Shortly

PRIVACY POLICY OF THE SHORTLY project (the "Shortly")

Revised as of April 11th, 2025

WHY DO WE HAVE THIS POLICY?

This Privacy Policy explains how GAMEGEARS LTD ("we," "us," "our"), as the publisher of the Shortly Website, collects, uses, and protects your personal data. We prioritize your privacy and follow applicable data protection laws, such as the GDPR (in the EU) and the CCPA (in the US). Where local laws grant you additional rights, we endeavor to respect them.

This Policy covers:

  • What information we collect;
  • How and why we process that data;
  • With whom we share it;
  • How long we retain it;
  • Your rights and how to exercise them;
  • How you can delete your account and data;
  • How we safeguard your data.

WHO ARE WE?

GAMEGEARS LTD is located at 55 Griva Digeni, 3101 Limassol, Cyprus. All data processing is conducted solely by GAMEGEARS LTD or our authorized service providers. The Shortly App is intended for users aged 18 and above. If you are under 18, please do not use the App. For privacy inquiries or account deletion, email support@gamegears.com.

Shortly is a digital multimedia product fully developed, owned, and operated by GAMEGEARS LTD, a company incorporated under the laws of the Republic of Cyprus, with its registered office at 55 Griva Digeni, 3101, Limassol, Cyprus.

The Shortly project includes a web interface, supporting tools, visual content, audiovisual assets, text materials, user interface components, and any other functional or content-related elements made available through the website located at https://shortly.show

All intellectual property rights, including exclusive proprietary rights in and to the Shortly product and its contents, are held solely by GAMEGEARS LTD and are protected under applicable copyright and intellectual property laws.

WHAT DATA DO WE COLLECT AND WHY?

We define personal data as any information identifying you directly or indirectly. Shortly is primarily a short-video viewing app with no user-generated uploads. We enable likes and sharing, but not direct messaging.

Below is an overview of data we collect and the legal bases for processing:

AI-Driven Recommendations

We may use AI-based algorithms to analyze your watch behavior and session data, in order to personalize short-video recommendations. Such models process usage patterns (likes, watch time) to surface more relevant content. They do not store or permanently link your personal identifiers beyond what is needed for recommendation logic.

LEGAL BASES FOR PROCESSING

Performance of a Contract: e.g., providing your account, handling subscriptions.

Legitimate Interests: e.g., analyzing engagement, ensuring security.

Consent: e.g., personalized ads in the EU, marketing emails.

Legal Obligations: e.g., record retention for tax or fraud prevention.

HOW WE SHARE YOUR DATA

We do not sell personal data. However, we may share limited data with:

Service Providers: hosting, analytics, advertising, payment gateways, crash reporting, form services (e.g., Formspree). We ensure data processing agreements are in place.

Legal Authorities: if required by law or to protect rights, safety, and property.

International Transfers: your data may be transferred outside your country; if you are in the EU/EEA, we rely on Standard Contractual Clauses or other GDPR-compliant safeguards.

A (non-exhaustive) list of third-party processors or categories of partners is available upon request. We periodically review these partnerships to ensure compliance.

COOKIES & TRACKING TECHNOLOGIES

For more details on the types of cookies we use, retention periods, and how to manage them, please refer to our Cookie Policy.

Although Shortly is primarily a mobile app, we and our partners may use tracking technologies (e.g., advertising IDs, SDK-based analytics). These help us:

Provide relevant advertising (subject to your consent in some regions);

Perform usage analytics to improve features;

Diagnose technical issues.

If you wish to opt out of personalized ads, you can adjust your device's "Limit Ad Tracking" or equivalent privacy settings. For further details, see your OS documentation.

DATA RETENTION

We keep personal data only as long as needed for the stated purposes or as required by law. Once data is no longer necessary, we securely delete or anonymize it. Aggregated, non-identifiable information may be retained for analytics.

YOUR RIGHTS AND REQUESTS

Depending on your jurisdiction (GDPR in the EU, CCPA in California, etc.), you may:

Access/Port: Request a copy of your data.

Rectify: Correct inaccuracies.

Delete: Erase your account/data.

Object/Restrict: Limit certain processing.

Withdraw Consent: For marketing or ad personalization.

Opt-Out (for US states with relevant privacy laws): e.g., CCPA right to opt out of "sales" of data.

To exercise these rights, email support@gamegears.com with a subject like "Privacy Request." We may require additional info to verify identity. We aim to respond within 30 days (extendable to 60 if complex). If unsatisfied, you can lodge a complaint with a local data protection authority.

HOW TO DELETE YOUR ACCOUNT

You can delete your account (and associated data) by:

Using the in-app "Delete Account" option in Settings;

Emailing support@gamegears.com from the address linked to your account.

After verification, we will remove or anonymize personal data within ~30 days, except where we must retain records to meet legal obligations.

SECURITY MEASURES & DATA BREACH

We employ industry-standard encryption, secure hosting, access controls, and anti-fraud monitoring to protect your data. No system is 100% secure, so we encourage strong passwords and mindful device security. If a data breach or security incident occurs, we will promptly investigate, mitigate, and notify affected users and relevant authorities as legally required.

CHILDREN'S PRIVACY

Shortly is not intended for individuals under 18. We do not knowingly collect personal data from minors. If you learn that a child has used the App, contact us at support@gamegears.com so we can promptly delete relevant data.

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. If we make a material change (e.g., new categories of personal data, new sharing practices), we will notify users in the App or by other means. The "Revised as of" date at the top indicates the most recent version. Continuing to use the App after a new version is posted signifies your acceptance.

CONTACT US

GAMEGEARS LTD
55 Griva Digeni, 3101 Limassol, Cyprus
Email: support@gamegears.com

If you have any questions about this Policy or your data, reach out to us.

FAITHFULLY YOURS,
GAMEGEARS LTD

Shortly

2025, Shortly

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