GearSay's mission is to connect athletes to everything that makes them better in their favorite recreational activities. Our registered users ("Members") share their athletic identities, exchange knowledge and athletic insights, and find new opportunities to enjoy their activities. We use commercially reasonable safeguards to protect your personal information and will only provide it to third parties: (1) as described in this policy; (2) with your consent; (3) where it is necessary to carry out your instructions; (4) as reasonably necessary in order to provide GearSay features and functionality to you; (5) as we reasonably believe is permitted by law or regulation; or (6) as necessary to enforce our Terms of Use or to protect the rights, property or safety of GearSay, its Members and the public.

This Privacy Policy ("Policy") applies to www.gearsay.com (the "Site"), which is owned and operated by Gearsay, Inc. ("GearSay"). This Policy describes how Gearsay collects, uses, and shares the personal and other information you provide on our Site. It also describes the choices available to you regarding our use and sharing of your personal information and how you can access and update this information.

Our Privacy Policy applies to anyone who visits the Site. The information provided to or gathered by GearSay is controlled by GearSay, Inc., 90 Canal Street, 4th Floor, Boston, MA 02114. If you have any concern about providing information to us or having such information displayed on the GearSay site or otherwise used in any manner permitted in this Privacy Policy and the Terms of Use, you should not become a Member of GearSay or visit our website. If you have already registered, you should close your account.

1. What information we collect.

GearSay collects both "personal information" and "other information" about Site users. For purposes of this Policy, "personal information," is information such as a name, telephone number or email address that GearSay can directly associate with a specific person without additional information, and we treat additional information, including IP addresses and cookie identifiers, as "personal information" where required by applicable law. By contrast, "other information" is information that GearSay cannot directly associate with a specific person without the aid of additional information. When we combine personal information with other information, we treat all of the combined information as personal information. Note that we may de-identify personal information so that it is non-personal, such as by aggregating it or converting it to a code, sometimes using a function known as a "hash." We will treat de-identified information as non-personal to the fullest extent permitted by applicable law. We collect information relating to any third-party account that you use to login to or link to your GearSay account (such as your username, bio, and number of followers).

We collect your personal and other information in the following ways:

 

 

A. Registration

When you create an account with us, you provide us with information (which may include your name, email address, password and information about activities you are involved with or are otherwise interested in) that we use to offer you a personalized, relevant experience on GearSay. To create an account on GearSay, you must provide us with at least an email address and a password. To ask a question using our AskAnswer feature, you must provide us with at least an email address and some information about yourself relating to the question you are asking. You can choose to provide further information about yourself following your completion of the registration process (for example, your gender, location and certain activities you are engaged in). We use this information to provide you with more customized services, and more relevant content and ads, and certain of this information, consisting of your name if you have added it to your profile, any biographical information you may choose to write about yourself and feeds you save to your lockers, may be viewable by others. You understand that, by creating an account, GearSay and others may be able to identify you by your GearSay profile, and you allow GearSay to use this information in accordance with this Privacy Policy and our Terms of Use.

B. Profile Information

After you create an account, you can add to your profile details of your recreational activities, such as your athletic experiences, places you go, gear you own and other information about your skills. You can list honors, awards, athletic affiliations, companies or individuals that you follow, and other information. A complete profile helps us provide you with a better user experience. It also means we can show you relevant content and ads. This information may also be viewable by others.

C. AskAnswer

We collect the information that you provide when requesting advice from an expert (our "AskAnswer" service), including your name and email address, any mobile phone contact number you choose to provide, the question you ask and the video and other details that you provide as part of your request. We process payment information you provide when you pay for a purchase. Your payments to GearSay are made through the third party payment provider selected by GearSay. You should review the payment provider's privacy policy before providing your personal information, as it is responsible for personal information (as a data controller if you're in the EEA) in its own right, and its privacy practices may vary from ours.

When you use our Site to become or enroll as an expert, we collect, in addition to information provided when you create your account, your name, email address, phone number, and the social media usernames you provide, videos prepared by you, and other information relating to our relationship with you, such as payment information. GearSay's payments to you are made through the third party payment provider selected by GearSay. You should review the payment provider's privacy policy before providing your personal information, as it is responsible for personal information (as a data controller if you're in the EEA) in its own right, and its privacy practices may vary from ours.

