Effective Date: April 4th, 2019
Information We Collect About You
We collect Personal Information and Other Information about Users in connection with the Services. For the purposes of this Policy, “Personal Information” is information that we can directly associate with a specific person without additional information, such as an email address. “Other Information” is any information we collect that is not Personal Information.
We may combine Personal Information with Other Information, in which case we will treat the combined information as Personal Information. We also may combine information that we have about you with additional information that we or third parties collect in other contexts—such as our communications with you via email or your customer service records. In those circumstances, we will treat the combined information in accordance with this Policy.
Information About Registrants
If you register through the Services, we may collect the following Personal Information about you:
- First name
- Last name
- Email address
- Postal address
- Phone number
In addition, we may collect messages you send to us through our messaging features.
Information About All Users (including Registrants)
We may collect Other Information about Users automatically through the Services. This may include information such as your IP address or domain name, your Internet service provider, the date and time of your visit, your use of the Services during your current session or over time (including the pages you view and the files you download), the URLs from the websites you visit before or after navigating to the Services, your computer’s operating system and browser type, your software or hardware attributes (such as device IDs, device OS or device type), search keyword or search engine, your general geographic location (e.g., your city, state or metropolitan region), or precise, real-time location data pertaining to your mobile device. We collect such information using the following technologies:
- Server Logs. When you use the Services, we automatically receive and record certain information from your computer (or other device) and your browser. To obtain such information, we may use server logs or applications thatrecognize your computer and gather information about its online activity.
- Pixel tags. The Services or the emails that you receive from us may use an application known as a “pixel tag” (also known as a “clear gif” or “web beacon”). A pixel tag is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include Personal Information. For example, it allows an email sender to determine whether a user has opened a particular email.
- Collaboration with Third Party Data Collectors. We may partner with certain third parties to collect, analyze or use some of the information described above. For example, we may allow third parties to set cookies or use pixel tags or other tracking mechanisms (such as tags or scripts) on the Services or in email communications from us, or we may allow third parties to use an application software development kit (SDK) or a server-to-server connection to collect information, including device identifiers such as IDFA and Advertising ID. The information collected by third parties using these technologies may be used for a variety of purposes, including analytics, as described in the “Third Party Analytics” section below.
In addition, we may offer the ability to refer others to our Services. If you use this feature, we may ask you for information needed to send the referral, such as a relevant name and email address. We will automatically send that person an email stating that you referred them to us. We may, from time to time, continue to send messages to that person as a reminder of your invitation. By providing such names and email addresses, you represent that you have the authority to do so.
How We Use Your Information
Information About Registrants. If you register through the Services, we use your information to:
- Provide the Services to you, administer your account, fulfill the terms of any agreement you have with us or respond to your requests.
- Send you administrative communications related to the Services, including communications about current or upcoming features.
- Send you marketing communications, in a manner consistent with your marketing preferences and applicable laws. If you wish to opt out of receiving promotional emails at any time, please click the “unsubscribe” link at the bottom of the email. Please note that if you unsubscribe from promotional emails, you will continue to receive non-promotional administrative emails with information relevant to your account and the operation of the Services.
Information About All Users. For all Users, we use your information to:
- Count and recognize Users of the Services, analyze how Users use the Services or understand our Users’ demographics and other information.
- Improve our existing products and services or create new products and services.
- Personalize your experience on the Services.
- Engage in analytics as described in the “Third Party Analytics” section below.
- Comply with legal or regulatory requirements or protect our rights and interests.
How We Share Your Information
We may share your information with the following third parties:
- Third party service providers. We use third party service providers to help us provide, manage and improve the Services. These service providers may collect or use your information to assist us in achieving the purposes discussed in this Policy.
- Business partners. We also may share your information with our business partners to fulfill your requests for services; complete a transaction that you initiate; or meet the terms of any agreement that you have with us or our business partners.
- Affiliates. We may share information with our corporate affiliates for the purposes described in this Policy.
- Analytics. We may share your information with third parties to research and analyze our Users and to seek to broaden our User base, or to better understand use of our Services.
- Legal purposes. We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation such as a judicial or governmental subpoena or warrant; (ii) protect and defend the rights or property of any person or entity; (iii) act in urgent circumstances to investigate or protect the personal safety of users of the Services or the public; or (iv) protect against legal liability, prevent suspected fraud or establish, protect or exercise our legal rights.
- Financing, business transfers and similar transactions. As we develop our business, we might sell or buy businesses or assets. In the event of a sale, merger, reorganization, dissolution or similar event relating to all or a portion of our business or assets, your information may be part of the transferred assets. We also may share information to facilitate the potential or actual financing, securitization, insuring, merger, acquisition, sale, assignment, bankruptcy or other disposal of all or part of our business or assets.
