Privacy Policy

1. Introduction

Welcome to the Going Merry Privacy Policy.

We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.

2. Where this Privacy Policy applies

This Privacy Policy applies to websites, apps and other services operated by Going Merry. For simplicity, we refer to all of these as our "services" or "apps" in this Privacy Policy. To make it extra clear, we've added links to this Privacy Policy on all applicable services.

3. Information we collect

It goes without saying, we can't help you have an awesome user experience without some information about you, such as your email address and password in some of our services. We also collect information generated as you use our services, as well as information from third parties. Your information may be kept in an identifiable format, or in an aggregate format which means that you cannot reasonably be identified from it.

Information you give us

You choose to give us certain information when using our services. This includes:

• When you create an account in some of our services, you provide us with your login credentials, such as email address, name and password.
• To use certain features in our services, you may allow us to access your camera or microphone. Depending on your device, Apple and Android systems will ask for your permission before allowing us to access these features.
• Features that allow you to share content about your use of our services with your connections or through your social network. We may also collect your information when you use our app such as when you post or share material, upload data, request further services or make selections using our app, if such functionality is available in the app.
• If you contact our support team, we collect the information you give us when you report a problem, contact or communicate with us.
• From time to time, we may request your opinions, suggestions, or modification and improvement ideas ("Feedback") through surveys or other similar requests. Any responses you provide are voluntary; however you agree that any Feedback you provide shall be owned by Going Merry and may be used by Going Merry in our sole discretion.

Information we receive from others

In addition to the information you provide us directly, we receive information about you from others, including:

Social Media

You may be able to use your Facebook account to log in or create an account. When you use this feature, we may receive any of your information you provide or permit to be provided to us via a social network or public forum provider like Facebook. This data may include your use of our app on such public forums and/or social networks, including with whom you share our app. For further information as to how and for what purpose the social network or public forum provider collects, uses and shares your data, as well as how you can set your privacy preferences on their site or apps, please see their privacy policy.

Other Partners

• We may receive information about you from our partners, for instance where our ads are published on a partner's website or platform (in which case they may pass along details on a campaign's success).
• If you purchase a subscription in our apps, neither Google nor Apple provide us with any personal information of the subscription purchaser (like name, email or payment information). Only anonymized data gets passed to Going Merry.

Information collected when you use our services

When you use our services, we collect information about which features you've used, how you've used them and the devices you use to access our services.

Usage information

We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, time spent in the app, features you've been using, advertising that you click on). If you opt-in, some services may collect movement data from your device.

Device information

We might collect information from and about the device(s) you use to access our services, including:

• geolocation data (in some of our apps), which is any information which indicates the geographical position of your device and which may include the time the location was recorded, and may include precise (e.g., GPS-level) location data. Some apps may collect this data when the app is not open or actively in use. This may help us or third parties to customize information, content, or offers to you, for instance.
• information on your wireless and mobile network connection, like your service provider and signal strength.
• hardware and software information such as IP address, device type, app crashes, app version, advertising IDs (such as Google's AdvertisingID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device's settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address).

4. Cookies and other similar data collection technologies

As described in Sections 3 and 5 of this Privacy Policy, we sometimes work with third parties to deliver ads or offers. Sometimes we or these third parties do so through a mobile "SDK." The SDK is a bit of computer code that app developers can include in their apps to enable data to be collected and ads to be shown. We may use this and similar technology to deliver certain advertising through mobile applications and browsers based on data associated with your mobile device, and we may work with third parties who likewise embed their SDKs into our services, for third party advertising. If you'd like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions below or in the app (as applicable).

If you wish to opt out of interest-based tracking through your mobile device, you can do so through your device "settings". Please note that if you opt out, you will continue to receive advertising after opting out, but it may not be tailored to your interests. For instance, advertising may be based on your real-time or "contextual" application usage or general location inferred from IP address.

