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High User Adoption
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3870 Peachtree Ind. Blvd,
S-340 #167,
Duluth, GA
30096, USA
Sales Inquiries: sales@gorillaexpense.com
General Questions: info@gorillaexpense.com
Support: support@gorillaexpense.com
Gorilla Expense Privacy Policy
Last Updated: September 27, 2018
1. Introduction
Reefin, LLC d/b/a Gorilla Expense (“Gorilla Expense”, “we,” “us” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we collect, store, process, transfer, share and use your personal information. “Personal information” means any information that identifies or can be associated with you.
By downloading, registering with, or using our websites (the “Sites”), or our services and applications for which your company, institution or other providing entity (“Company”) has subscribed (such services and applications, the “Platform”, and, together with the Sites, the “Services”), you agree to this Privacy Policy. This Privacy Policy applies to all personal information we collect through our Services, even if you have not signed up for a Gorilla Expense account. If you do not agree with our policies and practices, do not download, register with, or use the Services. Terms that are not defined in this Privacy Policy have the meaning given to them in our Terms and Conditions. This Privacy Policy is incorporated into and forms a part of the Terms and Conditions.
Please note that this Privacy Policy does not apply to the use of personal information collected outside of the Services, including personal information:
Those third parties may have their own privacy policies, which we encourage you to read before providing information to or through them. We do not accept any responsibility or liability for their privacy policies or any information you provide to or through them.
Please note that if you choose not to provide us with your information, we may not be able to provide some or all of the Services or respond to your other requests.
2. DATA CONTROLLER
A “data controller” is a person or organization who alone (or jointly) determines the purposes for which, and the way that, any personal information is, or is likely to be, processed. Your Company is the data controller of your personal information that we process through the Platform at your Company’s direction. Gorilla Expense is the data controller of your personal information collected through or otherwise provided to the Sites.
3. Information We Collect and How We Collect It
3.1. Categories of Information
When you use the Services, the categories of personal information about you that we collect may include:
We may collect your personal information when you provide it to us directly or when your Company provides it to us on your behalf.
The table in Attachment 1 further sets forth the categories of information we collect about you when you use the Services and how (for which purpose) we use that information. The table also lists the legal basis which we rely on to process the information.
3.2. Information You Provide to Us
When you download, register with, access or use the Services, or when you otherwise contact us, we may ask you to provide, or you may voluntarily provide, information, including personal information, to provide you with Services or the support you request.
3.3. Information Automatically Collected and Tracked
When you download, access, or use the Services, they may use technology to automatically collect information, including personal information, about the Services and how you use them.
The technologies we use for automatic information collection may include:
We use the information collected automatically to present the Services to you on your device; to determine news, alerts and other products and services that may be of interest to you for marketing purposes; to monitor, support and improve the Services and our business; and to help us develop new products and services. The table in Attachment 2 further sets forth the categories of information we collect about you automatically when you use the Services and how (for which purpose) we use that information. The table also lists the legal basis which we rely on to process the information.
3.4. Information We Collect from Third Parties
We may collect information, including personal information, that others provide about you when they use the Services, or obtain information from other sources (including social media networks) and combine that with information we collect through the Services. Any information request regarding the disclosure of your personal information to us should be directed to such third parties.
4. How We Use Your Information
4.1. Generally
We generally rely on the following three main bases to process your personal information:
Sometimes, we may rely on other legal bases to process your information, such as where you have given us consent to use your personal information in certain ways or to protect a user’s vital interest. We also may process your personal information relying on more than one legal basis, depending on the specific purpose for which we are using your personal information.
As noted above, the table in Attachment 1 provides further details on the categories of information we collect about you when you use the Services, how (for which purpose) we use that information, and the legal basis we rely on to process that information. You can also contact us at compliance@gorillaexpense.com if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set forth below.
4.2. Provide Our Services
We use your personal information to provide or facilitate:
We process your personal information where it is necessary for the adequate performance of the contract with you. We also process this information given our legitimate interest in providing the Services in an effective manner.
4.3. Understand and Improve Our Services
We use your personal information to analyze, operate, protect, improve, and customize the Services and user experience, such as by performing data analytics and studying how the Services are used. We process this information given our legitimate interest in improving the Services, understanding how our Services are being used, and developing and growing our business.
4.4. Administer and Protect the Services
We use your personal information to:
We process your personal information where it is necessary to comply with applicable laws and regulations. We also process this information given our legitimate interest in the providing administration and information technology services, ensuring network and information security, and complying with applicable laws and regulations.
4.5. Legal and Safety
We use your personal information to:
We process your personal information where it is necessary to comply with applicable laws and regulations or to ensure adequate performance of the contract with you. We also process this information given our legitimate interest in protecting our Services, preventing harm or illegal activities, enforcing or defending our legal rights, and complying with applicable laws and regulations.
4.6. Provide and Improve Our Marketing
We use your personal information to:
We will process your personal information given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest, informing our marketing strategies, and developing and growing our business. Generally, and unless you are a resident of the European Economic Area (EEA), we do not rely on your consent as a basis for processing your personal information other than in relation to sending third-party direct marketing communications to you via email or text message. Where we collect your personal information with consent, you may withdraw your consent for us to use your information at any time by unsubscribing, managing your preferences through your account, or contacting us (See “Your Choices About our Marketing Activities” below).
