PRIVACY POLICY

Last update: October 15, 2024

This Privacy Policy (this "Privacy Policy") explains grippingreel how our affiliated companies (hereinafter referred to as "we") collect, use, and disclose your personal data. This privacy policy applies to Grippingeel (hereinafter referred to as the "Platform") and related services (collectively referred to as our "Services"), informing you of our policies regarding the collection, use, and disclosure of personal data when you use our Services, as well as your choices regarding that data.

By downloading, accessing, using, and/or interacting with our services, you fully understand how we collect, use, and disclose your personal data as described in this privacy policy. This privacy policy is incorporated by reference into the End User License Agreement ("EULA") and is subject to the terms of the EULA. Capitalized terms used but not defined in this privacy policy shall have the meanings assigned to such terms in our EULA.

This privacy policy will help you understand:

What personal information do we collect and how do we use it

Cookies and similar technologies

How do we entrust third parties to process, share, transfer, and disclose your personal information

How long do we keep your personal information

The security of your personal data

children

Your rights

change

appendix

contact us

1. What personal information do we collect and how do we use it

We provide various articles created based on users' shopping experience and impressions. You don't need to register or log in to access our services. Some products on our website are controlled by third parties, including those located outside the European Union/European Economic Area, and these third parties should be subject to their own privacy policies. We only collect and process your personal data to the minimum extent necessary to achieve the following purposes, based on appropriate legal grounds.

one point one

In order to provide some location-based services, such as teaming up with nearby people, we may collect your IP address, GPS, RFID, and your home address.

The processing activities for this purpose are based on your consent. When you enable this feature, we will seek your consent and you have the right to withdraw your consent at any time.

one point two

In order to improve our services and correct any errors you make during your use, we may collect relevant information when you browse our platform, including but not limited to your behavior data, device information, and network status.

The processing activities for this purpose are based on our legitimate interests and will not override your legitimate rights and interests.

one point three

In order to comply with applicable laws (such as anti-money laundering regulations), we may collect your device and network information.

The processing activities for this purpose are necessary to comply with our legal obligations.

2. Cookies and similar technologies

We use cookies and other similar technologies (such as web beacons, log files, scripts, and eTags) ("cookies") to enhance your experience using the service. Cookies are small files that, when placed on your device, enable us to provide certain features and functions.

You can choose to allow the installation of such cookies or subsequently disable them. You can accept all cookies, or instruct the device or web browser (depending on the situation) to issue a notification when installing cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in the device. However, if you refuse to install cookies, your browsing experience may be interrupted.

3. How do we entrust third parties to process, share, transfer, and disclose your personal information

We may share your personal data with third parties in the following categories in order to provide you with our services

3.1 Affiliated Companies

We are a global company with branches around the world. In order to provide our services, we will share your personal data with our branches based on our respective legal foundations and the data processing agreements we have signed between us.

3.2 Advertising

This type of service allows user data to be used for advertising purposes, displayed on this website in the form of banners and other advertisements, possibly based on user interests.

This does not mean that all personal information is used for this purpose. The information and usage conditions are as follows.

The following services may use cookies to identify users or use behavior redirection technology to display customized ads based on users' interests and behaviors (including those detected outside of this website). For more information, please refer to the privacy policy of the relevant service.

In addition to any opt-out options provided by any of the following services, users can also choose to opt out of third-party services' use of cookies by accessing the Network Advertising Initiative opt-out page.

1 AdSense

Google AdSense is an advertising service provided by Google Inc. This service uses "Doubleclick" cookies to track the usage of this website and users' behavior towards the advertisements, products, and services provided.

Users can decide to disable all Doubleclick cookies by clicking on the following link: google.com/settings/ads/onweb/opt out

Processed personal data: Cookies; Using data

Processing location: Ireland - Privacy Policy - Opt Out

3.3 Data Analysis

In order to better understand and provide more effective services, we may conduct research and analysis on the personal information collected, such as your behavior data on our platform. We may analyze, classify, and segment these personal information. Research and analysis may be presented in a summarized manner.

We may also use third-party service providers to monitor and analyze the usage of our services. These third parties can only access your personal data on our behalf to perform these tasks and have an obligation not to disclose or use it for any other purpose. For more information, please visit our partner's privacy policy here:

(1) Google Analytics:

Google Analytics is a network analysis service provided by Google Inc. ("Google"). Google uses the collected data to track and inspect the usage of this website, write reports on its activities, and share them with other Google services.

Google may use the collected data to contextualize and personalize its own advertising network.

Processed personal data: Cookies; Using data

Processing location: Ireland - Privacy Policy - Opt Out

(2) Google Tag Manager:

Google Tag Manager is a tag management service provided by Google Ireland Limited.

Processed personal data: usage data.

Processing location: Ireland - Privacy Policy.

3.4 Re marketing and Behavioral Positioning

This type of service allows this website and its partners to notify, optimize, and provide advertisements based on users' past usage of this website.

This activity is facilitated by tracking usage data and collecting information using trackers, which is then transmitted to partners who manage re marketing and behavioral targeting activities.

