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Use our platform & services according to our Terms of Service, Rules, and:

Be at least 13 years old to use this service
Provide accurate and truthful information
Not engage in any unlawful activities including harassment, discrimination, or distribution of illegal content
Not upload content that promotes violence, hate speech, or violates intellectual property rights
Accept that we may monitor and remove content that violates our policies
Allow us to collect and process your data as described below

You can also view our full Privacy Policy in a new window.

ginza.app - Privacy Policy

This policy is effective as of 04th January 2025.

Ginza is owned and operated by Kraftwire Inc./Ltd. In the following text, Ginza and Kraftwire Inc./Ltd. may be used interchangeably.

Your privacy is important to us. It is Ginza's policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website, https://ginza.app, including all subdomains and other sites we own and operate.

Personal information is any information about you which can be used to identify you. This includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and even information about how you use a website or online service.

In the event our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our site.

Information We Collect

Information we collect falls into one of two categories: "voluntarily provided" information and "automatically collected" information.

"Voluntarily provided" information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotions.

"Automatically collected" information refers to any information automatically sent by your devices in the course of accessing our products and services.

Log Data

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device's Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, and other details about your visit.

Additionally, if you encounter certain errors while using the site, we may automatically collect data about the error and the circumstances surrounding its occurrence. This data may include technical details about your device, what you were trying to do when the error happened, and other technical information relating to the problem. You may or may not receive notice of such errors, even in the moment they occur, that they have occurred, or what the nature of the error is.

Please be aware that while this information may not be personally identifying by itself, it may be possible to combine it with other data to personally identify individual persons.

Personal Information

We may ask for personal information — for example, when you create an account, submit content or when you contact us — which may include one or more of the following:

Name
Email Address
Date of Birth
Other information you decide to share

User-Generated Content

We consider "user-generated content" to be materials (text, audio, image and/or video content) voluntarily supplied to us by our users for the purpose of publication on our website or re-publishing on our social media channels. All user-generated content is associated with the account or email address used to submit the materials.

Please be aware that any content you submit for the purpose of publication will be public after posting (and subsequent review or vetting process). Once published, it may be accessible to third parties not covered under this privacy policy.

Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. In which instance, we only collect personal information that is reasonably necessary to provide our services to you.

Collection and Use of Information

We may collect personal information from you when you do any of the following on our website:

Register for an account
Use a mobile device or web browser to access our content
Contact us via email, social media, or on any similar technologies
When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

to provide you with our platform's core features and services
to deliver products and/or services to you
to contact and communicate with you
to attribute any content (e.g. posts and comments) you submit that we publish on our website

We may combine voluntarily provided and automatically collected personal information.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use, or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security.

By design, our platform has minimum password requirements, which may be enhanced over time, as per industry standards. However, you are still responsible for selecting a unique and secure password and its overall security strength, ensuring the security of your own information within the bounds of our services. For example, ensuring any passwords associated with accessing your personal information and accounts are secure and confidential and unique to our platform.

How Long We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account with us, we may retain this information for the duration your account exists on our system. If your personal information is no longer required for this purpose, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, or historical research purposes or statistical purposes.

Children's Privacy

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

a parent, subsidiary, or affiliate of our company
third-party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, error loggers, debt collectors, maintenance or problem-solving providers, professional advisors, and payment systems operators
our employees, contractors, and/or related entities
our existing or potential agents or business partners
credit reporting agencies, courts, tribunals, and regulatory authorities, in the event you fail to pay for goods or services we have provided to you
courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
an entity that buys, or to which we transfer all or substantially all of our assets and business

Third parties we currently use include:

Heroku

We use Heroku as our server provider to host our website.

Heroku is a service provided by Salesforce.com, Inc., Salesforce Tower, 415 Mission Street, Suite 300, San Francisco, CA 94105, USA

Cloudinary

We use Cloudinary to store and deliver media files, including profile pictures, icons, and more.

Cloudinary is a service provided by Cloudinary Ltd., 111 W Evelyn Ave, Suite 206, Sunnyvale, CA 94086, USA

Your Rights and Controlling Your Personal Information

Your choice: By providing personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person's consent to provide the personal information to us.

Marketing permission: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access: You may request details of the personal information that we hold about you.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer (for example providing user support), we will not deny you goods or services and/or charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties, or provide you with a different level or quality of goods or services.

