Last updated 12-02-2024
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1. Introduction
Gainify ("Gainify," "we," "us," or "our") is committed to protecting the privacy of our users ("you" or "your"). This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information when you access or use our equity research platform, including our website at www.gainify.io, mobile applications, and related services (collectively, the "Services"). By accessing or using our Services, you agree to the terms of this Privacy Policy.
2. Scope of Policy
This Privacy Policy applies to all users of our Services worldwide, including but not limited to users in the United States, European Union (EU), United Kingdom (UK), Australia, and other jurisdictions. It governs the handling of personal information collected through our Services, as well as information collected through other means connected to the Services, such as emails or electronic communications.
3. Definitions
"Personal Information": Any information relating to an identified or identifiable natural person."Processing": Any operation performed on personal data, such as collection, storage, use, disclosure, or deletion."Data Controller": The entity that determines the purposes and means of processing personal data."Data Processor": The entity that processes personal data on behalf of the Data Controller.4. We Collect
We collect various types of information to provide and improve our Services:
4.1 Personal Information
Contact Information: Name, Surname and email address.Account Credentials: Username, password, and any other information you provide when creating an account as well as your account information with one of the following social Internet services: Facebook, Twitter, Google, Yahoo!, LinkedIn, Apple.Payment Information: Credit or debit card details, billing address, and other financial data necessary to process your payments. We use third-party payment processors and do not store full payment card information on our servers.Communications: Records of your communications with us, including support requests, feedback, and other correspondence.Profile Information: Preferences, interests, and any other personal details you choose to provide in your account profile.User Content: When you engage with our Services, you may provide various types of information, including inputs, file uploads, and feedback through your Client or User account. We gather this User Content to deliver and enhance our Services, support interactions among users, and improve your overall experience.4.2 Non-Personal Information
Usage Data: Information about how you use our Services, such as pages viewed, time spent on pages, clickstream data, search queries, and other diagnostic data.Device Information: Information about the device you use to access our Services, including IP address, browser type, operating system, device identifiers, and mobile network information.Location Data: General geographic location based on your IP address.Cookies and Similar Technologies: Data collected through cookies, web beacons, pixels, and other tracking technologies to understand your preferences and enhance your experience.4.3 Information from Third Parties
Social Media Platforms: If you choose to link or sign in to your account with social media services (e.g., Google), we may collect information from those services, subject to your privacy settings.Third-Party Services: Information from partners and service providers that help us deliver or improve our Services, such as analytics providers or advertising networks.5. How We Collect Information
5.1 Information You Provide Directly
Account Registration: When you create or modify your account.Transactions: When you subscribe to our Services or make a purchase.Communications: When you contact us directly for support or feedback.Surveys and Promotions: When you participate in surveys, promotions, or marketing campaigns.User Content: When you engage with our Services, you may provide various types of information, including inputs, file uploads, and feedback through your Client or User account.5.2 Information Collected Automatically
Through Cookies and Tracking Technologies: We collect information as you navigate the Services, using cookies and similar technologies.Usage Analytics: We use analytics tools to understand how users interact with our Services.5.3 Information from Third Parties
Service Providers: We may receive information from third-party services that assist us in providing the Services.Public Sources: Information from publicly available sources.6. How We Use Your Information
We use your information for various purposes, including but not limited to:
6.1 Service Delivery and Enhancement
Provide Services: To operate, maintain, and provide you with the features and functionality of the Services.Personalization: To customize your experience, such as displaying content tailored to your interests.Account Management: To manage your account, authenticate users, and provide customer support.Process Transactions: To process payments, subscriptions, and other financial activities.6.2 Communication
Administrative Messages: To send you important information regarding the Services, such as changes to terms, conditions, and policies.Promotional Communications: To send newsletters, offers, and other marketing communications, subject to your communication preferences.6.3 Analytics and Improvement
Usage Analysis: To monitor and analyze usage patterns and trends to improve the Services.Research and Development: To develop new products, services, and features.6.4 Legal and Compliance
Legal Obligations: To comply with applicable laws, regulations, and legal processes.Protection of Rights: To enforce our Terms of Service and protect the security and integrity of our Services.6.5 Other Purposes
Consent-Based Activities: For any other purpose disclosed to you with your consent.7. Legal Bases for Processing Personal Information
We process your personal information based on one or more of the following legal grounds:
7.1 Consent
When you have given explicit consent for a specific purpose.7.2 Contract Performance
To fulfill our contractual obligations to you, such as providing the Services you have requested.7.3 Legal Obligations
To comply with legal and regulatory requirements.7.4 Legitimate Interests
