Privacy Policy
[Last Updated: January 02, 2023]
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Gaya communities Ltd. (“Gaya”, “Company” or “we”) owns and operates a platform that enables users to share their feelings, beliefs, and thoughts and connect broadly and globally with one another through our communities, including one-on-one messages (“Platform”, “User” and “Services” respectively). We want you to feel comfortable with the content you share and publish, either publicly or anonymously, and be aware of how Gaya and others may make use of your data and the content you share, including: how we collect it, share it, what are your rights regarding your Personal Data (as such term is defined below), how you can exercise them, etc. Please read this Privacy Policy carefully before interacting with the Platform or using our Services.
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In general, we collect data necessary to provide you with the best services and user experience while interacting with the Platform and using our Services. For example, we use your profile picture and username to let other users see who you are while they communicate with you or when you share content in a Community; we may collect usage and technical data to optimize our Services and adjust them to your needs, ensure their proper operation, and other purposes as outlined below.
Note this Privacy Policy forms an integral part of our Terms of Service available www.gaya.app/terms (“Terms”), which collectively create the full agreement between you and Gaya. Hence, capitalized terms not defined herein are defined in the Terms.
You don’t have to provide us with your Personal Data. However, in some cases, unless you provide us with your data, we will not be able to allow you to use the Services. For example, unless you provide us with your email account, we will not be able to register you for the Services and let you use the Platform.
1. HOW DO YOU KNOW WHEN THE POLICY HAS CHANGED?
This Privacy Policy might change from time to time, and we want to make sure you review the changes and acknowledge them. Therefore, if we make any material changes that might substantially impact you, we will notify you as detailed in the Terms. You can always find the most recent and valid version of this Privacy Policy under the Privacy area in the Platform.
2. HOW TO CONTACT GAYA WITH QUESTIONS?
If you have any questions regarding our data privacy practices, please do not hesitate to contact us by any of the following means:
By email: almog@gaya.app
By mail: Hashoftim 37 St. Tel-Aviv Jaffa, Israel
3. WHAT DATA DO WE COLLECT?
We may collect two types of data from you, depending on your interaction with us:
The first type of information is non-identifiable and anonymous (“Non-Personal Data”). After collecting such Non-Personal Data, we are unaware of the identity of the individual from whom we have collected it. Non-Personal Data usually consists of technical information or general information regarding the usage and preferences of our Users, and may contain, among other things, the type of operating system and type of browser, type of device, the type and characteristics of Users accessing and participating in certain Community (without specifically identifying any of them) and records of actions performed in the Platform (such as session duration).
The second type of information is individually identifiable information, namely information that identifies an individual or may, with reasonable effort, identify an individual (“Personal Data”). Personal Data is collected through various means, including: directly from you when you feed such information; when you interact and publish content in the Platform; data inferred by us and things we learn about you from the data collected otherwise; automatically through the use of analysis and third-party systems, cookies (as elaborated below), etc.; through connection to other accounts and network such as your Facebook or Google accounts (in your sole discretion).
For the avoidance of doubt, any Non-Personal Data linked to Personal Data shall be deemed as Personal Data as long as such linkage exists.
The table below details the types of Personal Data we collect, the purpose, lawful basis, and our processing operations:
Type of Data
Purposes of Processing
Legal Basis under the GDPR
Registration Information
When you register to our Platform and create and configure your account, you will need to provide us with certain basic information about you (“Registration Information”). Such information may include your full name, email address, telephone number, date of birth, gender, and other relevant details about yourself, and your account credentials – username and password. We will further process and add to such data your general data, such as the country from which you registered, your preferred language, and other details regarding your general conduct as a User of the Platform, including your profile picture to the extent provided by you.
We collect your Registration Information to create your User Account. We will use such information to verify your means of contact (for example, we may send you an email to confirm that the email address you provided belongs to you), and to allow you to access the Platform (through your username and password).
Further, we will use your profile picture (if provided) to let other Users see who they are interacting with.
We may use the Registration Information to validate your information and suitability to the Services in accordance with our guidelines and restrictions as detailed in the Terms.
We may also use the means of contact you have provided to send you ongoing updates and operational messages regarding your Platform usage, and subject to applicable law send you marketing emails, meaning information regarding the Services you currently use or other features we believe you might be interested in.
We process your Registration Information for the purpose of performing our contract with you.
Processing of this information for marketing purposes is made subject to our legitimate interest. You can opt-out at any time using the “unsubscribe” option within the body of the message.
