Privacy Policy

This Privacy Policy applies to the landing page (the "Landing Page") operated by:

4GOO Holding GmbH Landauer Str. 56, 67346 Speyer, Germany ("Company", "we", "us", or "our")

For privacy-related enquiries, please contact us at: [email protected]

This Landing Page is a pre-launch subscription page. Its sole purpose is to allow interested users to submit their email address to receive early access invitations, beta updates, and launch announcements for the 4GOO social network application currently under development.

This Privacy Policy applies only to personal data collected through this Landing Page. It does not govern data collected through the 4GOO social network application itself, which will be subject to a separate, comprehensive Privacy Policy published within the application upon its launch.

A. Data you provide directly. When you submit the subscription form on our Landing Page, we may collect:

Email address — Required — To send beta access invitations and product announcements.

We do not collect sensitive personal data (as defined under GDPR Art. 9), payment information, or any data beyond what is listed above through this Landing Page.

B. Technical data collected automatically. When you visit our Landing Page, our hosting infrastructure may automatically log basic technical information required to serve and secure the page, including:

• IP address
• Browser type and version
• Operating system
• Date and time of visit
• Referring URL

This data is used solely for security, fraud prevention, and operational purposes. It is not used for profiling or marketing. We do not currently use cookies, analytics tools, or tracking technologies on this Landing Page. If we introduce such technologies in the future, this Privacy Policy will be updated accordingly and, where required by law, your consent will be obtained before any such technologies are activated.

We process your personal data on the following legal bases under the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679):

Sending beta invitations and product news to subscribers — Art. 6(1)(a) GDPR — Consent. You freely provide your email address and affirmatively tick a consent checkbox before submitting the form.

Sending marketing and launch communications — Art. 6(1)(a) GDPR — Consent. Consent is obtained at the point of subscription.

Technical site operation, fraud prevention, security logging — Art. 6(1)(f) GDPR — Legitimate Interests. We have a legitimate interest in keeping our Landing Page secure and operational.

Compliance with legal obligations (e.g. record-keeping of consent) — Art. 6(1)(c) GDPR — Legal Obligation.

Withdrawal of Consent. You may withdraw your consent at any time with no adverse consequences, by:

• Clicking the "Unsubscribe" link in any email we send you; or
• Sending an email to [email protected] with the subject line "Unsubscribe."

Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

We use the data collected through the Landing Page exclusively for:

1. Beta Access Communications — to notify you when early or beta access to the 4GOO application becomes available.

2. Product Updates — to inform you of significant milestones, launch dates, and feature previews.

3. Marketing Communications — to send relevant announcements about the 4GOO platform, where you have given consent.

4. Security and Operations — to protect the Landing Page against abuse, fraud, and technical failures, using technical log data.

5. Legal Compliance — to maintain records of consent as required under applicable data protection law.

We will not use your email address for any purpose other than those listed above without seeking fresh consent.

Subscription data (email, name) — Until you withdraw consent (unsubscribe), or a maximum of 24 months from the date of subscription if no further interaction occurs — whichever comes first.

Consent records — 5 years from the date of consent, to demonstrate compliance with applicable law.

Technical/server security logs — 90 days, after which they are automatically deleted or anonymised.

Upon withdrawal of consent, your subscription data will be deleted within 30 days, subject to our obligation to retain consent records.

We do not sell, rent, or otherwise transfer your personal data to third parties for their own marketing purposes.

We may share your data with the following categories of trusted third-party processors, solely to operate the Landing Page and manage our communications:

• Email service providers — to deliver subscription confirmation and announcement emails.
• Web hosting and CDN providers (e.g. Cloudflare CDN, AWS) — to host and deliver the Landing Page securely.
• Legal advisors and regulatory authorities — if required to comply with applicable law, respond to a legal process, or protect our legal rights.

All third-party processors are bound by appropriate data processing agreements (DPAs) and are required to process personal data only in accordance with our documented instructions and applicable law.

A current list of our sub-processors is available upon request at [email protected].

4GOO Holding GmbH is incorporated in Germany and operates within the European Union. Some of our third-party service providers may process data in countries outside the European Economic Area (EEA). Where such transfers occur, we ensure an adequate level of protection by relying on:

• EU Standard Contractual Clauses (SCCs) as adopted by the European Commission (Decision 2021/914/EU); and/or
• The EU-U.S. Data Privacy Framework (where applicable); and/or
• An adequacy decision of the European Commission covering the recipient country.

You may obtain further information about transfer safeguards by contacting [email protected].

EEA, UK, and Swiss residents have the following rights under the GDPR and applicable national law:

• Right of Access (Art. 15 GDPR) — to receive a copy of the personal data we hold about you.
• Right to Rectification (Art. 16 GDPR) — to have inaccurate or incomplete data corrected.
• Right to Erasure / "Right to be Forgotten" (Art. 17 GDPR) — to request deletion of your data, subject to retention obligations.
• Right to Restriction of Processing (Art. 18 GDPR) — to restrict how we process your data in certain circumstances.
• Right to Data Portability (Art. 20 GDPR) — to receive your data in a structured, machine-readable format.
• Right to Object (Art. 21 GDPR) — to object to processing based on legitimate interests.
• Right to Withdraw Consent (Art. 7(3) GDPR) — to withdraw your consent at any time without affecting the lawfulness of prior processing.

California residents have additional rights under the CCPA/CPRA, including the right to know, delete, correct, and opt-out of the sale or sharing of personal information. We do not sell or share personal information as defined under the CCPA.

UK residents have equivalent rights under the UK GDPR and the Data Protection Act 2018.

Brazilian residents have equivalent rights under the LGPD (Lei nº 13.709/2018).

Canadian residents have rights under PIPEDA or applicable provincial privacy legislation.

To exercise any of the above rights, please submit a written request to [email protected]. We will respond within the timeframe required by applicable law (typically 30 days for GDPR requests).

You also have the right to lodge a complaint with your relevant supervisory authority:

• EU / Germany: Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) — www.bfdi.bund.de
• Spain: Agencia Española de Protección de Datos (AEPD) — www.aepd.es
• UK: Information Commissioner's Office (ICO) — www.ico.org.uk

Our Landing Page is not directed to children under the age of 16. We do not knowingly collect personal data from persons under 16. If you become aware that a child has submitted personal data to us without verifiable parental consent, please contact [email protected] and we will take immediate steps to delete that data.

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, or alteration. These include:

• TLS/HTTPS encryption for all data in transit;
• Access controls limiting who within our organisation can access subscriber data;
• Regular review of security practices and vendor compliance.

No method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

Our Landing Page may contain links to third-party websites (e.g. App Store, Google Play). We are not responsible for the privacy practices of those third parties and encourage you to review their respective privacy policies before providing any personal data to them.

We will update this Privacy Policy to reflect any changes in our practices, including the future introduction of analytics or tracking technologies. When we do, we will update the "Updated" date at the top of this document. Where changes are material — such as the introduction of cookies or new data uses — we will provide a prominent notice on the Landing Page before such changes take effect, and obtain any necessary consents.

4GOO Holding GmbH
Landauer Str. 56,
67346 Speyer, Germany
[email protected]