gvwy.xyz Privacy Policy

The data submitted should not include any sensitive personal data, such as government identifiers (i.e. social security, driving licence, or taxpayer identification numbers), complete credit card or complete personal bank card numbers, medical records or particulars connected with applications for care or treatment associated with private individuals.

Data handling

The chart below summarizes the requirements for handling information based on classification. Information comingled with multiple classifications must always be handled with the highest applicable classification (e.g. public information that is stored or transmitted along with Confidential information may be encrypted in order to simplify the use of encryption solutions).

Confidential

Distribution

• Not shared with third parties
• Customer information never included in reports, regardless of accompanying data

Labeling

• Documents, spreadsheets, presentations and text files labeled "Confidential"
• All paper documents labeled "Confidential"

Paper documents

• Only printed when there is a legitimate business need and no reasonable alternative, with management approval 
• Stored in a locked cabinet 
• Placed in destruction bin for shredding immediately after use

Electronic files

• Collected or stored when there is a legitimate business need and no reasonable alternative, with management approval
• Stored and transmitted encrypted 
• Wiped from electronic media immediately after use

Internal

Distribution

• Redistributed to anyone within Giveaway

Labeling

• Not labeled

Paper documents

• Only printed when there is a legitimate business need and no reasonable alternative 
• Stored on Giveaway premesis or in locked cabinet
• Placed in destruction bin for shredding immediately after use

Electronic files

• Stored and transmitted in clear text on Giveaway corporate systems
• Deleted or wiped from electronic media immediately after use

Public

Distribution

• Shared with anyone internal or external to Giveaway

Labeling

• Not labeled

Paper documents

• Recycled conventionally when no longer needed

Electronic files 

• Stored and transmitted in clear text
• Deleted or wiped from electronic media immediately after use

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3. Purposes of processing and legal basis

Your personal data is processed to meet one or several of the following purposes. Each purpose is associated with a legal basis, the list of which can be found below.

On the basis of our legitimate interest of offering you a safe, optimum, efficient and personalized experience, we carry out processing operations for the following purposes:

• To solve any problems and improve the use of our sites and services;
• To personalize, assess, and improve our services, content and materials;
• To analyze the volume and history of your use of our services;
• To inform you about our services as Giveaway as our partners' services and/or promotional offers.

On the performance basis of a contract to which you are a party, we carry out processing operations for the following purposes:

• To provide our services;
• To facilitate performance, including verifications relating to you.

On the bases of your consent or legitimate interest, we carry out processing operations for the following purposes:

• To sign up to our newsletters, use case studies and marketing material.

On the basis of the compliance with our legal and regulatory obligations, we carry out processing for the following purposes:

• To prevent, detect and investigate any activities that are potentially prohibited, unlawful, contrary to good practices and to ensure compliance with our terms of use and sending policy.

We use the personal data submitted to us only in accordance with the applicable data protection legislation.

4. Newsletter and marketing emails

For those of you that have expressly opted in to receive our Giveaway newsletters, you are easily able to unsubscribe by following the "unsubscribe" links included in every email sent.

5. Email statistics

Without systematically doing so, we may analyze and track the various rates (for example: click, open, bounce rates) and the number of emails sent with Giveaway which you open to assess performance rates on your emailing campaigns.

6. Testimonials

Giveaway publishes a list of Customers & Testimonials on its sites with information on our customers' names and job titles. Giveaway undertakes to obtain the authorization of every customer before publishing any testimonial on its websites. If you wish to be removed from this list, you can send us an email to privacy@GVWY.io

7. Third party disclosures

Personal data relating to you collected on our website are destined for Giveaway's own use and may be forwarded to Giveaway's partner companies so that we may obtain assistance and support in the context of carrying out our services. Giveaway ensures that it has in place clear data protection requirements for all of its third party providers.

Giveaway does not sell or rent your personal data to third parties for marketing purposes whatsoever.

In addition, Giveaway does not disclose your personal data to third parties, except if: (1) you (or your account administrator acting on your behalf) requests or authorized disclosure thereof; (2) the disclosure is required to process transactions or supply services which you have requested (i.e. to check you are employing best practices in your mailings or for the purposes of processing an acquisition card with credit-card issuing companies); (3) Giveaway is compelled to do so by a government authority or a regulatory body, in the case of a court order, a summons to appear in court or any other similar requisition from a government or the judiciary, or to establish or defend a legal application; or, (4) the third party is a subcontractor or sub-processor of Giveaway in the carrying out of services (for example: Giveaway uses the services of an Internet provider, a telecommunications company, a host provider, CRM tools, customer support client tools, invoices tools, payment tools, analytics tools).

