Privacy Policy of Givling, Inc.
Last updated: 18 June 2020
This Privacy Policy describes and governs how Givling, Inc. (herein
"Givling", "us," "we," or "our") collects, uses, shares and protects
personal information from its users and the legal basis for doing so.
Please note that while Givling is a for-profit business, it does not exceed
any of the thresholds for application of the California Consumer Privacy Act
(CCPA). Givling does not sell your personal information.
Before you use or submit any information through our site or mobile app,
please carefully review this Privacy Policy ("Policy"). To use the Givling
website or mobile app, you need to submit personal information such as
during your account registration. By setting up an account or using any part
of the Givling services, you consent to the collection, use, and disclosure
of your information as outlined in this Policy. Additional personal
information may be required for game winners and debtor participants to
receive monetary prizes. Givling will inform the user, winners or debtors
regarding the information it requires and will only use this information for
the stated purpose(s), such as administering the game of skill and
crowdfunding activities. By providing the information, a user is giving
consent to Givling, Inc. to use the information for the stated purpose(s);
if the user does not provide the information, features of the website or
monetary prizes will not be available to the user.
Your submission of personal information is voluntary. When you voluntarily
submit information, you consent to the use of your information for the
purpose(s) stated in the Terms & Conditions including participating in a
game and crowdfunding loan debts. Givling services are not available in
Europe and we do not store or transfer information internationally,
therefore, Givling is not obligated to comply with EU General Data
Protection Regulation 2016/679 (the "GDPR"). Notwithstanding, users are
hereby informed of the following:
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the data controller is Gannett Peak Technical Services and can be
reached at the address 1709 Carey Ave, Suite 1, Cheyenne, WY 82001-4442.
Any information provided to Givling is stored at Green House Data of 340
Progress Circle, Cheyenne, WY 82007; and,
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if you are absolved under the law from giving consent to this Policy,
you nevertheless acknowledge you have read and understood its terms.
Information Collected and Stored
In order for you to create an account with Givling, participate in the game,
or take part in crowdfunding activities, we need to collect and process
certain information. Personal information which may be collected and some of
which may be required to register an account or for use of an account
includes:
- User Name, alias allowed
- Email address
- Phone number
- Zip code
- Internet protocol (IP) address
- Some uniform resource locators (URLs)
- Device identifiers
- Installed apps lists and usage stats
- App crash reports
- Bookmarks
- Browsing history
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Individual game participation records, such as scores, times of play,
and game results
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Overall game records such as scores, times of play, and game results,
and
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Any information you choose to provide us (such as a profile picture).
Givling also collects personal information for winners and debtors to
provide payments and comply with tax reporting. In those cases, additional
information collected may include:
- Legal name
- Address
- Social Security Number
- Date of birth
- Gender
- Photos uploaded or provided to us
- Debt holder information
- Debtors account number
- Educational lending institution information
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Other information that may be required by the IRS or other authorities.
All information collected by Givling is stored by Green House Data of
Cheyenne, WY and Givling utilizes the services of Gannett Peak Technical
Services of Cheyenne, WY to act as its data controller. While we do not
store credit card or banking information, such information from time to time
may be entered by you into PayPal's payment processing system. PayPal or
Givling will notify you via your email on file if we become aware of any
security breach that might compromise your personal information. If you have
any questions about, or wish to review or correct the information we
maintain about you, you may send an email to support@givling.com.
Our Use of Information
Givling uses the collected information for various purposes including:
- To administer a game of skill
- To administer crowdfunding services
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To monitor jurisdictions of users for compliance with Federal and State
Laws
- To contact or identify you
- To notify you about changes to our services
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To notify game victors, drawings recipients and debtors selected to be
funded
- To transmit payments and tax reporting
- To provide customer support
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To gather analysis or valuable information so that we can improve our
services
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To detect, prevent and address rules violations, technical issues, or
disputes
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To defend our legal rights, comply with state, local, federal or
international laws, and enforce our Terms of service and this Policy.
Givling may also use information for the purpose of information storage and
access; personalization; ad selection, delivery, and reporting; and
measurement. In support of these services, some partners may use some or all
of the following features: precise geographic location data; matching date
to offline sources; or linking devices.
