GRUUPUP Privacy Notice.

Last modified: 06/11/2021

I. Introduction / II. Overview / III. Data collections and uses / IV. Choice and transparency / V. Updates to this notice

When you use the Gruupup mobile application or any of the Gruupup platforms, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices. This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data.

A. Scope This notice applies to users of Gruupup services anywhere in the world, including users of the gruupup mobile app, website, features, or other services related to the Gruupup services.

This notice describes how Gruupup and its affiliates collect and use personal data. This notice applies to all users of our mobile application, website, features or other services anywhere in the world, unless covered by a separate privacy notice. This notice specifically applies to:
• Requestor: Individuals or community or personal groups who request or alerts any incidents inside of the Gruupup mobile application.
• Responders: Individuals or community or personal groups who respond to alerts any incidents originating from inside the Gruupup mobile application.
This notice also governs Gruupup on other collections of personal data in connection with Gruupup services. For example, we may collect the contact information of individuals who use accounts to access the Gruupup services. We may also collect the personal data of those who start but do not complete the registration process whilst trying to login into the Gruupup application. All those subject to this notice are referred to as ‘users’ in this notice.

Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places. Please contact us using the contact us on our website www.gruupup.com with any questions regarding our practices in a particular country or region.

Tsolnetworks limited are the data controllers for the personal data collected in connection with use of the Gruupup services. We may also transfer data to countries other than the one where our users live or use Gruupup services. We do so in order to fulfill our agreements with users, such as our Terms of Use, or based on users’ prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law. Questions, comments, and complaints about Gruupup´s data practices can be submitted to queries@gruupup.com. You may also use the form on our website www.gruupup.com to submit a question.

Gruupup collects: • Data provided by users to Gruupup, such as during account creation • Data created during use of our services, such as location, GPS tracking, Incident activity tasks, app usage, messaging / chats.

The following data is collected by or on behalf of Gruupup:

1- Data provided by users. This includes:
• User profile: We collect data when users create or update their Gruupup accounts. This may include their name, email, phone number, Country, City and password, profile picture. We do not ask or collect, payment or banking information (including related payment verification information), driver’s license and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo) inside of the Gruupup mobile application.
• We may use the photos submitted by users to verify their identities, such as through facial recognition technologies. For more information, please see the section titled “How we use personal data.”
• Background check and identity verification: We may come to use all available social media and online systems to do a background check and identity verification information for Service representative persons.
• User content: We collect the information users submit when they enter or use the the Gruupup mobile application. This may include feedback, photographs or other recordings collected by users.

2- Data created during use of our services. This includes:
• Location data: Gruupup collects this data when the Gruupup app is running, the app can be running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.
• Transaction information: We collect transaction information related to the use of our services, including the type of incidents activated, groups created, members invited to join groups, individual friend requests. All are saved with a date and time to the respect data point.
• Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.
• Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data. we use the app stores standard collection platform for this.
• Communications data: We enable users to communicate with each other through the Gruupup mobile application and website. To provide this service, Gruupup stores the above mentioned data regarding all chat messaging, group, individual alerting activity, including the date and time of the updates, comments, activities. Gruupup may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services, and for analytics.

3- Data from other sources. This includes:
• User feedback, such as ratings, feedback, or compliments on our website or on the release mobile app store.
• Users or others providing information in connection with claims or disputes.
• Publicly available sources.
• Marketing service providers.
Gruupup may combine the data collected from these sources with other data in its possession.

Gruupup collects and uses data to enable reliable and convenient Tracking and connecting your contacts services. We also use the data we collect:
• To enhance accurate, safety and security of our services.
• For customer support.
• For research and development.
• To enable communications between the users and Gruupup.
• In connection with legal proceedings.
Gruupup does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

Gruupup uses the data it collects for purposes including:

1- Providing services and features. Gruupup uses the data we collect to provide, personalize, maintain, and improve our software features and services.
This includes using the data to:
• Create and update users’ accounts.
• Verify users identity, background history, and eligibility to safely contribute and use the Gruupup platform.
• Offer, process, or facilitate reports for our services.
• Track and share the progress of incident alerts.
• Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

2- Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users.

