1. Collection of Information

We collect information about you when you:

• Create an account;
• Use the Platform;
• Visit our website; and
• Communicate with us.

We also collect information, such as usage statistics, by using cookies, server logs, and similar technologies.

If you elect to use certain features, we also collect information through other sources, such as social media services, invitations, and imported contacts.

1.1 Information You Provide to Us

We collect information that you provide directly to us. For example, we collect information that you provide when you create an account, choose interests or groups, fill out a form, or communicate with us. The types of information that we may collect include identifiers, such as your name, username, password, email address, postal address, and phone number; payment and commercial information, such as payment method data and purchases, if any; demographic information and any other personal information that you choose to provide, such as photos, choices of interests, groups, and professional or employment-related information, including your role, company, and years of experience. Certain information about yourself is optional to provide. Your choice of groups is also optional, but we are required to process this information in order to administer your account, and to indicate that you are a User of the groups that you join.

On occasion, the information that you give us when you join a group may imply information about your beliefs, political views, health conditions, or your sexual identity. This, and other kinds of sensitive information, is given special protection in accordance with applicable law. Posting personal or sensitive information about others without their permission is against our Community Guidelines.

1.2 Information We Collect Automatically When You Use the Platform

When you use our Platform, we automatically collect internet and other electronic network activity information about you and other information, including:

• Log Information: We collect log information about your use of the Platform, including the type of browser that you use; the time, duration, and frequency of your access; Platform pages viewed; your IP address; and the page you visited before visiting our Platform.
• Device Information: We collect information about the computer or mobile device that you use to access our Platform, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
• Information Collected by Cookies: We and our service providers collect information using various technologies, including cookies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Platform and your experience, and track usage of our Platform.
• Other Information: Based on your consent, we may collect other information from your device, such as photos from your camera roll or calendar information you want to manage via the Platform.

1.3 Information We Collect From Other Sources

We may collect information about you from other sources, such as through certain features on the Platform you elect to use. We rely on these third parties to either have your consent or ensure that they are otherwise legally permitted or required to disclose your information to us. Examples include:

• Social Media Services. If you register or log into your account through a third-party social media service, we will have access to some of your third-party account information from that service, including identifiers, such as your name and other information in that account, and used for purposes such as improving your Gruppl recommendations. We may also have access to third-party account information if you use the Platform feature to share a link.
• User Content. We may receive information about you when you or another User uploads photos or posts other content to the Platform.
• Current or Future Corporate Affiliates. We may receive information about you from our current or future corporate parents, subsidiaries, or affiliates.
• Information from Other Third-Party Sources. In order to provide you with more tailored recommendations, we may obtain information about you from publicly and commercially available sources, such as third-party publishers, advertising networks, and service providers that we use to manage our ads on other sites, and other third parties as permitted by law. For more information about the data that we obtain from these providers, please contact us at contact@gruppl.com.

2. Use of Information

We use information about you to:

• Operate, improve, promote, and protect our Platform;
• Communicate with you; and
• Personalize content.

2.1 Operating our Platform

We may use information about you described above for various business purposes related to operating our Platform, including to:

• Provide, maintain, and improve our Platform, including to process transactions, develop new products and services (for example, including you in tests or pilots of new or revised Platform functions, such as messaging or search functionality or using information about your usage of the Platform to develop new or revised messaging or search functionality), and manage the performance of our Platform;
• Display information about you, for instance, your list of interests, which will be visible on your profile;
• Personalize the Platform, for example, to suggest content in which we think you may be interested;
• Allow you to share information about your use of the Platform through a third-party social media service, if you connect your account through that service (which you can turn off at any time) and to provide you with better recommendations;
• Monitor and analyse trends, usage, and activities in connection with our Platform; and
• Detect, investigate, and prevent fraudulent transactions, abuse, and other illegal activities; to protect the rights, property, or safety of Gruppl and others; to enforce compliance with our policies; and to comply with applicable law and government requests; and
• Perform accounting and administrative tasks, and enforce or manage legal claims.

2.2 Communicating With You

We may use information about you for various business purposes related to communicating with you, including to:

• Respond to your comments, questions, and requests, and provide customer service;
• Communicate with you, in accordance with your account settings, about products, services, and events offered by us and others, to provide news and information that we think will be of interest to you, to conduct online surveys.
• Notify you about communications of other Users, in accordance with the communication preferences that you indicate in your account; and
• Send you technical notices, updates, security alerts and support, and administrative messages.

2.3 Advertising and Other Uses

We may use information about you for various other business purposes, including to:

• Provide content, features, or sponsorships that match User profiles or interests;
• Facilitate contests and other promotions;
• Send you marketing communications, subject to applicable law;
• Combine with information that we collect for the purposes described in this Privacy Policy; and
• Carry out any other purposes described to you at the time that we collected the information.

