Privacy Policy

This Privacy Policy explains how Angelo Gonsalves, an individual based in Qatar, trading as The Grey Gym ("The Grey Gym," "we," "us," or "our"), collects, uses, stores, shares, and protects personal information when you use:

• The Grey Gym website;

• the TGG SHRM Study App;

• Coach TGG;

• Studylitics;

• our subscription, trial, email, and customer-support services; and

• any related services that link to this Privacy Policy.
  The Grey Gym provides SHRM exam-preparation products and services to users internationally, with the United States as its primary market.
  The Grey Gym is an independent exam-preparation provider. It is not affiliated with, endorsed by, or sponsored by the Society for Human Resource Management, commonly known as SHRM. SHRM, SHRM-CP, SHRM-SCP, and related names and marks belong to their respective owners.
  By using our website, app, or services, you acknowledge the practices described in this Privacy Policy.

1. Information We Collect

Information You Provide

We may collect information that you provide directly, including:

• your name;

• your email address;

• your password or authentication credentials, which are handled through our authentication provider;

• your selected or expected exam date;

• your account settings and preferences;

• your marketing communication preferences;

• your cookie preferences;

• information included in customer-support requests or other communications with us; and

• any other information you voluntarily provide.
  We do not currently request your country, precise location, or phone number during normal account registration. We may update our data-collection practices if additional features are introduced, and this Privacy Policy will be updated where appropriate.

Quiz, Study, and Performance Information

When you use the TGG SHRM Study App, we may collect and store information necessary to operate the app and provide Studylitics, progress tracking, and personalized study guidance, including:

• quiz questions attempted;

• selected answers;

• correct and incorrect responses;

• quiz scores;

• quiz history;

• accuracy by topic or knowledge area;

• performance on situational judgment questions and knowledge questions;

• weak areas;

• time spent per question;

• difficulty patterns;

• progress trends;

• study priorities and recommendations;

• exam-readiness indicators;

• study streak information;

• exam countdown information;

• flagged or missed questions; and

• reports generated through the app.
  This information is used to provide your study history, performance analysis, recommendations, progress tracking, and other app features.

Coach TGG Information

Coach TGG allows users to request guidance while working through a question.
Messages entered into Coach TGG are processed during the current session so that Coach TGG can respond and help the user reason through the question.
Coach TGG conversations:

• are used only to support the current session;

• are not added to the user's study history;

• are not stored in the user's account; and

• are not retained in The Grey Gym's application database as conversation history.
  An artificial intelligence service provider may temporarily process message content as necessary to generate a response. Its handling of information may also be subject to its own technical and privacy practices.
  Users should not enter sensitive personal information, confidential employer information, health information, financial information, identification numbers, or other unnecessary personal data into Coach TGG.

Subscription and Payment Information

When you purchase a subscription, payments may be processed by Stripe or another third-party payment processor.
The Grey Gym does not receive or store your full payment-card number, card security code, or complete banking credentials.
We may receive and retain limited payment and subscription information, including:

• customer or transaction reference numbers;

• subscription status;

• selected plan;

• billing period;

• payment status;

• renewal status;

• cancellation status;

• transaction dates;

• partial payment-method details provided by the processor; and

• information needed for accounting, fraud prevention, customer support, or legal compliance.
  Payment processors handle payment information under their own privacy policies and security practices.

Website, Device, and Usage Information

When you visit our website or use the app, we or our service providers may automatically collect information such as:

• Internet Protocol address;

• browser type;

• device type;

• operating system;

• pages visited;

• referring pages or links;

• dates and times of visits;

• website and app interactions;

• session information;

• cookie identifiers;

• advertising identifiers;

• approximate location derived from an IP address;

• diagnostic and error information; and

• information about how users navigate and use our services.
  We may use cookies, pixels, software development kits, local storage, and similar technologies to collect this information.