There are certain circumstances in which we share information collected
through the services with certain third parties without further notice to
you. The first circumstances may occur as we develop our business, in which
case we might sell or buy businesses or assets. In the event of a corporate
sale, merger, reorganization, dissolution, similar event, or steps taken in
anticipation of such events (e.g., due diligence in a transaction), user
information may be part of the transferred assets. The second instance may
occur if we hire agents, consultants, vendors and related third parties to
perform certain business-related functions on Givling's behalf, and we
provide access to or share your information with these companies so they can
perform services for us. We limit the personal information provided to these
service providers to that which is reasonably necessary for them to perform
their functions, and we require them to agree to maintain the
confidentiality of such information.
Publicly Disclosed Information
Without additional notice to you, Givling will publicly disclose game
records such as names, towns, and states of winners and recipients of
funding according to the Terms and Conditions which you have agreed to by
accessing our services and playing the game.
You can post comments, leave feedback, send thank-you notes or otherwise
communicate with other users through Givling. Any content, including such
comments, feedback, and notes are your choose to post through Givling are
available to the public by default. You may also contact us via a contact
form, email, or by other means (for example, with questions about our
services, for customer support, or to let us know your ideas). When you do
so, we collect the information you choose to provide us, such as your
contact details, any images you choose to upload and the contents and nature
of your message.
Please remember that any information that is disclosed in these areas
becomes public information for both us and other users to use and share.
Please be considerate and respectful of others while using the community to
share your opinions. We reserve the right, but do not have the obligation,
to review and monitor such posting or any other content on Givling, and to
remove postings or content that may be viewed as inappropriate or offensive
to others.
Legal Basis for Collecting and Processing Personal Information
Givling's legal basis for collecting and using the personal information
described in this Policy depends on the personal information collected and
the specific context in which we collect the information, but the legal
basis may include one or more of the following:
- You have given Givling permission to process personal information
- Givling needs to perform a contract with you
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Processing your personal information is in Givling's legitimate business
interests
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Givling needs to comply with legal obligations such as IRS reporting
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Processing is necessary to protect your vital interests, demonstrate the
integrity of the game, and the Queue protocol.
Children
People under 18 years of age (or the legal age of majority in your
jurisdiction) are not permitted to use Givling. Givling does not knowingly
collect any personal information from children under the age of 18 and
children under 18 are not permitted to register for an account or use our
services.
If you believe that a child has provided us with personal information,
please contact us at support@givling.com. If we become aware that a person
under age 18 has provided us with personally identifiable information, we'll
delete it.
Retention of Personal Information
Givling will retain your personal information for as long as is necessary
for the purposes set out in this Policy which may be indefinitely. Givling
will retain and use your information to the extent necessary to comply with
our legal obligations, resolve disputes, and enforce our policies. When
determining the retention period, we take into account various criteria,
such as the type of services requested by or provided to you, the nature and
length of our your use of our services, possible re-enrolment with our
services, the impact on the services we provide to you if we delete some
information about you, mandatory retention periods provided by law and the
statute of limitations.
Your Rights and Choices
This Policy informs you about the categories and specific pieces of personal
information collected by Givling, how it uses the information, and
identifies the third parties with whom the information is kept. By visiting
your "Account Settings" portion of Givling, you can access, review, and
correct or change the personal information Givling holds about you. You can
also make a written request via the address listed below that, within 45
days, we provide copies in a readily portable format of personal information
about you held by us. If that information is inaccurate, it is your
responsibility to inform Givling of the inaccuracies at the same address and
we will endeavor to make the necessary amendments. You have the right to
object to Givling's use and storage of your information and may request that
we erase, do not process, or otherwise block specific personal information
about you, subject to our legal justifications for retaining copies of the
information; please note, should you choose to delete or restrict such
information, we may not be able to provide you with some or all of the
services.
Information Passively and Automatically Collected
Givling uses commercial software products, such as Fabric.io, to track usage
numbers and events within the mobile app, analyze and report on aggregated
web metrics data. This data is generally retained indefinitely to support
the website and mobile app.
When you use Givling, we automatically receive and store certain information
from devices that you use to access the services. This information is
collected passively by using various technologies, and includes the type of
internet browser or mobile device you use, any website from which you have
come to the services, your operating system, and location data through an IP
address that identifies the city and state where you logged into Givling or
your precise geo-location if you have permitted your mobile device to
provide that information to us. Givling either stores such information
itself or such information is included in databases owned and maintained by
Givling, or its agents or service providers.
