PRIVACY POLICY

 

(Effective as of November 01, 2019)

 

This Privacy Policy (this “Privacy Policy”) governs your use of the software application under the title “Give Away” for mobile devices (hereinafter to be referred to as “App”) that was created by Kakadu Development llc (hereinafter - “Company” or “we” or “us”). The App provides a way, that allows you to accept and give away used goods free of charge, including through the auction mechanism. The service is intended to provide general informational content about the goods and items represented. It collects user entered and otherwise provided data points related to the goods and items that can be picked up without charge. This Privacy Policy explains how Company collects, stores, uses, and discloses personal information from our users (“you”).

 

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and/or informing you via email or text message. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes. If you do not accept the terms of the Privacy Policy, we ask that you do not use the App. Please exit the App immediately if you do not agree to the terms of this Privacy Policy.

 

By creating a profile in the App, you explicitly consent that we may process your personal data (“processing” means using information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place on the territory of App distribution) you provide through the usage of the App and through the account creation process solely for the purpose of providing services to you, to improve our service features. Such services may include sending you information and reminders through the App or to the email address you provided to us. We will not transmit any of your personal data to third parties, except if it is required to provide the service to you (e.g. technical service providers), unless we have asked for your explicit consent.

 

 

1. INFORMATION WE COLLECT

 

1.1. Information You Give Us.

 

1.1.1 App gives you a number of options regarding what information you will give us:

 

1) When you register to create an account with App (if applicable);

 

2) When you participate on a forum or other communication mechanism (if applicable); and

 

3) When you update the App with information relevant to goods and items.

 

1.1.2. When you register with App and as you use the App you will submit a variety of information about yourself.

 

1.1.3. Also, when you sign up for App, we may collect other information such as credit card numbers and/or cell phone numbers, as well as other information about you necessary to ensure that the transaction is properly authorized, such as your address, zip code, and cv number (collectively, “payment information”). We also may retain such information to facilitate future transactions.

 

1.1.4. In addition to information about yourself, it may be possible for you to submit other content, such as photos and other media, each of which you present through technology available through the App including but not limited to our forum. It is entirely up to you whether you want to submit this additional information, and whether you would like to make it available to others – although information you share on the forum will automatically be shared with others. However, Company has no responsibility for how people you allow to view your content (or the public if you make any information available to the public or post on the forum) use that material, or to whom they may forward it.

 

1.1.5. All information that you provide to us through the App is automatically uploaded to our servers and is stored there in duplicate to the information stored on your device. If you remove data from your account, you will no longer see it in the App, but some backups of the data may remain in our archive servers. You are responsible for ensuring the accuracy of the information that you submit to App.

 

1.2. Information We Collect Automatically.

 

1.2.1. When you access or use the App, we may automatically collect the following information:

 

1) Device Information: We collect information about the mobile device you use to access the App, including the hardware model, operating system and version, unique device identifiers and mobile network information;

 

2) Location Information: We collect your IP address, time zone, and information about your mobile service provider, which allows us to infer your general location;

 

3) Other tracking technologies: We use various technologies to collect information about your use of the App, such as frequency of use, which areas and features of our App you visit and your use patterns generally, engagement tracking with particular features, etc.

 

 

2. HOW WE USE INFORMATION

 

2.1. We may use your information, including your personal information, as follows:

 

1) to analyze, operate, maintain and improve the App;

 

2) to customize content you see when you use the App;

 

3) to provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders;

 

4) to customize product and service offerings and recommendations to you;

 

5) to verify your identity;

 

6) to send you technical notices, updates, security alerts and support and administrative messages;

 

7) to respond to your comments, questions and requests and provide customer service;

 

8) to monitor and analyze trends, usage and activities in connection with our App;

 

9) solely with respect to information that you mark for sharing;

 

10) to link or combine with information we get from others to help understand your needs and provide you with better service; and

 

11) for any other purposes disclosed to you at the time we collect personal information.

 

2.2. To the extent necessary for above mentioned purposes, we take all reasonable steps to ensure that your personal data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amount and type of personal data that is strictly required for the purposes mentioned in this Privacy Policy (“data minimization principle”).

 

3. DISCLOSURE OF INFORMATION

 

3.1. Third Party.

 

3.1.1. We may share certain personal information that is entered by you and that you do not elect to share, with third party vendors who supply software, web hosting and other technologies for the App. We will only provide these third parties with access to information that is reasonably necessary to perform their work or comply with the law. Those third parties will never use such information for any other purpose except to provide services in connection with the App. The privacy policy of these services can be found on their respective websites. By using the App, you consent that we may use cookies and third-party services, and collect your usage data under a unique identifier, for the purposes of tracking, analysis, and improvement of the App.

 

3.1.3. You can direct us to share data from the App with other parties. Once you direct us to share your data with a third party, that third party will have their own privacy policy and we do not control how the third party uses or handles the information. You can revoke your consent to share information with such a third party at any time.

