Gravity Privacy and A.I. Policy
Date Last Modified: 9/27/2019
3. SPECIAL NOTE ABOUT CHILDREN
We do not offer the Services to, or knowingly collect or solicit information from, anyone under the age of eighteen (18). Accordingly, We do not knowingly collect age identifying information, nor do We knowingly collect any Personal Information from children under the age of thirteen (13). If You are under thirteen (13), do not create a User account, use or provide any information through the Services or on or through any of its features, use any of the interactive or public comment features, or provide any information about Yourself to Us. In the event We discover that anyone under thirteen (13) has provided Personal Information to Us, in accordance with Our policies and the Children’s Online Privacy Protection Act, We will delete that person’s Personal Information from Our files to the extent technologically possible. If You believe We might have any information from or about a person under thirteen (13), please send an email to email@example.com, with the subject heading “Children’s Online Privacy Protection Act.”
4. INFORMATION Gravity COLLECTS
In order to operate the Services and provide You with access to certain features, Gravity may collect the following types of information from You:
- Personal information - Information by which You may be identified (“Personal Information”) as well as information that may not be personally identifiable standing alone (for example, Your age), but which may become personally identifiable when combined with Personal Information (for example, Your age combined with Your name); and
- General Information - Information about You and Your activities on the Services that does not identify You personally (“General Information”), such as Your domain server, web browser, the operating system or platform You use, referrer data identifying the web pages You visited prior to and after accessing the Services, and Your movement and activity within the Services.
Personal Information does not include information regarding an organization or corporate entity.
A. PERSONAL INFORMATION
- Personal Information about You Collected Directly from You
Gravity may collect Personal Information directly from You when You interact with Us through the Services, such as when You access the Site, create a User account, complete a service request form, e.g., wwww.gravityglobal.com/contact, contact the Gravity Support Team, or conduct transactions within the Services. The Personal Information Gravity may collect and maintain about You includes:
- Contact information, such as legal first and last name and residential address;
- Date of birth;
- Account username and password;
- Email address;
- Information about Your project;
- Unique identifiers, such as an Internet Protocol (IP) address, a processor or device serial number or other unique device identifiers, that are combined with Personal Information; and
- Location coordinates (longitude, latitude, and radius) if You use Your mobile phone or a GPS equipped device to access the Services.
You can always choose not to provide Your Personal Information to Gravity, but it may mean that We are unable to provide You with the Services.
- Personal Information about You Received from other Sources
Where permitted by applicable law, Gravity may collect information about You from other sources, including through interactive applications (such as mobile devices and third-party services), from commercially available sources (such as data aggregators and public databases) and when You access the Services through a SNS. Gravity may access and store some or all of the following Personal Information:
- Contact information, such as legal first and last name and residential address;
- Date of birth;
- Email address;
- Account username and password;
- Unique identifiers, such as an Internet Protocol (IP) address, a processor or device serial number or other unique device identifiers, that are combined with Personal Information;
- Location coordinates (longitude, latitude, and radius) if You use Your mobile phone or a GPS equipped device to access the Services; and
- Your username and password for those services and other information available about or collected from You by those sources.
B. GENERAL INFORMATION
In addition to collecting Personal Information from You, We may use a variety of technologies that automatically collect General Information. General Information is information about You or Your use of the Services that does not identify You personally. This includes Your domain server, device type, web browser, the operating system or platform You use to access the Site as well as referrer data identifying the web pages You visited prior to and after visiting the Site and Your movement and activity within the Services.
- Device Information. We may collect information about the computer, mobile device or other device You use to access the Services, such as Internet protocol (IP) addresses (the region or general location where Your computer or device is accessing the Internet), geolocation information, unique device identifiers, browser type, browser language and other transactional information.