Some services offer remarketing options based on email address lists.

In addition to any opt-out function provided by any of the following services, users can also choose to opt out by accessing the Network Advertising Initiative opt-out page.

Users can also choose to opt out of certain advertising features through applicable device settings, such as device advertising settings on their phone or general advertising settings.

(1) Google Ads Remarketing (Google Ireland Limited)

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited, which links the activities of this website to the Google Ads advertising network and DoubleClick cookies. Users can choose to opt out of Google's use of cookies for personalized advertising by accessing Google's advertising settings.

Processed personal data: Cookies; Use data.

Processing location: Ireland - Privacy Policy - Opt Out.

(2) Utilizing Google Analytics for Remarketing (Google Ireland Limited)

Using Google Analytics for remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited, which connects the tracking activities performed by Google Analytics and its cookies with the Google Ads advertising network and Doubleclick cookies.

Processed personal data: Cookies; Use data.

Processing location: Ireland - Privacy Policy - Opt Out.

3.5 Transportation Optimization and Allocation

This type of service allows this website to distribute its content and optimize its performance using servers located in different countries.

The processing of personal information depends on the characteristics and implementation methods of these services. Its function is to filter communication between this website and the user's browser.

Considering the wide distribution of this system, it is difficult to determine where content that may contain user personal information is being transferred.

1 Cloudflare Cloudflare Inc.

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.

Cloudflare's integration method means that it filters all traffic passing through this website, i.e. communication between this website and the user's browser, while also allowing for the collection of analytical data from this website.

Processed personal data: Cookies; Various types of data specified in the service privacy policy.

Processing location: United States - Privacy Policy.

3.6 Enforcement/Legal Obligations

We may share information necessary for detecting, investigating, and preventing platform cheating and violations of end-user license agreements, solely for the purpose of detecting, investigating, and preventing platform violations.

Public authorities and auditors

Certain personal data should be disclosed to public authorities in accordance with applicable laws, such as tax and customs authorities, auditors, and other regulatory bodies.

3.7 Sale or merger

Acquiring all or a significant portion of our business from third parties. If we sell or purchase any business or merge, we may disclose information to third parties, in which case we will disclose your data to potential buyers of that business. If we sell, purchase, merge or cooperate with other companies or enterprises, or sell some or all of our assets, we may also disclose information to third parties. In such transactions, personal data may be considered as transferred assets. If there are any changes to your personal data ownership or user, we will notify you via email, in app/in-game notifications, and/or notifications on our website.

4. The duration for which we retain your personal information

4.1 How do we determine

We will consider the following factors to determine the retention period of your personal data:

The duration of the contractual relationship with you;

Sensitivity of personal data;

The time that has passed since your last interaction with us;

Safety reasons;

Applicable statute of limitations for litigation;

Ongoing or potential litigation or disputes;

Regulatory or legal obligations to retain personal data.

4.2 The duration for which we retain your personal information

We may retain most of your personal data for the time required to provide you with services or products, or as required or permitted by applicable laws.

When destroying personal data, measures will be taken to prevent the recovery or replication of personal data, and electronic files containing personal data will be permanently deleted using technical methods that prevent file replication.

If the processing and retention period has expired, but for other reasons (including but not limited to the purpose of applicable legal provisions), personal information needs to be retained, then the relevant personal information will be stored and maintained separately from other types of personal information. If you request us to destroy your personal information before the end of its lifecycle (as described in the retention policy above), we will destroy your personal information in accordance with local laws.

5. Security of your personal data

We are committed to maintaining the privacy and integrity of your personal data, regardless of where it is stored. Our group company has established information security and access policies to restrict access to our systems and technology. We also protect data by using encryption and other technical protection measures. Your personal data will continue to be subject to our technical and organizational controls, as well as our policies and procedures (including but not limited to this Privacy Policy).

Unfortunately, transmitting information over the Internet is not completely secure. Although we will take commercially reasonable measures to protect your personal data, we cannot guarantee the security of the information transmitted to our services; Any risks associated with information transmission are solely borne by you.

If a personal data breach occurs, we will notify the competent regulatory authority of the situation no later than 72 hours after becoming aware of it, unless the personal data breach is unlikely to pose a risk to your rights and freedoms. When a personal data breach may pose a high risk to your rights and freedoms, we will promptly notify you of the situation.

6. Children

You hereby declare that you are an "adult" (as defined by applicable laws in your jurisdiction) and have the necessary powers and permissions to access and/or use our services. If you are not an adult, you must obtain the consent of your parents or legal guardian before using the service. Normally, our services are not applicable to children under the age of 16 (this age requirement may vary depending on your country/region and is listed in the table below), and we do not intentionally collect any personal data from such children. Children under the age of 16 should not use or attempt to use our services. If you are under the age of 16, please do not attempt to use our services.

If we become aware that we have unintentionally collected personal data from children under the age of 16, we will take reasonable measures to remove such information from our records. If parents believe that we may have collected any information from children under the age of 16, they can submit a request to the email address listed in the 'Contact Us' section below.

