PRIVACY POLICY

Last update: March 26, 2024

Gala MIX Inc. ("Gala", “we”, “us” or “our”) is committed to protecting the privacy rights of our users ("users" or "you").

This Privacy Policy (the “Policy”) describes the ways we collect, store, use, and manage the information, including personal information, that you provide or we collect in connection with our applications (the “App”) and/or websites (collectively, the "Services").
Please note that this Statement applies only to the Services maintained by Gala or its affiliates, and not third party sites or services, whether linked to or from the Services. In addition, this Policy does not apply to other entities that we do not own or control or persons that are not our employees, agents or within our control.
By using the Services, you are expressing your agreement to this Policy and the processing of your data in the manner provided in this Policy. If you do not agree to these terms, please do not use the Services. You must be 16 years of age or older to use the Services.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice. We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

1. Information We Collect

When you access or use our Services, we may collect information about you as described below. Our primary goal is to limit the information we collect to the minimum, especially personal information, but some information is required to be able to provide you with a customized experience and to deliver and improve our Services.

1. Account Information: When you first launch the App, we assign you an anonymous Account ID, but we do not require you to provide your name, email address or phone number. In addition, you may create a nickname to use some of the features of our Services. We strongly advise you not to choose a handle that contains personally identifiable information such as your name.
2. Device Information: We collect certain information such as your device or mobile device identifiers, device advertising ID, device brand and model, operating system and version, last 20 IP addresses and corresponding connection date and time, and language information.
3. Content and Usage Information: We collect any content you submit to the Services as well as information about the content, such as when you submitted it. We also collect information about your use of the Services, including App activity, App statistics and interactions with other user contents.
4. Other Information you Provide to Us: When you interact with our Services or otherwise communicate with us in any way, we will collect the information you choose to share with us. For instance when you ask for assistance from our customer support team, we may collect and store the contact information you provide (generally includes but not limited to your e-mail address). We may store the correspondence and any information contained within. We also collect optional Account Information you provide, such as your height, weight and gender, which is used to estimate the distance walked and calories burned. We will also store your profile image if you choose to upload one. Finally we will collect your physical activity (your daily steps) and an anonymized Google Fit ID if you choose to use Google Fit in the App to count your steps. We do not access, collect or store any other data associated with your Google Fit account, such as your name, phone number, email, address, profile photo, etc.
5. Information Collected by Tracking Technologies: We and our marketing and outsourcing partners use various technologies to collect information, and this may include sending cookies or trackers to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits. You can disable cookies at any time, although you may not be able to access or use features of the Service. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. We use mobile analytics software to allow us to better understand the functionality of our Services on your device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you may submit within the mobile application.
6. Other Information Collected with Permission: Our mobile applications that are distributed through various "app" stores (including iOS and Android) may also request permission to automatically collect other information from your mobile device. We may only collect this information with your authorization in accordance with your device operating system's permission process.

2. Use of Information

In general, we use the information we collect from and about you to provide and operate the Services, respond to your requests, and to provide customer service and technical support. We may use the information we collect to:

1. Identify or to authenticate users.
2. Monitor and analyze trends, usage and activities in connection with our Services.
3. Personalize and customize your experience while using our Services.
4. Send information about the Services, including push notification and alerts.
5. Deliver advertising and to track its result for our or third party's products and services.
6. Prevent spam or potentially illegal activities, and enforce our Terms of Service.
7. Carry out any other purpose for which the information was collected.

If you choose to use Google Fit to count your steps, we will use your Google Fit ID only to retrieve your steps data from the Google Fit API. We do not use your Google user data for any other purpose. We do not sell, transfer, disclose or share your Google user data to any third party.

3. Sharing of Information

We are committed to ensuring your privacy and protecting the security of your personal information. We do not share information about you with third parties except in the following circumstances:

1. With Your Consent: We may share your information (in some cases personal information) with third party companies, organizations or individuals when we have your consent to do so.
2. With Third Party Service Providers: We may provide your information to vendors, consultants and other service providers who need access to such information to perform services on our behalf, including data analysis, hosting services, customer service or will assist us in our marketing efforts.
3. With Third Party Advertisers: We may share (i) certain technical information about your device (including IP addresses and mobile device IDs), (ii) aggregated non-personally identifiable information, and (iii) anonymous information with third party advertisers. You agree that this information may be used by us or by the said third party advertisers to undertake user trend analyses, demographic profiling, and web analytics and to offer you behavioral targeted advertising.
4. For Legal Reasons: It may be necessary by applicable law, regulation, legal process and/or requests from public and governmental authorities for us to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public interest, disclosure is necessary or appropriate. We may also disclose your information if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.
5. Sale or Merger: In the event of a reorganization, merger or sale, we may transfer any and all personal information we collect to the relevant third party.