- Mobile Device Identifiers. Certain mobile service providers uniquely identify mobile devices and Gravity and/or third parties providing services on Our behalf may receive such device information if You access the Services through a mobile device. Certain features on the Services may require collection of mobile phone numbers and Gravity may associate that phone number to mobile device identification information. Additionally, some mobile service providers operate systems that pinpoint the physical location of devices that use their services. Depending on the provider, Gravity and/or third parties providing services on Our behalf may receive this information.
- Log Files and Reading History. We may collect information that Your web browser sends when You visit a site. This information is recorded in server logs and contains such things as the requests You make through Your web browser, Your Internet Protocol (IP) address, browser type, browser language, referring and exit sites and URLs, platform type, clickstream data, domain names, landing pages, web pages viewed, the amount of time spent on a particular web page, the time and date of any request You make through Your web browser, and any cookies used to uniquely identify Your web browser.
- Cookies. We may place files called “cookies” onto Your device. Cookies are data text files that sites store on a device for record keeping purposes when You visit them. The cookie file then identifies You as a unique user. Cookies make Your use of the Services more efficient by “personalizing” Your experience on the Services and gathering statistical data, such as which parts of the Services You have previously visited, what material You downloaded, Your Internet provider’s domain name and country, and the addresses of the web pages You visited immediately before and after accessing the Services. Cookies enable Gravity to tailor the information You receive and to assist Gravity and third parties providing services on Our behalf by identifying You as a User of the Services. While some cookies are deleted when You close Your browser, others remain even after Your browser is closed. Most web browsers automatically accept cookies, unless You have configured Your browser not to accept them. You can program Your browser not to accept cookies, but if You do, You may not be able to use certain portions of the Services and the Services will not be able to customize certain features according to Your preferences.
The Services may also use Flash cookies, also known as local shared objects or persistent identification elements, to collect and store information, including information about Your use of and preferences on the Services. Flash cookies are managed by separate browser settings and can be controlled by visiting the Adobe® Flash® Player site at:
- Web Beacons. Small graphic images or web programming code called web beacons (also known as “pixel tags” or “clear GIFs”) may be included on the Services and in email messages sent to You. Web beacons or other similar technologies may be used for a number of purposes, such as to count visitors to the Services, monitor how You navigate the Services or to count how many links posted on the Services were actually viewed.
- Embedded Scripts. An embedded script is programming code designed to collect information about Your use of the Services, such as the links You click on. The code is temporarily downloaded to Your computer from the Gravity web server or a third-party provider, is active only while You are connected to the Services and is deactivated or deleted once You leave the Services.
- Analytics Data. We may use tools called “Google Analytics” and “Google AdWords” to collect general information about Your use of the Services. These tools collect information such as usage data, which We use only to improve the Services.
We may combine the General Information collected through the use of these tools with Personal Information. If We do combine General Information with Personal Information the combined information will be treated as Personal Information for as long as it remains combined.
5. HOW WE USE INFORMATION COLLECTED
The information collected by Gravity will be used for a variety of business purposes, including, for example, to operate, maintain and provide You with the features and functionality of the Services. This may include (but is not limited to):
- Processing Your registration, including verifying Your identity;
- Providing You with access to the Services, including project discussions and billing services;
- Fulfilling Your requests for services and information, including requests to be contacted by an agent;
- Processing payment and business requests related to the Services;
- Responding to Your inquiries, providing customer services, and resolving any complaints;
- Maintaining customer accounts;
- Promoting, marketing and communicating with You regarding certain offerings available through the Services as well as from Our third-party sponsors;
- Communicating with You regarding certain features or promotions offered by Gravity or certain third-party products or services We believe You may be interested in, provided that You have not already opted out of receiving such communications;
- Improving the quality and design of the Services, and to create new features and functionality, promotions and services;
- Customizing the content You see when You access the Services, including to develop and provide advertising tailored to Your interests. This is done via cookies and log files. This information is used to remember information so that You will not have to re-enter it during Your current or future use of the Services. Cookies and log file information is also used to provide customized and personalized information and content to Users, to monitor the effectiveness of Gravity marketing and promotional campaigns, and monitor certain aggregate metrics.