In an ongoing effort to better understand the use of our services and serve
you, Givling often conducts research on its customer demographics, interests
and behavior based on information we collect. We can de-identify and
aggregate the information collected through the services for research
purposes or any other purposes, and we can share this information with our
affiliates, agents, business partners, or other third parties (e.g., Google
Analytics).
When you use the services, the services request that you provide your city
or town and state of residence. Please keep in mind that other users of the
services can view your city or town and state of residence, if it is made
available within Givling's settings. We also use your location information
as described above under "Device & Usage Information", and in an aggregate
way, as described above in the "Aggregated Data" section.
Links to Other Websites
This Privacy Policy applies only to Givling. The Givling website or mobile
app may contain links or advertisements to other websites that are not
operated or controlled by Givling (the "Third-Party Sites," sometimes called
"Partners"). The policies and procedures set forth herein do not apply to
the Third-Party Sites. The availability of Third-Party Sites through Givling
does not imply that Givling endorses or has reviewed the Third-Party Sites.
Givling will not provide or sell your information to such Third-Party Sites
or other third parties. We suggest contacting those sites directly for
information on their respective privacy policies.
Use of Cookies and Tracking Technology
When you use Givling, our web server sends a cookie to your computer or
mobile device. This is in an effort to make your experience simple and
meaningful. "Cookies" are small files that a website transfers to a user's
computer to allow the site to remember specific information. Cookies store
and sometimes track information about your use of our services. If you do
not want cookies to be transferred to your computer, you may choose to opt
out of their use by modifying browser options. While you will still be able
to access most features of the website or mobile app, certain features may
not work as well or may be unavailable to you.
Givling may use certain types of information-collecting tools on its various
websites including:
Session Cookies
Givling uses session cookies on its website for technical purposes such as
to enable a user to more easily navigate the game. Session cookies only
collect non-personally identifiable data, and once a user closes his or her
browser, the session cookies disappear.
Persistent Cookies
Persistent cookies store information on a user's computer for longer periods
of time than session cookies, and the information is stored across multiple
sessions. Givling never uses persistent cookies to collect personally
identifiable information about its website visitors. Givling may use
persistent cookies to improve its web metrics by distinguishing between new
and returning visitors; to aggregate data anonymously on how visitors use
the services; and to "remember" preferences that users provide voluntarily.
Customization tools
Customization tools may allow users to voluntarily provide information to
personalize and improve their online experience on a particular site. This
information is saved on the Givling's contracted servers.
Functional Cookies
Some cookies may be necessary to make our services available to you
("Functional cookies"). For example, to provide the login functionality and
to remember your consent and privacy choices. We may not be able to provide
our services without Functional cookies.
Analytical Cookies
We may also use cookies for analytics purposes in order to operate,
maintain, and improve our services ("Analytical cookies"). Some of the
Analytical cookies used are set by us, and some are set by third parties
such as Google Analytics or Fabric.io, to collect and process certain
analytics data on our behalf. You can learn about Google's practices by
going to https://www.google.com/policies/privacy/partners/.
We may also work with third-party advertising companies to show you ads we
think may be of interest to you and to track sales from ads for our
services. For example, we may show you ads about our services on third party
websites and apps, or ads about third parties' products and services on our
website and app. To do so, we and our advertising partners place and access
cookies through our services and otherwise collect or access personal
information collected over time and across different online services. For
example, we may use Google Analytics Advertising Features, such as, Google
AdWords and Double Click. You can opt out of the Google Analytics
Advertising Features via https://tools.google.com/dlpage/gaoptout/.
We may use cookies and similar technologies to collect information about
your access to and use of our services: including to: (1) allow you to
navigate and use all the features provided by our services; (2) customize
elements of the layout and/or content within our services and remember that
you have visited us before; (3) identify the number of unique visitors we
receive; (4) improve our services and learn which functions of our services
are most popular with users; and (5) how you use our services (e.g., by
learning how long you spend using our services and where you have come to
our services from. As we adopt additional technologies, we may gather
additional information through other methods. We will notify you of such
changes as described in the "Changes to Givling's Privacy Policy" section
below.)
Your cookie preferences
Most web and mobile device browsers automatically accept cookies but, if you
prefer, you can change your browser to prevent that or to notify you each
time a cookie is set. You can also learn more about cookies by visiting
www.allaboutcookies.org, which includes additional useful information on
cookies and how to block cookies using different types of browsers or mobile
devices.