This includes:
• Using data from devices to help identify abusing or benefiting from inappropriate use of the Gruupup mobile application.
• Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.

3- Customer support. Gruupup uses the information we collect to provide customer support, including to:

• Direct questions to the appropriate customer support person.
• Investigate and address user concerns.
• Monitor and improve our customer support responses and processes.

4- Research and development. Gruupup may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the accuracy , efficiency, safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

5- Enabling offline communications between users. For example, a user may update a comment, note or add a document to an incident.

6- Marketing. Gruupup may use the data we collect to market our services to our users. This includes sending users communications about Gruupup services, features, studies, surveys, news, updates, and events.

We may also send communications to our users about products and services offered by Gruupup or any Gruupup official partners.
We may use the data we collect to personalize the Gruupup services and features, including based on user location and user preferences and settings.
We may also send users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services. For example, Gruupup has notified some users by email of events relating to the availability of Gruupup´s services in certain locations .

7- Non-marketing communications. Gruupup may use the data we collect to generate and provide users with information; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Gruupup or its partners.

8- Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Gruupup´s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

Gruupup and its partners use cookies and other identification technologies on our website for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Gruupup uses cookies and similar technologies for purposes such as:

• Authenticating users
• Remembering user preferences and settings
• Determining the popularity of content
• Delivering and measuring the effectiveness of advertising campaigns
• Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

Some of Gruupup´s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our customers, affiliates, subsidiaries, and partners, for legal reasons or in connection with reporting, audits, claims or disputes.
Gruupup may share the data we collect:
1- At the user’s request This includes sharing data with:
• Other people at the user’s request. For example, we share a user’s contact and location with a users within your group. This is done with the pr approval of the user..

2- With the general public questions or comments from users submitted through public forms or social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

3- With Gruupup subsidiaries and affiliates We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.

4- For legal reasons or in the event of a dispute Gruupup may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Gruupup´s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

5- With consent Gruupup may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

Gruupup retains user data for as long as necessary for the purposes described above. Users may request deletion of their accounts at any time by sending an email to remove@gruupup.com . Gruupup may retain user data after a deletion request due to legal or regulatory requirements or for the reasons stated in this policy. Gruupup retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the category of user to whom the data relates, the type of data, and the purposes for which we collected the data. As are subject to legal and regulatory requirements relating to service representative persons, this generally means that we retain their account and data for a minimum of 5 years after a deletion request except where retention is necessary for the above reasons.

Gruupup enables users to access and control the data that Gruupup collects, including through:
• In-app settings
• Device permissions
• In-app ratings pages
• Marketing opt-outs

Gruupup also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that Gruupup restrict its processing of user personal data.

When the Gruupup app is started, the user is promoted to allow or deny access to their location-sharing preferences.

• Location data

Gruupup uses service representatives’ device location services within the Gruupup application. This is used to plot map route information during all activity to ensure that the correct services can be provided. location tracking will not function without granting permission to location tracking to the Gruupup mobile application.

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. As example, IOS devices notify users the first time the Gruupup app requests permission to access certain types of data and gives users the option to grant or refuse permission. Android devices may notify users of the permissions that the Gruupup app requires before their first use of the application, and use of the application constitutes a grant of such permission.

Gruupup provides users with a variety of ways to learn about, control, and submit questions and comments about Gruupup´s handling of data. To make a request, please email Gruupup at devaccount@gruupup.com and ask for any of the below.
• Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.
• Receiving data: Users can ask for a copy of data that Gruupup collects from them with their consent or as necessary to provide our services.
• Changing or updating data: Users can edit the name, phone number, email address and photo associated with their account through the Settings menu in the Gruupup mobile application. Users may also ask that Gruupup change or update their data, including if they believe such data is inaccurate or incomplete.
• Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. Gruupup may continue to process data after such objection or request to the extent required or permitted by law.

Gruupup may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.br> Gruupup may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Gruupup app or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. After such notice, use of our services by users in countries outside the European Union will be understood as consent to the updates to the extent permitted by law.