8. Your data protection rights

In accordance with the CCPA and the European General Data Protection Regulation 2016/679 (GDPR) you have several rights related to the collection of your personal data:

• Right to be informed: This is precisely why we have drafted this privacy policy.
• Right of access: You have the right to access all your personal data at any time.
• Right to rectification: You have the right to rectify your inaccurate, incomplete or obsolete personal data at any time.
• Right to restriction of processing: You have the right to restrict the processing of your personal data in certain cases stated in art.18 of the GDPR.
• Right to erasure (‘right to be forgotten'): You have the right to demand that your personal data be deleted and to prohibit any future collection.
• Right to file a complaint to a competent supervisory authority (in France, the CNIL), if you consider that the processing of your personal data constitutes a breach of applicable regulations.
• Right to define instructions related to the retention, deletion and communication of your personal data after your death.
• Right to data portability: You have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.
• Right to object: You have the right to object to the processing of your personal data. Please note however that we may continue to process your personal data despite this opposition for legitimate reasons or for the defence of legal claims.

You can exercise these rights by sending us a support ticket directly on the support chat (either on the website or on the app) or, by sending an email at privacy@GVWY.io. Your requests will be processed within 30 days. We may require that your request be accompanied by a photocopy of proof of identity or authority.

You are also able at any time to modify personal data by logging into your account and navigating to "User Settings".

THIRD PARTY DATA

In the context of using our services, namely creating emailing campaigns and contact lists, Giveaway has access to the information contained in the email contact lists you create in your account, as Giveaway as the subject and content of the emails that you send out via our services.

This data is stored on secure servers and only a limited number of people are authorized to access your contact lists, in particular for the purpose of providing support services.

You are easily able to recover your contact lists from your Giveaway account at any time, by clicking on the "export" button. You may also modify and or delete contacts at any time from your account.

In no case does Giveaway sell, share or rent out your contact lists to third parties, nor does it use them for any purposes other than those set forth in this policy. We will use the information from your contact lists only for legal requirements, to invoice and collect summaries for our own statistics and for the purposes of providing you with customer support services.

As creator of the contact lists and associated email campaigns, you are considered the data controller within the meaning of the GDPR, and Giveaway is acting only as a data processor. In this capacity, you are responsible in particular for:

• making all the declarations necessary to the relative data protection authority,
• complying with all current regulations in force, including the data protection laws,
• obtaining the explicit consent of the persons concerned when collecting their personal data,
• ensuring your authority to use the in accordance with the defined end purposes and refraining from any unauthorized use.

If a recipient of your emails sent via our services requests us to modify or delete his/her personal data, we will honor that request after proper verification and will inform you of it.

DATA RETENTION PERIODS

Your personal data is kept for the periods set out below.

• for the execution of the services as Giveaway as information about how and when you use the services: The time needed to provide to you our services, and in no event no longer than 3 years after closing your account (unless otherwise required by law).
• in order to send newsletters, requests and direct marketing: 3 years from data collection or last active contact with the prospect.
• for evidentiary purposes: Duration of the statutory limitation period (generally 5 years).
• as part of your data subject's rights: If we ask you for proof of identity, we only retain it for the time necessary to verify your identity. Once the verification has been carried out, the proof is deleted.

LOCATION OF DATA STORAGE AND TRANSFERS

The host servers on which Giveaway processes and stores its databases are located exclusively within the United States.

Giveaway will inform you immediately, to the extent we are legally authorized to do so, in case of any application or order originating from an administrative or judicial authority relating to your personal data.

Regarding the tools we use (see article "Third party disclosures" on recipients of the collected data, concerning our processors), your personal data could be transferred outside the European Union. The transfer of your data within this framework is secured by the following safeguards:

• Either these data are transferred to a country which has been deemed to offer an adequate level of protection by the European Commission;
• Or we have concluded with our processors a specific contract governing the transfer of your data outside the European Union, based on the standard contractual clauses approved by the European Commission between a data controller and a processor.

PRIVACY POLICY CHANGES

Giveaway reserves the right to update this Privacy Policy at any time, in particular pursuant to any changes made to the laws and regulations in force. Any modifications made will be notified to you via our Website or by email, to the extent possible, thirty (30) days at least before any changes come into force. We would recommend that you check these rules from time to time to stay informed of our procedures and rules relating to your personal information.

CONTACT US

If you have questions, you can email us at Data Protection Officer directly at: privacy@GVWY.io or by mail to: xo capital outbound services, llc, Attn: Data Protection Officer / Legal Department, 7606 Santa Monica place, PMB 4571 West Hollywood, CA 90069-4109