Privacy Policy
Updated on 08/10/2020.
When using THE GULU Application (“THE GULU Application”), you may be required to provide Gorilla Group Limited(“GGL”, “we” or “us”) with your personal information. Any personal information provided to GGL will be used in accordance with this Privacy Policy. GGL is committed to protecting the users’ right of privacy and will comply with the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) with respect to the management of personal information collected. GGL will instruct its staff to comply with related internal
security and confidentiality rules.
This Privacy Policy governs your use of THE GULU Application and is designed to help you understand what information GGL gathers and what GGL does with the information.
1. Collection of Information
1.1 Collection of User Provided Personal Information
When you register an account with us and use THE GULU Application, you may be required to provide:-
a) your name, mobile number, email address, age, user name, password and other registration information;
b) transaction-related information, such as when you make purchases, respond to any offers, or download or use THE GULU Application from us;
c) information you provide us when you contact us for help; and
d) information you enter into our system when using THE GULU Application, such as contact information and project management information.
Registration of an account with us is optional. However, please keep in mind that you may not be able to use some of the features offered by THE GULU Application unless you register with us.
1.2 Automatically Collected Personal Information
In addition, THE GULU Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browsers you use, and information about the way you use THE GULU Application.
2. Usage of Personal Information
The collected personal information may be used for the following purposes (but not limited to:
a) usage of THE GULU Application (including verifying your identity, taking payments, communicating with you, making a restaurant reservation for you);
b) providing you with important information, required notices and marketing promotions;
c) direct marketing of products and services after obtaining prior consent from you;
d) designing new or improving existing services provided by us; investigation of complaints; and
e) ongoing research for service improvement; and conducting market research.
We will not use personal information or provide personal information to third parties for use in direct marketing without your explicit consent. If we intend to use the personal information for direct marketing, we will obtain explicit consent from you before using your personal information, and will cease to use the personal information in direct marketing if you so require.
3. Transfer of Personal Information
We will share your personal information with third parties only in the ways that are described in this Privacy Policy.
We may disclose user provided and automatically collected personal information: as required by law, such as to comply with a subpoena, or similar legal process; when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request; with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this Privacy Policy; or if GGL is involved in a merger, acquisition, or sale of all or a portion of its assets, where you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.
In order to provide the Services that you have requested, we may also disclose your personal information to organisations or parties outside of GGL (which may be within or outside of Hong Kong) (collectively, "Organisations"). Your personal information is disclosed to these Organisations for the strict purpose of enabling us to supply our Services to you.
These Organisations provide support services to our businesses and operations including without limitation:
a. customer enquiries;
b. courier, delivery, logistic and warehouse services;
c. mailing operations;
d. information technology services;
e. installation, maintenance and repair services;
f. marketing, advertising and telemarketing services;
g. market research;
h. customer usage and behavioural analysis;
i. process management;
j. after sale services;
k. surveys;
l. website usage analysis; and
m. cloud storage services.
These Organisations use your personal information for the sole purpose of carrying out the services for which they have been engaged, and not for their own or other purposes (including direct marketing).
4. Review, Correction and Deletion of Personal Information
We take all reasonable precautions to ensure that the personal information provided or collected, used or disclosed is accurate, complete and up-to-date. However, the accuracy of such information depends to a large extent on the personal information you provide. You have the right to request access to or a copy of, and correction of, your personal information and we recommend that you: (a) let us know if there are any errors in your personal information; and (b) keep us up-to-date with changes to your personal information. If you wish to access or amend any of your personal information we hold, or request that we delete any of your personal information that is no longer necessary for the provision of our services, you may contact us in the manner as set forth below in the “Contact Us” section. If you are a user of THE GULU Application, you may exercise your right of access and correction by logging on to your account in THE GULU Application where you will be able to view and correct your personal information.
5. What are my opt-out rights?
You can stop all collection of information (including direct marketing) by THE GULU Application easily by uninstalling THE GULU Application. You may use the standard uninstall processes as may be available as part of your mobile device or via THE GULU Application marketplace or network. You can also request to opt-out via email, at privacy@thegulu.com.
6. Data Retention Policy, Managing Your Personal Information
We will retain user provided personal information for as long as you use THE GULU Application and for a reasonable time thereafter to fulfil the aforementioned purposes. We will retain automatically collected information for up to 24 months and thereafter may store it in aggregate. Personal information which is no longer required will be destroyed or anonymised as soon as practicable. If you wish to request us to delete your personal information that you have provided via THE GULU Application, please contact us at privacy@thegulu.com and we will respond in a reasonable time. Please note that some or all of the user provided personal information may be required in order for THE GULU Application to function properly.
7. Children
We do not use THE GULU Application to knowingly solicit information from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at privacy@thegulu.com. We will delete such information from our files within a reasonable time.
8. Security
We are concerned about safeguarding the confidentiality of your personal information. We provide physical, electronic, and procedural safeguards to protect personal information we process and maintain. All your personal information will only be accessed or processed by authorized employees or contractors who need to know that information in order to operate, develop or improve THE GULU Application and will be stored and kept in an independent server in data format will be encrypted. Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
9. Links
THE GULU Application may contain third party materials and/or third party links or platforms. GGL has no control over these third party materials and/or third party links or platforms. Please refer to those third parties’ privacy policies to protect your own privacy.
10. Changes
This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy on THE GULU Application.
11. Your Consent
By using THE GULU Application, you are consenting to our processing of your personal information as set forth in this Privacy Policy now and as amended by us. "Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in Hong Kong. If you reside outside Hong Kong your personal information will be transferred, processed and stored there under Hong Kong privacy standards.
12. Contact us
If you have any questions regarding privacy while using THE GULU Application, or have questions about our practices, please contact us via email at privacy@thegulu.com.
If there is any inconsistency or conflict between the English and Chinese versions, the English version shall prevail.
Nothing in this Privacy Policy shall affect GGL’s rights and obligations under the Terms and Conditions.