Last updated: September 12, 2022
How We Collect and Use Information
We collect the following types of information about you:
Information you provide us directly:
We ask for certain information such as your username, real name, address, demographic information, phone number, email address, password, and other information when you register for a Groupcycle account, or if you correspond with us. We may also retain any messages and emails you send through the Service, and may collect information you provide in User Content you upload or post to the Service. We use this information to operate, maintain, and provide to you the features and functionality of the Service. Your username and if you choose to disclose it, your real name, will be published publicly. Once published your username and / or real name may not be able to be removed entirely from the Service.
Information about others:
We may also collect and store personal information about other people that you provide to us when you use our Service, including (without limitation) email address, phone number, and physical address. So, for example, if you use our Service to send invitations or emails by entering, uploading, or importing your contacts, we may store and use the information you provide to us. We use the information you provide about others in several ways, including (a) to send invitations initiated by you; (b) to send emails initiated by you; (c) to send promotional emails; and (d) to provide our Service.
Information from other sources:
We also obtain both personal and non-personal information about you from other users, business partners, contractors, and other third parties, and may add it to our account information or other information we have collected about you. Information collected includes, for example, email addresses entered, uploaded, or imported by business users. Other examples of information we may receive include but are not limited to: name, address, username.
Information we may receive from other services:
If you access our Service through a third-party connection or log-in, such as your Facebook or Google account credentials, by “following,” “liking,” adding the Groupcycle application, or linking your account to the Service, etc., that third party may pass certain information about your use of its service to Groupcycle. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook account credential), your email address, an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. If you allow us access to your connections list, your connections’ user IDs, email addresses, and your connection to those connections, may be used and stored to make your experience more social, and to allow you to invite your connections to use our Service as well as provide you with updates if and when your connections join Groupcycle. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Service. You may also unlink your third party account from the Service by adjusting your settings on the third party service.
Inviting a connection to use Groupcycle:
If you choose to use our invitation service to invite a third party to the Service through our “Invite connections” feature, you may directly choose one or more connections to invite through your contact list. We may use and store your connections’ contact information.
Finding your connections on the Service:
Groupcycle may, in its sole discretion, develop a feature that allows you to locate your connections with Groupcycle accounts through a “Find connections” feature. The “Find connections” feature allows you to choose to locate connections either through (i) your contact list, (ii) social media sites (such as Twitter or Facebook) or (iii) through a search of names and usernames on Groupcycle. If you choose to find your connections through your contact list, then you agree to provide Groupcycle access to your contact list so that we can perform the search necessary to determine whether or not someone associated with the information you provide is using Groupcycle. If you choose to find your connections through social media sites, then you understand that the information these sites provide to us to conduct this type of search is governed by their privacy policies and your account settings on those sites.
We may directly collect analytics data, or use third-party analytics tools and services, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual user.
Log file information:
Log file information is automatically reported by your browser or mobile device each time you access the Service. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.
Clear gifs/web beacons information:
When you use the Service, we may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.
When you access the Service by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Groupcycle. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
When you access the Service, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your device. Location data may convey to us information about how you browse and use the Service. Some features of the Service, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
We use credit card and other payment information, such as PayPal email addresses, you submit to us on the Service to process payments you make through the Service. We do not store credit card or other payment information that you provide to us. Financial institutions, such as Stripe, PayPal and Authorize.net, have the sole and entire responsibility for the storage of credit card and payment information.
Commercial and marketing communications:
We use the information we collect or receive, such as your email address, to communicate directly with you. We may send you emails containing newsletters, promotions, and special offers. If you do not want to receive such email messages, you will be given the option to opt out or change your preferences. We also use your information to send you Service-related emails (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). You may not opt out of Service-related emails. You may also be able to be “found” on Groupcycle based on information that you provide (see “Find connections” on Groupcycle) above.