D. Use Social Media with the Site

We collect information when you interact with our Site through social media platforms such as Facebook, Instagram, and Twitter (collectively, "Social Media Platforms"). For example, you may use your existing social media username and login information to create an account on our Site or "like" or "share" content from our Site. Some of your information, such as your username, may be publicly displayed. In addition, we and the Social Media Platform may have access to information about you and your use of our Site and the Social Media Platform. The information we collect is subject to this Privacy Policy. The information that any third party collects is subject to its privacy practices (including whether it shares information with us, the types of information shared, and your choices about what may be visible to others).

E. Customer Service

When you contact our Help Center, we collect information to respond to your questions and better serve you. When you contact GearSay's Help Center, we collect information that helps us categorize your question, respond to it, and, if applicable, investigate any breach of our Terms of Use or this Privacy Policy. We also use this information to track potential problems and trends and customize our support responses to better serve you.

F. Using the GearSay Site

We collect information when you use the GearSay website. For example, we collect information when you view or click on ads, save posts to the lockers in your profile, and share posts on GearSay. We also collect information from you when you use our AskAnswer service, either as a requester of information or a provider of information.

G. Cookies and Other Tracking Mechanisms

We use cookies on the Site. Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer's operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site. In addition, the Site or the emails that you receive from us may use an application known as a "web beacon" (also known as a "clear gif" or "web bug"). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it allows an email sender to determine whether a user has opened a particular email.

We use cookies, web beacons and similar technologies, including mobile device identifiers, to help us recognize you, improve your GearSay experience, increase security, measure and analyze use of our services, and target and serve advertising. You can control cookies and limit similar tracking through your browser settings and other tools that are discussed below in Section 2.E. By visiting GearSay, you consent to the placement of cookies and the use of other tracking mechanisms in accordance with this Privacy Policy.

"Do Not Track" Signals Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. There is no consensus among industry participants as to what "Do Not Track" means in this context. Like many websites and online services, we do not currently alter our practices when we receive a "Do Not Track" signal from a visitor's browser. For information about "do not track" from The Future of Privacy Forum, click here.

H. Log Files, IP Addresses, and Information About Your Computer and Mobile Device

We collect information from the devices and networks that you use to access GearSay. Among other things, this information helps us improve and secure our Services. When you visit or leave GearSay by clicking a hyperlink or view a plugin on a third-party site, we automatically receive the URL of the site from which you came or the one to which you are directed. We also receive the internet protocol ("IP") address of your computer or the proxy server that you use to access the web, your computer operating system, your type of web browser, your mobile device (including your mobile device identifier provided by your mobile device operating system), your mobile operating system (if you are accessing GearSay using a mobile device), and the name of your ISP or your mobile carrier.

I. Links to 3rd Party Sites

Our Site includes links to other Web sites whose privacy practices may differ from those of GearSay. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit.

J. Other

We are constantly innovating to improve our services, which means we may create new ways to collect information. GearSay is a dynamic, innovative environment, which means we are always seeking to improve the services we offer you. We often introduce new features, some of which may result in the collection of new information. Furthermore, new partnerships or corporate acquisitions may result in new features, and we may potentially collect new types of information.

2. How we use and share your personal information

At GearSay, we strive to use your information to provide you world-class services in a professional and trustworthy manner. We also give you control over how your information is disclosed on the Site or shared directly with third parties. Our use and sharing of your personal and other information is described in detail in this section.

A. GearSay's Use of Personal and Other Information

If we have personal information about you, we may use it, for example: to respond to your questions or requests concerning the Site or other services offered by GearSay or our partners; to fulfill the terms of any agreement you have with us; to fulfill your requests for our services or otherwise complete a transaction that you initiate; to send you information about our services and other topics that are likely to be of interest to you, including email newsletters, updates, or other communications; to deliver confirmations, account information, notifications, and similar operational communications; to improve your user experience and the quality of our products and services; to comply with legal and/or regulatory requirements; and to manage our business.

