Last Updated: 06.04.18
Effective June 4, 2018
1.Information Collected or Received from You. Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services.
(b) PAI, Voice, Camera and Authentication. If you create a PAI, we will collect and store your image, a video recording of you, your voice, a scan of your facial features, your government issued identification in order to verify your identity, and any information you provide to us in order to personalize your PAI. When you voluntarily record your voice, we collect such voice input, recording, related activity and the choices you make in the Services. We’ll access your recorder and audio files only with your consent. We also allow you to create an avatar, and in so doing, we collect the selfie images, related activity and the choices you make in using the Services. Images from your device’s camera and photos are provided voluntarily by you, and we will access your camera and photos only with your consent. If you choose to authenticate your PAI, then we will collect and share your identity information with other users.
(c) Transaction Details. If you make a transaction using the Service, we record the status of the transaction, information about the recipients, your memo (which is not visible to third parties), amount, and additional technical details. We also store the PAIcoin transaction ID that can be used as proof that a payment was made.
(d) Information Collected From Blogs, Newsletters & Posts. We may offer publicly accessible pages, blogs, private messages, or community forums (“Forums”). You should be aware that, when you disclose information about yourself in these Forums, our Site and/or third party sites will collect the information you provide in such submissions, including any personal information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
(e) Automatic Data Collection Including Information Collected Using Cookies and other Web Technologies. Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons (defined below) to collect certain information through our Services or other methods of analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences.
(ii) “Web Beacons” (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages, in an advertisement or in an e-mail.
(iii) “Log Data” means certain information about how a person uses our Services, including both Account holders and non-Account holders. Log Data may include information such as your Internet Protocol (IP) address, browser type, operating system, the web page that you were visiting before accessing our Services, the pages or features of our Services browsed and the time spent on those pages or features, search terms, the links on our Services that were clicked on and other statistics. We use Log Data to administer the Services, and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to your needs and preferences. We may use your IP address to generate aggregate, non-identifying information about how our Services are used.
(iv) Our uses of such these technologies fall into the following general categories:
• Advertising or Targeting Related. We may use first party or third party Cookies and Web Beacons to deliver content, including ads relevant to your interests, on our Sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to change your preferences and/or opt out of the technologies we employ on our Site(s), Services, Apps, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits or by visiting the third party links listed below.
(f) Location Information. When you use our Services, we may collect and store information about your location by converting your IP address into a rough geo-location or by accessing your device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your device.
(g)Information from Other Sources. We may receive information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our Services through a third party application, such as an App Store or SNS, we may collect information about you from that third party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and Services.
2. How We Use Your Information
We acquire, hold, use, and process personal information about you for a variety of business purposes, including:
(a) To Provide Products, Services, or Information Requested. We may use information about you to fulfill requests for Services, including information about potential or future Services, including to: generally manage your information and Accounts; respond to questions, comments, and other requests; provide access to certain areas, functionalities, and features of our Services; contact you to answer requests for customer support or technical support; and allow you to register for events. We will also use the information about you to personalize our Services by, among other things, customizing the content; enhancing the safety and security of our products and services; verifying your identity and preventing fraud or other unauthorized or illegal activity.
(b) For Administrative Purposes. We may use personal information about you for its administrative purposes, including to: measure interest in our Services; develop new products and Services; ensure internal quality control; verify Individual identity; communicate about your Accounts and activities on our Services and systems, and, at our discretion, changes to any of our policies; send email to the email address you provide to us to verify your Account and for informational and operational purposes, such as Account management, customer service, or system maintenance; process payment for products or Services purchased; process applications and transactions; prevent potentially prohibited or illegal activities; and enforce our Terms of Service.
(c) To Market Our Services. We may use personal information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, facsimile, messaging services through the Service or your device or email, as permitted by applicable law. Such uses include: to tailor content, advertisements, and offers; to notify you about offers, products, and services that may be of interest to you; to provide Services to you and our sponsors; for other purposes disclosed at the time you provide information; or otherwise with your consent. You may contact us at any time to opt out of the use of your personal information for marketing purposes, as further described below.
(d)For Research and Development. We may use personal information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, we may perform research (online and offline). We may engage third party service providers to conduct research on our behalf. We may also conduct surveys from time to time. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products and Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If you participate in a survey, the information given will be used along with that of other study participants. We may share de-identified individual and aggregate data for business, research and analysis purposes.
