We, GG INTERACTIVE COMPANYLIMITED (“we,” “us,” or “our”), will collect information related to individuals (“Personal Data”) in providing our products, apps, services and websites (collectively, the “Services”). We consider the protection of Personal Data to be one of the most important management issues as a responsibility of an Internet content service company. We will act in compliance with the laws and regulations applicable in countries and regions where we are conducting business (such laws and regulations are hereinafter collectively referred to as the “Applicable Laws”), and will make efforts to properly protect Personal Data based on this Privacy Policy (this “Policy”).
This "Policy" explains the types of Personal Data we will collect, how we will use and provide Personal Data, and how you can manage your Personal Data.
This Policy applies to all Personal Data that we collect regardless of the country or region.
This Policy applies to all Personal Data that we collect.
We may apply individual privacy policies or additional provisions to terms of use or this Policy (collectively, “Individual Policies”) to specific services. The Individual Policies explain what kind of Personal Data we will collect, and how we will use and provide such Personal Data, for such specific services, and the other policies that are applicable to such specific services. If there is any inconsistency between the subject matter of the Individual Policies and the subject matter of this Policy, the Individual Policies shall prevail.
In connection with the application of this Policy, we are the controller of the processing of Personal Data.
We will process Personal Data to the extent permitted by the Applicable Laws according to this Policy.
We will collect the following Personal Data in a lawful and fair manner:
If you do not provide certain categories of data that are required to use the Services, you may not be able to use all or part of the Services' features.
The following are some examples of the Personal Data that we will collect.
We may request you to provide your Personal Data by operating your device and entering information, or through documents or other media.
Examples of such Personal Data include but are not limited to:
We will collect information about your activities related to using the Services, as well as information about your devices and how you use them.
Examples of such Personal Data include but are not limited to:
We automatically collects information about when and how you use the Services, including your use of individual items and various features of the Services, such as the dates and times you use individual items of the Services, the duration of your use of individual items of the Services, your search activities through the Services and their results, items of the Services purchased, and content and advertisements viewed, clicked, or tapped.
For example, when using Gleezy, the content you post, text messages, images, videos, audio files, etc. that you send through our servers. Additionally, external information such as recipients of content, data format, posting time and location, how you interact with others, and URL information for pages you click or tap within the Services are recorded on our servers.
In principle, regarding transmission content (e.g., messages between users and specific recipients excluding us),we will not use such content except for transmitting it. However, when providing specific services in certain countries or regions(*1), we may use some of such content for purposes such as providing and maintaining the Services, developing and improving the Services, preventing unauthorized use, and providing optimized content (including advertisements) after obtaining your separate consent.
We may collect location information from your device when we provide content based on your location information, when you share your location information with your friends in the Services, or to provide optimized search results. If you set your mobile device not to allow Gleezy to access your location, your device will not provide your location information us.
Additionally, in certain countries or regions(*2), when we provide you with customized content or advertisements (e.g., local news based on your location), we may separately request your location information and ask for your permission to use such information. In this case, you can choose to provide your location information or select the scope of use of your location information by changing settings.
Even if you choose not to allow us to access your location information, we may still estimate your approximate location based on information such as your IP address.
We will collect information about the devices, browsers, and apps you use (advertising IDs for device/browser identification, Cookie IDs, device type, operating system, language/timezone settings, browser type, app version, etc.), as well as network information (carrier name, IP address, etc.).
We may collect your Personal Data from partners.
Below are examples of Personal Data collected from third parties.
We may obtain your Personal Data from our group companies in accordance with their relevant terms or policies. To understand the privacy policies applicable to individual services provided by our group companies, please refer to the relevant terms of those individual services.
We may obtain your Personal Data from our partners, including partners who independently operate services or operate services associated with our Services (e.g., Gleezy Official Accounts or Gleezy Login).
Additionally, we may collect your identifiers (internal identifiers, advertising IDs, etc.), one-way encrypted (using hash functions) email addresses and phone numbers, IP addresses, partial device information (e.g., operating system), your attribute/characteristic information and activity records (including shopping records, browsing records, search records, and location information) from our partners, and use this data for purposes stated in Section 4 "Purpose of Use of Personal Data," such as sending messages from partners' official accounts, serving advertisements, measuring advertising effectiveness, generating and providing statistical data, and other purposes.