We use the other information that we collect for such purposes as: counting and recognizing visitors to the Site; analyzing how visitors use the Site and various Site features; improving the Site and enhancing users' experiences with the Site; creating new products and services or improving our existing products and services; enabling additional website analytics and research concerning the Site; and managing our business.

B. Consent to GearSay Processing Information About You

When you join GearSay, you acknowledge that information you provide on your profile can be seen by the public at large and used by us as described in this Privacy Policy and our Terms of Use. The personal information you provide to us may reveal or allow others to identify aspects of your life that are not expressly stated on your profile (for example, your picture or your name (if you choose to add it to your profile) may reveal your gender or your favorite recreational activities). By providing personal information to us when you create or update your account and profile, you are expressly and voluntarily accepting the terms and conditions of GearSay's Terms of Use and freely accepting and agreeing to our processing of your personal information in ways set out by this Privacy Policy. Supplying information to us, including any information deemed "sensitive" by applicable law, is entirely voluntary on your part. You have the right to withdraw or modify your consent to GearSay's collection and processing of the information you provide at any time, in accordance with the terms of this Privacy Policy and the Terms of Use, by changing your Settings or by closing your account.

C. GearSay and Partner Communications

We communicate with you through email, notices posted on the GearSay website, and other means available through GearSay. Examples of these messages include: (1) welcome and engagement messages - when you register on GearSay, we may send you a series of emails to inform you about how to best use GearSay as well as new features; (2) service messages -- these will cover service availability, security, and other issues about the functioning of GearSay; (3) promotional messages -- these may contain promotional information directly or on behalf of our partners, including product and service promotions; and (4) notifications - these may inform you of activities on GearSay that we believe may be of interest to you. If you use our AskAnswer feature we will also send you emails to provide you with various confirmations and updates as well as promotional emails. These messages will be sent to you based on your profile information and messaging preferences. You also may receive email messages sent on behalf of GearSay business partners (such as product manufacturers or event sponsors). You may change your email and contact preferences at any time by signing into your account and changing your email settings. You can also opt out of promotional messages by sending a request to the GearSay

D. Customized Content

We use information that you provide to us to customize your experience. For example, when you sign in to your account, we will display recent updates and other content from companies or influencers in the sports you have designated.

E. Analytics and Online Behavioral Advertising

We partner with certain third parties to collect some of the cookie and other online tracking information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics and FullStory to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies on Google Analytics here And Full Story here.

The Site also enables third-party tracking mechanisms to collect your non-personal information for use in online behavioral advertising. For example, third parties may use the fact that you visited the Site to target online ads for GearSay services to you on non-GearSay websites. In addition, our third-party advertising networks might use information about your use of the Site to help target non-GearSay advertisements based on your online behavior in general. For information about behavioral advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third partie's own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance program by opting out here. Although our website currently does not respond to "do not track" browser headers, you can limit tracking through these third-party programs by taking the steps discussed above.

F. Sharing Information with Affiliates

We may establish affiliated entities from time to time. We may share your personal information with our GearSay affiliates as necessary to provide the GearSay services. By agreeing to this Privacy Policy, you are consenting to this sharing.

G. Sharing Information with Third Parties

Search engines. Your GearSay profile may be indexed and displayed through public search engines when someone searches for your name. Unless you delete it, your profile on GearSay is always viewable on GearSay. However, third-party search engines may not automatically update their caches, which may contain old public profile information.
GearSay business partners. We may share information about you with advertisers and other parties who seek to communicate with you. For example, we may share with a shoe manufacturer that you have identified yourself as a trail runner and make it possible for the manufacturer to reach out to you on GearSay, or we might facilitate their emailing you directly. We will not disclose personal information unless GearSay has a good faith belief that disclosure is permitted by law or is reasonably necessary to: (1) comply with a legal requirement or process, including, but not limited to, civil and criminal subpoenas, court orders or other compulsory disclosures; (2) enforce this Privacy Policy or our Terms of Use; (3) respond to claims of a violation of the rights of third parties; (4) respond to Member service inquiries; or (5) protect the rights, property, or safety of GearSay, our Members, or the public. See below for additional details about GearSay's compliance with legal requests for information.
Third-party service providers. GearSay uses third-party service providers to help us manage and improve the Site and other GearSay services. Thus, we may disclose your personal information to companies that provide services to help us with our business activities such as offering customer service, hosting our Site, or targeting and implementing our email communications.
Your direct sharing of personal information through third-party websites and services. The Site may enable you to share directly personal information with websites or online services operated by third parties. For example, the Site contains links to and integrations with third-party websites that incorporate comment and social media features. If you choose to use these features, you may disclose your personal information not just to those third-party websites and services, but also to their users and the public more generally. For example, you can easily share content from GearSay to Twitter or Facebook. Because these third-party websites and services are not operated by GearSay, we are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your personal and non-personal information will be subject to the privacy policies of the third party websites or services, and not this Policy.
Aggregated information.From time to time, GearSay may also share anonymized and aggregated information about Site users, such as by publishing a report on trends in the usage of the Site.

