This mobile application ("App") is operated by Gatekeeper Interactive LLC, a Washington limited liability company ("Gatekeeper Interactive", "Company", "we", or "our"). Gatekeeper Interactive provides white labeled mobile applications to our customers. We will share your information with the entity named on the App.

Gatekeeper Interactive and our affiliates respect and protect the privacy of the users that use our software, tools, and services offered through our various mobile applications available on iOS and Android. Via the App, Gatekeeper Interactive offers various services available to you including, but not limited to, access to content and social interaction capabilities (the "Services"). We maintain a strict policy to ensure the privacy of those who download this App ("End Users"). This policy ("Privacy Policy") describes the types of information we may collect from you and our practices for how we collect, use, maintain, protect, and disclose such information. This Privacy Policy also includes a description of certain rights that you may have over information that we may collect from you. Capitalized terms used in this Privacy Policy that are not defined have the same meaning as defined in the Gatekeeper Interactive Terms of Service ("Terms").

If you do not agree with our policies and practices, your choice is not to download the App or use our Services. By downloading the App or using the Services, you agree to this Privacy Policy. If you do not agree with this Privacy Policy, you should immediately delete the App from your device and cease use of the Services. This policy may change from time to time as stated below. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1. Scope of Privacy Policy
2. Information We Collect About You and How We Collect It
3. How We Use Your Information
4. How we Disclose or Share Your Information
5. Data Security: How We Protect Data We Hold
6. International Transfer of Personal Data
7. Legal Basis for Processing Personal Data (EEA Only)
8. Choices for Your Personal Data
9. EEA Specific Rights for Personal Data
10. Changes to the Privacy Policy
11. Children Under the Age of 16
12. California Privacy Rights
13. Questions and Right to Access

1. Scope of Privacy Policy

This Policy details our commitment to protecting the privacy of End Users of the App. This policy applies to information that is automatically collected via the Services or that is affirmatively provided to us by End Users.

This Privacy Policy does not apply to:

• Offline Information. Information collected by us offline or through any other means, including on any other website operated by Gatekeeper Interactive or any third party (including our affiliates and subsidiaries) is not subject to this Privacy Policy.
• Third Parties. Gatekeeper Interactive is not responsible for the privacy policies or other practices employed by websites linked to, or from, our website or App nor the information or content contained therein, and we encourage you to read the privacy statements of any linked third party.

2. Information We Collect About You and How We Collect It

Gatekeeper Interactive gathers a variety of information about our End Users, including information:

• by which you may be personally identified, such as name, e-mail address, or any other identifier by which you may be contacted online or offline ("Personal Data");
• that is about you but individually does not identify you; and
• about your internet connection, the devices you use to access our Services and usage details.

We collect this information directly from you when you provide it to us, automatically as you navigate through the Services, or from third parties, for example, our business partners.

Information That You Provide to Us

When you sign up to use the Services or when you request certain materials, you may be required to provide Personal Data. During these processes we may ask you to provide your name, e-mail address, telephone number, birth date, and unique identifiers, such as a username or password.

Through your use of the Services, we may obtain Personal Data from records and copies of your correspondence (including email), if you contact us; your responses to optional registration forms, feedback forms, or surveys that we might ask you to complete; or from transactions, including billing information, that you may carry out through our Services. Billing information, however, is processed by third party service providers and the billing information is not stored on our systems.

Finally, we may obtain information if you provide information to be published or displayed (hereinafter, "posted") on public areas of the Services or transmitted to other users of the Services or third parties (collectively, "User Contributions") including your participation in chat rooms, forums, or bulletin boards. Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that we cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information Automatically Collected Through Your Use of the Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your devices, internet protocol ("IP") address, operating system, browser type, browsing actions, and pattern. The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways. It helps us to improve our Services and allows us to deliver a better and more personalized service, including enabling us to estimate our audience size and usage patterns, to store information about your preferences, and to recognize you when you return to our Services.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). Gatekeeper Interactive uses a technology that is commonly known as "cookies." A cookie is a small file placed on the hard drive of your computer. We use cookies to help us manage and report on your interaction with the Service. Through cookies, we are able to collect information that we use to improve the Services, keep count of return visits to our website or our advertisers' or partners' websites, collect and report on aggregate statistical information, authenticate your login credentials, or manage multiple instances of the Services in a single browser. We may also collect other data such as the page or site that referred you to the Services, the date and time you visited the Services, and your current IP address. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Services or the functions of the Services may be impaired. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

3. How We Use Your Information

We may use aggregated (anonymized) information about our End Users, and information that does not identify any individual, without restriction.

Gatekeeper Interactive identifies the purposes for which the information is being collected before or at the time of collection. The collection of your Personal Data will be limited to that which is needed for the purposes identified by Gatekeeper Interactive. Unless you consent or we are required by law, we will only use the Personal Data for the purposes for which it was collected. If Gatekeeper Interactive will be processing your Personal Data for another purpose later on, we will seek your further legal permission or consent; except where the other purpose is compatible with the original purpose. We will keep your Personal Data only as long as required to serve those purposes. We will also retain and use your Personal Data for as long as necessary to comply with our legal obligations or to resolve disputes.

