns and for other internal purposes. Information about your location, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate or infer a device’s location by analyzing other information, like an IP address. We use this information to present the Service to you on your device and to enhance and personalize your experience using the Service. The processing is necessary for our legitimate interests, namely to tailor the Service to you. We use this information to determine news, alerts and other products and services that may be of interest to you for marketing purposes. The processing is necessary for our legitimate interests, namely to inform our direct marketing. We use this information to monitor and improve the Service, and for other internal purposes The processing is necessary for our legitimate interests, namely to improve the Service generally, to monitor and resolve issues and for other internal purposes. - MARKETING AND ADVERTISING
- From time to time we may contact you with information about our products and services. Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
- If you do not want to receive marketing messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details. You can change your marketing preferences later by:
- logging into your account on the Service and changing your notification preferences;
- in respect of marketing messages sent via email or text message, by clicking on the “unsubscribe link” (or following other similar instructions) at the bottom of that email, text message, or push notification respectively; and
- in respect of marketing messages sent via push notification, by changing your preferences on your Settings page, by clicking on send notifications tabs on screens such as favourites in your StayTouch contact book, or by emailing us at contact@staytouch.com .
- Where you have given us permission to do so, we may share your contact details with third parties as per your consent so that they can provide you with information about products and services that they believe may be of interest to you.
- If you decide you no longer want us to share your contact details with selected third parties for marketing purposes, you can let us know by emailing us at contact@staytouch.com .
In any event, we may contact you by email or otherwise with important service-related information (including, for example, confirmation of a transaction).
- STORING AND TRANSFERRING YOUR PERSONAL INFORMATION
- Security. We implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers behind firewalls. We will never send you unsolicited emails or contact you by phone requesting your account information, password, or credit or debit card information.
- International Transfers of your Personal Information. The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in including in the United States. These international transfers of your personal information are made pursuant to appropriate safeguards. If you wish to enquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy.
- We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this Privacy Policy.
- RETAINING YOUR INFORMATION
- We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of our legitimate business interests and satisfying any legal or reporting requirements.
- To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.
- YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION
- In accordance with applicable privacy law, in certain circumstances you have the following rights in respect of your personal information that we hold:
- Right of access and portability. The right to obtain access to your personal information along with certain information, and to receive that personal information in a commonly used format and to have it ported to another data controller.
- Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed (including processing undertaken to comply with any of our legal obligations).
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.
- Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information, and to object to processing of your personal information for direct marketing purposes, to the extent it is related to such direct marketing.
- If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.
- You may also update your profile information, such as your company name, job title and profile photo etc. by editing information on your user profile(s) screen(s) and may change some of your data sharing preferences on the Settings page within the Service or by emailing us at contact@staytouch.com . You may also control the Service’s access to your device information through your “Settings” on your device. For instance, you can withdraw permission for the Service to access your address book, location, photo stream, and camera.
- You have the right to lodge a complaint your local data protection authority. If you are based in the EU, information about how to contact your local data protection authority is available at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html.
- DISCLOSURE OF YOUR INFORMATION
- We will share your personal information with the following categories of recipients:
- Other users of the Service. You may share your contact information with others through email, or text, or you may want to invite others to join the Service and add you as a contact. Third parties will only see your name (and company name if you have provided one), until they accept you as a contact. Once the connection is made, a third party will be able to see the information you include in your profile.
- Service providers and advisors. Third party vendors and other service providers that perform services for us, on our behalf, which may include identifying and serving targeted advertisements, providing mailing or email services, tax and accounting services, payments processing, data enhancement services, fraud prevention, web or data and infrastructure hosting, or providing analytic services.
- The public. The public when you provide feedback on the Service. For example, if you post user content on our blog or comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our website or on our social media pages.
- Our companies and brands in the same group of companies as us. Other companies and brands owned or controlled by, and other companies owned by or under common ownership as, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns.
- Purchasers and third parties in connection with a business transaction. Personal information may be disclosed to third parties in connection with a StayTouch-related transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings.
- Law enforcement, regulators and other parties for legal reasons: third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) to enforce our Terms of Use or to protect the security or integrity of the Service; and/or (iii) to exercise or protect the rights, property, or personal safety of StayTouch, our users, or others.