3. Sharing of Information

We may disclose personal information about you, including:

• To Users or social media services, depending on how you engage with the Platform. Information that is public on our platform is accessible to others both on and off the Platform;
• To our third-party service providers who help us to operate or improve our Platform;
• To authorities to comply with legal obligations and to protect and defend our rights and property; and
• To an affiliate or successor entity as part of a corporate transaction
• Among our businesses and affiliated companies; and
• When you direct us to share your information.

We may also share information in a manner that does not identify you, such as de-identified or aggregated information. Such information is not subject to this Privacy Policy.

We do not sell or share information about you except as described in this Privacy Policy.

3.1 Through Our Platform

We share some of the information that we collect by displaying it on our Platform according to your User profile and account settings. Some information, such as username, is always public. Some information, such as interests, is public by default, but can be hidden on our Platform. Some information, such as Groups, Pages will always be visible to other Users of that Gruppl group, and may be public, depending on the settings of that group. We recommend that you check the group settings and what information will be available before joining the group to ensure that you are happy with the information that is visible to others.

Information that is public on our Platform is visible to others on and off the Platform.

3.2 With Our Service Providers

We may use service providers in connection with operating and improving the Platform to assist with certain business purposes, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads, and some aspects of our technical and customer support. These service providers, which include data analytics providers, may access, process, and store information about you on our behalf for the purposes we authorize, subject to confidentiality obligations.

3.3 Following the Law and Protecting Gruppl

We may access, preserve, and disclose information about you to government entities and other third parties, including the content of messages, if we believe disclosure is in accordance with, or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, Gruppl or others.

3.4 Affiliate Sharing and Merger, Sale or Other Asset Transfers

If Gruppl is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of our assets, information about you may be shared, sold, or transferred as part of that transaction. We may also share information about you with current or future corporate parents, subsidiaries, or affiliates.

3.5 Other Situations

We may de-identify or aggregate information about you and share it freely, so that you can no longer be identified. Such information is not subject to this Privacy Policy.

4. Security

4.1 Technical Security

We employ technical and organizational measures designed to protect your information that is under our control and that we process on your behalf from unauthorized access, collection, use, disclosure, copying, modification, or disposal, both during transmission and once we receive it. For example, we store all information that you provide to us on servers on which security controls are used. We train employees regarding our data privacy policies and procedures, and authorize employees to access personal information as required for their role. We use firewalls designed to protect against intruders and test for network vulnerabilities. However, no method of transmission over the internet or method of electronic storage is completely secure.

Where you have a password, which enables you to use our services, you are responsible for keeping this password complex, secure, and confidential. If you would like to update or change your password, you may select the “Forgot your password?” link on the login page. You will be sent an email that allows you to reset your password.

4.2 Data Retention

We may temporarily de-activate your account if you have not logged in for six months or more. You may contact us if you wish to reactivate your account.

We retain certain information that we collect from you while you visit or are a User of the Platform, and in certain cases where you have deleted your account, for the following business purposes:

• So you can use our Platform;
• So ensure that we do not communicate with you if you have asked us not to;
• To provide you with a refund, if entitled;
• To provide accurate accounting information to other Users about the groups.
• To better understand the traffic to our Platform so that we can provide all Users with the best possible experience;
• To detect and prevent abuse of our Platform, illegal activities and breaches of our Terms of Service; and
• To comply with applicable legal, tax or accounting requirements.

When we have no ongoing legitimate business need to process your information, we will either delete it or take steps to de-identify or anonymize it in accordance with applicable law.

5. Policy Scope

5.1 Applicability

This Privacy Policy does not apply to information that you have provided or made accessible to third parties, such as other Users, including group organizers and network administrators, and others with whom you may share information about yourself. Our Platform may direct you to a third-party service or a portion of our Platform may be controlled by a third party (typically through the use of a frame or pop-up window separate from other content on our Platform). Disclosure of information to these third parties is subject to the relevant third party’s privacy policy. We are not responsible for the third-party privacy policy or content, even if we link to those services from our Platform or if we share information with these third parties.

5.2 Revisions to This Policy

We may modify this Privacy Policy from time to time. When we do, we will provide notice to you by publishing the most current version and revising the date at the top of this page. If we make any material change to this policy, we will provide additional notice to you, such as by sending you an email or displaying a prominent notice on our Platform.

6. Contact Us

If you have any questions, you can contact us at contact@gruppl.com.
Under European data protection law, the controller of your information is Oquent Global Corporation (OGC).

If you have any questions or complaints about this Privacy Policy or how we use your information, please contact contact@gruppl.com.