- Anonymizing or aggregating Your information for business purposes, including for reporting and research purposes;
- Enforcing compliance with the Gravity Terms and Conditions;
- Complying with any applicable laws and regulations; and
- For any other purposes disclosed to You at the time Your information is collected or pursuant to Your consent.
6. HOW WE SHARE YOUR INFORMATION
Gravity may share Your Personal Information as set forth in the following circumstances:
- Third-Party Providers. In some cases, We may employ third-party service providers such as third-party payment processors to perform certain services on Our behalf, including, without limitation: (i) processing payments; (ii) providing customer service; (iii) hosting Our databases; (iv) performing business analysis, data processing and/or quality control; (v) per specific request from You to service Your request; and (vi) providing marketing assistance, search results and links (including, without limitation, paid listings and links). Consequently, We may share Your Personal Information with these third-party service providers if they need it to perform services on Our behalf. However, use of the Personal Information shared is strictly limited to the performance of the task We request and for no other purpose. All third parties with whom We share Personal Information are required to protect it in a manner similar to the way We protect information.
- Parent Companies and Subsidiaries of Gravity. We may need to share Your Personal Information with Our parent companies or subsidiaries in order to assist with certain requested services, including issuing invoices. Only employees with a need to obtain Your Personal Information will be granted access to such information.
- Disclosure of Personal Information for Legal and Administrative Reasons. If We believe in good faith that it is necessary and appropriate, We may disclose Your Personal Information without notice: (i) to cooperate in investigations of fraud or any other activity that is illegal or may expose Us or You to legal liability; (ii) when required by law or to comply with a court order, subpoena, search warrant or other legal process; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view Your Personal Information); (iv) to protect and defend the rights, property or safety of Us, Our affiliates, subsidiaries and partners and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the other Users of the Services; (v) to verify the identity of the Users; (vi) to protect the security and integrity of the Services; (vii) to protect the rights, property or personal safety of Gravity, Our Users or others; and (viii) to enforce the Gravity Terms and Conditions. Where possible and appropriate, We will notify You if We are required by law to disclose Your Personal Information.
- Business Transfers. Your Personal Information may be transferred, sold or otherwise conveyed to a third party where We: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of Our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganized. You consent to any and all such conveyances of Your Personal Information.
7. PERSONAL INFORMATION HELD ON SERVERS LOCATED IN THE UNITED STATES.
By providing Your Personal Information to Gravity, You consent to Gravity storing Your Personal Information on servers hosted in the United States. Your Personal Information will be stored on such servers and will remain within Gravity’s effective control at all times. We have taken steps to use the necessary level of protection for Your Personal Information.
You should not provide Gravity with Your Personal Information or use the Services if You do not want Your Personal Information to be stored on Our servers.
8. STORAGE OF PAYMENT DETAILS
If You choose to pay invoices online Your credit card details are not stored by the Services and cannot be accessed by Gravity staff. Your credit card details are encrypted and securely stored by a third-party payment gateway.
9. HOW LONG USER INFORMATION IS KEPT
We will only keep Your Personal Information for as long as We require it for the purposes of providing You with the Services. We may keep a copy of Your Personal Information in Our archives for as long as We reasonably need it. We may alter this practice according to changing requirements. For example, We may delete some data if needed to free up storage space. We may keep other data for longer periods if applicable law requires.
You may delete Your Gravity account and User profile at any time. If You ask Gravity to close Your Gravity account and delete Your information, We will do so within a reasonable period of time. Please note that Gravity may need to retain some information about You in order to satisfy legal and security obligations. In addition, You should be aware that it is not always possible to completely remove or delete all of Your information from databases without some residual data because of backups and other reasons.