2. How We Use Information

We may use personal information to:

• create, authenticate, and manage user accounts;

• verify email addresses;

• provide access to the TGG SHRM Study App;

• provide free-trial and paid-subscription access;

• administer daily question limits and other plan limits;

• deliver quizzes, mock exams, explanations, Coach TGG, Studylitics, flashcards, study resources, and other app features;

• calculate scores, progress trends, weak areas, and readiness indicators;

• maintain quiz history and study progress;

• personalize study recommendations and suggested priorities;

• process payments and manage subscriptions;

• send verification, security, password-reset, subscription, payment, service, and other operational emails;

• send marketing emails where the user has consented or where otherwise legally permitted;

• respond to support requests;

• measure website and marketing performance;

• understand how users interact with our website and app;

• improve, test, maintain, and secure our services;

• detect misuse, account sharing, fraud, payment problems, content theft, scraping, or security threats;

• enforce our Terms and Conditions;

• maintain consent, transaction, legal, security, and accounting records;

• comply with applicable legal obligations; and

• establish, exercise, or defend legal claims.

3. Legal Bases for Processing

Where applicable law requires us to identify a legal basis for processing personal information, we may rely on:

• Contract: Processing necessary to create and operate your account, provide the app, deliver purchased services, and manage subscriptions.

• Consent: Processing based on your permission, including certain marketing communications, analytics cookies, or advertising cookies.

• Legitimate interests: Processing necessary to operate, improve, protect, and understand our services, provided those interests are not overridden by your rights.

• Legal obligations: Processing necessary to comply with accounting, tax, regulatory, fraud-prevention, law-enforcement, or other legal requirements.

• Legal claims: Processing necessary to establish, exercise, or defend legal rights.
  You may withdraw consent at any time where processing is based on consent. Withdrawal does not affect processing that occurred before consent was withdrawn.

4. Authentication and Operational Emails

We may send emails necessary to operate your account or provide the service, including:

• account activation and email-verification messages;

• password-reset messages;

• security alerts;

• subscription confirmations;

• payment and renewal notices;

• cancellation confirmations;

• important service announcements;

• changes affecting your account or purchased service; and

• responses to support requests.
  These messages are transactional or operational and may still be sent when necessary even if you unsubscribe from marketing emails.

5. Marketing Communications

Where you have consented, or where otherwise permitted by applicable law, we may send marketing emails relating to The Grey Gym products, services, offers, study resources, or updates.
Marketing emails may be managed through Systeme.io or another email-service provider.
You may withdraw marketing consent or unsubscribe at any time by:

• using the unsubscribe link included in a marketing email;

• changing your communication preferences through available website or app settings; or

• contacting us at contactus@thegreygym.com.
  Unsubscribing from marketing communications will not prevent us from sending necessary authentication, subscription, payment, security, or account-related messages.

6. Cookies and Similar Technologies

We may use cookies, pixels, local storage, software development kits, and similar technologies.
These technologies may be used for:

• account authentication;

• security;

• remembering preferences;

• website functionality;

• analytics;

• performance measurement;

• error detection;

• advertising measurement;

• remarketing; and

• displaying more relevant advertising.
  Our website will provide a cookie consent tool that allows users to accept or reject nonessential analytics and advertising technologies where required.
  Essential cookies may be used without consent where they are necessary to provide requested website or account functionality.
  You may change or withdraw your cookie preferences at any time through the cookie settings available on the website or app, where provided. You may also adjust browser or device settings, although disabling some cookies may affect website or app functionality.

7. Analytics and Advertising

We may use services such as Google Analytics to understand website traffic, usage, and performance.
We may also use advertising technologies such as Meta Pixel and Google Ads tracking to:

• measure advertising effectiveness;

• understand whether users interact with our advertisements;

• create advertising audiences;

• conduct remarketing campaigns; and

• display advertisements that may be more relevant to users.
  These providers may collect information through cookies, pixels, advertising identifiers, IP addresses, browser information, device information, and website interactions.
  We do not sell personal information in exchange for money.
  However, the use of advertising cookies, pixels, or audience-matching technologies may be considered a "sale," "sharing," or use for targeted or cross-context behavioral advertising under certain privacy laws.
  Where applicable, users may:

• reject advertising cookies through the cookie consent tool;

• withdraw previously provided cookie consent;

• use available website privacy controls;

• adjust advertising preferences through the relevant advertising platform; or

• contact us to exercise a legally available opt-out right.

8. How We Share Information

We may share personal information only as reasonably necessary for the purposes described in this Privacy Policy.