(e) For Direct Mail, Email and Outbound Telemarketing. You may receive periodic emails, newsletters, mailings, or phone calls from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to you by following the instructions in below.
(g) For De-Identified and Aggregated Information Use. We may use personal information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. De-identified or aggregated information is not personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within we and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
(h)For Sharing Content with Friends or Colleagues. Our Services may offer various tools and functionalities. You may be able to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services.
(i)For Other Uses. We may use personal information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide personal information or with your consent.
3.Information that We Share with Third Parties. We will not share any information that we have collected from or regarding you except as described below:
(a) Information Shared with Our Service Providers. We may engage third party service providers to work with us to administer and provide the Services. These third party service providers, which include other users who will be authenticating your PAI, have access to your information only for the purpose of performing Services on our behalf. We may also share your information with our marketing service providers to help us better market our products provide and Services to you. These marketing service providers may use your information only for the purpose of helping us to relevant products and Services information to you.
(b) Information Shared with other Third Parties. We may share de-identified or aggregated data we collect from the use of the Services, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Services, market trends and other analysis that we create based on the information we receive from you and other users.
(c) Information Shared with Analytics and Other Service Providers.
(i) Google. We use Google Analytics and Fabric Analytics, a service provided by Google, Inc. (“Google”), to gather information about how users engage with our Site and Services. For more information, please visit https://answers.io/img/onepager/privacy.pdf and www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to https://tools.google.com/dlpage/gaoptout.
(d)Information Disclosed in Connection with Business Transactions. Information that we collect from our users, including per sonal information, is considered to be a business asset. Thus, 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 information, may be disclosed or transferred to a third party acquirer in connection with the transaction.
(e) 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 may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
4.Third Party Websites, Social Media Platforms, and Software Development Kits
(b) Blogs and Forums. Our Services may include or link to sites or services that offer publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets) as described above. If you already use these platforms, their technologies and cookies may be set on your device when using our Site or other Services. You should be aware that personal information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the personal information provided by you may be viewed and used by third parties for any number of purposes.
(c)SDKs and APIs. We may use third party software development kits (“SDKs”) and APIs as part of the functionality of our Services. Third party SDKs may allow third parties including advertisers to collect your personal information to provide content that is more relevant to you.
5.Third Party Payment Processing. You may acquire virtual items or merchandise through our Services. When you make purchases through the Services, we may process your payments through a virtual currency exchange or a third party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”) and social networking sites such as Facebook. The third party application may collect certain financial information from you to process a payment on our behalf, including your name, email address, address and other billing information.
7.Your Choices. We offer you choices regarding the collection, use and sharing of your information. Please note that if you decide not to provide us with the information that we request, you may not be able to access all of the features of the Services.
(b) Opt-out of Cookies and Ad Tracking. You can opt out of the collection and use of your information for ad targeting by going to http://www.aboutads.info/choices or http://www.youronlinechoices.eu/ to limit collection through the Site or by configuring the settings on your mobile device to limit ad tracking through the App. As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. To be clear, these cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings. Further information about your options can be found here: http://www.networkadvertising.org/mobile-choice.
(c) Modifying or Deleting Your Information. The Services offer the ability to modify or delete your information in the following ways: (i) logging into your Account and updating your address and contact information and (ii) deleting your Account.
8.Responding to Do Not Track Signals. Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.
10.The Security of Your Information. We take reasonable administrative, technical and physical measures designed to protect the information that we collect from or about you from unauthorized access, use or disclosure. When you enter information on our forms, we encrypt this data using SSL or other technologies. We offer a variety of security techniques including a PIN, a paper key and biometric authorization (e.g., fingerprint, Face ID or touch ID) depending on your device. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
11.International Transfer. You agree that all information, including personal information, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. You agree that all personal information collected via or by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your personal information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to us, you explicitly consent to the storage of your personal information in these locations.
12.Our Policy Toward Children. Our Services are not directed to children, and we do not knowingly collect information from children. If we learn that we have collected information from a child under 13 (or 16 in some jurisdictions), we will take steps to delete such information from our files as soon as possible.