Use of information we collect:
We may use information that we collect about you to:
* deliver emails, invitations initiated by other users;
* deliver other products and services;
* manage your account and provide you with customer support;
* perform research and analysis about your use of, or interest in, our products, services, or content, or products, services or content offered by others;
* communicate with you by email, postal mail, telephone and/or mobile devices about products or services that may be of interest to you;
* develop and display content and advertising tailored to your interests on our Service and other sites;
* enforce our Terms and Conditions;
* monetize our business;
* manage our business; and
* perform functions as otherwise described to you at the time of collection.
Personal Information from Social Network Services. We will use the personal information that you allow us to access from your social network services account to either create an account for you on the Service or, if you already have an account on the Service, then simply to associate your account with your social network services account. For example, if you already have an account with us and you choose to connect your Facebook account with us, then we will associate your Facebook ID with your account to allow you to log in to your account through with your Facebook ID.
Sharing of Your Information
We will not rent or sell your information into third parties outside Groupcycle and its group companies (including any parent, subsidiaries and affiliates) without your consent, except as noted below:
- Businesses Users on the Service: Business Users on the Service that you have subscribed to or that you have contacted may have access to your personal information, including, without limitation, your username, name and email address, and may send you emails, including promotional emails.
- Business Partners: We may share your information with third-party business partners for the purpose of providing the Service to you. Third party business partners will be given limited access to your information as is reasonably necessary to deliver the Service.
- Who can see User Content: Any User Content that you voluntarily disclose for posting to the Service becomes available to the public and cannot be removed, except by Groupcycle in its sole discretion. Once posted on Groupcycle, User Content may not be removable from public view, as copies may remain viewable in cached and archived pages of the Service, on other sites that have republished us, or if other Users have copied or saved that information. If you do not wish your User Content to be available to the public, please don’t post it on Groupcycle. Your username and if you choose to disclose it, your real name, will be published publicly. Once published your username and / or real name may not be able to be removed.
- Who can see your IP address: Any third party service embedded on Groupcycle such as an advertiser, video provider, social network or other third party will have access to your IP address.
What happens in the event of a change of control:
We may buy or sell/divest/transfer the company (including any shares in the company), or any combination of its products, services, assets and/or businesses. Your information such as names and email addresses, User Content and other user information related to the Service may be among the items sold or otherwise transferred in these types of transactions. We may also sell, assign or otherwise transfer such information in the course of corporate divestitures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, similar transactions or proceedings involving all or a portion of the company.
Instances where we are required to share your information:
Groupcycle will disclose your information where required to do so by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms and Conditions or to protect the security, quality or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Groupcycle, our Users, or others.
Sharing certain service type information we collect about you:
We may share certain service type information, including information obtained through tools such as cookies, log files, device identifiers, location data and clear gifs (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.): (i) with our third-party business partners for the purposes described in the section above on “How We Collect and Use Information.” We may also aggregate or otherwise strip data of all personally identifying characteristics and may share that aggregated, anonymized data with third parties.
Ads on Groupcycle:
For example, Google uses DART cookies in order to deliver ads to you through the Service. Google’s use of the DART cookie enables it and its partners to serve ads to you based on your visit to the Service and previous websites that you may have visited. Other advertising networks also use similar cookies, clear gifs, or other mechanisms to deliver targeted advertising to you through the Service. You may opt out of use of Google’s DART cookie and cookies placed by Network Advertising Initiative (NAI) certified ad networks here: http://www.networkadvertising.org/managing/opt_out.asp . Opting out of these cookies will be effective not only on the Service, but on all websites with NAI certified advertising networks. However, these opt-outs will be ineffective on networks that are not NAI certified.
Please note that an advertiser may ask Groupcycle to show an ad to a certain audience of Users (e.g., based on demographics or other interests). In that situation, Groupcycle or our partners determines the target audience, and Groupcycle serves the advertising to that audience and only provides anonymous data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.
To enhance your user experience or help us improve and measure our effectiveness, Groupcycle may embed code from third parties on the Service. Examples of such parties may include Facebook, Twitter, Pinterest, Google, YouTube, and others. These third parties may collect information about you including IP address, cookies in ways Groupcycle does not control.