- De-identified or aggregated information. We may also share de-identified or aggregated information about Users, such as by publishing a report on trends in the usage of the Services or sharing aggregated information about historical survey matching results.
Third Party Analytics
We may partner with certain third parties to collect the information discussed above and to engage in analytics, auditing, research and reporting. These third parties may use web logs, pixel tags or other technologies and they may set and access cookies on your computer or other device. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Services may not operate correctly.
In addition, the Services use Google Analytics to help collect and analyze certain information for the purposes discussed above.
“Do Not Track”
Like many other websites, our website does not respond to “do not track” browser headers.
Third Party Links, Websites, Apps and Communication Technologies
The Services may contain links to and from the websites or apps of other third parties. If you follow a link to any of these websites or apps, please note that these websites and apps and any services that may be accessible through them, have their own privacy policies. A link to any third party site does not imply that we endorse or accept any responsibility for the content or use of such site. We encourage our users to be aware when they leave the Services and to read the privacy policies applicable to such third party websites and apps. This Policy applies solely to information collected through the Services.
We use commercially reasonable physical, electronic and procedural safeguards to protect your information against loss or unauthorized access, use, modification or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your Personal Information or Other Information.
To the extent permitted by applicable law, we retain information for as long as reasonably necessary to deliver our Services to you, or to fulfill the purposes described in this Policy or as required by law. For example, we may retain your information for as long as you maintain your Pulsa account once we enable an account with the Services.
Your Choices and Access to Information
You have the right and ability to edit your Pulsa account information on our Services at any time by logging into and updating your account. You may access, amend or request deletion of certain information to the extent permitted under applicable law. To make such requests or inquire about such rights, please send us an email at email@example.com. For your protection, we may only implement requests with respect to the information associated with the particular email address you use to send us your request and we may need to verify your identity before implementing your request. We will attempt to comply with any reasonable requests for accessing, amending or deleting your information.
You may opt out of our sharing of your information as follows:
- Social Media Marketing Materials Opt Out – If you would like to opt out of receiving advertisements from us through social media platforms and similar services based on your email address, please send an email with the subject line “Unsubscribe from direct social media ads” that includes your name and contact information to firstname.lastname@example.org.
- Google Analytics Opt Out – To opt out of Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.
We do not knowingly collect information from children under the age of 13 and do not target our Services to children under 13. If you are under 13, please do not use the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this prohibition. If you have reason to believe that a child under the age of 13 has provided information to us, please contact us, and we will endeavor to delete that information from our databases.
Information for California Residents
If you are a California resident, you have a right to request certain information with respect to the types of information we have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. All requests for such information must be sent to email@example.com. This same California law permits us to provide you, in response to your written request, with a cost-free means to choose not to have your certain information shared rather than providing the above described information. To that end, you may request that we do not disclose certain of your information to unaffiliated third parties for their own direct marketing purposes by contacting us by email at firstname.lastname@example.org.
If you are a California resident under 18 years of age and a registered user of our Services, you may request that we remove content and information that you post on our Services. To obtain removal of such content and information, please send us an email at email@example.com with a short description of the content or information you would like to have removed. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
Information for Users Outside the United States
The information that we collect through the Services is transferred to and processed in the United States for the purposes described in this Policy. We may also subcontract the processing of such information to, or otherwise share information with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using our Services or accepting our Policy, you expressly consent to such transfer and processing.
You may have the right, in accordance with applicable data protection laws: to request access to, rectification of or erasure of your information; to seek restrictions on the processing of your information; to object to certain processing of your information; and to exercise a right of data portability.
Where any processing of information is solely dependent upon your consent, such as marketing to you, you have the right to withdraw such consent at any time.
Where you believe that we have not processed your information in accordance with the applicable data protection laws, you may lodge a complaint with the respective supervisory authority or data protection regulator.
The provision of information by you will be for contractual, marketing or analytical purposes as referred to above. If we do not have access to such information from you, then we will not be able to undertake the above types of services for you.
We may withhold information where the search for that information would require disproportionate effort or have a disproportionate effect due to, for example, the cost of providing the information, the time it would take to retrieve the information or how difficult it may be to obtain the information requested.
To inquire about or exercise your rights in accordance with applicable law, please contact us at firstname.lastname@example.org.
Pulsa may change the Services in the future and as a consequence may need to revise this Policy to reflect those changes. We will post the revised Policy on the website with an “effective date” that indicates when the revised Policy will take effect. We encourage you to review this page periodically.
Questions or Comments
607 Market St # 2
San Francisco, CA 94105