In particular, we may share information with the following Third Party Service Providers and Advertisers:

Hosting and data security

Amazon Web Services (USA): https://aws.amazon.com/privacy

Analytics, crashlytics, attribution and fraud detection

Google (USA): https://policies.google.com/privacy

Google Firebase (USA): https://firebase.google.com/support/privacy

Kochava (USA): https://media-index.kochava.com/privacy

Advertising, surveys and rewards

Adjoe (Germany): https://adjoe.io/privacy/

AppLovin (USA): https://www.applovin.com/privacy

AppSamurai (USA): https://insights.appsamurai.com/offerwall-privacy-policy

Bitburst (Germany): https://bitburst.net/privacy-policy/

Digital Turbine/Fyber (USA): https://www.digitalturbine.com/privacy-policy

InMobi (India): https://www.inmobi.com/privacy-policy

ironSource (Israel): https://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy

Liftoff (USA): https://liftoff.io/privacy-policy/

MakeOpinion (Germany): https://cpx-research.com/main/en/privacy.php

Mintegral (China): https://www.mintegral.com/en/privacy#privacy-policy-of-the-mintegral-services

Pollfish (USA): https://www.pollfish.com/gdpr

TV-Two (Liechtenstein): https://tv-two.com/privacy.html

TheoremReach (USA): https://info.theoremreach.com/privacy-policy/

Unity Ads (USA): https://unity.com/legal/game-player-and-app-user-privacy-policy

Online gift cards

Amilon (Italy): https://amilon.eu/privacy-policy/

GoGift (Denmark): https://www.content.gogift.com/privacypolicy-en

Tango Card (USA): https://www.tangocard.com/legal/privacy-notice

4. Analytics, Advertising and Other Third Party Services

We may allow third parties to serve advertisements in connection with our Services, to provide analytics services and provide you with other services, such as rewards programs. These third parties may use cookies, web beacons and other technologies to collect information about you on our Services and other websites and online services, such as your IP addresses, device manufacturer and operating system, identifiers associated with your mobile device or applications on the device, browser types and user activity. This information may be used by us, and these other companies and their customers and clients, to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your usage. Some of these third-party analytics and advertising services offer you a choice to opt out the collection of and/or sharing of this information; links to the opt-out mechanisms for the third parties that offer such a choice can be found in the "Your Choices" section below. This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies.

5. Storage and Protection of Information

We take reasonable technical, physical and administrative measures to safeguard your personal information against loss, theft, and misuse, as well as from unauthorized access, disclosure, alteration, and destruction. Furthermore, our trusted vendors and business partners are not authorized to use such information for purposes beyond those specified by us and are required to preserve the confidentiality with which we treat such information.

However, while we strive to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure, and there may be factors beyond our control that may result in disclosure of personal information. In particular, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information.

As a consequence, we disclaim any warranties or representations relating to maintenance or nondisclosure of any personal information collected from users.

6. Your Choices

1. Access to Personal Information

You have a right to request access to any personal information that we hold in relation to you. You may also review, update, correct or delete your personal information collected by the Services. You may also correct factual inaccuracies. To access the personal information that we hold in relation to you or to review, update, correct or delete your personal information collected by the Services, please contact us at info@winwalk.club.

In order to have access to your personal information, you must provide a proof of identification such as account ID and/or information about your recent activity on the Services. We reserve the right to deny access to any user if we believe there is a doubt about your identity. And if the burden or expense of providing access to your personal information is disproportionate to the risks to your privacy, or if the legitimate rights of others would be violated, we may decide not to provide access to such information. Moreover, we may still retain your information in our files to resolve disputes, enforce the Terms of Service, and for technical and legal requirements and constraints related to the Services. However, we will not use such personal information for any other purpose.

To delete your account data, please send us an email to info@winwalk.club specifying that you want to delete your account. We will contact you to confirm your request, and your account will be deleted within a few days.

You can also delete your account directly in the App, by visiting the Settings menu.

For more information about the account deletion process, please visit: https://s.winwalk.app/account-deletion

2. Opting Out of Push Notifications

We may occasionally send you push notifications to your mobile device. You may at any time opt out from receiving these types of communications by turning them off at the device level through your settings or by changing your App settings.

3. Special Note to Parents

Our Services are not intended for children under the age of 16 in principle and we do not knowingly or solicit personal information from anyone under the age of 16. If you are under 16, please do not use our Services and do not send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we learn that we have inadvertently gathered personally identifiable information from children under the age of 16 without their parents' consent, we will take reasonable measures to promptly erase such information from our record.

7. Users Outside Korea

Gala MIX Inc. is a company located in South Korea and its business operations are primarily conducted in South Korea. We operate our company and administer this Policy under applicable South Korean laws and regulations. If you use our service from outside South Korea, you are thereby consenting for your personal information to be processed in South Korea in the manner described in this Statement. We may also transfer information that we collect about you to affiliated entities or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world.
Furthermore, you acknowledge that the privacy laws of South Korea may differ from the laws in the country where you are located and may not provide you the same rights or protections as those laws.

8. Contact

If you have any questions, complaints, or comments regarding our Privacy Policy, or have other questions or suggestions about our Services, please contact us via e-mail at info@winwalk.club.