GIANT Connect Privacy Policy

 

Last Updated: January 27, 2022

 

1. Scope

This Privacy Policy applies to Personal Information Processed in the course of our business, including on our website https://www.giantconnect.com (the “GIANT Connect Site”), our mobile device application (the “GIANT Connect App”), and our WiFi sharing and access services accessible via the GIANT Connect Site and the GIANT Connect App (collectively, the “Services”) that are owned and operated by ShareG, Inc. a Delaware corporation. The terms “GIANT Connect,” “we,” “us,” and “our” refers to ShareG Inc. and our affiliates (“ShareG”). All capitalized terms not defined in this Privacy Policy will have the meanings set forth in the GIANT Connect Terms of Service.

 

2. Processing

“Process,” “Processed” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission , dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

 

3. Personal Information and What We Collect

“Personal Information” means information that (i) relates to you and (ii) can – either on its own or in combination with other information – identify you as an individual. Personal Information does not include data that has been de-identified or aggregated such that you can no longer be identified. The types of Personal Information we collect and our privacy practices depend on whether you are a GIANT Connect user, GIANT Connect Host, business partner, or visitor to our Services (together, “Individuals”) and the requirements of applicable law.

Below are the ways we collect Personal Information and how we use it.

 a.  Information You Provide to Us

      • Account Creation. When you create an Account, we will ask you for your mobile phone number and use this as the primary identifier for your Account. In some cases, we may also ask you for an invite code to create an Account. If you are a GIANT Connect Host, we will also ask you for information about your WiFi network and equipment (including its location). Users who complete Account registration and those wishing to be sent additional promotional information on ShareG products, may also provide Personal Information such as name, phone number, address, company, title, and unique identifiers such as passwords or account name. With respect to payment information, ShareG will typically collect information such as payment card type, payment card number, billing address and phone number. ShareG may also collect information regarding a user’s purchase history and consumer profiles depending upon the product being accessed.
      • GIANT Connect Balance Information. When you use the Services, ShareG will collect information about your usage rates to determine how much of your GIANT Connect balance you may have used or earned through your use of the Services.
      • GIANT Connect VPN Traffic. When you use GIANT Connect’s WiFi sharing and access services, GIANT Connect will route all your Internet traffic through the GIANT Connect Virtual Private Network. All traffic is encrypted and GIANT Connect cannot access or otherwise see this information.
      • Automatic Data Collection. We may collect certain information automatically when you use the Services through the use of cookies, pixel tags and web beacons. This information may include your Internet protocol (IP) address, user settings, IMEI (International Mobile Equipment Identity), MAC (Media Access Control) address, Technologies (as defined in section 4(g)) including cookie identifiers, mobile advertising and other unique identifiers, mobile carrier, details about your browser, operating system or device, location information (including inferred location based off of the WiFi network you are connected to), Internet service provider, pages that you visit before, during and after using the GIANT Connect Site, and other information about how you use the Services. Information we collect may be associated with accounts and other devices. More information on cookies and similar technologies can be found below.
      •  Communications with Us. We may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, request customer or technical support, or otherwise communicate with us.
      • Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include Personal Information.
      • Interactive Features. We may offer interactive features such as chat services, forums, and social media pages. We may collect the information you submit or make available through these features. Any content you provide on the public sections of these channels will be considered “public” and will Processed accordingly.
      • Conferences and Trade Shows. We may attend conferences and trade shows where we collect Personal Information from Individuals who interact with or express an interest in ShareG and/or any of its Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected.
      • The GIANT Connect App. With your permission, ShareG may collect and track certain geographic location information that is derived from your usage of the GIANT Connect App such as usage patterns, travel and traffic patterns and information about your geographic location. Geolocation information collected may include IP-address-based location information and GPS data that reveals the latitude and longitude of your mobile device at the time of connection. ShareG may also collect motion information through your use of the GIANT Connect App.
      • Information Collected Through Advertising Partners. We may also collect information from our advertising partners who assist us with marketing or promotional services related to how you interact with the GIANT Connect Site, the Services and related applications, products, advertisements and communications.