Service Providers

We may share information with third-party providers that help us operate the website, app, payments, email communications, analytics, advertising, authentication, hosting, infrastructure, security, and artificial intelligence functions.
These providers may include:

• Stripe, for payment and subscription processing;

• Supabase, for authentication, user accounts, and database storage;

• Systeme.io, for marketing email management;

• Zoho Mail, for business email communications;

• Framer, for website hosting and website functionality;

• Google Analytics, for website analytics;

• Google Ads, for advertising measurement and remarketing;

• Meta, for advertising measurement and remarketing;

• an artificial intelligence provider used to operate Coach TGG; and

• hosting, infrastructure, monitoring, security, and technical-support providers used to operate the app.
  These providers may process information only to perform services for us or as otherwise described in their own privacy terms.

Legal and Safety Reasons

We may disclose information when we reasonably believe disclosure is necessary to:

• comply with applicable law, regulation, court order, subpoena, or lawful government request;

• protect the rights, property, or safety of The Grey Gym, our users, or others;

• investigate fraud, misuse, security incidents, account sharing, or unlawful activity;

• enforce our Terms and Conditions; or

• establish, exercise, or defend legal claims.

Business Transfers

If the business, website, app, or related assets are sold, transferred, reorganized, financed, or acquired, personal information may be disclosed or transferred as part of that transaction, subject to applicable law.

With Your Direction or Consent

We may share information where you instruct us to do so or provide consent.

9. Data Retention

We retain information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including providing the service, maintaining security, resolving disputes, enforcing agreements, and meeting legal, accounting, and transaction-record requirements.

Active Accounts and Subscriptions

While an account or subscription is active, we may retain account information, study history, quiz performance, Studylitics data, subscription records, settings, and related information necessary to provide the service.

After Subscription Cancellation

When a paid subscription is canceled:

• access continues until the end of the current paid billing period;

• the subscription will not renew for the following billing period; and

• quiz history, scores, weak areas, Studylitics information, and related study data may remain available or recoverable for up to 30 days after access ends.
  This retention period allows a returning user to resume their study progress.
  After the 30-day period, the related study data may be permanently deleted or anonymized, unless a longer period is necessary for legal, security, fraud-prevention, dispute-resolution, or operational reasons.

After a Free Trial Ends

Quiz history and related trial study data may be retained for up to 30 days after the free trial expires. After that period, the information may be permanently deleted or anonymized.

Account Deletion

Users may initiate account deletion:

• directly through the app, where that option is available; or

• by emailing contactus@thegreygym.com.
  When account deletion is requested, the account may first be deactivated or scheduled for deletion. Personal profile information, quiz history, Studylitics information, and related app data may remain recoverable for up to 30 days.
  After this 30-day period, the information may be permanently deleted or anonymized, subject to any information we must retain for legal, accounting, transaction, security, fraud-prevention, dispute-resolution, or enforcement purposes.
  Users who wish to restore an account during the 30-day period may contact us. Restoration may not always be technically possible.

Records Retained for Longer Periods

We may retain limited records for longer where reasonably necessary, including:

• payment and transaction records;

• subscription records;

• consent and consent-withdrawal records;

• cookie preference records;

• unsubscribe records;

• security logs;

• fraud-prevention records;

• customer-support correspondence;

• records relating to disputes or violations;

• tax and accounting records; and

• information required to comply with legal obligations.

Coach TGG Conversations

Coach TGG conversations are session-only and are not retained as conversation history in the user's account or The Grey Gym's application database.

10. Data Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, alteration, disclosure, or misuse.
These measures may include:

• third-party authentication services;

• access controls;

• secure infrastructure;

• encryption where supported;

• database-security controls;

• payment processing through established payment providers;

• monitoring and logging; and

• limiting access to information based on operational need.
  No online service or storage system can guarantee complete security. Users are responsible for maintaining the confidentiality of their passwords and should notify us promptly if they believe their account has been compromised.

11. International Processing and Transfers

The Grey Gym provides services internationally.
Personal information may be processed, stored, or accessed in countries other than the country in which the user resides. These countries may have privacy or data-protection laws that differ from those in the user's home country.
Where required by applicable law, we or our service providers may use recognized safeguards for international transfers, such as contractual protections or other lawful transfer mechanisms.
By using the service, you acknowledge that your information may be processed by The Grey Gym and its service providers in different countries, subject to applicable legal requirements.