For purposes such as fraud prevention, network security, and improving our Services, provided that such processing does not outweigh your rights and freedoms.8. Disclosure of Your Information
We may share your information in the following circumstances:
8.1 Service Providers
Third-Party Providers: We employ third-party companies and individuals to facilitate our Services ("Service Providers"), such as payment processors, hosting providers, analytics services, and customer support. These third parties have access to your personal information only to perform tasks on our behalf and are obligated not to disclose or use it for any other purpose.8.2 Affiliates and Partners
Affiliates: We may share your information with our affiliates and subsidiaries, in which case we will require them to honor this Privacy Policy.Business Partners: With your consent, we may share information with trusted partners to offer you certain products, services, or promotions.8.3 Legal Compliance and Protection
Legal Requirements: We may disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., court orders, subpoenas).Protection of Rights: To enforce our Terms of Service, protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.8.4 Business Transfers
Mergers and Acquisitions: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your personal information may be transferred as part of the transaction. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy.8.5 With Your Consent
Consent-Based Sharing: We may disclose your personal information for any purpose with your explicit consent.9. International Data Transfers
Your information may be transferred to—and maintained on—servers and databases located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may differ from those in your jurisdiction. To ensure that your personal information remains protected, we implement the following safeguards:
Standard Contractual Clauses (SCCs): We utilize SCCs approved by the European Commission to provide appropriate safeguards for data transfers from the European Economic Area (EEA) to countries outside the EEA.Binding Corporate Rules (BCRs): For data transfers within our corporate group, we adhere to BCRs approved by relevant supervisory authorities.Privacy Shield Framework: Although the EU-US Privacy Shield has been invalidated, we continually monitor and adopt alternative frameworks and best practices to ensure compliance with international data protection standards.Data Processing Agreements (DPAs): We enter into DPAs with all our service providers to ensure they adhere to strict data protection obligations equivalent to those outlined in this Privacy Policy.By implementing these measures, we strive to ensure that your personal data is handled securely and in compliance with applicable international data protection laws.
10. Security of Your Information
We implement a variety of security measures to maintain the safety of your personal information:
Encryption: Data transmitted over the internet is encrypted using Secure Socket Layer (SSL) or Transport Layer Security (TLS) technology.Access Controls: Access to your personal information is restricted to authorized personnel who need to know that information to process it.Security Protocols: Regular audits, vulnerability scans, and updates to our security practices.Despite these measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.
11. Data Retention
We will retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The retention periods for different categories of personal information are as follows:
Account Information: Retained for the duration of your account existence and for 2 years after account deletion to comply with legal obligations and for legitimate business purposes such as fraud prevention and improving our Services.Payment Information: Stored only for the time necessary to process transactions and comply with financial regulations, typically no longer than 7 years.Communication Records: Maintained for up to 5 years to address support requests, resolve disputes, and enforce our agreements.Usage Data and Analytics: Retained in an aggregated and anonymized form indefinitely for statistical analysis and improvement of our Services.Identification Documents: Kept for 10 years post-account termination to comply with regulatory requirements and prevent fraudulent activities.Upon expiration of the applicable retention period, we will securely delete or anonymize your personal information in accordance with legal requirements and industry best practices.
12. Your Rights and Choices
Depending on your jurisdiction, you may have the following rights regarding your personal information:
12.1 Access and Correction
Right to Access: You have the right to request access to the personal information we hold about you.Right to Rectification: You may request that we correct or update any inaccurate or incomplete personal information.12.2 Deletion
Right to Erasure: You have the right to request the deletion of your personal information under certain circumstances, such as when the data is no longer necessary for the purposes it was collected.12.3 Objection and Restriction
Right to Object: You may object to the processing of your personal information based on legitimate interests or for direct marketing purposes.Right to Restrict Processing: You may request that we restrict the processing of your personal information under certain conditions.12.4 Data Portability
Right to Data Portability: You may request a copy of your personal information in a structured, commonly used, and machine-readable format, and have the right to transmit that data to another controller.12.5 Withdraw Consent
Right to Withdraw Consent: If processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.12.6 Automated Decision-Making
Rights Regarding Automated Decisions: You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects concerning you or similarly significantly affect you.12.7 Marketing
You may receive marketing emails about products or services similar to those you are subscribed to, including information about events and promotions that may interest you, unless you have opted out. We will send other promotional information by email only with your consent, which you provided when you supplied your personal data. You can opt out of receiving marketing communications at any time by clicking 'unsubscribe' in our emails.
