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Privacy Policy
Last updated November 5th, 2018
This Privacy Policy describes how we collect and use Personal Information we receive from our users (referred to as “you”) by using the Gentley App and www.gentleyapp.com and any subsites (together referred to as “Website”) and what Personal Information we transfer to which third parties. This Privacy Policy explains different scenarios to give you a clear understanding of what information we collect, process and use and why we do so.
Our Company
Adriatic Development Corporation 1001 Brickell Bay Drive Suite 1200 Miami, FL, 33131
Applicability of this Policy
This privacy policy applies to all information collected through the websites and mobile application from current and former users of Gentley. This policy applies only to services provided by Gentley, included personal identifiable information that our business partners share with us.
Personal Data
Personal Data is information about you that can be used by itself, or combined with other information, to identify you personally (referred to as “Personal Data” or “Personal Information”). We collect this Personal Information directly from you when you provide it to us.
Personal data will only be collected if you disclose it to us or others via our services.
Directly shared information
By using the services of Gentley you may be asked for certain Personal Information. These can include your name, email address, zip code, credit card information, occupation, hobbies and interests, along with passwords, pictures and other Personal Information you share while creating or updating your profile. Gentley also stores your payment service provider information such as credit or debit card numbers and other financial information.
Verification Information
Gentley is committed to providing a safe and secure user environment for all users. Therefore, before permitting you to use the Services of Gentley, you will be required to provide additional information from you that will be used for the sole purpose to verify your identity, address or other information, to manage risk and compliance throughout your relationship with Gentley. Gentley may also obtain information about you from third parties such as identity verification, fraud prevention, and similar services. The Adriatic Development Corporation collects data to operate effectively and provide better quality experiences as part of the execution of the contract. In addition, Personal data can be collected through other users in the event of a user generated report in relation to other users.
Usage Information
Gentley is collecting information about your activity on our services, such as how you use them, such as date and time you logged in, features you’ve been using, filter preferences, clicks and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).
Device Information
Gentley is collecting information from and about the device(es) you are using to access our services, including:
Information about hardware and software, such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);
information on your wireless and mobile network connection, like your service provider and signal strength; information on device sensors such as accelerometers, gyroscopes and compasses.
Additional information with consent
If you give us permission, Gentley can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, Gentley will not collect it.
Similarly, if you consent, Gentley may collect your photos and videos (for example, if you want to publish a photo, video or streaming on the services).
Purpose of the processing
Delivering and improving the services while executing of the contract and to comply with legal requirements including but not limited to assisting law enforcement.
Categories of recipients
Public authorities provided there are overriding legal provisions. External service providers or other contractors. Other external authorities provided the data subject has given his consent or unless the transmission of data is permissible due to overriding interest.
Transfers to third countries
Data processors outside the European Union can also be used, within the framework of contract fulfilment.
Information of minors
Our services are restricted to users who are 18 years of age or older. We do not permit users under the age of 18 on our platform and we do not knowingly collect Personal Information from anyone under the age of 18. If you suspect that a user is under the age of 18, please use the reporting mechanism available through the service.
Protection & storage of Personal Information
Your Personal Information is protected by physical, electronic, and procedural safeguards in compliance with applicable U.S. federal and state regulations. Gentley also uses computer safeguards such as firewalls and data encryption. For example, Gentley uses SSL encryption to safeguard your credit card data when used in e-commerce transactions. In addition, Gentley enforces physical access controls to it’s offices and files, and authorizes access to users’ Personal Information only for personnel who is required to fulfill their job responsibilities. Despite best efforts, Gentley cannot guarantee that Personal Information may not be accessed, disclosed, altered or destroyed by breach of the administrative, managerial, and technical safeguards.
Therefore, we urge you to take adequate precautions to protect your personal data as well, including never sharing the username and password used in connection with your participation in the Gentley’s Services. If Gentley learns of a systems security breach, we may attempt to notify you electronically so that you can take appropriate protective steps. By using the Gentley Services, you agree that Gentley may communicate with you electronically. Gentley may post a notice on the website or mobile application if a security breach occurs. We may also send an email to you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us of your request here.
