GLOXY PRIVACY AND COOKIE POLICY

Welcome to Gloxy's Privacy and Cookie Policy. This Policy explains how Gloxy gives you control of your Personal Data. When we talk about the processing of Personal Data, we mean how we collect, use, share and store Personal Data. This policy covers these contents in all of our services ("Services" or "Gloxy's Services").

This policy covers the following Gloxy Services:

https://www.gloxy.app and https://letsgloxy.com ("Gloxy Site") websites,

Gloxy mobile applications (for example, Gloxy iOS, Gloxy Android,) ("Gloxy App"),

We will be transparent about the information we collect and what we will do with it. We will use the information you provide to us for the purposes described in our Privacy Policy, including to provide you with the services you request and to improve your experience with Gloxy. We will also use the information to help us better understand you and to provide you with relevant services and information. If you tell us that you do not want to receive marketing messages, we will stop sending them. Of course, we will continue to send you important information about the Gloxy service and your account with us. We will take measures to protect and keep your information secure.

We will protect your data protection rights and aim for you to have control over your own information.

If you have any further questions, you can contact us via e-mail: help@gloxy.app

CONTROLLER OF PERSONAL INFORMATION

All personal information processed by Gloxy in connection with this Privacy Policy is controlled by Gloxy Limited, which is considered the data controller of your personal information under the relevant data protection laws.

WHAT DO WE MEAN WITH PERSONAL INFORMATION?

Personal information means details that identify you or can be used to identify you, such as your name and contact information, your age, profile, comments, photos, geographic locations, ethnicity, preference data, and more. It may also contain information about how you use our websites and mobile applications.

WHEN DOES THIS POLICY APPLY?

This Privacy Policy applies to personal information that we collect, use and otherwise process when you interact with us or use our other products or services, use our websites or mobile applications, or in relation to your relationship with us as a customer or potential customer.

HOW CAN YOU KEEP YOUR PERSONAL INFORMATION SAFE?

We take great care in protecting the personal information you provide to us. In order to adhere to this principle, we implemented our "Gloxy Trust Culture" policy. Here are some things you can do to keep your information safe.

Keep your Gloxy logins private

To make sure your access to our mobile apps is secure, you should not share your login information with anyone. When you have finished using the application, you must log out if others can access your device. This is especially important if you are using a device that is accessible to everyone.

Protect yourself by being aware of internet fraud and phishing

There is a practice of online fraud known as phishing, which involves the illegal collection of personal information in different ways. Unsolicited emails are sent to individuals from lists illegally collected by a third party, and recipients are asked to enter a cloned or illegal copy website login, password or other personal information. To minimize the risk of being a target of an attack, you should make sure you always have up-to-date protection software on your devices.

We will never ask you to reveal your password to any of our staff. If you receive a suspicious request claiming to be from us, do not take any action before confirming the authenticity of the request directly with us using the contact information provided in this policy.

WHEN DO WE COLLECT PERSONAL INFORMATION ABOUT YOU?

We collect personal information about you every time you use our products or services (whether those products or services are provided by us or by other companies or agents acting on our behalf), when you use our website or mobile applications, or when you communicate with us. send e-mail or use our contact centers.

WHAT INFORMATION DO WE COLLECT AND STORE?

To use Gloxy with your device, we create a unique ID for the device or browser on which you install and / or access this device. We will never disclose or share this identifier to other parties, unless legally required.

Information we share with Gloxy users

When using Gloxy, you can specifically provide Gloxy with the following personal information:

• The name you specified

• The description you specify in your profile

Any visual content you upload

Your geographic information

• Your ethnic origin

• Your height information

• Your weight information

• Your sexual role

• Your relationship status

Your HIV status

• Relevant filters you are looking for

Gloxy provides a social networking service to connect gays with each other. We use your information to help other users find and connect with you.

We may display the personal information listed above as part of our feed or on your profile page.

We provide users with the ability to find you based on this information.

Geographical information is provided to our users as a relative distance or at the city, region or country level.

Information we do not share with Gloxy users

You can provide us with the following information that we use to identify you to log in or contact you.

This is not shared with Gloxy users.