12.8 Account Deletion
You may choose to delete your account through the Profile settings on our Website or application. Upon requesting deletion, your account will be removed after 30 days, during which you can cancel the deletion process if desired. Please note that while your personal data will be deleted, certain information such as published ideas/scripts and messages sent to other users will remain to maintain platform integrity. Additionally, for legal and business purposes, we may retain specific data (e.g., transaction logs, financial records) for up to 10 years in compliance with applicable laws. Be aware that search engines and third parties may retain copies of your publicly available information even after account deletion.
12.9 How to Exercise Your Rights
To exercise any of these rights, please contact us at support@gainify.io. We may request specific information from you to confirm your identity and ensure your right to access your personal information.
13. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to enhance your experience. These technologies help us understand user behavior, remember your preferences, and improve our Services.
13.1 Types of Cookies Used
Essential Cookies: Necessary for the operation of our Services.Analytical/Performance Cookies: Allow us to recognize and count the number of visitors and see how visitors move around our Services.Functionality Cookies: Used to recognize you when you return to our Services.Targeting Cookies: Record your visit to our Services, the pages you have visited, and the links you have followed.13.2 Managing Cookies
You can control the use of cookies at the individual browser level. However, if you choose to disable cookies, it may limit your use of certain features or functions on our Services.
For detailed information, please see our Cookie Policy.
14. Children's Privacy
Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you become aware that a child has provided us with personal information, please contact us at support@gainify.io, and we will take steps to remove such information and terminate the child's account.
15. Third-Party Links and Services
Our Services may contain links to third-party websites, applications, or services that are not owned or controlled by Gainify. We are not responsible for the privacy practices or content of these third parties. We encourage you to review their privacy policies before providing any personal information.
16. Changes to This Privacy Policy
We may update our Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons.
16.1 Notification of Changes
Material Changes: We will notify you of any material changes by posting the new Privacy Policy on this page and updating the 'Effective Date' at the top.Additional Notification: Where required by law, we may also notify you via email or through a notice on our Services.We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.
17. Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Gainify
Address: Paupio str. 50-136, Vilnius, Lithuania
Email support@gainify.io
18. Additional Provisions for Specific Regions
18.1 European Economic Area (EEA), United Kingdom (UK), and Switzerland
If you are a resident of the EEA, UK, or Switzerland, you have certain rights under the General Data Protection Regulation (GDPR):
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal information violates applicable laws.International Transfers: We ensure appropriate safeguards are in place when transferring your personal information outside the EEA, UK, or Switzerland.18.2 California Privacy Rights
Under the California Consumer Privacy Act (CCPA), California residents have specific rights regarding their personal information:
Right to Know: You may request information about the categories and specific pieces of personal information we have collected about you.Right to Delete: You may request that we delete personal information we have collected from you.Right to Opt-Out: You may opt out of the sale of your personal information, though we do not sell personal information as defined by the CCPA.Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.To exercise your California privacy rights, please contact us at
support@gainify.io.18.3 Australia Privacy Principles
We comply with the Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Cth):
Access and Correction: You may request access to or correction of your personal information.Complaints: If you believe we have breached the APPs, you may contact us to lodge a complaint.19. Do Not Track Signals
Our Services do not respond to Do Not Track (DNT) signals. DNT is a preference you can set in your web browser to inform websites that you do not want to be tracked. For more information about DNT, please visit www.allaboutdnt.org.
20. Data Protection Officer
We have appointed a Data Protection Officer (DPO) to oversee compliance with this Privacy Policy:
Data Protection Officer:
Email: support@gainify.io
Address: Paupio str. 50-136, Vilnius, Lithuania 21. Consent to Electronic Communications
By providing your email address, you consent to receive electronic communications regarding security, privacy, and administrative issues relating to your use of the Services.
22. Governing Law
This Privacy Policy is governed by and construed in accordance with the laws of Lithuania, without regard to its conflict of law principles. You agree to submit to the exclusive jurisdiction of the courts located in Vilnius, Lithuania.
23. Dispute Resolution
This Privacy Policy is governed by the laws of Lithuania. Any disputes will be resolved through arbitration under the International Chamber of Commerce (ICC) rules in Vilnius, Lithuania. Users outside Lithuania may have the right to seek remedies in their local courts. Additionally, we encourage resolving disputes through good-faith negotiations before pursuing arbitration.
24. Language
This Privacy Policy is written in English. If it is translated into another language, the English version shall prevail in the event of any conflict.
25. Acknowledgment
By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms.
Note to Users:
We are committed to protecting your privacy and ensuring transparency in how we handle your personal information. If you have any questions or need further clarification, please do not hesitate to contact us at support@gainify.io.