7. Your Rights

7.1 Right to Information

You have the right to receive clear, transparent, and easily understandable information about how we use your personal data and your rights. This is the reason why we provide you with information in this policy.

7.2 Access Rights

You have the right to access your personal data. This way, you can understand and verify whether we are using your personal data in accordance with applicable data protection laws. Please contact us and submit a request to the email address listed in the 'Contact Us' section below.

7.3 Correction Right:

If your personal data is inaccurate or incomplete, you have the right to correct it. If you believe that any other personal data we hold about you is inaccurate, you can change the information that you can modify in the corresponding settings. For information that you cannot change, please contact us via email.

7.4 Deletion Right

This is also known as the 'right to be forgotten', which simply means that when we have no convincing reason to continue using your personal data, you can request the deletion or removal of your personal data. This is not an absolute right to delete; there are exceptions as well.

In the following situations, you may request us to delete the personal data we hold about you:

Do you believe that we no longer need to store such personal information; or

You believe that the personal information we hold about you is being illegally processed by us.

If data protection laws stipulate that we have legitimate reasons to retain personal data (such as to defend legitimate rights or freedom of speech), we may need to retain personal data, but if such a situation exists, we will notify you. If you request us to delete personal data that has been publicly disclosed on the service and there are reasons for deletion, we will take reasonable measures to try to inform others who display personal data or provide links to personal data to also delete these data.

When we consider your request, you may also exercise your right to restrict our processing of your personal data (as described below).

7.5 Right to restrict processing

In certain circumstances, you have the right to request that we cease processing the personal data we hold about you (excluding storage purposes). But please note that if we stop processing personal data, we may use it again if there are legitimate reasons under data protection laws (such as to defend legitimate claims or protect others). As mentioned above, if we agree to cease processing personal data, we will attempt to inform any third party to whom we have disclosed relevant personal data so that they can also cease processing such data.

In the following situations, you may request us to stop processing the personal data we hold about you:

You believe that personal information is inaccurate and we need to verify its accuracy during this period;

You wish to delete personal data because the processing we have carried out is illegal, but you wish us to retain personal data but only store it; perhaps

You wish to delete personal data as it is no longer necessary for our purposes, but you need to store it to establish, exercise or defend legal claims.

7.6 Data Portability Rights

You have the right to obtain and reuse your personal data in different services to achieve your own purposes. For example, if you decide to switch suppliers, this allows you to easily and securely move, copy, or transfer your personal data between our IT system and theirs without affecting its availability.

7.7 Right to object to processing

You have the right to object to certain types of processing, including direct marketing processing (which we only do with your consent).

7.8 Complaint Rights

You have the right to complain to the data protection agency in your country about the way we handle your personal data.

7.9 Right to withdraw consent

If you have agreed to any operation on your personal data, you have the right to withdraw your consent at any time (although doing so does not mean that any operation on your personal data with your consent is illegal). This includes your right to withdraw your consent for us to use your personal data for marketing purposes.

7.10 The right not to be constrained by automatic decision-making

You have the right not to be bound by decisions that have a legal (or similarly significant) impact on you solely based on automated processing (including analysis).

We usually take action upon request and provide information free of charge, but may charge reasonable fees to compensate for the management costs of providing the following information: unfounded or excessive/repetitive requests; Or more copies of the same information. Alternatively, we have the right to refuse to take action based on the request.

Please carefully consider before submitting your request. We will reply as soon as possible, usually within one month after receiving the request, but if processing the request takes longer, we will reply and inform you.

We will also collaborate with third parties who have data interactions with us to ensure your rights in accordance with applicable laws and regulations.

8. Change

If we make any significant changes to this policy, we will publish the updated policy here and notify our users. Please check this page frequently for any updates or changes to this policy.

9. Appendix

9.1 Brazilian Appendix

If you are located in Brazil, you acknowledge that we are subject to the General Data Protection Law (LGPD) of Brazil. If you have any questions, concerns, or complaints about this privacy policy or how we handle your personal data, please contact us as shown in the "Contact Us" section below.

9.2 Colombian Appendix

If you are located in Colombia, you acknowledge that we are bound by the 2012 Statutory Law 1581 (Law 1581). If you have any questions, concerns or complaints about this privacy policy or how we handle your personal data, please contact us at the address shown in the "Contact Us" section below.

9.3 Appendix of Türkiye

If you are located in Türkiye, you acknowledge that we are bound by the Personal Data Protection Act (Law 6698 (LPPD)). If you have any questions, concerns or complaints about this privacy policy or how we handle your personal data, please contact us at the address shown in the "Contact Us" section below.

9.4 Peru Appendix

If you are located in Peru, you acknowledge that we are bound by the Personal Data Protection Law No. 29733 (PDPL) and the PDLP Supreme Decree No. 003-2013-JUS Regulation. If you have any questions, concerns or complaints about this privacy policy or how we handle your personal data, please contact us at the address shown in the "Contact Us" section below.

10. Contact Us

If you would like to file a complaint about the way we handle your personal information, or if you need to contact us for any other reason (including exercising any rights related to the aforementioned personal information), please send your request to: [email protected]