Please note that if you choose to unsubscribe from our marketing emails, we will still retain your contact details and send you service-related emails, such as invoices, where applicable.
Content and Data you provide through your activities on the Platform:
We collect the content you provide while interacting with the Platform, including: your bio updates, interests, content you publish and post (either publicly or anonymously), content you like, comments you leave, hashtags you use, photos you choose to share, etc. (commonly known as “User Generated Content” or “UGC”)
In addition, we can learn about your interests, preferences, and personality from the topics of the Communities you choose to take part in, your comments on other Users' content, and your general interaction with the Services.
Information of sensitive nature - You might choose to provide information about your religious or political views, sexual orientation, health-related data, racial or ethnic origin, philosophical beliefs, or other information describing your personality ("Sensitive Data"). You can provide sensitive information directly or inferred from other data, allowing us to learn about your preferences, views, habits, and beliefs. Sensitive Data may be subject to special protections under the laws of your jurisdiction.
We will use such content to provide you with the Services. we will use your interest topics to present and offer you Communities that we find relevant for you or present you with specific content through the Platform and process your posts information to allow you to publish and participate in a Community.
In addition, we may collect contextual and inferred data to enhance your user experience and present you (or as part of a group or Community) with advertisements relevant to your preferences, etc.
We may collect Sensitive Data to confirm your posts and publish them per your request. However, it is essential to know that we will not use your Sensitive Data or share it with third parties for commercial purposes unless permitted by applicable law and subject to the limitations and obligations imposed by such law (i.e., advertisements).
When we collect such information to provide you with the services you require, such as publishing your post or leaving a comment, we do so to fulfill our contract with you.
When we collect such information to optimize and enhance the Services, we do so based on our legitimate interest.
When we use this information to present you with advertisements, or when collecting and using Sensitive Information, we will require your consent, which you can withdraw at any time by contacting us.
One-On-One messaging:
When messaging with other Users through our one-on-one messaging feature, we process and keep a record of your messages, including: the identity of the corresponding parties, the date and time, the content of the messages, and whether a message was read or not.
We use such data to allow you to correspond with other Users.
We may also generally monitor conversation content to detect illegal activities, offensive or harassive content, and other violations of the Restrictions detailed in the Terms.
We do not use the content of private conversations for any other purpose, unless required to do so by law.
We process your conversation data to allow you to correspond through the Platform as part of fulfilling our contract with you.
We may be required to use your content to address any legal obligation or court order, in accordance with applicable law.
Support:
When you contact us for support, either through an online designated form or our designated email address, we will process your Registration Information and the content of our correspondence.
We will use the information to provide the support needed. We will retain the correspondence with you for our internal analytic purposes - to improve our support services and evidence the support we provided.
We process such information to fulfill contractual obligations.
Usage data and online identifiers:
When you use the Platform, information regarding such use is automatically generated and collected, which may include the click stream within the Platform, the use of the Services (i.e., the date and time your access a specific page or Community, and the time spent on each page, etc.).
Such data may be collected aggregated and anonymously. However, in other cases, it can be linked and connected to your User Account, directly in our app or through third-party services and features (such as SDKs, Catching mechanisms, and other technologies, as elaborated below).
Such information can also be retrieved from the device you use to install our Platform, directly or indirectly, and may include: type of device, apps you use, your Device ID (whether IDFA or GAID) and your Internet Protocol (IP) address, User ID.
We use this information to better understand how you are using our Services and how to improve our Services and for general, operational, and technical management of the Platform and Services. That allows us to understand our business better, analyze our operations, maintain, improve, innovate, plan, design, and develop the Platform, including new features.
We also use such data for statistical analysis to better understand Users’ preferences and decide how to improve the Services.
Further, we may collect these online identifiers to market the Services and analyze and measure our Users' interaction with the Platform and Services through third-party services and systems.
We process this information subject to our legitimate interest.
If and when we use this information for marketing purposes, we will do so based on your consent which can be withdrawn at any time by contacting us.
Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of Personal Data to third-party countries, as further detailed in the Transfer of Data section below, is based on the same lawful basis as stipulated in the table above.
In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms of Service, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interest.
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SDKs, CATCHING AND OTHER TRACKING TECHNOLOGIES
We use “cookies” and similar tracking technologies such as caching mechanisms and software developer kits (“SDK“) on our App and Services. A cookie is a small text file that a website places and stores on your device while you are viewing a website. Cookies are very helpful and can be used for various purposes. These purposes include: (i) allowing you to navigate between pages efficiently; (ii) enabling automatic activation of certain features; (iii) remembering your preferences; and (iv) making the interaction between you and our services quicker and easier. The SDKs create the opportunity to enhance t App with more functionality
Our use of SDK shall always be subject to applicable law.