Opting out on iOS devices

If you have an Apple device, you can opt out of interest-based advertising by updating to iOS 6.0 or higher and setting Limit Ad Tracking to 'ON'. On an iPhone for example, you can do this by going to Settings → General → Privacy → Advertising and toggling "Limit Ad Tracking" to 'ON'. Our systems are designed to respect your choice and not use your personal information to provide interest-based advertising when this setting is ON.

Opting out on Android devices

If you have an Android device and would like to opt out of interest-based advertising: open the Settings app, go to "Google", select Ads, and opt out of interest-based ads.

5. How we use information

The main reason we use your information is to deliver and improve our services. Additionally, we may use your information to help keep you safe and to communicate with you.

To administer your account and provide our services to you

• Deliver our services to you and ensure their optimal functionality and operation.
• Identify, establish and manage your account and our relationship with you.
• Provide you with customer support and respond to your requests.
• Should you provide us with this information, we may use your email address, name, country and language for customized marketing purposes.
• When we collect your precise geolocation data (subject to your consent), we do so to provide you with our location-related products and services, and to facilitate, measure, or otherwise support advertising by third parties that may be related to your location over time.
• Some of our apps may offer you the ability to register and login using your third party social media account details. Where you choose to do this, we will receive certain profile information about you from your social media provider — typically including name, email, mobile phone number and friends list. We use this information only for the purposes described in this Privacy Policy.

To ensure a consistent experience across your devices

• Link the various apps and devices you use, so that you can enjoy a consistent experience of our services on all of them. For this purpose and better user experience generally, we may use and combine your personal information which we collect across different services used by you.

To improve our services and develop new ones

• Develop new features and services (for example, we may build a new feature in response to user requests or feedback).
• Going Merry uses the Google Analytics tool Firebase to analyze information gathered by our apps. Device information and other data we gather are provided to Google to enable them to carry out data analysis. Any information provided to Google becomes subject to Google's privacy policy at www.google.com/privacy.html.
• Conduct research and analysis of user behaviour about your use of, or interest in, our products, services or content. This may include how often you use the services, what happens within the services, aggregated usage, performance data, app errors and debugging information, and where the apps were downloaded from.

To communicate with you

• Communicate with you by postal mail, telephone and/or mobile devices (including through in-application advertising) about products or services that may be of interest to you, either from us or other third parties. If you do not wish to receive in-application advertising, in some cases you can upgrade to the paid version of the app.
• When you share your information with us via a social network provider like Facebook, we use this to show information on your social network profile (subject to your privacy setting and preferences for such social network) and to allow you to share information about our services with your connections.
• With your consent (where needed), to send you email marketing about services you may find of interest. You can opt-out of receiving direct marketing communications from us by following the unsubscribe instructions included in our marketing communications. We also send you non-marketing emails or messages, such as those related to transactions, your account, security, or product changes.

To serve you relevant offers and ads

• Develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. Third-party ad partners may provide you with advertising based on your interests; these companies may use technologies (including SDKs) to collect data about users to help them tailor relevant ads and measure their effectiveness. For European law purposes, most of these ad partners are independent controllers of your information.
• Verify your eligibility and deliver prizes in connection with contests and sweepstakes and in order to conduct polls and surveys.

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

• Perform data analysis to better understand and design countermeasures against such activities, and retain data related to fraudulent activities to prevent recurrences.

To ensure legal compliance

• Comply with legal requirements.
• Assist law enforcement.
• Enforce or exercise our rights, for example our EULA.

Legal bases

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 — to maintain your account and provide our features to you.
• Legitimate interests: We may use your information where we have legitimate interests to do so — for instance, to analyze user behavior to continuously improve our offerings, and 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 specific reasons. You may withdraw your consent at any time where indicated in the services or by contacting us at the address provided at the end of this Privacy Policy.

6. How we share your information

Since our goal is to provide the best services we can to you, the main sharing of users' information is with service providers and partners who assist us in operating the services and, in some cases, legal authorities.

