Privacy Policy

GroupXConnect respects your privacy. GroupXConnect LLC and its affiliates (“GroupXConnect” or the “Company”) offer scheduling and communication services related to group exercise and other group events to users of www.groupxc.com (the “Website”) and/or users of GroupXConnect’s mobile applications (the “Application”) (collectively referred to as the “Services”). When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, and delete your information. This Privacy Policy covers:

• User Accounts & Accessing the Services
• Information that is being collected
• Why GroupXConnect collects data
• Sharing your information
• Visibility
• Integration with social networks
• Integration with other third party services
• Controlling your personal information
• How GroupXConnect retains data we collect
• How does GroupXConnect use aggregated information
• Cookies
• Advertising campaigns
• Information security
• Compliance & cooperation with regulators
• Changes to this Privacy Policy

This Privacy Policy is incorporated as part of the GroupXConnect Terms of Use (the “Terms of Use” or the “Terms”). Your use of the Services is subject to the Terms of Use and this Privacy Policy and indicates your consent to them.

To use our Services you must be 16 years of age or older. If you are under 16, you may not download or use the Services.

In this Privacy Policy, the term “personal information” means information which you provide to us which personally identifies you, such as your name, email address or billing information, and, in certain circumstances, your location and schedule information or other data which can be reasonably linked to such information by GroupXConnect.

You can adjust your Privacy Settings in the app and choose which personal information we may collect about you and how your information is used.

Contact GroupXConnect – Privacy concerns reports

If you have any questions about this Privacy Policy, or if you believe that your privacy has been compromised in the course of using the Services, please contact GroupXConnect at: info@groupxc.com.

User Accounts & Accessing the Services

Please note that when you use our Services, GroupXConnect will set up an account (the “Account”). GroupXConnect will collect and use your information, including meta-data (as described below), in accordance with this Privacy Policy. This is the case whether or not you choose to actively register your Account, for example, by adding your email address or logging with your Google Account. When you register your Account:

• GroupXConnect will link all of your information with your registered Account. This includes information received from all devices and browsers which you have chosen to sign in ;
• With the exception described in the bullet below and as explained in the section “Visibility” below, your Account and information associated with your Account will be visible only to GroupXConnect; and
• When using the Services, your schedule and approximate location and other information you may choose to contribute will be visible to other users associated with this Account.
• GroupXConnect may also establish and require from time to time additional or different means of identification and authentication for logging in and accessing the Services or for accessing certain features or designated sections of the Services.
• Your login details are your responsibility. You are fully accountable for any use or misuse of your Account and personal details as a result of conveying your login details to someone else. You must maintain your login details in absolute confidentiality and avoid disclosing them to others. If you set a password, make sure that you change your password frequently and at least once every six months.

Information that is being collected

We want you to understand the types of information we collect as you use our services

GroupXConnect collects information to provide better services to all its users. The information GroupXConnect collects, and how that information is used, depends on how you choose to use our services and how you manage your privacy controls.

Information you create or provide to us:

• Account Information: information required when setting up an Account, such as your name or email address. Bear in mind that false, incorrect, or out-dated information may impair GroupXConnect’s ability to provide you with the Services and to contact you when necessary. GroupXConnect will explicitly indicate the fields for mandatory completion. If you do not enter the requisite data in these fields, you may not be able to register your Account or to be provided with certain features; and/or
• Information that you choose to share with GroupXConnect: information that you choose to share with GroupXConnect, including a username you have chosen, reports associated with your username, phone number, “home” or “work”, other “favorites”, schedule details, events you may attend, search queries, calendar information, and files you have uploaded to the service, including voice and audio files, if applicable. You can also choose to add payment information to your Account, if applicable, specifically for paid services (such as Be eXtra!). Even if you aren’t registered to a GroupXConnect Account, you might choose to provide us with information.
• Communication which you choose to conduct through the GroupXConnect Services: if you choose to use GroupXConnect to communicate with other GroupXConnect users or third parties through the GroupXConnect Services, such as chat messages or sending event invitations on the GroupXConnect platform. We may also collect information when you exchange communication with GroupXConnect, for example, if you submit a request, contact GroupXConnect’s support team, or report a violation to the abuse team.
• Information from your social networks which you choose to connect to your GroupXConnect Account: you may choose to connect your Account to your social network account(s). If you choose to do so, you may choose to share with GroupXConnect and/or other users information from your social network accounts, such as your Facebook profile photo or other personal information shared by you. For more information see Integration with social networks, below.
• “Invite friends feature”: if you use the “Invite Friends” feature, GroupXConnect will collect:
  • Periodically, GroupXConnect will collect all of the phone numbers which are stored on your device’s phone contacts book. With regards to the “invite friends” feature we only collect numbers in a form which is anonymous to GroupXConnect. This information will be used to help us find and create a list of other GroupXConnect users who you may know and with whom you may wish to connect. Note that we will not collect names, addresses or other information from your device’s phone contacts book, however some of this information may be saved locally on your device and may be used within searches for your friend’s name or address within the Services. and/or
  • Your phone number. Your phone number will be used to verify your account and as part of the “invite friends” feature, if applicable, to help find and create a list of other GroupXConnect users who you may know and with whom you may wish to connect.

You may also provide additional information that will be used to personalize the Services and enhance your experience with the Services.

Information we collect as you use our services

We collect information about your activity in the Services, which we use to provide you with the Services of GroupXConnect, including features which are meant to personalize your experience. This includes things like finding scheduled events near you or within your Pack. The activity information we collect may include:

• Terms or events you searched;
• Your views and interactions with content and ads;
• Your voice and audio information when you use voice and audio features;
• Communication or other content you chose to share with any third party, including GroupXConnect users through the Services;
• Your activity on third-party sites and apps that you chose to link to your GroupXConnect account or that you interact with through the Service.
• Your activity as a GroupXConnect event creator, such as users you invited and events that you accepted.

Meta-data (information about your device, browser and app use):

GroupXConnect collects information about the use of the Services and information from the device you have GroupXConnect installed on or the browser from which you use our Services. For example:

• GroupXConnect may collect and record how often you use our Services and for how long, your device type, unique identifiers, operating system type & version, battery usage, the third party web pages or applications you visit or use or interact with via the Application, information that you viewed on our Services, advertisements that are shown to you or that you view or click on, the fact that you used the Services to communicate with other users and the fact that you used third parties application/services via GroupXConnect to communicate with third parties, and the duration of such communications, the Internet Protocol (IP) address and the name of the domain that serves you to access the Services, and the geographic location of the device that you are using to log in and use GroupXConnect on.
• GroupXConnect may also collect information about apps installed on your device that GroupXConnect can link with.
• We also collect information about the interaction of your devices with our Services, including, system activity, and the date, time, and referrer URL of your request.

Information we collect about you from our partners

We work with ad partners, including advertisers on our platform and entities that belong to the Google group of companies, in order to show you more relevant and useful ads based on your GroupXConnect activity and information associated with your device’s identifier (i.e, Advertising identifiers or similar technologies) shared with us by our ad partners. Your device’s identifier can be managed in your device’s settings.

We may also receive aggregated, non-personally identifiable information and analysis from third parties measurement services which help us understand how our users interact with our ads. We may also receive information from third party services about how GroupXConnect’s own marketing efforts performed on third party sites or platforms.

We use various technologies to collect and store information, including, cookies, Advertising ID available on Android mobile devices or similar technologies, local storage, browser web storage, application data caches, databases, and server logs.

Why GroupXConnect collects data

GroupXConnect may use information collected from or provided by you for the following purposes:

Provide our services

We use your information to deliver our services. For example:

• Use your events and pack information and/or search query history to provide event alerts and to provide information about sites, shops and other places and attractions in your close vicinity; and
• (If you have opted in to the “invite friends” feature), use your phone number and the phone numbers which are stored in your device’s phone book to find and create a list of other GroupXConnect users who you may know and with whom you may wish to connect.
• To provide advertising services, including personalized ads, in accordance with the section titled ‘Advertising campaigns’ under this Privacy Policy.
• To share your submissions with other users of the Services and to facilitate communication between you, GroupXConnect and other users.