10. PROTECTION OF YOUR INFORMATION
We conduct Our business with great respect for the confidential nature of the information being provided and have security standards and procedures in place designed to prevent unauthorized access to Your Personal Information, to ensure that Your Personal Information is kept confidential, and that it is used only for the purposes for which it was collected. Consistent with industry standards and practices, We maintain physical, electronic, and procedural safeguards, which We review, refine, and upgrade as We deem appropriate based on new tools becoming available, to protect Your Personal Information.
Unfortunately, the transmission of information via the Internet is not completely secure. Although We do Our best to protect Your Personal Information, We do not guarantee, and You should not expect, the security of Your Personal Information or private communications transmitted to Us via the Internet. Email is generally not a secure means of transferring information. We therefore cannot guarantee that this information will not be lost or used in a fraudulent manner and We encourage the use of email encryption to communicate with Us. Any transmission of Personal Information is at Your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
We will advise You at the first reasonable opportunity upon discovering or being advised of a security breach where Your Personal Information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorized persons or in any unauthorized manner. The safety and security of Your Personal Information also depends on You. Where We have given You (or where You have chosen) a password for access to certain features of the Services, You are responsible for keeping this password confidential. We ask You not to share Your password with anyone. You should notify Us as soon as possible if You become aware of any misuse of Your password, and immediately change Your password within the Services.
11. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION
You are responsible for helping Us to maintain the accuracy and completeness of Your Personal Information. We urge You to review Your Personal Information regularly to ensure that it is correct and complete. If You would like to review Your Personal Information or if You believe that any of Your information is incorrect or has changed, please follow the instructions on the Site to update such information.
You may contact Your personal account manager, call ______, or send an email to ______, with the subject heading “Update Personal Information” and state the Personal Information You would like to review or provide the relevant Personal Information to be updated. Gravity will process Your request as soon as reasonably practicable, provided We are not otherwise prevented from doing so on legal grounds, or Your identity cannot be verified. If We are unable to meet Your request, We will let You know why. For example, it may be necessary for Us to deny Your request if it would have an unreasonable impact on the privacy or affairs of other individuals, or if it is not reasonable and practicable for Us to process Your request in the manner You have requested.
12. YOU CAN OPT-OUT OF ANY EMAIL COMMUNICATIONS
Your Personal Information will not be sold to advertisers or spammers. Gravity sends service information, Services updates and Services notifications to You via email. Our emails will contain clear and obvious instructions on how to unsubscribe. Gravity will also remove You at Your request if You send an email to firstname.lastname@example.org, with the subject heading “Opt-out.”
Please note that even if You opt-out or unsubscribe from promotional offers or other marketing messages, We still may need to share Your Personal Information or send communications relating to Your use of the Services, such as a transaction initiated by You, including, without limitation, engaging Us to assist with a project, or for other legitimate non-marketing reasons.
13. PUBLIC FORUMS
14. THIRD-PARTY WEBSITES/LINKS
The Services may contain advertising and links to external third-party sites or applications that We do not own or operate. This may include links from advertisers, sponsors and/or partners that may use Our logo(s) as part of a co-branding or co-marketing agreement. We do not control, recommend or endorse and are not responsible for these third-party sites or their content, products, services or privacy policies or practices. These other sites or applications may send their own cookies to Your device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of Our offerings (including those linked to through an email or application).
15. CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 permits residents of the State of California to request from certain businesses with whom the California resident has an established business relationship a list of all third parties to which the business, during the immediately preceding calendar year, has disclosed certain personally identifiable information for direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request You should send (i) an email to email@example.com, with the subject heading “California Privacy Rights,” or (ii) a letter to Gravity, Attention: Legal, 1201 San Jacinto, Suite 267, Houston, TX 77002. In Your request, please attest to the fact that You are a California resident and provide a current California address for Our response. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in Our response. We reserve the right not to respond to requests submitted to addresses other than the addresses specified in this paragraph.
