This Privacy Policy provides a comprehensive description of how Gilgamesh, Inc. (“Gilgamesh,” “we”, “us” or “our”) collects, uses, and shares information about you, and what rights and choices you have regarding such information. It applies to the Service as well as any offline location that makes this Privacy Policy available to you. The term “Service” refers to the following:
Gilgamesh provides branded app experiences and technology services for E-Learning facilities (collectively, “E-Learning facility customers”). As further described in the “Information Collected from E-Learning Facility Customers” section below, information provided to Gilgamesh by our E-Learning facility customers is governed by the terms of our agreements with those customers, and not this Privacy Policy. However, if you create an Gilgamesh Account, Gilgamesh may associate the information provided by our E-Learning facility customers with your Gilgamesh Account, and our processing of that information is subject to this Privacy Policy.
By using the Service, you agree to our Terms and consent to the collection, use, and sharing of information in accordance with this Privacy Policy. If you do not agree and consent, discontinue use of the Service.
If you have any questions, please contact us as set out in the “Contact Us” section below. If you are a data subject in the EEA, the collection of your personal data through the Service is governed by our EEA Privacy Policy
Information Collected through the Sites, Apps, and Equipment
We collect information you provide to us when you use the Sites, Apps, and Equipment, such as when you register an Gilgamesh Account, sign up for a subscription, subscribe to or read our emails, enter a promotion or competition we sponsor, apply for a job, or otherwise interact with us. Certain of this information may identify you personally (whether alone or in combination).
The categories of information we collect include:
In addition, we automatically collect information when you use the Sites, Apps, and Equipment. The categories of information we automatically collect include:
The tracking technologies we use to automatically collect information include:
For further information on tracking technologies and your rights and choices regarding them, please see the “Other Parties” “Analytics and Advertising,” and “Your Rights and Choices” sections below.
Information Collected from E-Learning Facility Students and Teachers
Gilgamesh provides branded app experiences and technology services for E-Learning facility customers. As part of our provision of services to E-Learning facilities, these customers may directly provide Gilgamesh with information about you. For example, a Gilgamesh to which you belong may share with us your contact data, Gilgamesh membership ID and barcode, photo, training data, and physical characteristics with us as necessary for us to provide services to them. Similarly, trainers employed by E-Learning facility customers may provide data about you through the Gilgamesh trainer app we offer to E-Learning facility customers.
Our processing of information provided by our E-Learning facility customers and their trainers is governed by the terms of our agreements with those customers, and not this Privacy Policy. However, if you create an Gilgamesh Account, Gilgamesh may associate the information provided by our E-Learning facility customers with your Gilgamesh Account, and our processing of that information is subject to this Privacy Policy. Further, any information collected directly through our Sites, Apps, or Equipment is subject to this Privacy Policy, as discussed above. Also, we may automatically collect service use data, device data and imprecise location data about trainer use of the Gilgamesh trainer app, and such processing is subject to this Privacy Policy.
Where we act as a service provider for our E-Learning facility customers, our customers, and not us, determine what information is shared with us. If you wish to not have your information shared by a E-Learning facility customer, please contact the E-Learning facility customer directly. We are not responsible for any customer data practices, and you should carefully review the applicable customer’s policies.
We collect and use information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information include:
Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see the “Your Rights and Choices” section below.
We share information about you in accordance with the practices described in this Privacy Policy. The types of parties with whom we share information include:
Notwithstanding the above, we may share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the “Your Rights and Choices” section below.
If you have an Gilgamesh Account, you may be able to share certain information about your account activity with other Service users. For example, you may be able to share your name, photo, activity points, Gilgamesh ranking, ranking and progress in challenges, when and what workout you completed, and overview of workouts, such as calories burned and miles ran. You may also be able to comment on other user workouts.
You should think carefully about what information you choose to disclose – Gilgamesh is not responsible for the conduct of other users with whom you decide to share your information and those users may choose to make that information public. You may change your settings at any time through your Gilgamesh Account settings as further set out in “Your Rights and Choices” below.
The Service may, from time to time, contain content and tracking technologies from and links to external sites, locations, platforms, or services operated by other parties. In addition, we may offer parts of our Service through sites, locations, platforms, or services operated by third parties. For example, we may offer our content through social media. Any information you provide to us when you engage with our content (such as through our brand page) is treated in accordance with this Privacy Policy. Also, if you publicly reference our Service on social media (e.g., by using a hashtag associated with Gilgamesh in a tweet or post), we may use your reference on or in connection with our Service.