Maintain & improve our services

• We also use your information to ensure our services are working as intended, such as tracking outages or troubleshooting issues you report to us. And we use your information to improve the service or to develop new features or services.

Provide personalized services, including content and ads

• We use the information we collect to operate the Services and to customize your experience with the Services.
• We may also use the information to provide you with support and handle requests and complaints.
• Depending on your settings, we may also show you personalized ads based on your interests and past activity. For more information see section titled ‘Advertising campaigns’ under this Privacy Policy.

Measure performance

• We use data for analytics and measurement to understand how our services are used. For example, we analyze data about your usage of the Services to do things like optimize product design. We also use the data we collected about the ads you view or interact with (e.g. click on) to help advertisers understand the performance of their ad campaigns and to provide them with aggregated reports. We may also use data to measure the usability and effectiveness of GroupXConnect’s own marketing efforts on third party sites or platforms.

Communicate with you

• We also use your information to send you updates, notices, announcements, users’ requests and additional information related to the Services (including through push notifications, email address and SMS);
• We may also use your information to conduct surveys and questionnaires; and if you contact GroupXConnect we may keep a record of your request in order to help solve any issues you might be facing.
• Subject to your prior indication of consent (to the extent required under applicable law), we may also use the email address that you provided to send you promotional and/or marketing materials. At any time you may choose not to receive such materials by clicking on the “Unsubscribe” link in the email messages that we may send to you. In any case, GroupXConnect will not share your contact details with any advertiser, unless explicitly permitted or required by law.

To protect GroupXConnect, our users, the public and for Legal reasons

We may also use and process your information and content, using different technologies to the following purposes:

• To enforce the Terms of Use or Privacy Policy;
• To contact you when GroupXConnect believes it to be necessary;
• To comply with any applicable law and assist law enforcement agencies under any applicable law, when GroupXConnect has a good faith belief that GroupXConnect’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;
• To detect abuse and illegal activity; to detect and prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;
• To handle breakdowns and malfunctions;
• To take any action in any case of dispute, or legal proceeding of any kind between you and the Services, or between you and other users or third parties with respect to, or in relation with the Services;
• For purposes provided under this Privacy Policy and Terms of Use;
• To help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to security risks, and technical issues that could harm GroupXConnect, our users, or the public;
• To create aggregated and/or anonymous data (where such data does not enable the identification of a specific user). See “How does GroupXConnect use aggregated information”, below;

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.

Sharing your information

Personal information that you share

The Services are based on a community of users publicly sharing information with GroupXConnect and with other members of that community.

In particular, users may choose to share personal information such as name, age, gender, picture, their location information, reports and other files. This information may be shared either directly to the Services and to all users, or just to your friends on GroupXConnect. This information may also be shared via third party services (such as social networks) which interact with the Services upon such users’ choice.

You can decide whether or not to upload content to the Services. However any content that you choose to share and submit for posting is neither private nor confidential and you should expect that it may be made public and known to others. Information you choose to upload will be posted along with your user name and other information including personal information you attached to your publicly available user profile. Therefore, you must exercise caution and common sense when submitting information. At the very least you should demonstrate the same degree of caution as when publishing personal information by means other than the Internet and cellular services.

In any event (but except as detailed below with respect to information shared from your social network accounts according to your privacy settings for such social network accounts), your email address will not be visible to others through any reports or user posts that you share or upload.

We, at GroupXConnect, take great measures to provide you with the best experience you can have while using the Services. However, GroupXConnect has no control over the conduct of any user and disclaims all liability in this regard. Users are advised to carefully and thoroughly consider whether or not to make public or available any information and carefully examine all necessary details related to any communication with other users prior to any engagement or communication being made.

Participating in any user’s activities as a result, directly or indirectly, from using GroupXConnect, is entirely at your own risk. GroupXConnect is not a party to any agreement entered into between the users in any circumstances. The user has the sole and ultimate responsibility regarding compliance with all laws, regulations or any other duty. We do not accept any liability for any loss, damage, cost or expense that you may suffer or incur as a result of or in connection with your participation in any activity or event initiated, held or conducted by a user or a third party nor in connection to any agreement between the users or third parties, including any activity or event related in any way, directly or indirectly, the Services or the use thereof.