16. DO NOT TRACK
We may work with third parties that use tracking technologies on the Site, including in order to provide tailored advertisements on Our behalf and on behalf of other advertisers across the Internet. These companies may collect information about Your activity on the Site and other sites over time, as well as Your interaction with Our advertising and other communications, and use this information to determine which ads You see on third-party sites and applications. For more information about this practice and to understand Your options, please visit http://www.networkadvertising.org/ or http://www.aboutads.info.
18. HOW TO CONTACT US
1201 San Jacinto
Houston, TX 77002
Gravity is committed to working with You to obtain a fair resolution of any privacy concern in compliance with applicable law.
This website is operated by Gravity Global Limited and its subsidiaries (“we” or “us”).
The use of our website is possible without any submission of personal data; however, if a user wants to enquire about employing our services or sign up for our newsletter via our website, processing of personal data could become necessary.
If the processing of personal data is necessary and there is no statutory basis for such processing, we seek to obtain consent from the data subject.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the General Data Protection Regulation (GDPR), and in accordance with the country-specific data protection regulations applicable to Gravity Global.
What information do we collect?
At times we may request that you voluntarily supply us with personal information. Generally, this information is requested when you want us to provide you with information.
We may gather the following information about you when you use this website:
- Email address
- Telephone number
- IP address (a unique identifier for your computer or other device)
- Mobile device ID
- Information provided by you in relation to submitting a job application to us (this may include sensitive personal information e.g. ethnic origin)
How do we use it?
We will use your personal information in the following ways. We are also required by law to state a “legal basis for processing”, i.e. to tell you on what grounds we are allowed to use your information, and this is also set out below:
|How we will use your personal information||Our legal basis for processing|
|to provide you with information that you have requested e.g. a newsletter, bulletins;||Consent – we only use your personal information for this purpose if you have asked us to do so. You can withdraw your consent at any time.|
|to respond to specific queries you may raise regarding Gravity Global and its operating companies;||Consent – we only use your personal information for this purpose if you have asked us to do so. You can withdraw your consent at any time.|
|to provide you with better ways of accessing information from this website;||Our legitimate interests – we use your personal information to help us to deliver the best online experience to you and other website users.|
|to process and consider your job application;||Our legitimate interests – we use your personal information to assess your job application, and to keep you updated throughout the application process.|
For how we use your information that is collected using cookies and similar technologies please see the “Cookies” page here.
How do we use your information for marketing?
We will only provide information to you that you have asked for via the website.
Where do we send your information?
We are a global company and therefore we may transfer your personal information to countries around the world including the US and other countries outside Europe. We will, where the country to which your data is transferred has not been found to provide an adequate level of protection, put in place appropriate safeguards (we use standard contractual clauses) to ensure your information is protected.
How long do we keep your information?
We will keep your information for a period of 2 years.
What are cookies?
We may use information obtained from cookies or similar technology. Cookies are text files containing small amounts of information which we download onto your computer or device when you visit our website. Therefore, when we refer to “you” in this section we mean your computer. We can recognise these cookies on subsequent visits and they allow us to remember you.
Cookies come in many forms. We have set out below the main types and categories of cookies that are used. This section refers to all types and categories of cookies and not just those we use on our website.
First and third-party cookies – whether a cookie is first-party or third-party refers to the domain placing the cookie. First-party cookies are those set by a website that is being visited by the user, the website displayed in the URL window e.g. www.gravityglobal.com. Third-Party cookies are cookies that are set by a domain other than that of the website being visited by the user. If a user visits a website and another entity sets a cookie through that website this would be a third-party cookie.
Persistent cookies – these cookies remain on a user’s device for the period of time specified in the cookie. They are activated each time that the user visits the website that created that particular cookie.
Session cookie – these cookies allow website operators to link the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.
- Strictly necessary cookies – These cookies enable services you have specifically asked for.
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies certain services you have asked for cannot be provided. e.g. the ASP.NET cookie.
- Performance cookies – These cookies collect information on the pages visited.
These cookies collect information about how users use a website, for instance which pages users go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. They are only used to improve how the website works.