 

b. Information from Other Sources. We may obtain information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, if you access our Services through a third-party application, such as an App Store, a third-party login service, or a social networking site (“SNS”), we may collect information about you from that third-party application that you have made available via your privacy settings. This additional information allows us to verify information that you have provided to us and to enhance our ability to provide you with the Services.

 

4. How We Use Your Information

We Process Personal Information about Individuals for a variety of business purposes, including:

  1. To Provide Products, Services, or Information Requested.
      • Create your Account or other user profiles and provide operational support for provisioning the Services;
      • Manage Individual information and Accounts;
      • Respond to questions, comments, and other requests;
      • Provide access to certain areas, functionalities, and features of our Services;
      • Answer requests for customer or technical support; and
      • Allow you to register for Services and events.
  1. Administrative Purposes.
      • Measure interest and engagement in the GIANT Connect Site and Services;
      • Improve our products and Services;
      • Develop new products and services;
      • Ensure internal quality control;
      • Verify Individual identity;
      • Communicate with you about your Account, activities on the GIANT Connect Site and Services and policy changes;
      • Process transactions;
      • Prevent potentially harmful or prohibited conduct and deter fraudulent or other illegal activities in order to maintain the safety, security and integrity of our Services ; and
      • Enforce our Terms of Service and fulfill ShareG’s legal obligations and defend ShareG’s legal rights or resolve disputes as needed.
  1. Marketing Our Products and Services. We may use Personal Information to personalize website content and communications based on your preferences, including targeted offers and ads served through the Services (see detailed herein below) and to tailor and provide you with materials about offers, products, and services that may be of interest to you. We may provide you with these materials by email, phone, and/or postal mail, as permitted by applicable law.You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as described below.
  2. De-identified and Aggregated Information Use. We may use Personal Information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, de-identified or aggregated trends, reports, or statistics, information about the computer or device from which you  access our Services, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the GIANT Connect Site and Services. De-identified and aggregated information is not Personal Information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
  3. Sharing Content with Friends or Colleagues. ShareG’s Services may offer various tools and functionalities. For example, ShareG may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Contact information that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by ShareG or any other third parties for any other purpose.
  4. Other Uses. ShareG may use Personal Information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, and fraud prevention. In addition, ShareG may use Personal Information for other purposes that are clearly disclosed to you at the time you provide Personal Information or with your consent and for any other business purpose stated when collecting your personal information or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”) and the General Data Protection Regulation (the “GDPR”) applicable to users in the EEA. We may also use a user’s email address to send promotional or marketing materials on related Services, such as updates on the ShareG product line, but this is only after the user is a registered client, Service is requested by the user, or ShareG has some other pre-existing business relationship with the user. We use your IP address and browser-type information in the general administration of our website.
  5. Technologies. We, as well as third parties that provide content, advertising, or other functionality on the GIANT Connect Site and Services, may use cookies, pixel tags, local storage, and  other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with the GIANT Connect Site and Services.
  6. GIANT Connect App Data Use.  Geographic location information collected through your laptop or mobile device (Including tracking and location information) may generally be used for statistical, analytical or business-related purposes to improve our products, offerings and services and to manage our networks and systems more efficiently. The GIANT Connect Services  hotspot aggregator uses this geolocation information to show the nearby hotspots that are visually depicted on a screen in the app as pins on a map and its location to provide range information. In range hotspots are shown as something users can connect with immediately.  Motion information is used to detect when the user is in-flight in order to facilitate proper functioning of the Service through seamless interfaces and to support location accuracy.  The GIANT Connect App may also use Personal Information collected from your device to provide notifications (push notifications) in order to notify you when your account is approaching zero balance during an active usage session.  Collection of these categories of information will be performed with your permission subject to the disclosures set forth herein.
  7. Cookies and Internet-Based Advertising. Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/. Alternatively, for some devices you may use your device’s platform controls in your settings to exercise choice.
    • Please note you must separately opt out in each browser and on each device. Advertisements on third-party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
  8.  Pixel Tags/ Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Services that collects information about users’ engagement. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
    • Our uses of such Technologies fall into the following general categories:
      • Operationally Necessary. This includes Technologies that allow you access to our Services that are required to identify irregular behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions;
      • Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
      • Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services, keeping track of your specified preferences or past pages viewed;
      • Advertising or Targeting Related. We may use first party or third-party Technologies to develop and deliver content, including ads relevant to your interests, on our Services or on third-party sites.
  1. Analytics. We may use analytics we obtain from other service providers to collect information regarding visitor behavior and visitor demographics on the GIANT Connect Site and Services.
  2. Third Party Websites/Applications and Software Development Kits. The Services may contain links to other websites/applications and other websites/applications may reference or link to the GIANT Connect Site or other Services. These other domains and websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
    • We may use third party APIs (Application Programming Interface) and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you as provided herein. For more information about our use of APIs and SDKs, please contact us as set forth below.

