Table of Contents

1. Introduction and Applicability of This Policy

2. Data We Collect and Receive

2. Who We Share Your Data With

3. Third-Party Websites and Services

4. How We Protect Your Data

5. Storing of Your Data

6. International Data Transfers

7. Your Rights and Options

8. Changes to This Privacy Policy

9. Contact Us

1. Introduction and Applicability of This Policy

1.1. Throughout this document, “Company,” “We,” “Us,” “Our,” and “Ours” refer to:

Great Golden Investment JSC (also referred to as “Data Controller”)
Tax ID: 83-2987714
Address: 78B Ton That Thuyet Street, Ward 16, District 4, Ho Chi Minh City
Contact Email: info@ggigroup.org
Contact Phone: +84 98 5559777

The identity and contact information of the Company representative for European Union users: Tran Dinh Tri
Data Protection Officer of European Union users: info@ggigroup.org

1.2. This Privacy Policy describes how we collect, store, use, and manage the personal information you provide to us or that we collect in connection with our website https://ggigroup.org/ (referred to as the “Website”), official company communities on social media, mobile apps “PPP-Kids” and “PPP-GGI” (referred to collectively as the “Applications”), as well as your choices and rights regarding the collection and use of personal information.

The Privacy Policy applies to all visitors and users who use our Services (hereinafter referred to as “Users” or “You”). Some of our Services are intended for children. This privacy policy includes a section on Children’s Privacy. However, some other sections of this privacy policy equally apply to children’s personal information and the personal information of adults. When this is the case, we explicitly state it.

This Privacy Policy is also part of the Terms of Use located at https://ggigroup.org/docs/terms-of-use/ (the “Terms of Use”), which you, or if you have not reached the age of majority in your jurisdiction, a parent or legal guardian on your behalf, must read and accept. The Terms of Use explain your rights and the responsibilities of the Company when you use the Services. Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Use.

Whenever we refer to a child, we mean a child under the age of 13 for US users, and a child under the age of 16 for EU users.

Before accessing or using our Services, please ensure that you have read and understood how we collect, store, use, and disclose your personal information as described in this Privacy Policy.

2. Data We Collect and Receive

Our child monitoring, protection, and care service is designed to ensure the safety and well-being of children and prevent strokes in adults. When using our service, we collect the following personal information:

– User Registration Data: When users create an account for our service, we may collect personal information such as their name, email address, and contact number. This information is necessary for account setup and communication purposes.

– Child Profile Data: As part of the service, parents or guardians provide information about their children, including their names, ages, and any specific health conditions or requirements. This information helps us tailor our monitoring and care services to each child’s needs.

– Location Data: Our service utilizes GPS technology to monitor the whereabouts of children and track their movements. We collect location data, including country, region, and city, to provide accurate location information to parents or guardians.

– Communication Data: We may process communication data exchanged between users and our support channels, such as messages, reports, or inquiries. This helps us address any issues or concerns raised by our users effectively.

– Usage Data: We collect data on how users interact with our service, including app usage, feature usage, and preferences. This information helps us improve our service, enhance user experience, and personalize content.

– Health Data (for adult stroke prevention): In the case of our stroke prevention feature for adults, we may collect health-related data, such as blood pressure readings, heart rate measurements, and other relevant health indicators. This data is used to assess the risk of stroke and provide personalized recommendations for prevention.

– Cookies and Similar Technologies: We may use cookies or similar technologies to collect certain information, such as session data and user preferences, to enhance the functionality of our service and personalize the user experience.

– Anonymized Data: We may collect and analyze anonymized data from our service to identify trends, patterns, and insights. This data does not contain personally identifiable information and is used for research, statistical analysis, and service improvement purposes.

We are committed to protecting the privacy and security of personal information in accordance with applicable data protection laws. We implement appropriate safeguards to ensure the confidentiality and integrity of the data we collect.

Please note that the collection and processing of personal information in our service are carried out with the consent and involvement of the parents or legal guardians. We encourage parents or guardians to review our privacy practices and contact us if they have any questions or concerns regarding the privacy or security of their child’s information.