How We Store and Protect Your Information
Storage and Processing:
Keeping your information safe:
Groupcycle cares about the security of your information. To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to your email communications from Groupcycle, at all times. However, Groupcycle cannot ensure or warrant the security of any information you transmit to Groupcycle or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed. Your privacy settings may also be affected by changes to the functionality of third party sites and services that you add to the Groupcycle Service, such as social networks. Groupcycle is not responsible for the functionality or security measures of any third party.
Your Choices about Your Information
You control your account information and settings: You may update your account information and email-communication preferences at any time.
As noted above, you may not opt out of Service-related communications (e.g., account verification, purchase and billing confirmations and reminders, changes/updates to features of the Service, technical and security notices). If you have any questions about reviewing or modifying your account information, you can contact us directly at support@Groupcycle.com.
Opting out of collection of your information for Tracking / Advertising:
Please refer to your mobile device or browser’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of device, it may not be possible to delete or disable tracking mechanisms on your mobile device. Note that disabling cookies and/or other tracking tools prevents Groupcycle or its business partners from tracking your browser’s activities in relation to the Service, and for use in targeted advertising activities by third parties. However, doing so may disable many of the features available through the Service. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at support@Groupcycle.com.
How long we keep your private profile information:
Following termination of your User account, Groupcycle may retain your private profile information for a commercially reasonable time for backup, archival, or audit purposes. For the avoidance of doubt, any information that you choose to make public on the service may not be removable.
Groupcycle does not knowingly collect or solicit any information from anyone under the age of 16 or knowingly allow such persons to register as Users. The Service and its content are not directed at children under the age of 16. In the event that we learn that we have collected personal information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible.
Links to Other Websites and Services
EU Privacy Rights
Legal Basis for Processing Your information
For the purposes of the processing of personal data of individuals in the European Union (“EU”), we rely on the following lawful basis for the processing of your personal data:
(a) Our legitimate interests in (among other things) delivering the Service, conducting commercial research, improving and maintaining the Service, personalizing and tailoring content made available to you through the Service, protecting the security or integrity of our databases, protecting our business or reputation, taking precautions against legal liability, dealing with our assets in the event of a business change (see further below), protecting and defending our legal rights or property, or for resolving disputes, investigating and attending to inquiries or complaints with respect to your use of the Service;
(b) Where relevant, your express consent. If you provide us with personal information relating to you and give your consent for using it;
(c) Where relevant, the fulfillment of our contractual obligations to you under our Terms and Conditions; and
(d) Where relevant, for compliance with legal obligations to which we are subject.
Users based in the European Union have the following legal rights in respect of their information:
(a) The right to require us to confirm whether or not your information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which your information is to be stored and whether any automated decision-making processes are used in relation to their information;
(b) The right to require us to rectify inaccurate information without undue delay;
(c) Where we relied on the ‘consent’ basis for processing that information, the right to withdraw your consent at any time. This right to withdraw consent does not affect the lawfulness of processing based on consent before its withdrawal;
(d) The right to request the erasure of your information. Subject to certain conditions, you can make a request for erasure where:
(i) the information is no longer necessary in relation to the purpose for which it was collected;
(ii) the processing of the information is based on your consent (and the other circumstances described in the ‘Legal Basis for Processing Your information’ and ‘How
We May Share Your information’ sections above no longer apply), if you withdraw your consent; or
(iii) where the personal data is processed by us solely on the basis of our ‘legitimate interest’ referred to above (and the other legal basis set out above do not apply), if you object to the processing of your personal data and there are no overriding legitimate grounds for the processing (such as, for example, where the processing of the data is required to meet statutory obligations or for the defense of legal claims).