• Your Facebook ID, if you choose to sign in using Facebook.
• Your Google ID if you choose to login using Google.
• In-app chats

While using Gloxy, you can use our in-app messaging service to communicate with other Gloxy users from our web application or mobile applications. We store messages, photos and stickers from your chats on our servers so that you can access your messaging history from your device whenever you want.

When you delete your account, you will find your chat messages and user profile below, "How long will we retain your personal information?" We delete it subject to certain conditions stated in the section.

Information we collect from your mobile application or website use

We may also collect:

Your contact with our support team

-We collect information about contacting our support team to help us answer your questions. We also collect information about any suggestions or complaints you make to help you with your questions and to improve the products we offer you.

IP address

The last IP address associated with a profile or user account is stored. This is used to control spam and fake account creation and to identify illegal access to the Gloxy service.

Anonymous usage information

Your use of the mobile application or website. We anonymize this information so that we can no longer link it to your user account. We collect this to guide our product development so that we can continually improve the services we offer to our members.

How you pay for premium subscriptions

-If you have an existing premium subscription and details of how you paid for it so that we can continue to receive payment for your subscription.

Email preferences

-To know which emails we will send you and which you do not want to receive

your preferences for receiving emails from us.

Information about violations of our terms of service

- To help control and suspend users who repeatedly violate our terms of service, we store information about events that we believe violate our terms of service.

Reports of violations you made about other users

- If you report another user for violating our terms of service, we collect information about what you think the violation is, the time of the report, the user you reported and other details you provided to us.

WHEN AND WHY DO WE COLLECT 'SENSITIVE PERSONAL DATA'?

Certain categories of personal information, such as race, ethnicity, religion, health, sexuality or biometric information, are special categories of data that require additional protection under the European Union and UK data protection law, referred to herein as "sensitive personal data".

You can choose to provide us with the following specific sensitive personal data that we show on your profile and allow users to find you accordingly:

• Your ethnic background

• Your preferred sexual role

• Your relationship status

• You can also choose to share your HIV status with us.

Your HIV status can only be searched for by users who identify themselves as HIV positive.

You can choose to receive in-app reminders and get information about the location of nearby test centers.

We do not share sensitive personal data information with third parties, unless required by law.

You can edit or delete this information at any time.

HOW IS YOUR INFORMATION USED BY OTHERS WHO HAVE LINKS ON GLOXY?

You can access other websites or apps through Gloxy via links or advertisements. When you do this, you are subject to their privacy and data collection policies, and you should read these policies carefully before using them. Gloxy is not responsible for the use, privacy and data collection practices of your personal information.

WHEN WE WILL SEND YOU MARKETING AND NEWSLETTERS?

For users who join our community who are subject to EU data protection legislation, we will ask them specifically if they would like to receive our newsletters. All other new users will automatically benefit from our newsletters, and all users can unsubscribe from our newsletters at any time. Please note that we sometimes send marketing communications promoting our own products as well as products and services of third parties (for example, products and services of our business partners).

We may ask you whether you agree to receive marketing communications from other members of our group or from third parties.

We will respect your choice of what communications you would like to receive and how you send them.

How can you change what marketing communications you receive and how you receive them?

If you decide that you no longer want marketing communications to be sent, you can change your mind at any time.

If you are a registered user of Gloxy, you can change your marketing preferences at any time by changing your profile on the website or mobile application.

You can also opt out of our newsletter or all e-mail communications by following the unsubscribe link below the relevant e-mails you receive from us.

Please note that if you tell us that you do not want to receive further marketing communications, you will continue to receive required service communications such as membership and other important service information. Please note that if you ask us to stop sending marketing communications, we will store your personal information to indicate that you do not want to receive marketing communications.

WHAT ARE OUR LEGAL BASES FOR USING YOUR PERSONAL INFORMATION?

Gloxy will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons Gloxy collects and should use your information. In most of the relevant laws (EU, UK and others) the legal basis in almost all cases will be:

Because we need to use your information so that we can provide you with products and services and otherwise fulfill the contract with you.

Because it is in Gloxy's legitimate interests to use your personal information to run and develop our business.

Because Gloxy needs to use your personal information to comply with a legal obligation.

To protect your or another person's vital interests.

Because you have allowed Gloxy to use your information for a specific purpose.