When GroupXConnect shares your information

GroupXConnect does not sell, rent or lease your personal information to third parties.

GroupXConnect will not share your personal information with others, without your permission, except for the following purposes and to the extent necessary in GroupXConnect’s good-faith discretion:

• As necessary for the facilitation and operation of the Services. For example, making public events you create and which are associated with your username and your location;
• If GroupXConnect reasonably believes that you have breached the Terms of Use or is investigating potential breach of the Terms of Use, or believes that you abused your rights to use the Services, or performed any act or omission that GroupXConnect reasonably believes to be violating any applicable law, rules, or regulations. GroupXConnect may share your information in these cases, with law enforcement agencies and other competent authorities and with any third party as may be required to handle any result of your wrongdoing;
• If GroupXConnect is required, or reasonably believes that it is required by law to share or disclose your information;
• In any case of dispute, or legal proceeding of any kind between you and GroupXConnect, or between you and other users with respect to, or in relation with the Services;
• In any case where GroupXConnect reasonably believes that sharing information is necessary to protect against harm to the rights, property or safety of GroupXConnect, our users, or the public as required or permitted by law, including to prevent imminent physical damage or damage to property;
• To detect, prevent, or otherwise address fraud, security, or technical issues;
• If GroupXConnect organizes the operation of the Services within a different framework, or through another legal structure or entity, or if GroupXConnect is acquired by, or merged into or with another entity, or if GroupXConnect enters bankruptcy, provided however, that those entities agree to be bound by the provisions of this Privacy Policy, with respective changes taken into consideration;
• To collect, store, hold and manage your personal information through cloud based or hosting services or a third party or a party affiliated or connected to GroupXConnect, as reasonable for business purposes, which may be located in the European Union and the U.S.A., potentially countries outside of your jurisdiction;
• GroupXConnect may also share personal information with companies or organizations connected or affiliated with GroupXConnect, such as subsidiaries, sister-companies and parent companies;
• We work with other services for advertising and ad measurement purposes. In order to help advertisers decide what ads to show on GroupXConnect, we may share information with these services, such as a unique identifier for advertising (i.e, Advertising ID available on Android mobile devices or similar technologies). For more information see section titled ‘Advertising campaigns’ under this Privacy Policy.
• We also work with selected advertising and measurement services which help us understand how our users interact with ads served in our platform and in order to provide marketing, advertising and measurement services for GroupXConnect with respect to GroupXConnect’s own marketing efforts, by using and sharing devices’ identifiers (i.e, Advertising ID, cookies or similar technologies).
• Personal information may also be shared with GroupXConnect’s trusted partners and service providers to process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures.

Visibility

Please note that your username and some other information will be visible to others. Note that your username will be included along with any information you submit for posting (such as events or chat messages). It will therefore be visible to others. Also – your friends on GroupXConnect will see your name & profile photo and any other information you chose to share with them.

If you prefer to remain private on the GroupXConnect app, you can set the Application not to show your events on the calendar. To do so you should go to the Privacy Settings and adjust accordingly by switching off all visibility options. If off, some features may not be available. If you make this choice, while you will be ‘invisible’ on the calendar to other users, your events and calendar information will continue to be collected by GroupXConnect for the purposes listed in this Privacy Policy.

 

Integration with social networks

You may choose to share information between your GroupXConnect account and your social network account (such as Facebook). Through this option, you may choose to have personal information and other content about you available from social networks, transmitted and shared through the Services. Similarly, you may choose to have personal information and other content about you available from GroupXConnect, including your schedule and event information, transmitted to and shared through your social network account.

By setting your GroupXConnect Account to integrate with social networks, including by signing onto GroupXConnect by using your social network account, you agree to share information (including personal information) between GroupXConnect and such social networks, for the purposes provided under this Privacy Policy.

The social network’s use of information made available by GroupXConnect is governed by that social network’s privacy policy and controlled by the social network, not by this Privacy Policy or GroupXConnect.