H. Search

You can search for information about companies and influencers and community content on GearSay. We use personal information from GearSay to inform and refine our search service.

I. Compliance with Legal Process and Other Disclosures

It is possible that we may need to disclose personal information, profile information, information about your activities as a GearSay Member, or other information when required by law, subpoena, court order, or other legal process, or if GearSay has a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce the Terms of Use, investigate and defend ourselves against any third-party claims or allegations, or protect the security or integrity of our Service; or (3) establish, exercise or protect the rights, property, or safety of GearSay, our Members, personnel, or others.

J. Disclosures to Others as the Result of a Change in Control or Sale of GearSay, Inc.

We may also disclose your personal or other information to a third party as part of a sale of the assets of GearSay, Inc, a subsidiary, or division, or as the result of a change in control of GearSay, Inc. or one of its affiliates, or in preparation for any of these events, including due diligence conducted by prospective purchasers. Any third party to which GearSay transfers or sells GearSay's assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy. In this case, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personally identifiable information, as well as any choices you may have regarding your personally identifiable information. We also may disclose your personal or other information outside the context of a change in control to facilitate the financing, securitization, or insuring of all or part of our business or assets.

3. Your Choices & Obligations

A. Rights to Access, Correct, or Delete Your Personal Information, and Closing Your Account

You have a right to (1) access, modify, correct, or delete your personal information controlled by GearSay regarding your profile by making these changes in the settings, or profile edit pages of your online account or contacting us through any of our contact details below, (2) change or remove your content, and/or (3) close your account. You can also contact us for any account information which is not on your profile or readily accessible to you. Please note: Information you have shared with others (for example, through content sharing) or that others have copied may also remain visible after you have closed your account or deleted the information from your own profile. In addition, you may not be able to access, correct, or eliminate any information about you that other Members copied or exported out of GearSay, or that GearSay has shared with third parties, because this information may not be in our control. Your public profile may be displayed in search engine results until the search engine refreshes its cache.

B. Data Retention

We retain the personal information you provide while your account is active or as needed to provide you services. GearSay may retain your personal information even after you have closed your account if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Members, prevent fraud and abuse, or enforce this Privacy Policy and our Terms of Use. We may retain personal information, for a limited period of time, if requested by law enforcement. GearSay Customer Service may retain information for as long as is necessary to provide support-related reporting and trend analysis only.

C. Marketing Preferences

You have choices about our use and sharing of your personal information for marketing purposes. You may, at any time, ask us not to:

• Use your personal information to contact you by email, postal mail, or phone regarding products, services, promotions, and special events that might appeal to your interests
• Share your name and contact information with third parties so that they may contact you by email, postal mail, or phone regarding products, services, promotions, or special events that might appeal to your interests

You may exercise these preferences by emailing us at support@gearsay.com, by sending a request to the GearSay Help Center, or by writing to us at GearSay , Inc., 90 Canal Street, 4th Floor, Boston, MA 02114.

D. Your Obligations

As a Member, you have certain obligations to other Members. Some of these obligations are imposed by applicable law and regulations and others have become commonplace in communities of like-minded Members such as GearSay:

• You must, at all times, abide by the terms and conditions of the current Privacy Policy, Terms of Use, and other policies of GearSay. This includes respecting all intellectual property rights that may belong to third parties, such as trademarks or copyrights.
• You must not upload or otherwise disseminate any information that may infringe on the rights of others or which may be deemed to be injurious, violent, offensive, racist, or xenophobic, or which may otherwise violate the purpose and spirit of GearSay and its community of Members.
• You must keep your password confidential and not share it with others.
  Any violation of these guidelines or those detailed in our Terms of Use or elsewhere may lead to the restriction, suspension, or termination of your account at the sole discretion of GearSay.