 

3.1.4. We take reasonable steps in order to ensure compliance of such third parties with any applicable laws that might govern processing of your personal information.

 

 

3.2. Aggregated Information.

 

3.2.1. We may also share aggregated, anonymized or de-identified information, which cannot reasonably be used to identify you. For example, we may share, including, without limitation, in articles, blog posts and scientific publications, general age demographic information and aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users.

 

3.3. Special Circumstances.

 

3.3.1. We will not share or sell any of your Personal Information to any third party except as otherwise stated in this Privacy Policy and in the following circumstances: (i) in response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law; (ii) when disclosure is required to maintain the security and integrity of the App, or to protect any user’s security or the security of other persons, consistent with applicable laws; (iii) when disclosure is directed or consented to by the user who has input the personal information; or (iv) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred.

 

3.4. Information Posted by User (if applicable).

 

3.4.1. The App features several community areas and other public forums where users with similar interests can share information and support one another or where users can post questions. Our communities are open to the public/the App community and should not be considered private. Any information (including personal information) you share in any online community area or online discussion is by design open to the public and is not private. You should think carefully before posting any personal information in any public forum.

 

3.5. Retained Information.

 

3.5.1. We will retain your personal information as long as your account is active or needed to provide you services. At any time, you can remove your personal information or instruct us to remove it by emailing us, but you should be aware that we may retain certain personal information after your account has been terminated in an aggregated, anonymized form. Any posts or comments you submit may remain visible if and after you delete your account. We are not obligated to remove your posts or comments. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your personal information as necessary to comply with legal obligations, resolve disputes and enforce our agreements. Please note that some information may remain in our records after deletion of your account, including any information or records that we are legally obligated to retain or that we elect to retain for legitimate business purposes.

 

4. SECURITY

 

4.1. We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our App. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

 

5. CHILDREN’S PRIVACY

 

5.1. We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 13 years old. The App does not collect Personal Data from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the App, please contact us and we will take required steps to delete such information and (or) delete her account.

 

5.2. Due to requirements of the GDPR with respect to the EU residents you shall be at least 16 years old in order to use the App. To the extent prohibited by applicable law, we do not allow use of the App by the EU residents younger than 16 years old. If you are aware of anyone younger than 16 using the App, please contact us.

 

 

6. THIRD PARTY LINKS

 

6.1. Although the App may contain links to third party websites or services, we are not responsible for the privacy policies and/or practices on those third-party websites or services. Please understand that this Privacy Policy applies only to information we collect from you. Where we have linked to a third-party website or service, you should read the privacy policy stated on that third-party website or service.

 

7. EMAIL COMMUNICATIONS

 

7.1. We may contact you from time to time via email to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you.

 

8. INTERNATIONAL DATA TRANSFERS

 

8.1. The information we collect is governed by the law of the Republic of Belarus. Please be advised that the law of the Republic of Belarus and laws of other countries may not offer the same protections as the law of your jurisdiction.

 

8.2. In addition, you agree that information collected through the App may be stored and processed in other states, where the Company currently rents servers, or in any other country in which the Company or its affiliates, subsidiaries or agents maintain facilities, and by using the App, you consent to any such transfer of information outside of your country. From our side, we will take reasonable steps in order to ensure compliance of processors and storage providers with the rules and adequate protection private data protection practices for international data transfers.

 

9. GDPR

 

9.1. Individuals residing in the countries of the European Union have certain statutory rights in relation to their personal data introduced by the General Data Protection Regulation (the “GDPR”). Subject to any exemptions provided by law, you may have the right to request access to personal data (including in a structured and portable form), as well as to seek to update, delete or correct Personal data:

1) Rectification of personal data and restriction of processing. You are responsible for ensuring the accuracy of your Personal Data that you submit to App. Inaccurate information will affect your experience when using the App and tools and our ability to contact you. If you believe that your personal data is inaccurate, you have right to contact us and ask us to correct such personal data by contacting us at support@giveaway.com. You shall also have the right to request restriction of processing of your personal data, if you contest the accuracy of the personal data and we need some time to verify its accuracy.

2) Access to your personal data and data portability. The App gives you the ability to access and update personal data within the App and your account settings. You shall have the right to request information about whether we have any personal data about you, to access your personal data (including in a structured and portable form) by simply writing us at support@giveaway.com.

3) Erasure of your personal data. If you believe that your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed, or in cases where you have withdrawn your consent or object to the processing of your personal data, or in cases where the processing of your personal data does not otherwise comply with the GDPR, you have right to contact us and ask us to erase such personal data as described above. You can simply write us at support@giveaway.com. Please be aware that erasing some personal data inserted by you may affect your possibility to utilize the App and its features. Erasure of some personal data may also take some time due to technical reasons.

4) Right to object processing of your personal data. You can object processing your personal data and stop us from processing your personal data, simply write us at support@giveaway.com. Please be aware that erasing some personal data inserted by you may affect your possibility to use the App and its features.