When you connect to the social network account through the Services for the first time or otherwise make the Services interact with your social network account, you will be asked by the social network to permit the social network to share your personal information stored on such social network with GroupXConnect. We collect your information from your social network account only in accordance with the permissions granted by you (such as your name, email address, list of friends, profile picture and other information available via the applicable social network).

You understand and agree that the Services may access, make available and store such information so that it is available on and through your GroupXConnect Account, until your GroupXConnect Account is deleted.

Please note that certain information which you have defined as private on your third party social network accounts may become public to other GroupXConnect Users through the Services once you have allowed the social network to share such information with GroupXConnect.

Integration with other third party services

GroupXConnect may offer you the option to link GroupXConnect to third party services that may be useful to you. Where GroupXConnect detects an integration may be available (either because a third party service attempts to link to GroupXConnect, or GroupXConnect detects an installed service on the device which has an integration option, or you request a particular integration), GroupXConnect will ask for confirmation to connect the accounts. If you choose to connect the accounts, GroupXConnect will ask for your permission to share data with the third party service. You should only agree to connect accounts if you are comfortable with the third party service receiving the data set out at the time of connecting the accounts and GroupXConnect is not responsible for the third party service’s use of data. You can disconnect GroupXConnect and the third party service at any time and GroupXConnect will cease sharing data with that service from the point of disconnection onwards.

Controlling your personal information

You can always review and update certain information by visiting your Account & Login settings (such as your phone, name, photo and more) or the in-app profile menu.

If you find that the information associated with your Account is not accurate, complete or updated, then you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from setting up an Account and impair the ability to provide you with Services.

Privacy controls

Your in-app Privacy Settings provide you with quick access to settings and tools that let you safeguard your data and decide how your information can make GroupXConnect services work better for you. For example, you can control your visibility on the calendar and manage your preferences about the ads shown to you on GroupXConnect.

There are other ways to control the information GroupXConnect collects whether or not you’re signed in to a GroupXConnect Account, including device-level settings: your device may have controls that determine what information we collect. For example, you can modify location settings on your device.

Deleting your information

If you would like us to delete your Account, please send an email to info@groupxc.com. On receiving such a request, GroupXConnect will use reasonable efforts to delete such information, however please note that information may not be deleted immediately from our back-up systems. We aim to initiate the deletion process immediately after your request. Once we receive your request, your data will no longer be used to personalize your GroupXConnect experience. We then begin a process designed to safely and completely delete the data from our storage systems. This process generally takes around 2 months from the time of deletion. As with any deletion process, things like routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the processes and time frames defined in this policy. We maintain systems designed to detect and remediate such issues.

How GroupXConnect retains data we collect

Some data you can delete whenever you like, some data is deleted automatically, and some data we retain for longer periods of time when necessary. This section describes why we hold onto different types of data for different periods of time.

• Information retained until you remove it – such as your pack, events, favorites, email address and other account related information. We’ll keep this data in your GroupXConnect Account until you choose to remove it and/or update it.
• Data that expires after a specific period of time – in some cases, you don’t need to actively delete your information as we set retention timeframes based on the reason for the data’s collection. For example, if you choose to connect your calendar to your GroupXConnect Account, we extract your calendar events for several days in advance and delete them after their occurrence. We may also take steps to anonymize certain data within set timeperiods.
• Information retained until your GroupXConnect Account is deleted – we may keep some data for the life of your GroupXConnect Account if it’s useful for helping us understand how users interact with our features and how we can improve our services.
• Information retained for extended time periods for limited purposes – sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period of time. For example, when GroupXConnect processes a payment for you, we’ll retain this data for longer periods of time as required for tax or accounting purposes. Reasons we might retain some data for extended periods of time include:
  • Security, fraud & abuse prevention
  • Financial record-keeping
  • Complying with legal or regulatory requirements
  • Ensuring the continuity of our services
  • Direct communications with GroupXConnect

How does GroupXConnect use aggregated information?

GroupXConnect may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes (including advertising).

GroupXConnect may also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services’ providers, partners and any other third party.

