The categories of personal information we collect depend on the Service you use, and the requirements of applicable law.

1.1 Information You Provide Us Directly:

• Your email address and other contact information.

• Your username, profile photo and other profile information.

• Your social network or third-party service user identification (such as your Google account, Apple ID, or LINE ID number).

• Other information you choose to give us, such as your name, occupation, location, and other information you provide in your feedbacks to us.

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Some of the personal data we will ask you to provide is required in order to create your account and to enable the Service. You may also have the option to provide us with additional personal data in order to make your account more personalized.

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1.2 Information We Collect Automatically:

• Information about your account, such as an automatically created internal account ID. *

• Information about your use of the Service, such as step-count, coin earning and redemption history, interactions with other users inside the Service, and visits and clicks on a certain page.

• Your IP address and mobile device identifiers (such as advertising IDs).

• Information about your device, such as device name and operating system, browser type and language, internet service provider, and mobile carrier. 

• Approximate location data, as derived from IP address.

• Information we collect with cookies and similar technologies (see Section 6 “Cookies and Similar Technologies” below).

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1.3 Information We Collect from Third Parties:
We may also cooperate with third parties, such as social networking sites, data analytics providers and advertising networks to collect supplementary information about you, such as:

• Information we receive if you link a third-party tool (such as Google, Apple or LINE) with the Service.

• Information from third-party platforms that our Service run on, such as that needed to verify payment or to process an order.

• Demographic data, such as those used to determine the coarse location of your IP address.

• Information for advertising and analytics purposes, such as cookie ID or mobile device ID, so we could improve our Service’s functionality and provide you a better Service.

Please be advised that the third-party tool, platform or other service provider you use may operate under their own terms of service and privacy policies.
 

2.1 To Enable the Service.
On basis of necessity to perform your contract with us, we collect and process necessary information to:

• Create your account and allow you to use our Service.

• Verify and confirm purchases and payments. 

• Provide and deliver portions of the Service you request.

• Verify your physical movement and issue coins on basis of the verified data.

• Send you Service-related communications.

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2.2 To Improve the Service and Customize Your Service Experience.
To improve our Service, we, on basis of your consent and/or legitimate interest, collect and process necessary information to:

• Develop, maintain and update user profiles and user activity history.

• Enable you to invite and interact with your friends.

• Develop and improve the Service and user experience.

• Provide in-app purchases.

• Customize your Service experience.

• Maintain the safety and fairness of the Service.

• Manage our relationship with you and seek your feedback on our Service.

• Respond to your requests and provide customer support.

• Provide you promotional offers in the Service as well as in other websites and services (including by email).

• Send you related information, such as updates, new products, features, security alerts, support messages, upgrade opportunities, contests and events of interest.

2.3 To Comply with Applicable Law
In accordance with the applicable law, we collect and process necessary information to:

• Comply with a legal obligation to which we are subject.

• Comply with a request by a competent court or other law enforcement authority.

• Enforce our Terms & Conditions.

• Establish, exercise or defense a legal claim.

2.4 To Show Personalized Advertisements.
To show you personalized advertisements in the Service as well as in other websites and services (including email), we, on basis of your consent and/or legitimate interest, collect and process necessary information to:

• Track the content you access in connection with the Service and your online behavior.

• Deliver, target and improve our advertising and the Service.

We may use remarketing/retargeting services provided by LINE, Google, etc., to advertise on third party platforms to you on basis of information collected upon your access to our Service. We, and our third-party vendors, use cookies and/or advertising identifiers to inform, optimize and serve ads based on your past access to our Service. Depending on the privacy settings on your device, the information collection may initiate immediately when you open our application.

Our use of remarking/retargeting services will always be in compliance with the privacy settings on your device, and the applicable platform rules. For information on how to opt-out from personalized advertisements, see Section 9 “Your Rights and Options” below.


2.5. Additional Purposes with Your Consent.
With your consent, we may collect and process your information for additional purposes, such as to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners, and to conduct research.