We use information about you, including Personal Data, for a variety of purposes, including:

• To share data with entity named in this App;
• To generally enable you to use our Services;
• To provide you with information, products, or services that you request from us;
• To customize and personalize the advertising and other content we deliver to you on the Services;
• To respond to your comments, questions, and requests;
• To provide customer service and support;
• To send you administrative messages about the Services;
• To provide you with notices about your account, including expiration and renewal notices;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• To notify you about changes to our Services or any products or services we offer or provide through it.
• To monitor and analyze trends, usage, and activities in connection with the Services;
• To investigate and prevent fraudulent transactions, unauthorized access to the Services, violations of the Terms, and other illegal activities;
• To share testimonials or reviews that you may have posted to the Services or other Gatekeeper Interactive owned social media pages;
• In any other way we may describe when you provide the information; or
• For any other purpose with your consent.

4. How we Disclose or Share Your Information

We may disclose aggregated information about our End Users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide:

• To our subsidiaries, affiliates, and with the entity named on this App;
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Gatekeeper Interactive's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Gatekeeper Interactive about our End Users is among the assets transferred. You will be notified of any such change by a prominent notice displayed on our Services or by e-mail to the primary address affiliated with your account. Any successor in interest to this Privacy Policy will be bound to the Privacy Policy at the time of transfer; or
• To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Gatekeeper Interactive, our End Users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

5. Data Security: How We Protect Data We Hold

We have implemented industry standard technical and organizational measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. All information you provide to us is stored on our secure servers behind firewalls.

To provide you with the App and Services and to store and process your data we use Microsoft Azure ("Azure"). We use Azure to store certain data and software. Azure delivers a network of data centers located around the world, including in the United States of America. For more details of Azure's privacy and security processes, please visit https://privacy.microsoft.com/en-us/privacystatement.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Services like company profile pages or message boards. The information you share in public areas may be viewed by any End User of the Services.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your Personal Data transmitted to the Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.

In the event that there is breach in the data that we hold, we shall notify of such breach via email to the email listed in connection with your account.

6. International Transfer of Personal Data

Gatekeeper Interactive stores personal information about End Users within the United States. If you are using the Services from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your Personal Data to the United States. The United States may have laws which are different, and potentially not as protective, as the laws of your own country. By providing your Personal Data, you consent to any transfer and processing in accordance with this Privacy Policy.

7. Legal Basis for Processing Personal Data (EEA Only)

With respect to Personal Data collected from individuals from the EEA, our legal basis for data collection and storage is your consent, within the meaning of Art. 6 paragraph 1 sentence 1 letter a GDPR. For any additional data collection beyond what is disclosed in this Privacy Policy our legal basis will depend on the Personal Data concerned and the specific context in which we collect it. Our Company will normally collect Personal Data only where: (a) we have specific consent to do so, (b) where we need the Personal Data to fulfil a contract with an End User, or (c) where the processing is in our or a third party's legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).

If we ask you to provide Personal Data to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to use your Personal Data. If we process Personal Data in reliance on your consent, you may withdraw your consent at any time.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided below.

8. Choices for Your Personal Data

You can review and change your personal information by visiting your account profile page.

You may also send us an email to request access to, correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete User Contributions from the Services, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other users.

Gatekeeper Interactive tolerates only permission-based email. In addition, End Users always have the opportunity to opt-out or change preferences via a link in the footer of all non-transactional email messages. These options are made available in email messages delivered from our company. Some communications, however, are considered transactional and are necessary for all Gatekeeper Interactive End Users (e.g. important account notifications and billing information). You must cancel your Gatekeeper Interactive account to stop receiving transactional communications.

Gatekeeper Interactive does not currently respond to browser "Do Not Track" signals or other mechanisms. To find out more about "Do Not Track," you may wish to visit www.allaboutdnt.com.

9. EEA Specific Rights for Personal Data

For the purposes of data collection under the GDPR, Gatekeeper Interactive shall be the data controller. If you are an individual resident in EEA, you have the following data protection rights regarding Personal Data:

• You have the right to access, correct, update or request deletion of your Personal Data. You can do so at any time by contacting us.
• You have the right to object to processing of your Personal Data, to ask us to restrict processing of your Personal Data, or to request portability of your Personal Data. Again, you can exercise these rights by contacting us.
• You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us.
• You have that right to revoke consent that was previously given. If we have collected and process your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
• You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.

If you would like to exercise any of the above rights, please contact our support team or contact us at info@gatekeeper.mobi or through our Data Protection Officer at data@gatekeeper.mobi.

10. Changes to the Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the App. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account, through a prominent notice on the App. Such changes will be effective when posted. 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 for you, and for periodically visiting this Privacy Policy to check for any changes. Your continued use of our Services following the posting of any amendment, modification, or change to this Privacy Policy shall constitute your acceptance of the amendments to this Privacy Policy. You can choose to discontinue use of the Service if you do not accept the terms of this Privacy Policy, or any modified version of this Privacy Policy.

11. Children Under the Age of 16

Our Services are not intended for children under 16 years of age. No one under age 16 may provide any personal information to or on the Services. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or register on the Services, make any purchases, use any of the interactive or public comment features, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. 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 the email address listed below.

12. 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 send an email to the email address listed below.

If you are a California resident under the age of 18, and a registered user of our Services, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an e-mail with a detailed description of the specific content or information to the email address listed below.

Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Under California law, California residents who have an established business relationship with us may opt-out of our disclosing Personal Data about them to third parties for their marketing purposes.

Gatekeeper Interactive acknowledges the individual's right to access their personal information.  Any individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct the query to the address below.  If requested to remove data, we will respond within a reasonable timeframe.

If you have any questions about this Privacy Policy, please contact us:

By email: info@gatekeeper.mobi