OUR COMMITMENT TO YOU
At GinaLabs, your privacy is a top priority. Your privacy is at the core of the way we design and build the services and products you know and love so that you can fully trust them and focus on building your wealth.
We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design, and others to make sure that no decision is taken without respect for your privacy.
We strive to be transparent in the way we process your data. Because we use many of the same online services you do, we know that insufficient information and overly complicated language are common issues in privacy policies. We have written our Privacy Policy and related documents in plain language. We actually want you to read our policies and understand our privacy practices.
We work hard to keep your information secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.
PRIVACY POLICY
GinaLabs (“we,” “us” or “our”) appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used, and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.
The company that is responsible for your information under this Privacy Policy (the “data controller” in the European Union) is:
GinaLabs
Warsaw
POLAND
2. WHERE THIS PRIVACY POLICY APPLIES
This Privacy Policy applies to websites, apps, events, and other services and products operated by us. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on applicable services.
Some services may require their own unique privacy policy. If a particular service has its own privacy policy, then that policy – not this Privacy Policy – applies.
3. INFORMATION WE COLLECT
It goes without saying, we can’t help you develop meaningful trading without some information about you, such as your date of birth, address, gender, occupation, and contact information such as telephone, email address, and other contact details you may provide to us. We also collect Identity information such as your photo IDs, proof of address documents, and any other documents you may provide to us. We collect information generated as you use our services, for example, access logs, as well as information from third parties. If you want additional info, we go into more detail below.
Information you give us
You choose to give us certain information when using our services. This includes:
- When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your gender and date of birth.
- When you subscribe to a paid service or make a purchase, you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.
- When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions, and testimonials.
- When you choose to participate in our promotions, events, or contests, we collect the information that you use to register or enter.
- If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.
- If you ask us to communicate with or otherwise process information about other people, we collect the information about others that you give us in order to complete your request.
Information we receive from others
In addition to the information you provide us directly, we receive information about you from others, including:
- Other Users
Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you. - Social Media
You may be able to use your social media login (such as Facebook Login) to create and log into your GinaLabs account. This saves you from having to remember yet another username and password and allows you to share some information from your social media account with us. - Other Partners
We may receive info about you from our partners, for instance where GinaLabs ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).
Information collected when you use our services
When you use our services, we collect information about which features you’ve used, how you’ve used them, and the devices you use to access our services. See below for more details:
- Usage Information
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on). - Device information
We collect information from and about the device(s) you use to access our services, including:- hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device’s settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
- information on your wireless and mobile network connection, like your service provider and signal strength;
- information on device sensors such as accelerometers, gyroscopes, and compasses.
- Other information with your consent
If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth, or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.
Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video, or streaming on the services).
4. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES
We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns) and how you can better control their use, through your browser settings and other tools.
5. HOW WE USE INFORMATION
The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.
To administer your account and provide our services to you
- Create and manage your account.
- Provide you with customer support and respond to your requests.
- Complete your transactions.
- Communicate with you about our services, including order management and billing.
To ensure a consistent experience across your devices
- Link the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices, or by using partial or full IP addresses, browser versions, and similar data about your devices to help identify and link them.
To provide our new services to you
- Register yourself and display your profile on new features and apps.
- Administer your account on these new features and apps.
To serve you with relevant offers and ads
- Administer contests, discounts, or other offers.
- Develop, display, and track content and advertising tailored to your interests on our services and other sites.
- Communicate with you by email, phone, social media, or mobile device about products or services that we think may interest you.
To improve our services and develop new ones
- Administer focus groups and surveys.
- Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior).
- Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
To prevent, detect, and fight fraud or other illegal or unauthorized activities
- Perform data analysis to better understand and design countermeasures against these activities;
- Retain data related to fraudulent activities to prevent recurrences.
To ensure legal compliance
- Comply with legal requirements.
- Assist law enforcement.
- Enforce or exercise our rights, for example, our Terms of Use.
To process your information as described above, we rely on the following legal bases:
- Provide our service to you.
Most of the time, the reason we process your information is to perform the contract that you have with us.
- Legitimate interests.
We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection, and other legal purposes.
- Consent.
From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.
6. HOW WE SHARE INFORMATION
Since our goal is to help you make meaningful trading we share some users’ information with service providers and partners who assist us in operating the services and, in some cases, legal authorities. Read on for more details about how your information is shared with others.
- With our service providers and partners.
We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, and security operations. We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners. The providers of such services do not have access to certain personal data provided by users. The providers only have access to data that is necessary and relevant.
- For corporate transactions.
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.
- When required by law.
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government/law enforcement investigation, or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
- To enforce legal rights.
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
- With your consent or at your request.
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy.
7. CROSS-BORDER DATA TRANSFERS
The sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguards to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.
8. YOUR RIGHTS
We want you to be in control of your information, so we have provided you with the following tools:
- Access / Update tools in the service.
Tools and account settings that help you to access, rectify, or delete information that you provided to us and that’s associated with your account directly within the service. If you have any question about those tools and settings, please contact our customer care team for help.
- Device permissions.
Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
- Deletion.
You can delete your account by using the corresponding functionality directly on the service.
We want you to be aware of your privacy rights. Here are a few key points to remember:
- Reviewing your information.
Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability, or variations of those terms). You can request a copy of your personal information by putting in such a request.
- Updating your information.
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please contact us.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, that we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property.
Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.
- Uninstall.
You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.
- Accountability.
In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work, or where we are established.
9. HOW WE PROTECT YOUR INFORMATION
We work hard to protect you from unauthorized access to or alteration, disclosure, or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage, and processing practices to update our physical, technical, and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately.
10. LINKS TO OTHER SITES
Where we provide links to websites of other organizations, this privacy notice does not cover how that organization processes personal information. We encourage you to read the privacy notices on the other websites you visit.
11. HOW LONG WE RETAIN YOUR INFORMATION
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.
In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:
- we must keep it to comply with applicable law;
- we must keep it to evidence of our compliance with applicable law;
- there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
- the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
Retention periods vary depending on the type of Personal Data. We will retain, store and process your personal information in accordance with applicable laws, and we shall take reasonable steps to erase or destroy any personal information we no longer require to retain for the purposes set out above.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.
12. CHILDREN’S PRIVACY
Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect personal information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.
13. PRIVACY POLICY CHANGES
Because we’re always looking for new and innovative ways to help you build meaningful trades, this policy may change over time. We will keep this Privacy Policy under review and make updates periodically, and we will communicate any changes related to how we handle your data information.
- We may modify this Privacy Policy from time to time, and any such change shall be reflected on the Website with the updated version of the Privacy Policy and you agree to be bound to any changes to the updated version of the Privacy Policy when you use the Website or its services.
- You acknowledge and agree that it is your responsibility to review this Website and this Policy periodically and to be aware of any modifications. Updates to this Policy will be posted on this page.
- Also, occasionally there may be information on the Website that contains typographical errors, inaccuracies, or omissions that may relate to service descriptions, pricing, availability, and various other information, and the Website reserves the right to correct any errors, inaccuracies, or omissions and to change or update the information at any time, without prior notice.
14. HOW TO CONTACT US
If you have a complaint about how we have handled your personal information or you have questions about this Privacy Policy, you may contact us using the details below.
You can contact us by writing to us:
via email: official.ginalabs@gmail.com