If you have any further questions or require additional information, please feel free to contact us at info@ggigroup.org.

3. Who We Share Your Data With

3.1. We only share the information we collect about you in the following circumstances: when necessary for the performance of a contract with you, to comply with a legal obligation, or based on our legitimate interests. We may share your personal information, as well as your child’s personal information, with third-party service providers who perform services on our behalf. These services may include payment processing, email services, fraud prevention, analytics, and other specified services. We do not sell your information to advertisers or other third parties. Any third party that has access to your personal data is strictly prohibited from using it for any purpose other than providing the agreed-upon services.

3.2. Hosting Services: We may use third-party companies such as Namecheap, Vultr to host information or provide infrastructure for the delivery of our services.

3.3. Customer Support Services: We engage third-party providers to assist us in providing customer support for specific territories and products. These providers may have access to your personal data, including data you provide in your customer support requests.

3.4. Email Service Providers: We utilize partners like the Rocket Science Group LLC (“Mailchimp”) and eSputnik Inc. to send email notifications, and these partners may have access to your email address.

3.5. Advertising and Advertising Measurement Partners: We may share your personal information to facilitate targeted advertising, delivery, and measurement of online advertising on third-party services. This may include partners such as Facebook Inc. and Google Ads. We do not share children’s personal information for these advertising purposes.

3.6. Sharing Anonymous Information: We may share anonymous or aggregated information with third parties that does not directly identify you. This includes sharing trends about the use of our services. We may also allow our third-party advertisers to collect anonymous and aggregated information within our services to deliver targeted advertising. Advertisers may use tracking technologies like cookies and web beacons for this purpose.

3.7. Publicly Available Information: Our sites may provide publicly available chats, forums, and blogs. Any information you voluntarily share in these public areas is at your own risk. We are not responsible for the information you choose to make public. Please be aware that any information you provide in these communication services, including your account information, may be read, collected, and used by the public. If you want your personal information removed from publicly accessible websites operated by us, please contact us as specified below.

3.8. Change of Control: In the event of a sale, merger, or change in control of our company, we may share your data as part of that transaction. Any entity acquiring our company or part of our business will have the right to use your data in accordance with this Privacy Policy, unless you agree otherwise.

We may also disclose your personally identifiable information when required by law or when we believe such disclosure is necessary to protect our rights, comply with judicial proceedings, court orders, or legal processes.

4. Third-Party Websites and Services

There are instances on our Services where you may encounter links to other websites, services, or web resources that are not affiliated with us and do not operate under this Privacy Policy. Clicking on such links, for example, an advertisement, may redirect you to a website that we do not control. Please be aware that these third-party websites may collect information, including your personal information, independently. We recommend reviewing the privacy policies of any third-party websites you visit.

5. How We Protect Your Data

The Company implements various precautions, including legal, organizational, administrative, technical, and physical measures, to protect your personal data, including that of child users, from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, or any other unlawful actions by third parties. To ensure the security of your and your child’s personal data, we communicate confidentiality and security standards to our employees and closely monitor the implementation of these measures within the company.

6. Storing of Your and Your Child’s Data

6.1. We do not retain personal data that can identify a user for a period longer than necessary to fulfill the purpose for which the information was collected. Your personal data is stored as long as your user account remains active or as needed to provide you with the service. This also applies to the data of child users.

Please note that if you request the removal of your personal data, we may retain certain information as required for our legitimate business interests, such as fulfilling legal obligations, resolving disputes, and enforcing our agreements.

6.2. Storage of Information for Marketing Purposes: If you have opted to receive marketing notifications from us, we retain information about your marketing preferences for a reasonable period of time from the date of your last expressed interest in our services.

Information obtained from cookies and other tracking technologies is stored for a reasonable period of time from the date of its creation, following the conditions outlined in section 2.2.4 (Data Collected Automatically via Cookies and Related Technologies).

