Effective Date: 09.10.2025]
Issued by: Five Abricos Limited (Gramplys)
Legal address: Unit 1102, 11/F, 29 Austin Road, Tsim Sha Tsui, Kowloon, Hong Kong
Contact: support@gramplys.com

1. IntroductionThis Privacy Policy ("Policy") explains how Five Abricos Limited ("Company", "we", "our", "Gramplys") collects, uses, processes, and protects your personal data when you purchase, use, or interact with our Products, Services, and websites.
 By using our Services or submitting information, you agree to this Policy. If you do not agree, please discontinue use of Gramplys Services.

2. ScopeThis Policy applies to:
●       all websites, applications, and connected devices under the Gramplys brand;


●       users, customers, and visitors ("you");


●       both personal and anonymized data processed by us.


It does not apply to third-party services (e.g., Google, Apple, PayPal, Stripe, or other integrations) that have their own privacy terms.

3. Information We CollectWe may collect the following categories of information:
(a) Personal Information
●       Name, email address, phone number, postal address;


●       Account credentials and billing details;


●       Device identifiers and subscription information.


(b) Technical and Usage Data
●       IP address, device model, operating system, browser type;


●       Log files, diagnostic and performance data;


●       Usage statistics, crash reports, and event analytics.


(c) Device and Sensor Data
●       Images, video, audio, motion, and environmental sensor data captured by Gramplys devices;


●       Metadata (e.g., timestamps, device IDs, detection events).


(d) Communication Data
●       Messages and support tickets sent to us;


●       Feedback, surveys, or reviews.


We do not collect sensitive data (such as biometrics, political opinions, or health information) unless required for safety or legal compliance.

4. How We Use Your InformationWe process collected data to:
●       provide, operate, and improve our Services;


●       authenticate accounts and manage subscriptions;


●       deliver notifications, fall alerts, and other functionality;


●       provide customer support and technical assistance;


●       ensure device security and fraud prevention;


●       comply with legal or regulatory obligations.


We may also use anonymized and aggregated data to improve algorithms, train AI models, and enhance product quality.

5. Legal Bases for Processing (GDPR)If you reside in the European Economic Area (EEA), we rely on the following lawful bases under the GDPR:
●       Contract performance: to deliver Products or Services you purchased.


●       Legitimate interest: to improve functionality, detect fraud, and maintain security.


●       Consent: for marketing or optional data collection.


●       Legal obligation: to comply with tax or regulatory requirements.



6. Data Storage and RetentionWe store personal and sensor data on secure servers located in Hong Kong, the EU, and the United States.
 Data is retained only as long as necessary for the purpose it was collected, unless longer storage is required by law or to protect legitimate business interests.
After your account is closed or subscription ends, we may anonymize or delete data following our internal retention schedule.

7. Data Sharing and International TransfersWe may share limited data with trusted third parties for service provision, including:
●       hosting providers (e.g., AWS, Google Cloud);


●       payment processors (e.g., Stripe, PayPal);


●       analytics and technical support vendors.


All third parties act under confidentiality and data-protection agreements.
 Your information may be transferred and processed outside your country of residence, including in Hong Kong, the EU, and the United States.
By using our Services, you consent to such transfers and understand that data protection standards may differ from those in your jurisdiction.

8. Data SecurityWe use industry-standard safeguards including encryption, authentication, and access controls.
 However, no system is 100% secure, and we cannot guarantee absolute protection against unauthorized access, hacking, or data loss.
 You are responsible for keeping your login credentials secure and immediately notifying us of any suspected compromise.

9. Your RightsDepending on your jurisdiction, you may have the right to:
●       access, correct, or delete your personal data;


●       request a copy of your data (portability);


●       withdraw consent to processing;


●       object to automated decision-making or profiling.


Requests can be submitted to support@gramplys.com, and we will respond within 30 days where required by law.

10. Data Concerning ChildrenGramplys Services are intended for users aged 18 or older.
 We do not knowingly collect or store personal data from minors.
 If we become aware that information from a minor was collected, we will delete it promptly.

11. Third-Party Services and LinksOur websites and apps may include links or integrations with third-party platforms (e.g., Google, Apple, Facebook).
 We are not responsible for the privacy practices or content of such third parties.
 You should review their respective privacy policies before use.

12. Cookies and AnalyticsWe use cookies, web beacons, and similar technologies to enhance functionality, analyze usage, and improve user experience.
 You can adjust cookie preferences in your browser settings. Disabling cookies may affect certain features of the Services.

13. Data Requests and DeletionTo exercise your rights, email support@gramplys.com with subject "Data Request."
 Verification of identity may be required.
 We reserve the right to refuse requests that are excessive, repetitive, or legally exempt.

14. Data Breach NotificationIn case of a data breach that may affect your rights or personal data, we will notify you and relevant authorities within 72 hours as required by applicable law.

15. Policy Updates and AmendmentsFive Abricos Limited reserves the right to modify or update this Privacy Policy at any time, at its sole discretion.
 Any changes become effective:
●       thirty (30) days after publication on https://gramplys.com/privacy, or


●       immediately, if required by law, regulation, or a platform partner.


Your continued use of Gramplys Products or Services after updates take effect constitutes acceptance of the revised Policy.
You are responsible for reviewing this Policy periodically for changes.