With our service providers and partners

We follow a strict vetting process prior to engaging any service provider or working with any partner. These third parties assist us with tasks including data hosting and maintenance, analytics, marketing, advertising and security operations. They may have limited access to your information, only to perform their functions, and are not permitted to share or use such information for any other purposes. We may share aggregated information we collect with third parties, including advisors, advertisers and investors, for general business analysis or other legitimate business purposes; such aggregated information does not identify you.

For corporate transactions

We may transfer your information if we are involved, whether in whole or in part, in 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 if reasonably necessary: (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) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; or (iii) to protect and defend the rights, property or safety of our company, our users, our employees, or others.

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 and/or to comply with applicable law; (iii) to enforce our agreements or policies 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.

7. How we protect your information

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and after it is received. We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, 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.

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.

8. Information relating to children

Our services are intended for general audiences over the age of 13 years old (or over the age of 16 if you are resident in the EEA). We do not knowingly collect information from children under the age of 13 (or 16 in the EEA). If you are not over 13 (or 16 in the EEA), do not download or use the services. If you believe that we may have personal information from or about a child under the relevant age, please contact us and we will promptly delete that information.

9. Your rights

We want you to be in control of your information. Depending on your location you may have some or all of the following rights in relation to how we use your personal information:

• Access: you may request access to your personal information and receive copies of it;
• Correction: you may have inaccurate/incomplete personal information corrected and updated;
• Object to, or limit or restrict, use of data: you can ask us to stop using all or some of your personal information or to limit our use of it;
• Deletion: in certain circumstances, you can request a right "to be forgotten". We will honour such requests unless we have to retain this information to comply with a legal obligation or unless we have an overriding interest to retain it;
• Portability: in certain circumstances, exercise the right to data portability — to obtain a transferable version of your personal information;
• Consent management: where we rely on consent to process your personal data, you may withdraw consent at any time.

If you wish to exercise any of these rights, or wish to object to our use of your information, please write to us at the address listed below and we will consider your request in accordance with applicable laws. We may reject requests for certain reasons, including if the request is unlawful or if it may infringe on the rights and freedoms of another person. For your protection, we may ask you to provide proof of identity before we can answer the above requests.

10. Cross-border data transfers

Sharing of information sometimes involves cross-border data transfers, for instance to the United States and other jurisdictions. The United States, European Economic Area ("EEA") Member States, and other countries all have different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information may be different.

The European Commission has adopted standard contractual clauses (also known as Model Clauses), which provide safeguards for personal information that is transferred outside of the EEA. We use these Model Clauses or other suitable safeguards to permit data transfers from the EEA to other countries.

11. How long we store your information

We retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active or as needed to provide the services to you. We will also retain and use your information to the extent necessary:

• to comply with applicable law;
• to evidence our compliance with applicable law;
• if there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved;
• if the information must be kept for our legitimate business interests, such as enforcing our terms or fraud prevention.

Even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.

12. Delete your personal data and information

You have the right to delete or request that we assist in deleting the personal data and information we have collected about you. Our services may give you the ability to delete certain information from within the services. You may update, amend or delete your information at any time by signing in to your account, if you have one, and visiting the account settings section that allows you to manage your personal information. You may also contact us to request access to, correct, or delete any personal information you have provided to us. Please note that we may need to retain certain information when we have a legal obligation or lawful basis to do so.

13. Privacy Policy changes

Because we're always looking for new and innovative ways to help you enjoy our services, this policy may change over time. We will notify you of any material changes so that you have time to review them.

14. Data Protection Officer

For our European users, our Data Protection Officer is responsible for ensuring your rights are respected and to review and oversee how we collect and use your personal information.

15. How to contact us

If you have questions about this Privacy Policy, here's how you can reach us:

• Email: support@goingmerry.xyz
• For contact: team@goingmerry.xyz