Privacy Policy

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 data secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your data.

PRIVACY POLICY

GinaLabs (“we,” “us” or “our”) appreciates that you trust us with your data and we intend to always keep that trust. This starts with making sure you understand the data we collect, why we collect it, how it is used and your choices regarding your data. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

1. WHO WE ARE

The company that is responsible for your data 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. DATA WE COLLECT

It goes without saying, we can’t help you develop meaningful trading without some data about you, such as your date of birth, address, gender, occupation and contact data such as telephone, email address and other contact details you may provide to us. We also collect Identity data such as your photo IDs, proof of address documents and any other documents you may provide to us. We collect data generated as you use our services, for example access logs, as well as data from third parties. If you want additional info, we go into more detail below.

Data you give us

You choose to give us certain data 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 data, such as your debit or credit card number or other financial data.

•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 data that you use to register or enter.

•If you contact our customer care team, we collect the data 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 data of other people, we collect the data about others that you give us in order to complete your request.

Data we receive from others

In addition to the data you provide us directly, we receive data about you from others, including:

•Other Users. Other users may provide data about you as they use our services. For instance, we may collect data 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 user name and password and allows you to share some data 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).

Data collected when you use our services When you use our services, we collect data 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 data. We collect data 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 data. We collect data from and about the device(s) you use to access our services, including: #hardware and software data 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 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); #data on your wireless and mobile network connection, like your service provider and signal strength; #data on device sensors such as accelerometers, gyroscopes and compasses.

•Other data 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 DATA

The main reason we use your data 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 data, 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 address, browser version and similar data about your devices to help identify and link them.

To provide our new services to you

•Register you and display your profile on new features and apps.

•Administer your account on these new features and apps. To serve you 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 against 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 data as described above, we rely on the following legal bases:

•Provide our service to you. Most of the time, the reason we process your data is to perform the contract that you have with us.

•Legitimate interests. We may use your data 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 data for administrative, fraud detection and other legal purposes.

•Consent. From time to time, we may ask for your consent to use your data 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 DATA

Since our goal is to help you make meaningful trading we share some users’ data 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 data 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 data with partners who distribute and assist us in advertising our services. For instance, we may share limited data 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 data 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 data 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 data: (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 data with third parties. In any such case, we will make it clear why we want to share the data. We may use and share non-personal data (meaning data that, by itself, does not identify who you are such as device data, general demographics, general behavioral data, geolocation in de-identified form), as well as personal data in hashed, non-human readable form, under any of the above circumstances. We may also share this data 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 data with additional non-personal data or personal data in hashed, non-human readable form collected from other sources. More data on our use of cookies and similar technologies can be found in our Cookie Policy.

7. CROSS-BORDER DATA TRANSFERS

Sharing of data 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 data is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard 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 data, 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 data that you provided to us and that’s associated with your account directly within the service. If you have any question on 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 data 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 data. Applicable privacy laws may give you the right to review the personal data 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 data by putting in such a request.

•Updating your data.

If you believe that the data 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, 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 data, notably where such requests would not allow us to provide our service to you anymore.

• Uninstall. You can stop all data 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 data. 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 DATA

We invest appropriate resources to protect your personal data, from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure hence we cannot be held responsible for unauthorised or unintended access that is beyond our control.

10. LINKS TO OTHER SITES

Where we provide links to websites of other organisations, this privacy notice does not cover how that organisation processes personal data. We encourage you to read the privacy notices on the other websites you visit.

11. HOW LONG WE RETAIN YOUR DATA

We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements. Retention periods vary depending on the type of Personal Data. We are legally required to retain basic data about our customers (including identity, contact details and other transaction data) for six years after they cease being our customers. We will retain, store and process your personal data in accordance with applicable laws, and we shall take reasonable steps to erase or destroy any personal data we no longer require to retain for the purposes set out above.

12. CHILDREN’S PRIVACY

Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable data from anyone under the age of 18. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that data from our servers.

13. PRIVACY POLICY CHANGES

We will keep this Privacy Policy under review and make updates periodically, and we will communicate any changes relating to how we handle your data.

• We may modify this Privacy Policy from time to time, and any such change will be reflected on the Website with the updated version of the Privacy Policy. By continuing to use the Website or its services, you agree to be bound by any changes to the updated Privacy Policy.

• 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 data on the Website that contains typographical errors, inaccuracies or omissions that may relate to service descriptions, pricing, availability, and various other data, and the Website reserves the right to correct any errors, inaccuracies or omissions and to change or update the data at any time, without prior notice.

14. HOW TO CONTACT US

If you have a complaint about how we have handled your personal data 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.com