5) Notice about automated decision-making. We use automated decision-making tools that process your personal data in order to provide you proper services (for example, predictions of your cycle).

6) Notification requirements. We commit to notify you within reasonable period of time and your data protection authority within the timeframe specified in applicable law (72 hours) about any personal data breaches in the App.

7) Data protection authorities. Subject to GDPR, you also have the right to restrict our use of Personal Data and lodge a complaint with your local data protection authority about any of our activities that you deem are not compliant with GDPR.

 

9.2. Following the provisions of GDPR we might also require you to prove your identity (for example, by requesting an ID or any other proof of identity) in order for you to invoke the mentioned rights, specifically if you exercise them in respect to special categories of personal data like data about health. This is made to ensure that no rights of third parties are violated by your request, and the rights are exercised by an actual personal data subject or an authorized person. Please note that we will grant your request within 30 days after receiving it, but it may take us up to 90 days in some cases, for example for full erasure of your personal data stored in our backup systems – this is due to the size and complexity of the systems we use to store data.

 

10. CONTACT US

 

10.1. If you have any questions regarding privacy while using the App, or have questions about our practices, please contact us via email (support@giveaway.com). You are able to modify, correct, erase, and update your personal information. Also, you have a right to access your Personal Data you insert into the App and ask us about what kind of Personal Data we have about you. You can do this by using the App settings or by writing us support@giveaway.com.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

PRIVACY STATEMENT-CALIFORNIA (Effective as of January 01, 2020)

 

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy of GiveAway Global, Inc. and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“users” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

 

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

 

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

NO

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements.

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

 

1. Personal information does not include:

1.1. Publicly available information from government records.

1.2. De-identified or aggregated consumer information.

1.3. Information excluded from the CCPA's scope, like:

1.3.1.health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

1.3.2. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

 

2. We obtain the categories of personal information listed above from the following categories of sources:

1.1. Information you give us directly.

1.2. Information we collect automatically. For example, when you access or use the App, we may automatically collect the device information and/or geolocation information, etc.

1.3. From third-parties that interact with us in connection with the services we perform (incl. service providers and providers of analytical tools)

 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  1. to analyze, operate, maintain and improve the App;

  2. to customize content you see when you use the App;

  3. to provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders;

  4. to customize product and service offerings and recommendations to you;

  5. to verify your identity;

  6. to send you technical notices, updates, security alerts and support and administrative messages;

  7. to respond to your comments, questions and requests and provide customer service;

  8. to monitor and analyze trends, usage and activities in connection with our App;

  9. solely with respect to information that you mark for sharing;

  10. to link or combine with information we get from others to help understand your needs and provide you with better service; and

  11. for any other purposes disclosed to you at the time we collect personal information.

  12. as necessary or appropriate to protect the rights, property or safety of us, our clients or others.

  13. to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  14. as described to you when collecting your personal information or as otherwise set forth in the CCPA.

  15. to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

 

To the extent necessary for above mentioned purposes, we take all reasonable steps to ensure that your personal data is reliable for its intended use, accurate, complete, and current. We also undertake to collect only such amount and type of personal data that is strictly required for the purposes mentioned in this CCPA Notice and our Privacy Policy (“data minimization principle”). We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:            Identifiers.

Category D: Commercial information.
Category F:            Internet or other similar network activity.

Category G:            Geolocation data.

We disclose your personal information for a business purpose to the following categories of third parties:

  1. Our affiliates.

  2. Service providers.

  3. Third parties to whom you or your agents authorize us to disclose your personal information in connection with service we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

 

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  1. The categories of personal information we collected about you.

  2. The categories of sources for the personal information we collected about you.

  3. Our business or commercial purpose for collecting or selling that personal information.

  4. The categories of third parties with whom we share that personal information.

  5. The specific pieces of personal information we collected about you (also called a data portability request).

  6. If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

    1. sales, identifying the personal information categories that each category of recipient purchased; and

    2. disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable user request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing relationship with you, or otherwise perform our duties to you.

  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  3. Debug product to identify and repair errors that impair existing intended functionality.

  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  7. Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.

  8. Comply with a legal obligation.

  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable user request to us by email at support@giveaway.mobi.

 

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable user request related to your personal information. You may also make a verifiable user request on behalf of your minor child.

You may only make a verifiable user request for access or data portability twice within a 12-month period. The verifiable user request must:

  1. Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  2. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable user request does not require you to create any account with us.  We will only use personal information provided in a verifiable user request to verify the requestor's identity or authority to make the request.

 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver we will deliver our written response electronically.  Any disclosures we provide will only cover the 12-month period preceding the verifiable user request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  1. Deny you access to the App (service).

  2. Charge you different prices or rates for the service (if applicable), including through granting discounts or other benefits, or imposing penalties.

  3. Provide you a different level or quality of the service.

  4. Suggest that you may receive a different price or rate for goods or services or a different level or quality of the service.

 

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage (giveaway.mobi/privacy).

 

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at: support@giveaway.mobi.