Please note that when you interact with other parties, including when you leave our Service or link your third party E-Learning tracker, wearable or device to your Gilgamesh Account or our App, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
We use analytics services, such as Google Analytics, to help evaluate usage of our Sites and Apps, and improve our services, content, performance, advertising, and user experiences. In addition, we work with agencies, advertisers, ad networks, and other technology services, such as Facebook and Google, to place ads about our products and services on other websites and services.
As part of this process, we may incorporate tracking technologies from us and other parties into our own Sites and Apps (including our emails) as well as into our ads displayed on other websites and services. These tracking technologies may collect data across time and services for purposes of measuring conversions or actions you take, associating the various devices you use, and serving ads and/or other content targeted to your interests (“Interest-based Advertising”). For instance, we incorporate pixels and SDKs from Facebook and Google in the Sites and Apps, and may share information with them for these purposes as well as to provide you with other functionality.
As indicated above, these parties may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
Gilgamesh Account
You may access, update, and remove certain information that you have voluntarily submitted to us through your Gilgamesh Account through your account settings or by emailing us at [email protected] . We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Most web browsers automatically accept cookies, but if you prefer, you may be able to edit your browser settings to block them in the future. If you use multiple browsers on your device, you will need to instruct each browser separately. Your ability to limit cookies is subject to your browser settings and limitations.
Currently, unless and until the law is interpreted to require us to do so, our systems do not monitor or take action with respect to browser “Do-Not-Track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the “Analytics and Advertising Choices” section below.
With respect to our Apps, you can stop all collection of information via an App by uninstalling the App. You may also turn off location-based functions through the location settings on your device. You can also reset your device Ad Id at any time through your device settings, which is designed to allow you to limit the use of information collected about you.
We have security measures in place designed to safeguard information about you against loss, destruction, misuse, or unauthorized access or disclosure. For example, we periodically review our internal security measures and policies, and implement measures designed to restrict unauthorized personnel from accessing information about you. Nevertheless, you should bear in mind that transmission of information over the internet is never entirely secure, and we cannot guarantee the security of information about you.
The information we collect pursuant to this Privacy Policy is governed by U.S. law. Information collected about you may be transferred to and processed in the U.S. and other jurisdictions, including the EEA. These jurisdictions may have data protection laws different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Privacy Policy. If your information is collected in the EEA, the United Kingdom, or Switzerland, we will transfer your information subject to appropriate safeguards, such as Standard Contractual.
Gilgamesh has applied to participate in the EU-U.S. Privacy Shield Framework and Swiss U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from the EEA, the United Kingdom, and Switzerland. Gilgamesh has certified or will certify to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability. For purposes of this section, Gilgamesh refers to the following U.S. legal entities: Gilgamesh, Inc.
In accordance with our obligations under Privacy Shield, and subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission, we hereby affirm our commitment to subject to the Privacy Shield Principles all personal data transferred from the EEA, the United Kingdom, and Switzerland in reliance on the Privacy Shield. This means that, in addition to our other obligations under the Privacy Shield Principles, we shall be liable to you for any third party agent to which we transfer your personal data in reliance on Privacy Shield and that processes such personal data in a manner that violates the Privacy Shield Principles, unless we can demonstrate that we are not responsible for the resulting damages.
You have the right to ask us not to disclose your personal data to a third party (except where the third party is acting as an agent to perform tasks on our behalf and under our instruction) or purposes materially different than for which the personal data was originally collected or subsequently authorized by you.
We reserve the right to change this Privacy Policy from time to time. Any changes will be effective immediately upon posting of the revised Privacy Policy on the Service. Your continued use of our Service indicates your consent to the Privacy Policy then posted. If the changes are material, we may provide you additional notice, to your email address.
If you have any questions or comments about this Privacy Policy or our data practices, or wish to exercise your rights, please contact us:
By email: [email protected]
By mail:
Gilgamesh, Inc.
Attention: Privacy Compliance
Viglen House Business Centre,
Alperton Ln, Wembley, London HA0 1HD
United Kingdom
This Privacy Policy has been designed to be accessible to people with disabilities. If you experience any difficulties accessing the information here, please contact us [email protected]
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