Other users using the Services may upload information containing third-party Personal Data, such as photographs containing third parties, and we will collect such information.
In addition to the above examples, we may also collect Personal Data in the following situations (including but not limited to).
We may collect login records from third-party (including partner) websites and apps with plugins such as "Send with Gleezy" and collect related URL information by linking such login records and related URL information with your account when you visit websites with such plugins through your browser while logged into our Services. We will use such data to understand how you use the Services and perform maintenance, improvement, security, and prevention of unauthorized use, impersonation, or misuse of the Services.
Additionally, in certain countries or regions, we may collect the following Personal Data when third parties (including partners) use the Services:
We will collect public information, such as information published online on corporate official websites, for purposes related to search services and other uses.
If the collected public information contains Personal Data, we may use such information to display search results.
We will use the collected Personal Data (including all Personal Data collected when you use the Services and Personal Data collected from third parties) for the following purposes:
We use Personal Data to provide the Services to users, utilize it for research and development to provide safer and better quality services, and provide services (including advertisements) that are more relevant to users.
Such use includes management and use of internal identifiers of the Services assigned to users, partner identifiers, advertising IDs (including Advertising Identifier (IDFA) and Google Advertising ID (AAID)), and various other identifiers and one-way encrypted (hashed) email addresses and phone numbers.
Additionally, we may collect your information from partners and combine it with our information for purposes stated in Section 4 "Purpose of Use of Personal Data," such as publishing messages from partners, serving advertisements, measuring advertising effectiveness, creating and providing statistical information, and other purposes.
Regarding information collected from partners, we may collect your identifiers (internal identifiers, advertising IDs, etc.), hashed email addresses and phone numbers, IP addresses, partial information about your devices (operating system, etc.), your attribute information, and your operation records, including purchase records, browsing records, search records, and location information.
When collecting Personal Data, we will notify or announce the purpose of use to users to the extent required by applicable laws (including notification and announcement of purpose of use according to this Policy).
Unless we obtain your consent or it is permitted by law, we will not process Personal Data outside the scope of the purpose of use. At the same time, we will take appropriate measures to ensure Personal Data is not used for any other purposes.
Notwithstanding the above, when receiving Personal Data from third parties, if such Personal Data has other purposes of use, we will use such Personal Data according to the provided purpose within the scope permitted by applicable laws.
The purposes of use of Personal Data include, but are not limited to, the following.
We will use necessary related information to provide you with the Services, respond to your inquiries, conduct marketing activities, and publish announcements related to the Services and partner announcements.
For example: We will use Personal Data to provide and maintain the Services in the following cases:
We will use Personal Data for development and improvement of the Services to provide better services, products, and content to users.
For example: We will use Personal Data for development and improvement of the Services in the following cases:
We will use Personal Data and implement security measures to prevent unauthorized use and maintain the usage environment to ensure uninterrupted provision of the Services and allow users to use the Services with peace of mind daily.
For example: We will use Personal Data for security and prevention of unauthorized use in the following cases:
We will use Personal Data to recommend content (including advertisements) to each user.
For example: We will use Personal Data to provide optimized content to users in the following cases:
In principle, we will obtain your consent before processing your Personal Data related to Gleezy; however, we may also process your Personal Data based on the following legal grounds within the scope permitted by Applicable Laws:
For example, we may process your Personal Data based on legitimate interests as described in (5) below for purposes such as providing and improving the Services, developing and improving the Services, and ensuring security and implementing measures to prevent unauthorized use:
(1) Processing of Personal Data is necessary for the performance of a contract between us and you or to take steps at your request prior to entering into a contract;
(2) Processing of Personal Data is necessary for compliance with our legal obligations (e.g., compliance with information disclosure orders issued by government authorities based on relevant laws);
(3) Processing of Personal Data is necessary to protect vital interests of you or third parties;
(4) Processing of Personal Data is necessary to investigate or prevent illegal or suspected illegal acts, or to take related measures;
(5) Processing of Personal Data is necessary for legitimate interests pursued by us or third parties (including operation or system improvements by us, fraud prevention, security maintenance, marketing, and research), unless your privacy-related rights, interests, and freedoms clearly deserve more protection than such legitimate interests; or
(6) Processing of Personal Data is necessary for public interest, historical document preservation, investigation, or statistical purposes, and appropriate security measures have been implemented.
