1. Introduction
This Privacy Policy explains how [Company Name] (“we,” “our,” “us”) collects, uses, shares, and protects your personal information when you use our Service. By accessing or using the Service, you agree to the practices described below.
2. Information We Collect
2.1. Personal Information You Provide
- Account registration: name, email address, phone number, password.
- Profile information: avatar, bio, preferences.
- Content you upload: reviews, photos, comments.
2.2. Usage Data & Cookies
- Usage Data: pages visited, features used, timestamps, logs.
- Device Data: IP address, browser type, operating system.
- Cookies & Tracking: session cookies, analytics cookies to improve performance and personalize content.
2.3. Third-Party Data
- Information from social logins (e.g. Google, Facebook) when you authorize.
- Data from integrated services (e.g. payment processors).
3. How We Use Your Information
We use your information for:
- Providing & Improving the Service: authenticate users, deliver content, monitor usage.
- Communication: respond to inquiries, send updates, marketing (with opt-out).
- Analytics & Research: understand trends, detect fraud, optimize features.
- Legal Compliance: enforce our Terms, comply with law enforcement requests.
4. Legal Basis for Processing (GDPR Users)
- Consent: where you voluntarily provide data for a specific purpose (e.g. newsletter).
- Contractual Necessity: to fulfill our agreement (e.g. account management).
- Legitimate Interests: administer the Service, prevent fraud, ensure security.
5. Sharing & Disclosure
We may share your information with:
- Service Providers: hosting, analytics, payment processors, email delivery.
- Affiliates & Subsidiaries: for internal business operations.
- Legal Authorities: to respond to lawful requests or protect rights.
- Business Transfers: in connection with a merger, acquisition, or sale of assets (you will be notified).
We never sell your personal data to third parties.
6. International Transfers
Your data may be stored and processed in locations outside your country. We ensure adequate safeguards (e.g. standard contractual clauses) for such transfers.
7. Data Security
We implement reasonable technical and organizational measures (encryption at rest/in transit, access controls, regular audits) to protect your information. However, no method of transmission over the Internet is 100% secure.
8. Data Retention
We retain personal data only as long as necessary to fulfill the purposes outlined here or to comply with legal obligations (e.g. tax, accounting). Afterward, data is securely deleted or anonymized.
9. Your Rights
Depending on your jurisdiction, you may have the right to:
- Access, correct, or delete your personal data.
- Object to or restrict processing.
- Port your data to another service.
- Withdraw consent where processing is based on consent.
To exercise these rights, contact us at privacy@gappy.jp.
10. Children’s Privacy
Our Service is not directed to children under 13. We do not knowingly collect data from minors. If you believe we have inadvertently done so, please contact us to delete that information.
11. Third-Party Links
Our Service may contain links to external sites. We are not responsible for their privacy practices; please review their policies separately.
12. Changes to This Privacy Policy
We may update this Policy for legal, technical, or business reasons. We will post the new date at the top and, for material changes, provide notice via email or in-app.
13. Contact Information
Privacy Officer
Gappy Inc.
Tokyo, Japan
Email: privacy@gappy.jp