Cookies

GroupXConnect may use cookies and similar technologies on the Services. Cookies are packets of information sent by the Website’s servers to your web browser and then sent back by the browser each time it accesses the Website’s servers.

GroupXConnect may use cookies for various purposes, such as to save you the need to re-enter your username and password each time you log in, to facilitate the use of the Website, to collect statistical information, to verify information, and to customize the Website to your personal preferences and for information security purposes.

Some of the cookies may expire when the session ends and you exit your browser. Other cookies are saved on your computer’s hard drive. If you wish to block the Website’s cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Website, or certain features thereof.

Advertising campaigns

GroupXConnect allows advertisers to run ad campaigns on the Services.

The information and advertisements that you see when accessing the Services may be targeted on the basis of your current GroupXConnect activity, such as your current location, your destination or contextual information based on your current events. For example: if you search for “yoga” you may see an ad for a local yoga studio.

Depending on your settings, you may also see ads personalized to you based on:

• Information we received from you (for example, your saved addresses)
• Past activity and search query history (for example, events that appear in your calendar)
• Information from our ad partners, including entities that belong to the Google group of companies and other trusted ad partners.

You can decide whether we’ll show you personalized ads or not through your in-app Privacy Settings–>Ads personalization. Note: turning Ads personalization off does not turn off ads – only their personalization.

Please note:

• We don’t knowingly collect nor do we show you personalized ads based on sensitive categories, such as race, religion, sexual orientation, or health.
• We don’t share information that personally identifies you with advertisers, such as your name or email, unless you ask us to. For example, if you see an ad for a nearby yoga studio and select the “tap to call” button, we’ll connect your call and share your phone number with the flower shop.
• As described under “When GroupXConnect shares your information” section above, we work with other services for advertising and ad measurement purposes. In order to help advertisers decide what ads to show on GroupXConnect, GroupXConnect may share information with these services such as a unique identifier for advertising (Advertising ID available on Android mobile devices or similar technologies).
• The Ads personalization control described above apply to personalized ads served by GroupXConnect on the GroupXConnect platform and they do not apply to ads served on third parties platforms, including on GroupXConnect’s behalf.
• When you visit a third party website from the Application, such third party may use cookies on your computer. The third party’s use of cookies is subject to their own privacy policies and not to this Privacy Policy. If you wish to study the privacy policies of those third parties you should visit their services, or contact them directly.

The Services includes an internal messaging system which provides you the ability to send and receive messages to and from other users, and to receive marketing messages from us. You hereby agree that we may use the internal messaging system for the purpose of informing you regarding products or services, which may interest you.

Please note however that other GroupXConnect users are not allowed to use your contact details or our internal messaging account for commercial advertising purposes. If you have encountered any user generated advertising material, please inform us through info@groupxc.com.

It is clarified that we are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable for any loss, damage, cost or expense that you may suffer or incur as a result or in connection thereof.

Information security

GroupXConnect considers information security to be a top priority. GroupXConnect services are built with strong security features that continuously protect your information. GroupXConnect implements systems, applications and procedures to secure your personal information, to minimize the risk of theft, damage, loss of information, or unauthorized access or use of information. For example, we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems. In addition, we restrict access to personal information to GroupXConnect employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you.

However, these measures are unable to provide absolute assurance. Therefore, although GroupXConnect takes great efforts to protect your personal information, GroupXConnect cannot guarantee and you cannot reasonably expect that GroupXConnect’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Compliance & cooperation with regulators

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

Data transfers

We store data on servers located around the world and your information may be processed on servers located outside of the country where you live. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

European requirements

If European Union (EU) or United Kingdom (UK) data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to request access to, update, remove, delete, and restrict the processing of your information.

You also have the right to object to the processing of your information.

We process your information for the purposes described in this policy, based on the following legal grounds:

With your consent

We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. You can manage your settings at any time, including your in-app Privacy Settings.