4. Notice to California Residents

This notice supplements GearSay's privacy policy and applies only to California residents. This California Privacy Notice sets forth disclosures and rights for California consumers regarding their personal information, as required by the California Consumer Privacy Act ("CCPA"). Terms used in this California Privacy Notice have the same meanings given in the CCPA and the regulations of the Attorney General implementing the CCPA, unless otherwise defined.

This notice provides information about the categories of information that we collect from California residents generally, the sources of the information, the purposes for which we use the information, and the categories of third parties to whom we disclose the information for business purposes and to whom we sell Personal Information as defined by CCPA (and information on how to opt-out).

Your Rights under the CCPA

Under this Privacy Policy, and by law if You are a resident of California, You have the following rights:

The right to notice.
You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
The right to access / the right to request.
The CCPA permits You to request and obtain from the Company information regarding the disclosure of Your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party's direct marketing purposes.
The right to say no to the sale of Personal Data.
You also have the right to ask the Company not to sell Your Personal Data to third parties. You can submit such a request by sending an email to support@gearsay.com with the subject line "Do not sell my personal data" and provide your first and last name and state the nature of your request..
The right to know about Your Personal Data.
You have the right to request and obtain from the Company information regarding the disclosure of the following:

1. The categories of Personal Data collected
2. The sources from which the Personal Data was collected
3. The business or commercial purpose for collecting or selling the Personal Data
4. Categories of third parties with whom We share Personal Data
5. The specific pieces of Personal Data we collected about You

The right to delete Personal Data.
You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.

The right not to be discriminated against.
You have the right not to be discriminated against for exercising any of Your Consumer's rights, including by:

1. Denying goods or services to You'
2. Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
3. Providing a different level or quality of goods or services to You
4. Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if you are a California resident, You can send us an email to support@gearsay.com with the subject line "Do not sell my personal data" and provide your first and last name and state the nature of your request. The Company will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Do Not Sell My Personal Data

We do not sell personal information. However, the Service Providers we may partner with (for example, future advertising partners) may use technology on the Service that "sells" personal information as defined by the CCPA law.

In addition, some of the companies we work with for analytics and advertising purposes are members of the Network Advertising Initiative ("NAI") or the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. For information from NAI about opting out, click here. For information from DAA about opting out, click here, and for information about DAA's AppChoices application, click here. You may opt-out from interest-based advertising on your mobile device through your mobile device settings.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals. However, some third party websites do keep track of Your browsing activities. If You are visiting such websites, You can set Your preferences in Your web browser to inform websites that You do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of Your web browser.

Children's Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16 without verification of parental consent, We take steps to remove that information from Our servers. GearSay does not knowingly sell Personal Information of minors younger than 16 years of age without affirmative authorization

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Contact for More Information

You can contact us for more information by email at support@gearsay.com. or writing to us at:
GearSay, Inc.
90 Canal Street, 4th Floor, Boston, MA 02114

Attn: Privacy Officer

Your California Privacy Rights (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes. If you'd like to request more information under the California Shine the Light law, and if you are a California resident, You can contact Us using the contact information provided below.

California Privacy Rights for Minor Users (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted. To request removal of such data, and if you are a California resident, You can contact Us using the contact information provided below, and include the email address associated with Your account. Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

5. Notice to Nevada Residents

GearSay does not currently sell your covered information as those terms are defined under applicable Nevada law. However, you may still submit an opt-out request and we will honor that request as required by Nevada law if GearSay were to ever engage in such a sale in the future. If you are a GearSay resident and would like to opt-out of future sales of your covered information, please submit your request by email to support@gearsay.com. Your request must include your full name, username (if any),street address, city, state, zip code, and an email address so that we can contact you if needed regarding this request. You may also be required to take reasonable steps as we determine from time to time in order to verify your identity and/or the authenticity of the request. GearSat will respond to your request within 60 days either confirming that your request has been processed or indicating that we need an additional 30 days to complete it.