International data
Gentley is a worldwide service. We are based in the United States and the information collected is governed by U.S. law. By accessing or using the Gentley’s Services or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the U.S. and other countries, where you may not have the same rights as you do under local law. Pending Privacy Shield Approval: In connection with Gentley’s processing of personal data received from the European Union and Switzerland, we adhere to the E.U.-U.S. and Swiss-U.S. Privacy Shield Program (“Privacy Shield”) and comply with its framework and principles. For more information about Privacy Shield principles and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield website. If we do not resolve your complaint, you may submit your complaint free of charge to International Centre For Dispute Resolution-American Arbitration Association (ICDR-AAA) Privacy Shield Program Independent Recourse Mechanism based in the United States. Under certain conditions specified by the Privacy Shield Principles, you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the Federal Trade Commission. If we share E.U. or Swiss data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party’s processing of E.U. or Swiss data in violation of the Privacy Shield Principles, unless we can prove that we are not responsible for the event giving rise to the damage.
If you are a California resident, you can request a notice disclosing the categories of Personal Information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request here. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.
Legal Basis for Processing Personal Information Under General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), Gentley legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.
Gentley may process your Personal Information because:
  • We need to perform a contract with you
  • You have given us consent to do so
  • We must comply with the law
  • The processing is in our legitimate interests, part of a product features, and it's not overridden by your rights
Performance of a contract with you
We process your Personal Information to perform our obligations under the Terms and Conditions applicable to the product or service you are using. This Terms and Conditions are provided before you enter into a contract with us or before you have access to our services.
Your consent
We process your Personal Information if you have consented to the processing activity. You may revoke your consent at any time. Doing so will bar us from further processing of your Personal Information based on your consent but will not impact the lawfulness of processing based on your consent before it was withdrawn. Some of the features of our products and services might be only available based on consent.
Legal obligations
We process your Personal Information as needed to comply with laws and regulations.
Legitimate interests
We process your Personal Information to further our legitimate interests, such as in connection with managing, developing, testing, securing, and in limited circumstances marketing, advertising, and making recommendations regarding our products and services. Any such processing is conducted subject to appropriate measures to protect your fundamental rights and freedoms related to your Personal Information, and in any event will be subject to the restrictions provided in this Policy. Further information or specification of our legitimate interests may be provided before you purchase a Gentley product or use Gentley’s services.
Duration of data storage
The duration of data storage is based on the legal obligations to retain data and is up to 10 years. In regards to privacy Data, we implemented a safety retention window of three months following account deletion To protect the safety and security of our users on and off our services. During this period, account information will be retained although the account will of course not be visible on the services anymore.
In practice, Gentley deletes or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:
we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.
Use of the newsletter
In the course of registering for our newsletter, you are sharing your email address and, optionally, other data with us. We exclusively use this information to send you the newsletter. The data you entered while subscribing to the newsletter shall remain stored with us until you unsubscribe from our newsletter. You can unsubscribe anytime by clicking the link provided in the newsletter or sending us a message to that effect. Unsubscribing allows you to opt out of the use of your email address.
Third parties that we use to perform our services
Some services that we provide require the involvement of third parties. We have carefully selected those third parties and concluded contracts with them that ensure that your Personal Information is adequately protected.
Use of Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses so-called “cookies” – text files that are stored on your computer and that allow an analysis of your use of the website. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there. If you activate IP anonymisation on this website, Google will, however, truncate your IP address prior to this within European union member states or in other states that are party to the Agreement on the European Economic Area. The full IP address will only be transmitted to a Google server in the USA and truncated there in exceptional cases. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activities, and to provide further services related to website use and Internet use to the website operator. The IP address transmitted by your browser to Google Analytics will not be merged with other Google’s data. You can prevent the storage of cookies by using the corresponding setting in your browser software; however, we would advise that in this case, you may not be able to use all functions of this website in full. You can also prevent the collection of data (including your IP address) generated by the cookie and relating to your use of the website to Google and the processing of this data by Google by downloading and installing the browser plug-in available via the following link (http://tools.google.com/dlpage/gaoptout?hl=de). Due to the debate about the use of analytics tools with complete IP addresses, we want to point out that this website uses Google Analytics with the “_anonymizeIp()” extension and thus, only shortened IP addresses are processed to exclude a direct personal reference. Specifically for browsers on mobile devices, please click this link to prevent, for the future, the anonymised collection of data by Google Analytics on this website for your browser by using a so-called “opt-out cookie”.