Where we disclosed your information to a third party and you request the erasure or rectification of the data, we will take all reasonable steps to inform the third party of such request;
(e) The right to require us to restrict the processing of your personal data in certain circumstances, such as where the accuracy of that data is disputed or an objection has been raised. In such circumstances, we will only process that information with your express consent, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;
(f) Where data is processed based on your consent or to fulfill a contractual obligation, under certain conditions you may have the right to receive your personal data from us in a structured, commonly used and machine-readable format;
(g) The right to object to the processing of personal data where:
(i) we rely solely on the ‘legitimate interest’ basis for processing that data, in which case we may be legally required to stop processing your information unless we have compelling legitimate grounds for the processing which override your privacy rights and interests; or
(ii) the information is used for direct marketing purposes, in which case we will immediately stop processing your information for such purposes;
(h) You have the right to lodge a complaint with the data protection supervisory authority of the EU member state where you reside.
Please note that the above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment.
California Privacy Rights
If you reside in California, please read this section for additional disclosures about how we collect, use, and disclose information about you and your rights under the California Consumer Privacy Act (or “CCPA”) (California Civil Code Section 1798.100 et seq.).
Additional Disclosures Related to the Collection, Use, Disclosure, and Sale of Personal Information
- Categories of Personal Information Collected: In the previous 12 months, we have collected the categories of personal information described in the section below on ‘Summary of types of information we may collect and disclose’. For examples of the data we collect, please see “How We Collect and Use Information” above.
- Business or Commercial Purpose for Collecting and Selling Information: We collect personal information for the business and commercial purposes described in “How We Collect and Use Information” above.
- Categories of Sources of Personal Information: We collect personal information from and about you as described in “How We Collect and Use Information” above.
- Categories of Third Parties with Whom We Share Information: We may share your personal information with third parties as described in “How We Collect and Use Information” and “Sharing of Your Information” above.
- Categories of Personal Information Disclosed: In the preceding 12 months, we have disclosed the categories of personal information described in the section below on ‘Summary of types of information we may collect and disclose’.
- Google Ads on Groupcycle: We have chosen the restricted data processing setting with Google for all programmatic traffic for users in California via a network control. As such, Google will use user IP addresses to determine the location of users and enable restricted data processing mode for any users that Google can detect have a California IP address. When a publisher enables restricted data processing, Google will limit how it uses data and begin serving non-personalized ads only. Non-personalized ads are not based on a user’s past behavior. They are targeted using contextual information, including coarse (such as city-level, but not ZIP/postal code) geo-targeting based on current location, and content on the current site or app or current query terms. For more information on Google’s restricted data processing settings, visit https://support.google.com/admanager/answer/9561023?hl=en
Summary of types of information we may collect and disclose
* Identifiers such as your IP, email, address, and name;
* Personal Information such as payment information;
* Protected Classifications such as your gender and age;
* Commercial Information such as your purchase history;
* Electronic Network Activity Information such as how you browsed or interacted with the Services;
* Geolocation Data such as zip code;
* Audio, Electronic, Visual, or Other Similar Information such as photos you upload to the Service;
* Professional or Employment-related Information such as the industry you work in and your job title; and
* Inferences such as information based on how you use and interact with the Services.
Your Consumer Rights
The CCPA grants residents of California certain rights in relation to their personal information. If you are a California consumer, you have the following rights:
- Access: California consumers have the right to request access to the specific pieces of personal information we have collected about them in the last 12 months. They may also request the categories of personal information we have collected about them, the categories of sources of such collection, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share and sell their personal information, the categories of personal information we have disclosed and sold about them in the preceding 12 months, and the categories of third parties to whom we sold personal information in the preceding 12 months.
- Deletion: California consumers have the right to request deletion of their personal information (subject to certain exceptions).
- Opt Out of Sale: California consumers have the right to opt out of the sale of their personal information.
- Nondiscrimination: California consumers have the right to receive equal service and price and not be discriminated against even if they exercise any of their other CCPA rights; however, financial incentive programs may condition participation on collection of personal information.
If you are a California resident, you may exercise your rights under the CCPA by calling 650-204-8001 or via an email to email@example.com. You may also login to your account to access and correct your account information at any time.
When you exercise your rights, to confirm your request and ensure we respect your privacy and security, we will prompt you to verify your identify by confirming your name, email address, or phone number (or other identifiable information).