5. Disclosure of Your Personal Information
We will only share personal information collected through the Services as follows:
6. Your Choices About Our Marketing Activities
6.1. Marketing Communications for Non-EEA Residents
From time to time, you may receive marketing communications from us if you have requested information from us or purchased services from us and, in each case (unless you are a resident of the European Economic Area (EEA)), you have not opted out of receiving such communications. If you are a resident of the EEA, you will not receive such communications from us unless you have specifically opted in to receive them, as described further in Section 5.4 (EEA Residents) below. In any case, most such communications we send will be by email. For some communications, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.
6.2. Opt-Out
You can ask us to stop sending you marketing messages at any time by contacting us at compliance@gorillaexpense.com or by using the contact information set forth below.
6.3. Third Party Marketing
We will get your express opt-in consent before we share your personal information with any company outside Gorilla Expense for marketing purposes.
6.4. EEA Residents
If you are resident in the EEA, we will only send you marketing messages if you have given us your consent to do so. If you do not want to receive messages from us, you will be able to tell us by selecting certain boxes on forms we use when we first collect your contact details or by refusing or withdrawing your consent. You can also change your preferences later by clicking on the unsubscribe link at the bottom of our messages or by emailing us at compliance@gorillaexpense.com.
6.5. Non-Marketing Messages
Please note that if you do opt out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages.
6.6. Affiliate Usage
Your personal information may also be shared with any affiliates of Gorilla Expense, who may also use this information for the same purposes outlined in this Privacy Policy.
7. Interest-Based Advertising
7.1. Interest-Based Advertising
We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. If so, we may permit third party online advertising networks, social media companies and other third party services to collect information about your use of the Services over time so that they may play or display ads on the Services, on other websites, apps or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
7.2. Online Resources
To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, the DAA’s resources at www.aboutads.info/choices and/or Your Online Choices at www.youronlinechoices.com/uk. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s or Your Online Choices online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use. In addition, some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
8. USER CONTENT
Your content will be viewed by other users in accordance with privacy settings available through the Services. Gorilla Expense can, but has no obligation, to monitor any content you post on the Services. We can remove any information you post for any reason or no reason. Unless your content is made viewable in accordance with your settings in the Services, Gorilla Expense will not view your content except: (i) to maintain, provide or improve the Services; (ii) to help you and resolve your support requests; or (iii) as Gorilla Expense believes, in its sole opinion, is necessary to comply with or avoid the violation of applicable law or regulation, cooperate with law enforcement, or enforce its rights under the Terms and Conditions, Privacy Policy, and other agreements and policies with you or third parties. If you remove your content, including personal information contained in that content, from the Services, copies may remain viewable in cached or archived pages of the Services, or if other users have copied or saved that information.
9. Your Rights OVER YOUR PERSONAL INFORMATION
If you are resident in the European Economic Area (EEA), under the General Data Protection Regulation (GDPR) you have the following rights in respect of your personal information that we hold:
If you are resident in France, you also have the right to set guidelines for the retention and communication of your personal information after your death.
If you are concerned about the personal information collected as you use our Services or would like to discuss or exercise rights you may have under this Privacy Policy or applicable law, you may contact us at compliance@gorillaexpense.com. If we are acting as a data controller with respect to the personal information at issue (e.g., personal information collected via the Sites), we will respond to your request directly. If we are acting as a processor of your personal information on behalf of your Company as the data controller, then we will forward your request to your Company to allow them to respond. If your Company then requests Gorilla Expense to facilitate your request with respect to any personal information with respect to which we are the processor, we will respond to your Company’s request as quickly as is practicable under the circumstances. You may also contact your Company directly if you have questions about the personal information with respect to which the Company is the data controller.
10. DATA RETENTION
We will only retain your personal information for no longer than necessary for the purposes for which it was collected (as described in further detail in Attachments 1 and 2), and if necessary to comply with our legal obligations and legitimate business interests. If you no longer want us to use your personal information to provide the Services to you, you can request that we erase your personal information and close your account. Please be aware that because we maintain the Services to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
11. Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure, and currently self-attest as a Payment Card Industry (PCI) compliant service provider. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we cannot guarantee its absolute security. If you have any questions about the security of our Services, please contact us at compliance@gorillaexpense.com.
12. Children Under the Age of 16
The Services are not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at compliance@gorillaexpense.com or by using the contact information set forth below.
13. Your California Privacy Rights
California Civil Code Section 1798.83 permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at compliance@gorillaexpense.com.
14. INTERNATIONAL DATA TRANSFER
Your personal information may be transferred to, stored, and processed in the United States or a country that is not regarded as providing the same level of protection for personal information as the laws of your home country. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information.
Whenever we transfer the personal information of individuals resident in the European Economic Area (EEA) to countries out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
15. Changes to Our Privacy Policy
We may update our Privacy Policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new Privacy Policy on this page with a notice that the Privacy Policy has been updated and notify you by email to the primary email address and/or phone number specified in your account, or an in-Services alert the first time you use the Services after we make the change. Modifications will be effective as of the date stated on the update, or such other date as communicated in the notice to you.
The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address and/or phone number for you and for periodically visiting this Privacy Policy to check for any changes.
16. Lodging Complaints
You have the right to lodge complaints about the data processing activities carried out by Gorilla Expense before your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. In addition, residents in other jurisdictions may also have similar rights to the above. Please contact us at compliance@gorillaexpense.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.
17. Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at compliance@gorillaexpense.com or Gorilla Expense, 3870 Peachtree Industrial Boulevard, S-340 #167, Duluth, GA 30096.
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