When we’re pursuing legitimate interests

We process your information for our legitimate interests and those of third parties (such as partners including advertisers, in order to report use statistics) while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:

• Providing, maintaining, and improving our services to meet the needs of our users
• Developing new services and features that are useful for our users
• Understanding how people use our services (including how they interact with our ads) to ensure and improve the performance of our services
• Customizing our services to provide you with a better user experience
• Marketing to inform users about our services
• Providing advertising, which keeps many of our services free
• Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our services
• Protecting against harm to the rights, property or safety of GroupXConnect, our users, or the public as required or permitted by law, including disclosing information to government authorities
• Performing research that improves our services for our users and benefits the public
• Fulfilling obligations to our partners like developers and rights holders
• Enforcing legal claims, including investigation of potential violations of applicable Terms of Use

When we’re providing a service

We process your data to provide a service you’ve asked for under a contract (including our terms of use).

When we’re complying with legal obligations

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process or an enforceable governmental request.

If you have questions, you can contact GroupXConnect and our data protection office at: info@groupxc.com. And you can contact your local data protection authority if you have concerns regarding your rights under local law.

Brazilian requirements

If Brazilian data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to:

• Obtain confirmation on whether we process your information
• Request access to, update, review, anonymise, and remove your information
• Object to or restrict the processing of your information
• Export your information to another service

We process your information for the purposes described in this policy, based on the following legal grounds:

With your consent

Where we ask for your consent to process your information for specific purposes, you do not have to provide your consent but where you choose to do so, you have the right to withdraw your consent at any time. You can manage your settings at any time, including your in-app Privacy Settings. You also have the right to obtain information about the effects of not providing your consent to processing for specific purposes.

When we’re pursuing legitimate interests

We process your information for our legitimate interests and those of third parties (such as partners including advertisers, in order to report use statistics) while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:

• Providing, maintaining, and improving our services to meet the needs of our users
• Developing new services and features that are useful for our users
• Understanding how people use our services (including how they interact with our ads) to ensure and improve the performance of our services
• Customizing our services to provide you with a better user experience
• Marketing to inform users about our services
• Providing advertising, which keeps many of our services free
• Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our services
• Protecting against harm to the rights, property or safety of GroupXConnect, our users, or the public as required or permitted by law, including disclosing information to government authorities
• Performing research that improves our services for our users and benefits the public
• Fulfilling obligations to our partners like developers and rights holders
• Enforcing legal claims, including investigation of potential violations of applicable Terms of Service

When we’re providing a service

We process your data to provide a service you’ve asked for under a contract (including our terms of use).

When we’re complying with legal obligations

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process or an enforceable governmental request. If you have questions, you can contact GroupXConnect and our data protection office at info@groupxc.com. And you can contact your local data protection authority if you have concerns regarding your rights under Brazilian law.

California requirement

The California Consumer Privacy Act (CCPA) requires specific disclosures for California residents. This Privacy Policy is designed to help you understand how GroupXConnect handles your information:

• We explain the categories of information GroupXConnect collects and the sources of that information in “Information That is being collected”.
• We explain how GroupXConnect uses information in “Why GroupXConnect collects data.”
• We explain when GroupXConnect may share information in “Sharing your information.” GroupXConnect does not sell your personal information.

The CCPA also provides the right to request information about how GroupXConnect collects, uses, and discloses your personal information. And it gives you the right to access your information and request that GroupXConnect delete that information. Finally, the CCPA provides the right to not be discriminated against for exercising your privacy rights.

We describe the choices you have to manage your privacy and data in “Controlling your personal information” section. If you have questions or requests related to your rights under the CCPA, you (or your authorized agent) can also contact GroupXConnect at info@groupxc.com.

Changes to this Privacy Policy

GroupXConnect may from time to time change the terms of this Privacy Policy. Substantial changes will take effect 30 days after GroupXConnect has posted a:

• System message to users notifying them of changes to the Privacy Policy; and
• Notification on the Website’s homepage or any other relevant web pages, explaining the changes to the Privacy Policy alongside a comparison of the “old” and “new” versions of the Privacy Policy.

Other changes will take effect 7 days after their initial posting on the Website. However, if GroupXConnect amends this Privacy Policy to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required.

You agree to be bound by any of the changes made in the terms of this Privacy Policy. Continuing to use the Services will indicate your acceptance of the amended terms. If you do not agree with any of the amended terms, you must avoid any further use of the Services.