- Functionality cookies – These cookies remember choices you make to improve your experience.
These cookies allow the website to remember choices you make and provide enhanced, more personal features. They may also be used to help provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity to other websites.
- Targeting cookies or advertising cookies – these cookies collect information about your browsing habits in order to make advertising relevant to you and your interests.
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisation such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
If you want to delete any cookies that may already be on your computer or device, please refer to the instructions for your file management software to locate the file or directory that stores cookies. If you want to stop cookies being stored on your computer in future, please refer to your browser manufacturer’s instructions by clicking “Help” in your browser menu. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our website.
Third Party Websites
How do we protect your information?
We take appropriate measures to ensure that your personal information disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used.
This website is not intended or designed to attract children under the age of 13. We do not knowingly collect personal information from or about any person under the age of 13. If you are under 13 years old and wish to ask a question or use this site in any way which requires you to submit your personal information, please get your parent or guardian to do so on your behalf.
You are entitled to ask:
- For a copy of the personal information we hold about you, and details about how we are processing your personal information;
- To have any inaccuracies in your personal information corrected;
- If we are processing your personal information by automated means and on the basis of your consent (see “How do we use it?”, above), for us to provide your personal information to you in a structured, commonly-used and machine-readable format. You can also ask us to provide your personal information directly to a third party in this format, and, if technically feasible, we will do so; and
- To have your personal information erased, or for our use of it to be restricted (for example, if your preferences change, or if you don’t want us to send you the information you have requested).
Please contact us using the details set out below if you would like to exercise any of these rights.
You also have the right to make a complaint to the supervisory authority if you’re not happy with how we’ve handled your personal information. In the UK, the supervisory authority is the Information Commissioner’s Office (https://www.ico.org.uk).
How to contact us
If you wish to exercise any of your rights in relation to your personal information or if you have any queries about how we use your personal information, please let us know by contacting us at the following address: firstname.lastname@example.org
Artificial Intelligence Policy – v1 11 May 2022
Our policy towards artificial intelligence (AI) is that it will never replace human creativity, neither will published work created by AI ever be passed off as our own.
That is not to say that Gravity Global does not recognise that the world is in a constant state of change and technological evolution. We embrace this change and are working to understand the impact, importance, and implications of when, where and how we can use AI in developing effective marketing strategies, informing creative concepts, and assisting with performance optimization and evaluation.
However, it’s essential to establish a clear AI use policy to ensure that our business uses AI ethically and responsibly.
When using AI in a published environment, we will ensure that any generated content is clearly labeled as such. We will ensure to the best of our ability that it complies with all relevant regulations and guidelines. We will also monitor the performance of the AI-generated content and make any necessary adjustments to ensure it meets the required standards.
To communicate our AI use policy to clients, we will include it in our new client contracts and inform them about the use of AI in their projects when applicable. We will ensure our use fulfils our contractual obligations to our clients including ownership and IP. We will track AI use on client projects for audit purposes. We will also have a dedicated page on our website outlining our AI policy, and we will make it available to anyone who requests it. Additionally, we will provide regular updates to our clients about the performance of the AI systems and address any concerns they may have.
Here are the basic use-case rules for our business:
- Human-centered: We believe in a human-centered approach to AI that empowers and augments professionals, and that AI technologies should be assistive, not autonomous.
- Data Privacy: We will ensure that all data used by AI is collected and stored securely, and we will only use it for authorized purposes.
- Fairness and Transparency: AI will not be used to discriminate against any individuals or groups.
- Bias Mitigation: We will work to identify and mitigate any biases in AI.
- Accountability: We will take responsibility for any harm caused by AI and take measures to rectify them.
- Human Oversight: We will ensure that all AI systems are overseen by human experts who can monitor their operation and intervene if necessary.
- Boundaries: We believe in understanding the limitations and dangers of AI and considering those factors in all our decisions and actions.