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PRIVACY STATEMENT

Last updated: November 2018

Your privacy is important to GINA. We developed this Privacy Statement so you know how we collect, use, share and store your personal information.

This Privacy Statement applies to all websites, applications (“apps“) and products on which this Privacy Statement is shown. If a GINA website, app or product links to a different privacy statement, then that privacy statement will apply to your use of that site, app or product.

WAYS GINA COLLECTS AND USES PERSONAL INFORMATION

"Personal Information" is information that, either alone or in combination with other information collected, identifies an individual. When we combine other information (i.e., information that does not, on its own, identify an individual) with Personal Information, we treat the combined information as Personal Information.

 

WHEN YOU CREATE A GINA ACCOUNT

When you create an account on a GINA website, mobile app or directly with our sales team, we ask you to provide Personal Information, including your name, email address and IMEI number of the device you will be using our app on. Your personal data provided to GINA when creating an account are processed by GINA on legal basis of conclusion and performance of contract. You will use your email address and your password to login to your account. IMEI of the device is checked automatically via the app to provide additional security and prevent unauthorized devices and users to acces your shared data. Your GINA account will be password-protected. We use your name to help verify your account when you call customer support. You as the data subject are responsible for the accuracy and verity of the personal data given to GINA.

 

WHEN YOU COMMUNICATE WITH GINA

When you interact with our customer support representatives via email, telephone or in person, we may collect Personal Information, such as your name, mailing address, phone number, email address and contact preferences; and information about the GINA products you own, such as their serial and IMEI numbers and date of purchase. Your personal data provided to GINA for the purpose of communication are processed by GINA on legal basis of legitimate interest. We also may create event logs that are useful in diagnosing product or app performance related issues, and capture information relating to the support or service issue. We use this information to provide you with customer and product support. We may access your GINA account in order to assist us in providing you the necessary assistance. To improve customer service, subject to applicable laws, we may also record and review conversations with customer support representatives.

We may use Personal Information to communicate with you, including communicating with you about your account or transactions with us, giving you important information about your products or apps, sending you notice about material changes to this Privacy Statement, and, consistent with applicable laws.

WHEN YOU USE LOCATION FEATURES ON YOUR GINA DEVICE OR APP

The GINA apps are used mainly for continuous tracking of its user, so the physical location of your device will be collected and stored in order for GINA to provide you with such location-based services, unless you choose otherwise using the settings available in the app. These personal data are processed by GINA in connection with the service provided on the legal basis of the conclusion and performance of the contract.

WHEN YOU USE YOUR AUTO NAVIGATION APP

GINA apps rely on third-party navigation software so we suggest you carefully review Sygic or Google privacy policies, depending on which one you use.

OTHER USES OF PERSONAL INFORMATION BY GINA

GINA may use Personal Information for internal statistical, marketing or operational purposes, including generating sales reports and measuring and understanding demographic, user interest, purchasing and other trends among our customers. Personal data are also processed by GINA on a legal basis of legitimate interest.

ENTITIES WITH WHICH GINA MAY SHARE PERSONAL INFORMATION
WITH SERVICE PROVIDERS

We use third party service providers to help us to administer certain activities on our behalf, such as fulfilling purchases and shipping products, processing credit card payments, sending emails and analyzing usage of our websites and apps. We may share Personal Information about you with such third party service providers to the extent necessary for the sole purpose of enabling them to perform services on our behalf.

Here are examples of third-party service providers we use:

  • E-mail Providers: Cloud services from Microsoft are used to assist GINA in sending emails, consistent with applicable laws.

 

OTHER DISCLOSURES

We may disclose Personal Information about you to others if we have your consent to do so in such form of consent as may be required under applicable law.

Subject to applicable laws in your jurisdiction, we may also disclose Personal Information about you to others as we believe to be necessary or appropriate: (a) under applicable law or regulation, including laws or regulations outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public authorities and law enforcement officials, including officials outside your country of residence; (d) to assist or support theft investigations involving GINA products or property, (e) to enforce any of our terms and conditions or policies; (f) to protect our operations or those of any of our affiliates and subsidiaries; (g) to protect the rights, privacy, safety or property of GINA, its affiliates and subsidiaries, you or others; or (h) to permit us to pursue available remedies or limit the damages that we may sustain.

We may also transfer Personal Information to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of GINA’s business and assets, including, without limitation, in connection with any bankruptcy or similar proceeding.

WAYS YOU MAY SHARE PERSONAL INFORMATION OR DIRECT GINA TO SHARE YOUR PERSONAL INFORMATION
LIVE TRACKING

As GINA apps are mostly used by emergency services and you usually pick a set of users, operators and co- workers, that you can share real-time location of your device with so they can provide you with assistance if necessary and it provides them with better awareness over your unit location. Those users have to use compatible GINA app of their own to be able to display your location.

LINKS, THIRD PARTY APPS, AND THIRD PARTIES’ PRIVACY PRACTICES

Our websites, apps and products may contain links to other sites that are not operated by GINA, and our websites or your product may contain apps that you can download from third parties. These linked sites and apps are not under our control and we are not responsible for the privacy practices or the content of any linked sites and apps. If you use any third-party sites or apps, any Personal Information collected by the third party’s site or app will be controlled by the privacy policy of that third party. We recommend that you carefully review the privacy statements of any third parties to which you provide Personal Information.

SECURITY

GINA takes reasonable security measures to help protect against loss, misuse, unauthorized access and unauthorized disclosure or alteration of the Personal Information under its control.


PRIVACY STATEMENT UPDATES

We may change this Privacy Statement from time to time as we add new products and apps, as we improve our current offerings, and as technologies and laws change. You can determine when this Privacy Statement was last revised by referring to the "LAST UPDATED" legend at the top of this page. Any changes will become effective upon our posting of the revised Privacy Statement on our affected websites. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. This notice will be provided by email or by posting notice of the changes on our affected websites or products/apps, consistent with applicable laws.


RETENTION AND PROCESSING METHOD OF PERSONAL INFORMATION

We will retain your Personal Information for the period necessary to fulfill the purposes for which your Personal Information has been collected as outlined in this Privacy Statement unless a longer retention period is required by law. Gina processes the provided personal data manually in paper and electronically in an automated manner.


HOW YOU CAN REVIEW, CORRECT, UPDATE AND DELETE YOUR PERSONAL INFORMATION

GINA takes reasonable steps to help ensure that the Personal Information we collect from you is accurate, complete and current. You may request access to your Personal Information and request that erroneous or inaccurate Personal Information be updated. You may also request that your Personal Information and GINA account be deleted. You also have the right to limit the processing of personal data, the right to object against the processing of personal data and the right to portability of personal data. When personal data are being processed on the basis of the consent, you have the right to withdraw the consent at any time. You can do so via e-mail as is mentioned below. You also have the right to file a complaint about the processing of your personal data with the supervising authority. GINA will respond promptly to your requests in accordance with applicable law. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We may decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we may need to retain certain Personal Information for a longer period of time for record keeping purposes, such as retaining records relating to your purchases for warranty or accounting purposes.

Access, correction or deletion requests can be made as follows:

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