We will not provide, disclose, or share your Personal Data with any third party unless you consent to it or such provision, disclosure, or sharing of Personal Data is permitted by Applicable Laws.
However, we may provide Personal Data to third parties in the cases described in Sections 5.a to 5.f below.
The countries or regions where Personal Data recipients are located are as follows:
■ United Kingdom and European Economic Area
■ Countries or regions recognized by the European Commission as having adequate protection for personal data
■ APEC Cross-Border Privacy Rules (CBPR) System member economies
■ Other countries (Thailand, Indonesia, Vietnam)
To properly provide the Services, we may add more subcontractors and group companies to the list of Personal Data recipients. Although we cannot predict all countries and regions where Personal Data may be provided in the future, if the countries or regions of third parties receiving Personal Data expand in the future, we will notify you of the new recipient countries or regions through this Policy.
We have data center locations in Japan, the European Economic Area, countries or regions recognized by the European Commission as having adequate protection for personal data, or CBPR System member economies. Additionally, persons who can access Personal Data stored in our data centers may be located in third countries where personal data protection laws differ from those in Japan. Even when accessing from such countries, we will stipulate in service agreements that companies accessing Personal Data are obligated to implement appropriate security management, and we will take management and supervision measures for such companies. We will take necessary measures to ensure Personal Data is properly protected according to our security standards, such as implementing appropriate encryption measures on paths for accessing Personal Data.
Public information and profile information set as public can be viewed by third parties other than users, such as posts and comments on bulletin boards that can be accessed by an unspecified or large number of users.
Due to the nature of digital data, viewers of such information can copy, store, or transmit such data, which can be accessed and used by unspecified third parties. Please carefully review the content and disclosure scope of posts when setting your profile information or posting on the Services.
Please note that we may provide your public information to third parties. Public information we provide to third parties may be published on third-party services.
We confirm that such third parties comply with personal data protection policies in their locations.
If transactions between companies involve Company businesses subject to this Policy, such as acquisitions, mergers, or changes in business entities, Personal Data may be transferred to the successor of such businesses within the scope permitted by Applicable Laws.
In the following situations, within the scope permitted by applicable laws, we may provide your Personal Data to third parties (including Company partners) to the extent necessary after removing information that can directly identify specific users (such as user names, addresses, detailed location information, or Gleezy message content).
■ When necessary for providing the Services or improving the quality of the Services (including when necessary for advertising and promotional activities related to the Services)
■ When necessary for considering new Company services
■ When necessary for preventing unauthorized use
■ When Personal Data is provided to research institutions for survey, research, and analysis purposes
For example, when you add a Gleezy Official Account as a friend, send messages to a Gleezy Official Account, or join a group that includes official accounts, we will provide necessary information to the minimum extent (such as internal identifiers assigned to your account and language settings) to enable such official accounts to send you messages for proper provision of our services. For specific services or features provided by certain partners, we may request additional Personal Data from you, such as your email address or phone number. In such cases, we will seek your consent regarding providing Personal Data to such partners before you use such services or features.
Personal Data recipients will process Personal Data according to their own rules and policies. We confirm that such recipients comply with personal data protection policies in their locations.
If we receive requests made pursuant to legal procedures, such as subpoenas, or if anyone faces imminent danger to life or property, such as suicide threats or bomb threats, we may disclose Personal Data to third parties (including law enforcement agencies such as police or courts) in accordance with Applicable Laws.
We will establish basic policies to properly manage collected Personal Data and implement strict organizational, personnel, physical, and technical security measures. We will review and improve our internal rules and regulations in accordance with changes in applicable laws and social norms to continuously enhance our data protection measures.
In principle, we will retain most of your information unless you request to delete your account. Once we receive your request to delete your account, we will retain your information for a certain period in accordance with Applicable Laws and internal rules before deletion.
We will implement strict organizational, personnel, physical, and technical security measures to manage collected Personal Data to respect and protect your privacy and the confidentiality of your Personal Data, and to prevent unauthorized access to your Personal Data. These measures include: security controls implemented according to industry standards to prevent unauthorized access, disclosure, use, alteration, or destruction of Personal Data.