We will retain your information as needed for the purpose for which your information is collected, or as required for the applicable law. We will not retain your personal information for longer than is necessary for our business purposes or for legal requirements. For instance, your step-counts for a walk to earn points function will not be retained after the function completes.

Your profile information will be removed as soon as you delete your account. Please note that we may retain some information such as your order information and email correspondence with us for a few years after you have deleted your account if this is necessary for us to fulfill a legal obligation or to exercise, defend or establish a legal claim. Also, there may be instances where we are legally required to retain your information. Unless otherwise provided for under this Privacy Policy or permitted by and applicable law, we will not use any information in a way that might identify you after you delete your account.

We will not rent, loan, lease or sell your information to any third party. Your information may only be accessed by a third party in the following situations.


4.1 Other Users
As social features are a component of our Service, other users may, for example, see your Earn LINE Points achievement when you shared.


4.2 Our Service Providers
We employ third-party services to facilitate our Service, to provide the Service on our behalf, or to help us improve the Service. These third-party service providers may process your information, only at and according to our instructions, for purposes of Service-related tasks, such as hosting, user support, advertising, analytics and fraud prevention. Such third-party services include:

• We use Firebase Crashlytics and Firebase Analytics to detect and fix any error and to improve the HAHAGO Global App’s performance. We also use Firebase Analytics to analyze our HAHAGO Global App’s data, to better understand our users, to facilitate the continuous development of our Service, and to help with our marketing. For more information about the Firebase services, please read their terms of service at https://firebase.google.com/terms.

• We use Google Analytics, Urchin Tracking Module and Google Tag Manager to optimize user experience on the HAHAGO Global Website, to analyze the HAHAGO Global Website’s data, and to help with our marketing. For more information about these Google services, please read their terms of service at https://marketingplatform.google.com/about/analytics/terms/us/, and https://www.google.com/analytics/terms/tag-manager/.

4.3 Public Authorities, Other Organizations
In accordance with the applicable law, we may provide your information to public authorities. We may also disclose your information based on your consent, or to protect the rights, property or safety of us, our users or others.


4.4 Mergers and Acquisitions
If we are involved in a merger, acquisition or asset sale, your personal information may be transferred as a portion of our assets. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

HAHAGO’s use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

The security of your personal information is important to us. Though no method of transmission or storage is 100% secure, we are continuously developing and implementing organizational and technical security measures, including pseudonymization of your profile data and access control to our servers, to protect your information from unauthorized access or disclosure, and against destruction, loss, misuse or alteration.

Cookies are files with small amount of data, which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device.

We use cookies and similar technologies to collect information, to enable/personalize the Service, to analyze use and to target advertisements. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, certain cookies are essential for the proper functioning of the Service. If you do not accept these cookies, you may not be able to use some portions of our Service. For information on how to manage cookies and other similar technologies used for personalized advertisements, see Section 9 “Your Rights and Options” below.

Your information will be stored on servers controlled by our hosting service provider located in the United States. In exceptional cases, we may need to transfer your information to a different country. Where we do so, we rely separately, alternatively, and independently on the applicable legal bases. We take steps to ensure that adequate safeguards and mechanisms are in place for the protection of your information. If you would like to find out more about these safeguards, please let us know by writing to hahago.service@gimmatek.com.

The Service is not intended for Children younger than 13 years of age, or of any age under the applicable law that is unable to independently give valid consent to data collection (the “Restricted Age”). If you are a parent or guardian and you are aware that your Children has provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under the Restricted Age, we take steps to remove that information from our servers, unless we have a legal obligation to keep it.

9.1 Your Rights
You have rights under privacy/data protection law. The rights available to you depend on our reason for processing your information. Where we process your personal information on basis of your consent, you will always have the right to withdraw your consent at any time.
 

• Right of access: the right to ask us for copies of your personal information that we process.

• Right to rectification: the right to ask us to rectify or update your personal information that you think is inaccurate or incomplete.

• Right to erasure: the right to ask us to erase your personal information.

• Right to restriction of processing: the right to ask us to temporarily or permanently restrict the processing of your personal information.