If the processing of your data is subject to any other law, the basis for the processing of your data may differ from those stated above and in these cases may in any case be subject to your consent.

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

Your personal information may be shared with companies in our group to help us provide services to you. We may also disclose your personal information to the following third parties for the purposes described here:

• Credit and payment card companies and fraud prevention screening service providers to process payments and (where required) to screen for fraud.
• In response to a valid legal request from government, regulatory authorities and law enforcement agencies.
• Third parties such as law firms and courts of law to execute or enforce any contract with you or including subpoenas, court orders, legal proceedings.
• To improve our business services, we may share information about your age and location, as well as non-personally identifiable information with our advertising and analytics providers and related service providers.
• We may share your personal data with any subsidiary, joint venture or other companies under joint control. If another company buys our company, business or assets, that company will own the personal data collected by us and will assume the rights and obligations regarding your personal data described in this Privacy Policy.

HOW MUCH DO WE KEEP YOUR PERSONAL INFORMATION?

We will retain your personal information for as long as necessary to provide our services to you and to the extent permitted by applicable legal requirements.

When you delete your account, it will be removed from our active database, but in some cases it may remain in some archives where it is impractical or impossible to delete.

We may also store your personal data and usage history (including censored, prohibited text or photo history) as necessary to comply with our legal obligations, resolve disputes, and / or enforce any of our agreements.

WHICH COUNTRIES WILL YOUR PERSONAL INFORMATION BE SENT?

Your personal information may be sent and stored to us and to third parties outside your country of residence and in countries other than the European Economic Area (EEA) and the United Kingdom (England).

The nature of our business means that we usually need to send your personal information outside of the EEA or the UK in order to fulfill your use of our products and services. This is because of our business and 'Who do we share your personal information with?' It has operations in countries around the world. For example, you may be located in the European Economic Area or the UK, your personal information will be transferred to other Gloxy members outside these regions.

In addition, we may transfer your data to parties in countries other than your country of residence to provide services to us.

This may include sending your data to countries where you may have less legal rights under their local laws.

REQUEST A COPY OF YOUR PERSONAL INFORMATION

In accordance with applicable data protection laws, you may request a copy of any personal data about you held by Gloxy Limited. In most cases, this is provided for free.

You can request your personal data via the mobile application.

We will need to verify your identity to request your data, and we prefer to email your data to you.

If you can no longer access your account, our support team (feedback@gloxy.app) can help you find your account details so you can log back in.

If you have deleted your account, the "How long will we retain your personal information?" We no longer retain your personal information, subject to certain conditions specified in the section.

WHAT ARE YOUR OTHER RIGHTS RELATED TO THE PERSONAL DATA WE COLLECT?

Depending on the jurisdiction to which you are subject, you may have some additional rights regarding your personal information. If you are subject to EU data protection legislation, for example, under certain conditions, you have the right to:

Access your personal data, correct inaccurate data or delete your personal data, and also request or object to a restriction on the processing of your personal data. Your profile can be changed by you at any time to allow you to update your personal data as needed;

Withdraw your consent at any time where the consent forms the legal basis for the data being processed. Remember that withdrawing a consent can affect the services we can offer you; and

To make a complaint, contact your relevant data protection officer. For a list of EU data protection authorities, please see: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

In order to make our services more suitable for you and to improve our general services, we may use the automatic processing of some of your personal information. We can use this type of automatic processing in the following situations:

Regarding your interactions with other users and certain content on the Gloxy platform (who you communicate with, which profiles you view and / or follow, the content of your profile, and

Our special software automatically analyzes and classifies such images to allow us to manage the large number of images sent to us. If any of your images were not accepted or you have any questions regarding our image classification, please contact us using the contact information in this policy.

CHILDREN'S PERSONAL INFORMATION

Our services are intended only for users 18 years of age or older. We do not knowingly collect, store or use the personal information of anyone under the age of 18. If you notice that someone under the age of 18 has submitted personal information to us, please contact us using the contact information contained in this policy; the problem accordingly.

CHANGES AND UPDATES TO THIS PRIVACY POLICY

Your use of Gloxy means you accept the above Policy. We expressly reserve the right to change the Policy from time to time at our discretion. Your continued use indicates your acceptance of these changes.