For example: We currently implement the following measures
Furthermore, we will never provide any means of fraudulently accessing Personal Data to third parties.
However, since no electronic transmission or data storage method is perfect or impenetrable, we cannot guarantee that your Personal Data will be 100% secure from attacks during transmission or while stored in our systems.
To help protect your privacy and Personal Data security, we need your cooperation. Please do not share your password with others or use the same password as other services. Also, if you suspect any unauthorized use of your Gleezy account or other security vulnerabilities, please contact us through our email at "[email protected]".
We collect and retain Personal Data to provide the Services at your request, achieve any purposes stated in this Policy, or comply with Applicable Laws.
In principle, we will retain most of your information unless you request to delete your account. After your account is deleted, we will retain your Personal Data for a period in accordance with Applicable Laws and our internal regulations for the following purposes:
Additionally, we will establish Personal Data retention periods based on the following criteria:
After the expiration of data retention periods stipulated by Applicable Laws and our internal rules, we may retain relevant data in a form that cannot identify the data subject.
We may use tags and modules including cookies and third-party software development kits (SDKs) for purposes stated in this Policy.
We may install third-party software development kit (SDK) modules in the Services for the following purposes (including but not limited to):
When third parties process your Personal Data through third-party modules, their privacy policies will apply.
"Cookies" are small text files that are stored on your computer when you visit a website. The information stored in these text files can be read by the website operator when you visit the website again.
For example, we may use cookies and other similar web tracking technologies (web beacons, pixels, etc.) for the following purposes:
You can control whether to accept cookies through your browser settings or using other tools. However, if you disable cookies or set restrictions on cookies, you may not be able to use all content or features of the website, which may affect your overall user experience.
To improve the Services, we use Google Analytics to measure the Services (such as our websites). Google may place cookies or read existing cookies to collect data. Information such as the URLs you visit and your IP address will be automatically transmitted to Google. We may use such information to understand usage of the Services or use such information in the Services. Regarding Google's data processing in Google Analytics, please refer to Google Analytics Terms of Service and Google Privacy Policy.
We may use Apple's TrueDepth camera to collect additional information from your device's camera to improve our camera and video call quality or enhance features such as effects, but such information is only processed in real-time when providing and improving such features and is not stored on our servers or shared with any third parties.
We may modify this Policy. The latest version of the Policy will always be posted on this site, and we encourage you to review the contents of the latest version of the Policy carefully.
When we make any material changes to this Policy, we will notify you through reasonable means.
The Services are provided to the general public, and if minors wish to use the Services and provide Personal Data, they must obtain consent from their legal representatives. You represent and warrant that you have the capacity and legal qualification to use the Services. If you are a minor, you represent and warrant that you have obtained consent from your legal representative regarding use of the Services. We proactively set age restrictions in specific services to prevent situations where we cannot confirm users' ages.
We understand that Personal Data of minor users (under 13 in the United States, under 16 in Europe, under 11 in Thailand, and under 18 in Indonesia) using the Services in the United States, Europe, Thailand, or Indonesia should be specially protected, and we will not knowingly collect any Personal Data from minor users.
However, if you believe we have collected Personal Data from minor users in the above countries or regions, please contact us through our email at "[email protected]". If we discover that we have inadvertently collected data from minor users in the above countries or regions, we will disable such Gleezy accounts and take reasonable measures to promptly delete such Personal Data from our records.
Unless otherwise specified in this Policy, we are the data controller for Personal Data collected through the Services and subject to this Policy. If you have any questions or requests regarding this Policy, or any issues, complaints, concerns, or opinions regarding the processing of Personal Data in the Services, please contact us through our email at "[email protected]".
We may change this Policy from time to time, and the latest version of this Policy will always be posted on our website. Please carefully review the content of the latest version of this Policy. If there are any material changes to this Policy, we will send you notifications in the Services or through reasonable channels. Please carefully review the content of the latest version of this Policy.
If you do not accept any changes to this Policy or wish to stop using the Services, you may choose to disable your account. Your continued use of the Services after we send you notifications regarding changes to this Policy or post such notifications in the Services indicates that you agree to and accept the changes to this Policy and its latest version. We will seek your consent in accordance with Applicable Laws.
GG INTERACTIVE COMPANYLIMITED
Established Date: March 17, 2025
Last Updated: March 17, 2025