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6. Notice to UK And EEA Users

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one or more specific purposes.
• Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with You and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
• Vital interests: Processing Personal Data is necessary in order to protect Your vital interests or of another natural person.
• Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
• Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

In any case, the Company will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU, to:

Request access to Your Personal Data. The right to access, update or delete the information We have on You. Whenever made possible, you can access, update or request deletion of Your Personal Data directly within Your account settings section. If you are unable to perform these actions yourself, please contact Us to assist You. This also enables You to receive a copy of the Personal Data We hold about You.
Request correction of the Personal Data that We hold about You. You have the right to to have any incomplete or inaccurate information We hold about You corrected.
Object to processing of Your Personal Data. This right exists where We are relying on a legitimate interest as the legal basis for Our processing and there is something about Your particular situation, which makes You want to object to our processing of Your Personal Data on this ground. You also have the right to object where We are processing Your Personal Data for direct marketing purposes.
Request erasure of Your Personal Data. You have the right to ask Us to delete or remove Personal Data when there is no good reason for Us to continue processing it.
Request the transfer of Your Personal Data. We will provide to You, or to a third-party You have chosen, Your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which You initially provided consent for Us to use or where We used the information to perform a contract with You.
Withdraw Your consent. You have the right to withdraw Your consent on using your Personal Data. If You withdraw Your consent, We may not be able to provide You with access to certain specific functionalities of the Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition by by sending an email to support@gearsay.com with the subject line "GDPR Data Protection". Please note that we may ask You to verify Your identity before responding to such requests. If You make a request, We will try our best to respond to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. For more information, if You are in the European Economic Area (EEA), please contact Your local data protection authority in the EEA.

International Transfers

Your information will be collected, processed, and stored directly on or transferred to servers in the U.S. In addition, it may be transferred to other countries where GearSay, other GearSay affiliates, or third party business partners maintain facilities or business operations, which may include countries outside the UK or EEA. Where we are required by law to implement appropriate safeguards to protect your personal information, we use European Commission-approved contract clauses to do so. If you have questions, please contact us using the contact details in the Contact Us section.

7. Notice to Users Outside the U.S., UK, and EEA

As noted in the International Transfers section, your information will be collected, processed, and stored directly on or transferred to servers in the U.S. and may be transferred other countries where GearSay, GearSay affiliates or our third party business partners maintain facilities or business operations. No matter where the information is located, GearSay takes commercially reasonable measures to safeguard your privacy rights in accordance with this Privacy Policy. If you do not agree to the collection, processing, storage and transfer of your information, please do not provide your information to us and stop using our Site.

8. Important Information

A. Minimum Age

Persons must be of Minimum Age to use GearSay. The Minimum Age is 16. GearSay does not knowingly collect personal or other information from anyone who is under the age of 16. We recommend that persons over 16 but under 18 years of age ask their parents for permission before using the Site or sending any information about themselves to anyone over the Internet.

B. Changes to this Privacy Policy

We may change this Privacy Policy from time to time. If we make significant changes in the way we treat your personal information, or to the Privacy Policy, we will provide notice to you on the GearSay site or by some other means, such as email, prior to the change becoming effective. Please review the changes carefully. If you agree to the changes, simply continue to use our website. If you object to any of the changes to our terms and you no longer wish to use GearSay, you may close your account. Unless stated otherwise, our then current Privacy Policy applies to all information that GearSay has about you and your account. Using GearSay after a notice of changes has been communicated to you or published on our Service shall constitute consent to the changed terms or practices.

C. Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

D. No Guarantee

GearSay uses commercially reasonable safeguards to protect your personal information against loss or unauthorized access, use, modification, or deletion. However, no security program is foolproof, and thus we cannot guarantee the absolute security of your personal or other information.

E. Contact Us

If you have questions or concerns regarding this policy, you may contact us through the following:
GearSay, Inc.
90 Canal Street, 4th Floor, Boston, MA 02114
Email Address:
support@gearsay.com.
Phone: (617) 834-8176

Attn: Privacy Officer

Effective date: December 5, 2020