12. Your Privacy Rights

Depending on your location and the laws that apply, you may have the right to:

• request confirmation of whether we process your personal information;

• request access to personal information we hold about you;

• request correction of inaccurate or incomplete information;

• request deletion of personal information;

• request restriction of certain processing;

• object to certain processing;

• withdraw consent where processing is based on consent;

• request a portable copy of certain information;

• opt out of certain targeted advertising or advertising-related sharing;

• opt out of marketing communications;

• change cookie preferences;

• appeal a decision relating to a privacy request where applicable;

• submit a complaint to an applicable privacy or data-protection authority; and

• receive equal service without unlawful discrimination for exercising a privacy right.
  These rights are not absolute. A request may be limited or refused where permitted by law, including where information must be retained for legal, security, accounting, fraud-prevention, contractual, or dispute-resolution purposes.
  To exercise a privacy right, email contactus@thegreygym.com.
  Please include enough information for us to identify your account and understand your request. We may request reasonable verification before completing a request.
  Authorized agents may submit requests where permitted by applicable law. We may require evidence of authorization and may need to verify the user's identity directly.
  We will respond within the period required by applicable law.

13. U.S. State Privacy Disclosures

Residents of certain U.S. states may have additional rights under applicable state privacy laws.
Depending on the law and whether its requirements apply to The Grey Gym, these rights may include:

• access;

• correction;

• deletion;

• data portability;

• information about categories of personal information collected;

• information about purposes of collection and disclosure;

• information about categories of third parties receiving information;

• opting out of the sale or sharing of personal information;

• opting out of targeted advertising;

• limiting certain uses of sensitive personal information;

• appealing a privacy-request decision; and

• protection from unlawful discrimination for exercising privacy rights.
  The Grey Gym does not sell personal information for money.
  The use of analytics, advertising pixels, audience matching, or remarketing tools may nevertheless be treated as "sharing," "sale," or targeted advertising under certain state laws. Users may reject nonessential advertising cookies or contact us to submit an applicable opt-out request.
  These rights apply only when the relevant law covers the user, the information, and The Grey Gym's activities.

14. Rights of Users in the European Economic Area, United Kingdom, or Similar Jurisdictions

Where applicable data-protection law applies, users may have rights including:

• the right to be informed;

• the right of access;

• the right to correction;

• the right to deletion;

• the right to restriction of processing;

• the right to object;

• the right to data portability;

• the right to withdraw consent;

• rights relating to certain automated decisions; and

• the right to complain to a competent supervisory authority.
  The availability and scope of these rights depend on the applicable law and circumstances of the processing.
  Studylitics scores, weak-area indicators, study priorities, and exam-readiness indicators are provided to support studying. They are not used to make employment, financial, legal, educational-admission, or similarly significant decisions about users.

15. Children and Age Restrictions

The website, app, and services are intended only for individuals who are at least 18 years old.
We do not knowingly offer the service to, or knowingly collect personal information from, individuals under 18.
If we learn that an individual under 18 has provided personal information, we may suspend or delete the account and take reasonable steps to remove the information.
A parent or legal guardian who believes that a minor has provided information may contact us at contactus@thegreygym.com.

16. Third-Party Links and Services

Our website or app may contain links to third-party websites, services, platforms, or resources.
The Grey Gym is not responsible for the privacy, security, or content practices of third parties. Users should review the privacy policies of third-party services before providing information to them.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

• changes to the website or app;

• new features or service providers;

• changes to data practices;

• changes to analytics or advertising technologies;

• legal or regulatory developments; or

• operational or security requirements.
  The updated version will be posted with a revised "Last updated" date.
  Where required by law or where changes materially affect users' rights, we may provide additional notice through the website, app, or email.
  Continued use of the service after an updated Privacy Policy takes effect is subject to applicable law.

18. Contact Us

For privacy questions, requests, concerns, account deletion, or complaints, contact:
Angelo Gonsalves, trading as The Grey Gym
Email: contactus@thegreygym.com