 

5. How We May Disclose Your Information

  1. We Use Service Providers. We may share any Personal Information we collect about you with our third-party service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) invoice processing; (iv) customer service activities; and (v) the provision of the Services.
  2. Internet Service and Telecom Providers. We may share the information we collect with Internet service and telecom providers to help us calculate usage rates and GIANT Connect account invoicing.
  3. Business Partners. We may provide relevant Personal Information to business partners to provide you with a product or service you have requested. We may also provide relevant Personal Information to business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
  4. Marketing – Interest-Based Advertising and Third-Party Marketing. Through our Services, ShareG may allow third-party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising.” We may allow access to other data collected by the GIANT Connect Site and Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may follow the instructions below to opt out of these actions.
  5. Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) to collect amounts owed to us; (iv) when we believe disclosure is necessary or appropriate to prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (v) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
  6. Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be transferred as part of such a transaction as permitted by law and/or contract.

 

6. International Data Transfers

You agree that all information Processed by us may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States and other countries. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers.

 

7. Your Choices

  1. General. You may have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the Processing of your Personal Information, you may withdraw that consent at any time by contacting us as described below. This includes the right to opt out of Interest-Based Advertising and Third-Party Marketing as described above.
  2. Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Policy).
  3. The GIANT Connect App. We may send you push notifications through the GIANT Connect App. You may opt-out from receiving these communications by changing the settings on your mobile device. With your permission, ShareG may also collect location-based and motion information through your use of the GIANT Connect App. You may opt-out of this collection by changing the settings on your mobile device.
  4. “Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

 

8. Access, Rectification, Erasure, and Restriction

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are Processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by ShareG, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will process such requests in accordance with applicable laws. To protect your privacy, ShareG will take steps to verify your identity before fulfilling your request.

  1. Data Retention. We retain the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
  2. Security of Your Information. We undertake reasonable and appropriate administrative, technical, and physical safeguards to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of the information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by sending a notice through the Services or by sending an e-mail to you.

  1. Children’s Information. The GIANT Connect Site and Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below. If we learn that we have collected any Personal Information in violation of applicable law, we will promptly take steps to delete such information.
  2. California Privacy Rights.  California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Except as otherwise provided in this Privacy Policy, ShareG does not share Personal Information with third parties for their own marketing purposes and we do not sell Personal Information to third parties.
  3. Supervisory Authority. If you are located in the European Economic Area, you have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law.
  4. Changes to Our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. The revised Privacy Policy will be effective as of the published effective date. Your use of the GIANT Connect Site or Services following such notification constitutes your acceptance of the terms and conditions of this Privacy Policy as modified. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact us at:

ShareG, Inc.

99 Wall Street, Suite 5950, New York, NY 10005

[email protected]