PRIVACY POLICY


Half Isle, Inc. Privacy Resource

1515 Mockingbird Lane #420
Charlotte, NC 28209
United States

A. APPLICATION OF PRIVACY

This Privacy Policy applies to websites, apps and other events and services either provided or operated by Half Isle, Inc. for GOTU. We will refer to our products, events and services as only “services” through out the remainder of this Privacy Policy. In the event that a specific service requires a separate privacy policy, one will be provided. It will supersede this Privacy Policy only for the specific event and only during its date and time of operation. Once the specific service is no longer available, this Privacy Policy then takes effect.

B. INFORMATION WE COLLECT

We collect information generated during your use of our services. This information may be public or non-public information. Specifics on how and when this information is collected is provided below.

We receive your information when:

  • you create your profile. You provide us with your login credentials and some personal details, like your physical characteristics, gender identity and date of birth. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions. You consent to our processing of this information when you provide it to us.

  • you participate on our platforms. We analyze the content you publish to gain insight into how to enhance our services. We also collect and assess feedback about you, as it is provided by other users.

  • you participate in our surveys, service testing or focus groups. You may give us additional information about yourself.

  • you contact customer service. We collect the information you share during these interactions. NOTE: We may monitor and/or record these interactions for training or quality purposes.

  • you ask us to communicate with a third-party on your behalf. We collect and process information about you and others that is received during these interactions in order to complete your request.

  • our partners share engagement results for our ads, campaigns or other services that are published on their platforms where you have participated.

Additional information we receive when you use our services:

  • Usage Information - your activity on our services, such as date and time you logged in, features you’ve been using, clicks and pages which have been shown to you, referring webpage address, advertising that you click on, users you connect and interact with, time and date of your published correspondence, comments and posts, number of messages you send and receive.

  • Device information - information collected for device(s) you use to access our services:

    • hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs, browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser;

    • information on your wireless and mobile network connection; and,

    • information on device sensors such as accelerometers, gyroscopes and compasses.

  • Other information - we may collect your geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background, even when you aren’t using the services, only if you grant us permission to do so. We will not collect your geolocation if you don’t grant us permission to do so.

C. COOKIES AND OTHER SIMILAR DATA COLLECTION TECHNOLOGIES

We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns) and how you can better control their use, through your browser settings and other tools.

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website to not track a user’s online activity. If a website responds to a DNT signal and receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Currently, not all browsers offer a DNT option and all DNT signals are not yet uniform. For this reason, GOTU does not currently respond to DNT signals.

D. HOW WE USE INFORMATION

To provide our services to you:

  • Create and manage your profile

  • Provide you with customer support

  • Respond to and process your requests

  • Communicate with you about our services

To help you connect with other users:

  • Analyze your profile, activity on the service, and preferences to update existing and create new services. For more information, please see our FAQ

  • Show users’ comments to one another

To serve you relevant offers and ads:

  • Develop, display and track content

  • Communicate with you by email or mobile device about GOTU products or services

To improve our services and develop new ones:

  • Administer focus groups, service testing and surveys

  • Conduct research and analysis of users’ behavior to improve our services and content

To prevent, detect and fight fraud or other illegal or unauthorized activities:

  • Address ongoing or alleged misbehavior on and off-platform

  • Perform data analysis to better understand and design countermeasures against these activities

  • Retain data related to fraudulent, harassing and bullying activities to work against recurrences

To ensure legal compliance:

  • Comply with legal requirements

  • Assist law enforcement

  • Enforce or exercise our rights, for example our Terms of Service

To process your information as described above, we rely on the following legal bases:

  • Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service, we use your information to maintain your profile.

  • Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings and process information for administrative, fraud detection and other legal purposes.

  • Consent: From time to time, we may ask for your consent to use your information for certain reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

E. HOW WE SHARE INFORMATION

We share your information with other users. We also share some users’ information with service providers and partners who assist us in operating the services and, in some cases, legal authorities. Read on for more details about how your information is shared with others.

  • With other users

    You share information with other users when you voluntarily disclose information on the service, including your profile.

    We share information for service testing purposes and to help facilitate (group) feedback sessions.

  • With our service providers and partners

    We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, sales, marketing, advertising, payment processing and security operations.

    We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.

    We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality requirements.

  • For corporate transactions such as a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.

  • When required by law

    We may disclose your information: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.

  • To enforce legal rights

    We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

  • With your consent or at your request

    We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.

    We may use and share non-personal information (meaning information that, by itself, does not identify who you are such as device information, general demographics, general behavioral data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties, and to analyze and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy.

F. CROSS-BORDER DATA TRANSFERS

Sharing of information laid out in the above section may involve international data transfers, for instance to other jurisdictions that function for GOTU. We use standard contract clauses approved by domestic and international agencies or other suitable safeguards to permit data transfers from the United States to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.

G. YOUR RIGHTS

You have access to the following tools to control your information:

  • Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Note: Updating your device permissions may cause certain services to lose full functionality.

  • Deletion. You can delete your account by sending a deletion request to info@getontheup.com. Please allow 24 hours for your request to be processed and completed.

We want you to be aware of your privacy rights. Here are a few key points to remember:

  • Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by putting in such a request here.

  • Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us here.

For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can process and complete any of the above requests.

We may reject requests for reasons including, but not limited to: unlawful asks and/or infringement of trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.

In addition, we may not be able to accommodate certain requests where such requests prevent us from providing our service to you in the future. For instance, we cannot provide our service if we do not have your email address.

  • Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

  • Accountability. In certain countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information.

H. RESIDENTS OF CALIFORNIA

If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request here. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.

I. HOW WE PROTECT YOUR INFORMATION

We take steps to secure your information. But, we do not promise, and you should not expect, that your personal information will always remain secure.

We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately here.

J. HOW LONG WE RETAIN YOUR INFORMATION

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of six months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.

In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:

  1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);

  2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);

  3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

  4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

K. CHILDREN’S PRIVACY

Our services are restricted to users who are 17 years of age or older. We do not permit users under the age of 17 on our platform and we do not knowingly collect personal information from anyone under the age of 17. If you suspect that a user is under the age of 17, please send an email to info@getontheup.com.

L. PRIVACY POLICY CHANGES

This policy may change over time. User notifications will be provided before any material changes take effect so that you have time to review them.

M. HOW TO CONTACT US

If you have questions about this Privacy Policy, contact us by email or by mail:

Half Isle, Inc. Privacy Resource

1515 Mockingbird Lane #420
Charlotte, NC 28209
United States