You can also consult the "Help" section of your browser for more information
(e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari).
You can also manage the use of Flash technologies, including cookies and
local storage objects with the Flash management tools available at Adobe's
website. Please note that by blocking any or all cookies, you may not have
access to certain features or offerings of our services.
If you are accessing our services through a mobile device, you can also
update your privacy settings on your device by setting the "Limit Ad
Tracking" and Diagnostics and Usage setting property located in the settings
screen of your Apple iPhone or iPad, or by resetting your Android ID through
apps that are available in the Play Store. You can also limit information
collection by uninstalling the App on your device and you can use the
standard uninstall process available as part of your device for this
purpose.
Other technology: Web beacons
A web beacon is a transparent image file. Web beacons enable websites to
track website usage information, such as the number of times a given web
page has been viewed. Web beacons are invisible to you and (unlike cookies)
are not placed on your computer. We may use them in association with cookies
to understand how visitors interact with the pages and content on the pages
of our services. We may also use web beacons to track whether you have
opened an HTML email. When the email is opened, a part of the code that
makes up the HTML page calls a web server to load the web beacon that then
generates a record showing that the email has been viewed. Web beacons may
also recognize when the email was opened, how many times it was forwarded
and which URLs (links within the email) were clicked.
Other technology: Pixel Tags
In addition, we may use pixel tags or similar technologies (also referred to
as clear gifs or web bugs). Pixel tags are tiny graphic images with a unique
identifier, similar in function to cookies, that are used to track online
movements of our users. In contrast to cookies, which are stored on a user's
computer hard drive, pixel tags are embedded invisibly in web pages. Pixel
tags also allow us to send email messages in a format users can read, and
they tell us whether emails have been opened to ensure that we are sending
only messages that are of interest to our users. We may use this information
to reduce or eliminate messages sent to a user. We do not tie the
information gathered by pixel tags to information that is intended to
identify our users.
Security
Givling has implemented technical and organizational security measures to
protect the information provided from loss, misuse, and unauthorized access,
disclosure, alteration, or destruction. For example, limiting access to
information only to employees and authorized service providers who need to
know such information for the purposes described in this Policy. However, no
Internet or email transmission is ever fully secure or error free. In
particular, email sent to or from our services may not be secure. Therefore,
you should take special care in deciding what information you send to us via
email. Please keep this in mind when disclosing any information to Givling
via the Internet.
Changes to Givling's Privacy Policy
Givling reserves the right to update or modify this Policy at any time and
from time to time. We will notify you of any updates or changes we make to
this Policy. If you disagree with our revisions to the Policy, you can
deactivate your account or discontinue the use of our services. Please
review this Policy periodically, for any updates or changes to this Policy.
3rd Party Privacy Policies
Givling works with other technologies and networks, each which may have
their own privacy policies, including this one from Pollfish:
Survey Serving Technology
This app uses Pollfish SDK. Pollfish is an on-line survey platform,
through which, anyone may conduct surveys. Pollfish collaborates with
Developers of applications for smartphones in order to have access to
users of such applications and address survey questionnaires to them. When
a user connects to this app, a specific set of user’s device data
(including Advertising ID which will may be processed by Pollfish only in
strict compliance with google play policies- and/or other device data) and
response meta-data is automatically sent to Pollfish servers, in order for
Pollfish to discern whether the user is eligible for a survey. For a full
list of data received by Pollfish through this app, please read carefully
Pollfish respondent terms located at
https://www.pollfish.com/terms/respondent. These data will be associated with your answers to the questionnaires
whenever Pollfish sends such questionnaires to eligible users. By
downloading the application you accept this privacy policy document and
you hereby give your consent for the processing by Pollfish of the
aforementioned data. Furthermore, you are informed that you may disable
Pollfish operation at any time by using the Pollfish “opt out section”
available on Pollfish website . We once more invite you to check the
respondent’s terms of use, if you wish to have more detailed view of the
way Pollfish works.
Givling encourages users to review all 3rd Party Privacy Policies
carefully.
Contact Us
If you have any questions about this Privacy Policy, please contact us at
support@givling.com or through our automatic contact form within the Givling
App or at www.givling.com.
You may also contact us in writing at:
Givling, Inc.
P.O. Box 9149
Jackson, WY 83002.