• Right to object to processing: the right to object to us processing your personal information.

• Right to data portability: the right to request a copy of your personal information in electronic format and the right to transmit that personal information for use in another party’s service.

• Right not to be subject to automated decision-making: the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
   

If you wish to exercise any of your data subject rights described above, you can make a request through the HAHAGO Global App, the HAHAGO Global Website, or by contacting us with the details listed in Section 13 below. We will respond to all requests in accordance with applicable laws and within a reasonable timeframe. To protect your privacy, we may also take additional steps to verify your identity before fulfilling your request. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, we hope you will continue to work with us to resolve them. However, you also have the right to lodge a complaint with your local data protection authority.


9.2 Direct Marketing Communications
With your consent, we may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the instructions provided in such communications. The updated settings may not be effective immediately. Please note that you may still continue to receive non-promotional emails from us, such as communications regarding the Service or updates to our Terms & Conditions or this Privacy Policy.


9.3 Behavioral Remarketing/Targeted Advertising
You may opt out of targeted ads by disabling advertising and tracking cookies in your browser, or by refusing tracking in your device’s privacy settings. You may consult official support information pages (usually entitled “Privacy” or “Advertising”) to learn how to refuse tracking on a particular browser/device. The following links may also contain useful information.
 

• For iOS devices: https://support.apple.com/en-us/HT205223.

• For Android devices: https://support.google.com/ads/answer/2662856?co=GENIE.Platform%3DAndroid&hl=en

• For Google: https://policies.google.com/privacy?hl=en.

• For Facebook: https://www.facebook.com/help/568137493302217.

9.4 Use of Location Information
You can enable or disable location services when you use our Service at any time, through your device’s privacy settings. When you disable location services, our ability to provide certain features or functions may be limited.

Our Service may contain links to other sites or services that are not operated by us. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party link, please understand that you are leaving the Service and any personal information you provide will not be covered by this Privacy Policy. We strongly advise that you review their privacy policies.

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page, and by other means as appropriate under the circumstances. If we make any material changes, we will notify you as required under applicable law, including by posting a notice in the Service prior to the change becoming effective. Your continued use of the Service after the effective date will be subject to the new Privacy Policy.

The California Consumer Privacy Act (CCPA) gives California residents certain rights with respect to the processing of personal information, and requires businesses to made certain disclosures. The following information supplements the other sections of this Privacy Policy.


12.1 Personal Information Collected and Processed
Section 1 of this Privacy Policy describes the categories of personal information that we collect and process about you, and the sources from which we obtain each category.


12.2 Disclosures of Personal Information for a Business Purpose
We may disclose personal information listed in Section 1 to the categories of recipients listed in Section 4 of this Privacy Policy for one or more business purposes.


12.3 Sale of Personal Information
We do not sell personal information. However, we do provide certain personal information to advertising partners to enable us to provide you with interest-based advertising. If you prefer not to receive interest-based advertising, please see the opt-out options listed in Section 9.


12.4 Financial Incentives
We do not offer financial incentives for personal information, though we do reward you for connecting with other users via the HAHAGO Global App.


12.5 Your Rights

• Right to know: Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

  • information collected;

  • sources from which the personal information is collected;

  • purposes for collecting personal information;

  • personal information that we have sold or disclosed about you for a business purpose;

  • third parties with whom we share personal information;

• Right to delete: Under the CCPA, you also have a right to request that we delete personal information, subject to certain exceptions.

• Right to opt-out of the sale of personal information: As mentioned above, we do not and will not sell your personal information.

• Right to non-discrimination for exercising your rights.

If you wish to exercise any of your data subject rights described above, you can make a request through the HAHAGO Global App, the HAHAGO Global Website, or by contacting us with the details listed in Section 13 below.

If you have any questions about these Terms or the Service, please contact us at:
Gimmatek Corporation
hahago.service@gimmatek.com

9F.-6, No. 118, Ciyun Rd.
East Dist.
Hsinchu City
Taiwan (R.O.C.)