Downloading of Personal Information: Please email us at support@ginza.app and we will make your information available to you. Please contact us for more information.

Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.

Unsubscribe: To unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details provided in this privacy policy, or opt-out using the opt-out facilities provided in the communication. We may need to request specific information from you to help us confirm your identity.

Use of Cookies

We use "cookies" to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified.

Types of cookies we use

Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts, and payment processing. We use essential cookies to enable certain functions on our website.

Functionality cookies are used to store any settings you may configure on the website you're visiting (like language and time zone settings). With this information, websites can provide you with customized, enhanced, or optimized content and services. These cookies may be set by the website you're visiting (first-party) or by third-party services. We use functionality cookies for selected features on our site.

We do not use any performance or targeting/advertising cookies on our site.

Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data, including your personal information, among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

Limits of Our Policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If the changes are significant, or if required by applicable law, we will contact you (based on your selected preferences for communications from us) and all our registered users with the new details and links to the updated or changed policy.

If required by law, we will get your permission or give you the opportunity to opt in to or opt out of, as applicable, any new uses of your personal information.

Additional Disclosures for Brazilian General Personal Data Protection Law (LGPD) Compliance (BR)

Data Controller / Data Processor

Under the LGPD, we are considered a Data Controller ("Controlador") with respect to the personal information you provide to us. As a Data Controller, we are responsible for making decisions about how we process your personal information.

Legal Bases for Processing Your Personal Information

We will only process your personal data when we have a legal basis to do so under the LGPD. Our legal bases include:

Consent (consentimento)
Legal or regulatory obligation (obrigação legal ou regulatória)
Execution of contract (execução de contrato)
Legitimate interests (legítimo interesse)
Protection of life or physical safety (proteção da vida ou da incolumidade física)
Protection of rights (proteção ao crédito)
Health protection (tutela da saúde)
Research (estudos por órgão de pesquisa)
Exercise of rights in legal proceedings (exercício regular de direitos)

Your Rights Under LGPD

Under the LGPD, you have the following rights:

Confirmation of the existence of processing
Access to your personal data
Correction of incomplete, inaccurate, or outdated data
Anonymisation, blocking, or deletion of unnecessary or excessive data
Portability of data to another service provider
Deletion of personal data processed with consent
Information about public and private entities with which we have shared data
Information about the possibility of not providing consent
Revocation of consent

To exercise any of these rights, please contact us using the details provided in the Contact Us section.

International Data Transfers

When we transfer your personal data outside Brazil, we ensure that appropriate safeguards are in place to protect your information and comply with LGPD requirements. This may include:

Ensuring the receiving country provides an adequate level of data protection
Using standard contractual clauses
Obtaining specific consent for the transfer
Other legally permitted mechanisms under LGPD

Additional Disclosures for Australian Privacy Act Compliance (AU)

International Transfers of Personal Information

Where the disclosure of your personal information is solely subject to Australian privacy laws, you acknowledge that some third parties may not be regulated by the Privacy Act and the Australian Privacy Principles in the Privacy Act. You acknowledge that if any such third party engages in any act or practice that contravenes the Australian Privacy Principles, it would not be accountable under the Privacy Act, and you will not be able to seek redress under the Privacy Act.

Additional Disclosures for General Data Protection Regulation (GDPR) Compliance (EU)

Data Controller / Data Processor

The GDPR distinguishes between organisations that process personal information for their own purposes (known as "data controllers") and organisations that process personal information on behalf of other organisations (known as "data processors"). We, Ginza, located at the address provided in our Contact Us section, are a Data Controller with respect to the personal information you provide to us.

Legal Bases for Processing Your Personal Information

We will only collect and use your personal information when we have a legal right to do so. In which case, we will collect and use your personal information lawfully, fairly, and in a transparent manner. If we seek your consent to process your personal information, and you are under 16 years of age, we will seek your parent or legal guardian's consent to process your personal information for that specific purpose.