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We may also share information about your device, and information about how you use and
access the Service, with third party providers of analytics tools, such as Google Analytics,
Google Firebase, Facebook Analytics and AppsFlyer. We also use third parties, such as
Branch, to track how users are referred to our Service in order to monitor the effectiveness of
our online marketing campaigns. These providers may combine the personal information
collected through our Service with personal information collected through other websites and
apps. To find out more about how these parties use your personal information, please visit:
- https://policies.google.com/technologies/partner-sites (for Google products);
- b https://www.facebook.com/about/privacy#sharing-partner-information (for Facebook);
- https://www.appsflyer.com/services-privacy-policy (for AppsFlyer); and
- https://branch.io/policies/#phrivacy (for Branch)
- We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
- COOKIES AND SIMILAR TECHNOLOGIES
- The Service uses tracking technologies including cookies, web beacons, embedded scripts, location-identifying technologies and file information (collectively “cookies”). We generally use cookies to distinguish you from other users. This helps us to provide you with a good experience when you use the Service and allows us to improve the Service.
- We use the following types of cookies:
- Strictly necessary cookies. These are cookies that are required for the essential operation of the Service such as to authenticate users and prevent fraudulent use.
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Analytical/performance cookies.
They allow us to recognise and count the number of users and to see how users move around the Service. This helps us to improve the way the Service works, for example, by ensuring that users are finding what they are looking for easily. The service providers that we use to help us do this may enable us to set cookies on your device in order to collect information about your use of the Service. For instance, we may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. To learn more about these cookies and how to opt out of their use, please visit https://policies.google.com/technologies/cookies (for Google Analytics and Firebase cookies), https://www.appsflyer.com/cookie-policy (for AppsFlyer cookies), and https://www.facebook.com/policies/cookies/ (for Facebook cookies) and https://branch.io/policies/#privacy (for Branch.io cookies).
We may also use certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.
- Your choices. The cookies we use are designed to help you get the most from the Service but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our website. These settings will typically be found in the “options” or “preferences” menu of your browser. To understand these settings, the following links may be helpful, otherwise you should use the “Help” option in your browser for more details.
- If you only want to limit third party advertising cookies, you can turn such cookies off by visiting the following links:
- Your Online Choices
( http://www.youronlinechoices.com/ ) - Network Advertising Initiative
( http://www.networkadvertising.org/ ) - Digital Advertising Alliance
( http://www.aboutads.info/consumers ) - Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also be able to opt-out of some — but not all — interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Functionality cookies. These are used to recognise you when you return to the Service. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region). We use the Google Maps API to gather information about your location. Google uses various technologies to determine your location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points, and cell towers (see Google Maps Privacy Policy to learn more).
Targeting cookies. These cookies record your visit to the Service, the pages you have visited and the links you have followed. We will use this information to make the Service and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Third party cookies. Please be aware that advertisers and other third parties may use their own cookies tags when you click on an advertisement or link on the Service. These third parties are responsible for setting out their own cookie and privacy policies.
- LINKS TO THIRD PARTY SITES
The Service may, from time to time, contain links to and from third party websites, including, but not limited to, those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites may be collecting information from you when you are browsing and have their own privacy policies; we do not accept any responsibility or liability for their collection activities or policies. Please check the individual policies before you submit any information to those websites.
- OUR POLICY TOWARDS CHILDREN
- The Service is not directed at children and we do not knowingly collect personal information from children under the age of 16. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.
- CHANGE TO THIS POLICY
We may update this Privacy Policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the “last modified” date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.
- NOTICE TO YOU
If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.
- GOOGLE AUTH
if you link, connect, or login to your StayTouch Account with Google, the Google service may send us information such as your registration, contacts list, calendar list and profile information from that service This information varies and is controlled by Google or as authorised by via your privacy settings managed at your Google Account.
- GOOGLE ACCOUNT INFORMATION MANAGEMENT
You may access and update some of your information through your Account settings. If you have choose to connect your Google account with StayTouch, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping information updated.
- CONTACTING US
- If you have any questions, comments or requests regarding this Privacy Policy, please contact us at privacy@staytouch.com.
- This privacy policy was last modified on 09 July 2020.
