Effective as of: October 30, 2018

We provide a functional tracking, recording and reporting platform, designed to enable you to keep track of sandalwood tree growth. To do that, we need information about you. Protecting your privacy is really important to us. We only use your information where we have a legal basis to do so. This Privacy Policy will help you understand what information we collect, how we use it and what choices you have when you use any of TGV Planter/Grower Apps (the "Services").

Please note that in addition to the general information below, specific information about how certain of our Services use your information is provided at the end of this Privacy Policy in the "App Specific Disclosures".

You should also read our Terms of Service which set out the contract between you and The Green Venture Plantation Management Limited.

1. Who decides how your information is used?

The Green Venture Plantation Management Limited is the data controller responsible for making decisions about how we use your personal information.

2. The information we collect about you and how we use it

This Privacy Policy covers our use of any information that can or could be used to identify you ("Personal Data"). It does not cover information which cannot be used to identify you ("Anonymous Data").

We need to collect and use certain Personal Data to provide the Services to you and fulfil the promises we make to you in the Terms of Service:

• When you sign up for our Services you give us Personal Data voluntarily by providing it to us, for example when you sign up for an account. We collect and use that information in order to authenticate you when you register an account and use the Services, to make sure you are eligible and able to receive the Services, and so that you receive the correct version of the Services. That information includes the username you choose to use on our Services, and internal account IDs that we assign to your account.


• You must have an account with a supported third party single sign-on service to use our Services. As such, the Personal Data we collect also depends on which third party accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access TGV Planter/Grower Apps.


• We collect and use your device location information as you use our Services (and, if you elect to turn on background location tracking for our Services, while you are not directly interacting with the Services), including how you move around. Our Services include location based tracking system whose core feature is to provide a navigation to sandalwood tree, so we need to know where you are to operate these functions for you. We identify your location using a variety of technologies, including GPS, the WiFi points you are accessing the Service through and mobile/cell tower triangulation.


• We further use the information above in order to provide technical and customer support to you.

We collect information about your location in the Services, which we use to provide you with the Services, including features which are meant to personalize your experience. The information we collect may include:

• Detailed location, travel and route information. Location and route information is collected for example in the form of GPS signals (combined with a time-stamp) and other information sent by your mobile device on which TGV Planter/Grower app is installed and activated. This location and route information is saved to a route history of all of the journeys you have made while using the apps. The types of location data we collect depends in part on your device and account settings. For example, depending on your selected device settings and/or your account settings we may collect information about your location and travel (or lack thereof) also while you are not using the app, in order to be able to tell you the information about your sandalwood tree including its health, growth, location, and more;

In addition, we have and rely on a legitimate interest in using your Personal Data as follows:

• Using your IP address, browser type, operating system, the web page you were visiting before accessing our Services, the pages of our Services which you browsed or the features you used, and the time spent on those pages or features, the links on our Services that you click on, device identifiers, as well as actions you take to understand who is using our Services and how.


• Using your contact information, namely your email address in order to communicate with you to provide technical and customer support.


• Using your internal account ID in order to attribute to your account any user content (such as sandalwood tree location) that you elect to submit to The Green Venture Plantation Management Limited through the Services.


• Using your email address and device information in order to share updates and news about the Services with you by email. You can unsubscribe from these at any time in your device settings or in-app settings.


• To carry out relevant measures and to ensure that you and other users are complying with our Terms of Service.


• To make legal or regulatory disclosures.

We will only use your Personal Data to do the following if we have your consent:

• If you elect to turn on background location tracking in our Services we will collect your Personal Data as you use the Services as well as in the background when you do not have the Services open on your device. You can change your mind and turn off background location tracking at any time in your device settings or in-app settings.


• Send you marketing materials by email or via in-app notifications. You can unsubscribe from these at any time in your device settings or in-app settings.


• We also rely on your consent where we use cookies or similar technologies. Insofar as cookies collect Personal Data, we will process it only based on your explicit consent, in anonymized form, or under a pseudonym.

3. Who we share information with

We will not share any Personal Data that we have collected from or regarding you except as described below:

Information Shared with Our Services Providers. We engage third party service providers to work with us to administer and provide the Services. As part of that they will process your Personal Data on our behalf. These third party service providers have access to your Personal Data only for the purpose of performing services on our behalf, in compliance with this Privacy Policy, and we make sure each one is contractually obliged not to disclose or use your Personal Data for any other purpose. The service providers we use help us to:

• run, operate and maintain our mobile apps through third party platform and software tools;


• perform content moderation and crash analytics;


• run email and mobile messaging campaigns;


• perform marketing analytics;


• provide technical and customer support.

Information Shared with Third Parties. We share Anonymous Data with third parties for industry and market analysis. We may share Personal Data with our third-party publishing partners for their direct marketing purposes only if we have your express permission. We do not share Personal Data with any other third parties for their direct marketing purposes.

Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We only share information about you to government or law enforcement officials or private parties when we reasonably believe necessary or appropriate: (a) to respond to claims, legal process (including subpoenas and warrants); (b) to protect our property, rights, and safety and the property, rights, and safety of a third party or the public in general; and (c) to investigate and stop any activity that we consider illegal, unethical, or legally actionable.

Information Disclosed in Connection with Business Transactions.Information that we collect from our users, including Personal Data, is a business asset. If we are acquired by a third party as a result of a transaction such as a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Data, will be disclosed or transferred to a third party acquirer in connection with the transaction.

4. How your Personal Data is transferred

The Green Venture Plantation Management Limited operates its Services across the globe. Your Personal Data will very likely be transferred and stored in a country outside of your home country for the purposes outlined in this Privacy Policy. The data protection laws in these countries may not be the same as in your home country.

5. How we keep your Personal Data safe

We have appropriate security measures in place to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, improperly altered or disclosed. We also limit access to your Personal Data to employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. How long we will keep your Personal Data