Our lawful bases depend on the services you use and how you use them. This means we only collect and use your information on the following grounds:

Consent From You

Where you give us consent to collect and use your personal information for a specific purpose. You may withdraw your consent at any time using the facilities we provide; however this will not affect any use of your information that has already taken place. When you contact us, you may consent to your name and email address being used so we can respond to your enquiry. While you may request that we delete your contact details at any time, we cannot recall any email we have already sent. If you have any further enquiries about how to withdraw your consent, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

Performance of a Contract or Transaction

Where you have entered into a contract or transaction with us, or in order to take preparatory steps prior to our entering into a contract or transaction with you. For example, if you contact us with an enquiry, we may require personal information such as your name and contact details in order to respond.

Our Legitimate Interests

Where we assess it is necessary for our legitimate interests, such as for us to provide, operate, improve and communicate our services. We consider our legitimate interests to include research and development, understanding our audience, marketing and promoting our services, measures taken to operate our services efficiently, marketing analysis, and measures taken to protect our legal rights and interests.

Compliance with Law

In some cases, we may have a legal obligation to use or keep your personal information. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further enquiries about how we retain personal information in order to comply with the law, please feel free to enquire using the details provided in the Contact Us section of this privacy policy.

International Transfers Outside of the European Economic Area (EEA)

We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Your Rights and Controlling Your Personal Information

Restrict: You have the right to request that we restrict the processing of your personal information if (i) you are concerned about the accuracy of your personal information; (ii) you believe your personal information has been unlawfully processed; (iii) you need us to maintain the personal information solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

Objecting to processing: You have the right to object to processing of your personal information that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights, and freedoms, in order to proceed with the processing of your personal information.

Data portability: You may have the right to request a copy of the personal information we hold about you. Where possible, we will provide this information in JSON format or other easily readable machine format. You may also have the right to request that we transfer this personal information to a third party.

Deletion: You can delete all personal information we hold about you at any time in your Account Settings. Please be aware that search engines and similar third parties may still retain copies of your personal information that has been made public at least once, like certain profile information and public comments, even after you have deleted the information from our services or deactivated your account.

Additional Disclosures for California Compliance (US)

California Notice of Collection

In the past 12 months, we have collected the following categories of personal information enumerated in the California Consumer Privacy Act:

Identifiers, such as name, email address, account name, IP address, and an ID or number assigned to your account.
Audio or visual data, such as photos or videos you share with us or post on the service.
Customer records, such as billing and shipping address, and credit or debit card data.
Any other personal information you share with us or post on the service.

For more information on information we collect, including the sources we receive information from, review the "Information We Collect" section. We collect and use these categories of personal information for the business purposes described in the "Collection and Use of Information" section, including to provide and manage our Service.

Lawful Use of Our Platform and Services

Users are prohibited from engaging in unlawful activities on Ginza's platform, including but not limited to the promotion of violence, bullying, harassment, discrimination, religion, faith, paedophilia, xenophobia, terrorism, or the distribution of any and all illegal materials such as copyrighted, trademarked, otherwise protected or illegal content. Ginza complies with relevant laws and cooperates with authorities to prevent and address such activities.

1. Prohibited Content or Activities:

Users are prohibited from uploading, sharing, or posting content that:

Promotes or incites violence, terrorism, or unlawful activities.
Includes hate speech, harassment, or defamation.
Contains sexually explicit, obscene, or illegal materials.
Violates intellectual property rights or privacy laws.

2. Compliance with Laws:

The platform complies with applicable laws and cooperates with law enforcement to prevent activities such as:

Money laundering.
Terrorist financing or planning.
Distribution of illegal content.

Ginza reserves the right to report any suspicious activity or content to relevant authorities.

3. Monitoring and Enforcement:

Ginza may, at its discretion, monitor user-generated content and take action (e.g., removal or account suspension) against content or accounts that violate these restrictions.

4. User Responsibilities:

Users are responsible for ensuring their content complies with the platform's policies and applicable laws. Violations may result in account termination or legal action.

5. Jurisdiction-Specific Compliance:

Ginza adheres to jurisdiction-specific laws such as the General Data Protection Regulation (GDPR), the General Personal Data Protection Law (Brazil), and applicable anti-terrorism or cybersecurity regulations.

All users agree to this policy by creating an account with us and using the platform/service.

Contact Us

For any questions or concerns regarding your privacy, you may contact us using the following details:

Kraftwire Inc./Ltd.

E-mail: support@ginza.app

85 Great Portland Street,
First Floor
London
England
W1W 7LT
UK

CEO: Daniel Agoston