Google AdWords Conversion Tracking
This website uses Google AdWords Conversion Tracking, a web analytics service provided by Google Inc. (“Google”). Google AdWords Conversion Tracking also uses “cookies” that are stored on your computer and allow an analysis of your use of the website. The information generated by the cookie about your use of this website is transmitted to a Google server in the USA and stored there. Google will use this information to evaluate your use of the website, to compile reports about website activities for the website operators and to provide further services associated with the use of the website and the Internet. Google will also transfer this information to third parties where applicable insofar as this is legally required or insofar as third parties process this data on behalf of Google. Google will In no event associate your data with other Google data. You can generally prevent the use of cookies if you prohibit the storage of cookies in your browser.
Using own “cookies”
This website uses its own “cookies” to increase user-friendliness (“cookies” are data records that are sent from the web server to the user’s browser and stored there for later retrieval). No personal data is stored in our own “cookies”. You can generally prevent the use of “cookies” if you prohibit the storage of “cookies” in your browser.
AWeber
We use the services of AWeber Communications to send out our newsletter and other mailshots (call for papers), to manage advertising permissions, and to collect statistical data on the use of our website and optimize the site accordingly.
If you purchase a product or service from Gentley or subscribe to the Newsletter, your email address will be imported into AWeber’ssystems so that Gentley can send you information emails for similar goods or services in future. The legal basis for this is Article 6 (1) f) GDPR.
AWeber also uses cookies, which are text files that are stored on your computer and enable your use of the website to be analyzed. The information generated by the cookie on your use of this website is transmitted to one of AWeber’s servers (in the USA) and stored there. AWeber uses this information on behalf of the operator of this website to analyze the use of the website by registered persons and to compile reports on the activities of the website. You can prevent cookies being stored by amending your browser settings accordingly. However, we would like to inform you that you may not be able to make full use of this website’s entire range of functions in this case.
Tracking pixel and how you can prevent this: We should like to point out that when sending out the newsletter or other requested information on our behalf, AWeber analyzes your user behavior. To perform this analysis, the emails that are dispatched contain ‘web beacons’ (also known as ‘tracking pixels’). These are single-pixel image files that link to our website, thereby enabling us to perform a session-based analysis of your user behavior. We record when you read our newsletter, which links in the newsletter you click on, and conclude from this what your personal interests are. AWeber stores the information collected in this way on its server in the USA.
Tracking is not possible if you have disabled the display of images by default in your email program. In this event however, the newsletter will not be displayed to you in full and you may not be able to use all of its functions. If you manually allow the images to be displayed, the abovementioned tracking will take place.
AWeber’s address and URL with its Privacy Notice:
AWeber Communications 1100 Manor Drive Chalfont, PA 18914, USA.
https://www.aweber.com/privacy.html
Changes to our privacy policy
We may update this Privacy Policy from time to time. We will place any updates to this policy on our website. You may also request a paper copy of the Privacy Policy by contacting us at the email or address noted below. You are bound by any changes to the Privacy Policy by using the Gentley Services after such changes have been posted to the website.
Your rights
You can always access your Personal Information by asking us what Personal Information we hold about you.
You may modify, add, delete or update your Personal Information or request deletion of Personal Information by emailing us support@gentleyapp.com or by contacting us as described below. We will usually respond to all access requests within 30 days. We will retain your Personal Information as needed to provide you with our services.
In case you request to delete Personal Information, you may no longer be able to use all features and functions of our services.
Please note that we may be required to keep some of your Personal Information for legal reasons, for instance to comply with statutory retention periods or for tax purposes. In such cases, we will mark your Personal Information accordingly to make sure that it is not used for any other purpose than complying with the retention requirement.
Right to opt-out of marketing
If you signed up for our newsletter and no longer want us to use your Personal Information for marketing purposes you can unsubscribe from marketing-related e-mails by following the unsubscribe instructions included in each e-mail.
Contact details
Adriatic Development Corporation
1001 Brickell Bay Drive Suite 1200
Miami, FL, 33131