7. International Data Transfers

7.1. Our service is global in nature, which means that your and your child’s data may be transferred to locations anywhere in the world. In order to provide you with the services, we may transfer, process, and store your information outside of your country of residence. We take measures to ensure the protection of your data whenever it is transferred.

7.2. International transfers to third parties. Some of the third-party service providers mentioned in this privacy policy may be located in countries that do not have privacy and data protection laws equivalent to those in your country of residence. If we share the information of customers in the European Economic Area or Switzerland, we adhere to the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms to safeguard the transfer. Upon request, we can provide you with a copy of the standard data protection clauses.

8. Your Rights and Options

8.1. You have certain rights and options regarding your information. Here is a summary of those rights, how to exercise them, and any limitations that may apply.

8.2. Please note that there may be limitations to your requests and choices in certain cases, such as when fulfilling your request would reveal information about another person or if you ask to delete information that we are legally required to keep or have compelling legitimate interests to retain.

8.3. Right to Know Your Personal Data Processed (Right of Access)
Upon verifying your identity, we will provide you with a copy of your personal data in a structured, electronic format if you request it. The process for making such requests is described below. You can contact us as outlined in section 12 (Contact Us) to seek assistance.

8.4. Change or Correct Your Personal Data (Right to Rectification)
If available, you can edit certain personal data through your account settings. In specific cases where your data is inaccurate, you can request us to change, update, or correct it by contacting us as explained in section 12 (Contact Us).

8.5. Delete Your Personal Data (Right to Erasure)
You can request us to erase or delete all or some of your personal data if it is no longer necessary for providing services to you. Deleting your account will result in the loss of access to most services, including account-related information and the associated user history.

8.6. Opt-Out of Direct Marketing
You have the option to opt-out of our use of your information for marketing purposes. You can follow the instructions provided in promotional communications or contact us as outlined in section 12 (Contact Us). Please note that certain service-related messages, such as account verification, parental consent, order confirmation, and important service updates, cannot be deactivated.

Additionally, you can opt-out of interest-based advertising on mobile applications by adjusting the privacy settings on your Android or iOS device.

8.7. Withdraw Consent
If the processing of your personal information is based on your consent, you have the right to withdraw that consent. You can do so by contacting us as explained in the “Contact Us” section. Withdrawal of consent will not affect the lawfulness of processing based on your consent before its withdrawal.

8.8. We aim to respond to all requests within one calendar month. In case of complex or multiple requests, the response time may be extended by an additional two calendar months. If such an extension is necessary, we will provide an explanation for the delay. Whenever possible, we will provide the requested information electronically if your request was submitted electronically, unless you specify otherwise.

8.9. You have the right to lodge a complaint with the Data Protection supervisory authority regarding unresolved complaints.

8.10. European Union users have additional specific rights:

8.10.1. Request That We Stop Using Your Data (Right to Object)
If the processing of your personal data is based on legitimate interests, you have the right to object at any time. If you object, we will cease processing your personal data unless there are compelling legitimate grounds for the processing or if the data is necessary for the establishment, exercise, or defense of legal claims.

8.10.2. Data Portability
You have the right to obtain some of your personal information in a format that allows you to transfer it from one service provider to another, where applicable and depending on the context.

9. Changes to This Privacy Policy

9.1. We may modify this privacy policy periodically. Any changes will be published on this page, and if the changes are significant, we will provide a more noticeable notice by adding a notification within the Services or by sending you a notification. We encourage you to review our privacy policy whenever you use the Services to stay informed about our information practices and the ways you can help protect your privacy.

9.2. For users in Vietnam, if any changes we make to this policy affect users under the age of 13 in a way that requires parental consent under the PPP (Personal Data Protection) regulations in Vietnam, we will obtain prior parental consent.

10. Contact Us

If you have any questions regarding the Company’s Privacy Policy or the processing of data by the Company, you can contact us at:

Great Golden Investment JSC
Tax ID: 83-2987714
Address: 78B Ton That Thuyet Street, Ward 16, District 4, Ho Chi Minh City
Contact Email: info@ggigroup.org
Contact Phone: +84 98 5559777