The following SDKs are being utilized in the Platform:
Cookie/SDK
Purpose
Privacy Policy
Google Analytics
Analytical, Measurement & and Sign in
www.google.com/policies/privacy/partners
https://policies.google.com/technologies/managing?hl=en
https://tools.google.com/dlpage/gaoptout
For additional information regarding our use of Google products, click here.
Apple
Operational, Sign in & Essential
https://www.apple.com/legal/privacy/en-ww/
FireBase
Operational, Technical & Essential
https://firebase.google.com/support/privacy/
Flutter
Operational, Technical & Essential
https://docs.flutter.dev/security
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SHARING PERSONAL DATA
We share your Personal Data with third parties, including our partners or service providers that help us provide our Services. You can find in the table below information about the categories of such third-party recipients.
Category of Recipient
Data That Will Be Shared
Purpose of Sharing
Service providers
All types of Personal Data
We employ other companies and individuals to perform functions on our behalf. Examples include: cloud storage and computing services, sending communications, analyzing data, providing marketing and sales assistance (including advertising and event management), and identifying errors and crashes. Additionally, your data might be shared with other software developers whose services we use to perform our Service.
These third-party service providers have access to Personal Data needed to perform their services, but they are prohibited from using your Personal Data for any purposes other than providing us with requested services.
Any acquirer of our business
All types of Personal Data
We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Privacy Policy.
Enforcement of our rights and security monitoring.
All types of data
We may disclose Personal Data to enforce our policies and agreements and defend our rights. That includes the investigation of potential violations thereof, alleged illegal activity, or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Data to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.
Legal and law enforcement
Subject to law enforcement authority request.
We may share certain data when we believe it is appropriate to comply with law enforcement, governmental agencies, or authorized third parties or to protect our rights, property, Services’ security, or other Users.
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YOUR RIGHTS RELATED TO YOUR PERSONAL DATA
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the applicable data protection laws that apply to you, you might have the following rights regarding the Personal Data that we collect:
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Right to access your Personal Data;
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Right to rectification and amendment;
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Right to deletion/erasure;
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Right to restrict processing;
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Right to data portability;
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Right to object to the processing of Personal Data;
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Right to Non-Discrimination; and others.
If you wish to exercise any of your applicable rights, please contact us at: almog@gaya.app As noted, not all rights apply in any jurisdiction. However, we encourage you to approach us with any such inquiry, and we will handle your request according to the limitations and requirements imposed on us by applicable data protection laws regarding the request.
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OPT OUT OPTION
To provide our Services we collect certain Personal Data and we act as an independent controller or “business” as such terms are defined by applicable laws. Subject to this definition and your interaction with us we are required to provide you with disclosures and options to opt out. Therefore, please notice the following table mapping your various ways to opt out from certain Personal Data collection, in accordance to the device you hold:
INTERFACE
HOW TO OPT OUT
Apple Interface: iOS Settings.
You may opt out or influence personalized advertising iOS:
On your iPhone or iPad, go to Settings > Privacy > Apple Advertising and deselect Personalized Ads.
To learn more about how to affect advertising choices on various devices and different versions, please look at the information available here.
Android Interface.
To opt-out of ads on an Android device:
go to Settings > Privacy > Ads and enable opt out of Ads personalization.
In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads).
To learn even more about how to affect advertising choices on various devices and different versions, please look at the information available here.
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DATA RETENTION
We retain the Personal Data we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out.
Other circumstances in which we will retain your Personal Data for longer periods include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements; (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges; or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we may, at our sole discretion, delete or amend information from our systems without notice to you once we deem it is no longer necessary for such purposes.
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SECURITY
As detailed in the Terms, we design our systems with security and privacy in mind while implementing various security measures that comply with applicable laws and industry standards.
Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.
Please contact us at: almog@gaya.app, if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data.
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DATA TRANSFER
The data servers operating the Services and the Platform are in the EU. Gaya is an Israeli-based company. Any international transfer of Personal Data to a country different from the country where such data was collected will always be done after ensuring your Personal Data receives an adequate level of protection as required under applicable law.
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CHILDREN
Our Services are not intended for children under the age of 13. Therefore, we do not knowingly collect Personal Data via our Platform and Services from anyone under 13. If you believe any User is under 13, contact us immediately atalmog@gaya.app .