Introduction to this Policy.
This Policy shall be supplemented by our Terms and Conditions of Use, and any other guidelines, terms and policies made available by us from time to time, all incorporated herein by reference.
Scope of this Policy.
This Policy is applicable to the information collected through your use of our platform, our downloadable mobile application software, websites, services and products, as applicable. As used herein and elsewhere, the words “collect”, “use”, “process”, “treat”, “ disclose” and analogous shall be related to personally identifiable information (the “PI”) and other data that we may collect from our users and/or visitors, including cookies inside a computer and mobile device IDs.
By registering with us or otherwise using our products and services, you thereto consent to the collection, transfer, processing, storage, disclosure and other uses of your PI as described in this Policy.
Information You Provide to Us.
When you sign up for any of our account options, you will need to provide your name, surname, age, ethnicity, email address, gender, geo-location and phone number, among other information.
Here at Go Polly, we work hard to earn and keep your trust; and therefore we adhere to the following principles in order to protect your privacy: (i) we will not sell or lease your PI to third parties; (ii) we will not disclose your PI with other users or third parties without your consent; (ii) any PI that you provide to Go Polly will be secured with industry standard safety protocols and technology.
Use of Information Collected by Go Polly.
We use your information to provide and improve our services and products. By making a sale or a purchase via Go Polly, you thereby consent and direct us to share your PI information in this manner. By storing your PI on our secure servers, we are able to shorten your login process and allow you to modify your personal profile online.
We will generally collect, use and disclose your PI to:
· Provide, operate, maintain, improve, and promote our platform and our products and services.
· Verify your e-mail address; send password retrieval links and other account notices.
· Improve your user experience and provide you with personalized support
· Develop, research, process, safeguard and improve our services.
· Answer to comments, questions, and requests you submit to us.
· Offer promotions, newsletters, sweepstakes entries and rewards, send service related announcements and contact you about inquiries for our products and services.
· Investigate and prevent fraudulent transactions, unauthorized access to our services, and other suspicious activities.
· Monitor and analyze trends, usage, and activities in connection with our products and services and for marketing or advertising purposes.
If you do not wish to disclose any or part of your PI to us, you may still be able to use some of the functionalities of our products and services, though we will not be able to guarantee that you will be able to enjoy them at their fullest if you elect not to disclose it to us. Overall, your final remedies will be to close this web tab, delete your account with us and/or exit our app.
Information We May Collect if You Use Our Technology and Services.
We may also collect non-personally identifiable information with third parties, such as aggregate user statistics, analytics, demographic information, and web site usage information. We will not share PI with third parties for marketing purposes without your permission. With your consent, these third parties may offer promotions (including email promotions) or sell items or services to you through our services.
For some of our partners, this information will be shared automatically. For other third parties, such as our affiliates, this information will only be shared with your explicit permission or if you choose to share it via your account or mobile device’s settings.
Financial Information Collected.
Information Collected from Mobile Devices.
When you access our platform via a mobile device, we will use your mobile device ID (i.e. the unique identifier assigned to a mobile device by the manufacturer) and/or Advertising ID (for Apple iOS 6 and later) instead of cookies in order to recognize you, track the number of relevant ads displayed, their performance and display.
The Go Polly platform includes various location-based features used to provide our services, and will be used to collect, use and share precise location data from your mobile device (including its reported real-time geographic location) and also to calculate your position within a determined area called a geo-fence. This information will be used to provide location-based notifications, check-ins, local search, social networking and other functionalities. For some third-party partners, such as Google, this information will be shared automatically. For others, such as and Facebook, this information will only be shared with your explicit permission or if you choose to share it via your mobile device’s settings.
Sharing your Information.
Go Polly may offer the functionality of using your third-party credentials (e.g. Microsoft, Slack, Google or Facebook) to execute single-sign-on, and in that manner we will also collect your PI as provided to us by such third-party platforms; such as your account data, text, archives, photos, bookmarks, info of your contacts and their common contacts, login data and profile information such as “about me”, “friend lists” and “interests”.
You may also have the option of posting your activities on our services and other content to social media networks when you access content through our platform. For example, you may post to Facebook or Twitter that you used our services.
We will not collect more information when using such credentials beyond the PI such third parties generally disclose to us via their services. For more information, please refer to the terms and policies of such platforms.
As our user, you will generally be able to control and select the amount and type of PI you may disclose to us. We continuously try to improve our user experience, and strive to provide you the best choices for the disclosure, edition or removal of the PI being processed by us. Accordingly, we will undertake the open and transparent management of your PI and will: (i) inform you about how your personal information may be used and disclosed (including overseas); (ii) maintain the safety and integrity of your personal information; and/or (iii) enforce your individual right to access and correct your personal information.
We will retain your PI only for as long as it is reasonably necessary for our business purposes (e.g. as long as your account is active). We will also retain and use your PI for our compliance obligations, to resolve disputes among our users, and enforce our contracts with authorized third parties.
Access to Personally Identifiable Information.
In order to enforce your privacy rights, please contact us as indicated in the contact section of our websites. Your privacy request must include, at the least, the following information: (i) your complete name, address and/or e-mail address in order for us to notify you the response to your request; (ii) attached documents establishing your identity; and (iii) a clear and concise description of the PI with regard to which you seek to enforce any of your privacy rights. If you request rectification, please indicate amendments to be made and attach documentation to back up your request.
Upon receipt of your privacy request, and after due review, we may then edit, deactivate and/or delete your PI from our products and services. Please take into account that we may not be able to delete all of your data from our secure databases or the databases of third parties to which your PI has already been disclosed. If that is the case, please contact such third parties directly in order to request enforcement of your privacy rights. In case of secure databases under our control where deletion is impossible, we will make such information inaccessible.
Security of Information.
We use industry standard protocols and technology to protect your registered user information and PI, such as Secure Socket Layer (SSL) technology and secure databases. Your PI is only accessible by a limited number of our employees who have special access rights. Overall, we implement and maintain reasonable security measures to protect our databases and records from unauthorized access, acquisition, destruction, use, modification or disclosure. Notwithstanding the foregoing, please take into account that the Internet and related transmissions are not secure or error free communication means.
Additionally, if you post information on a public forum, message board, blog or bulletin board, any PI you elect to disclose therein there may or will be read, collected and/or used by other users of such forums and could be used by third parties to send you unsolicited messages.
Lawful Disclosure of Information .
· If required under applicable law, rules or regulations.
· In response to a valid request or subpoena from a government or law enforcement agency.
· To defend ourselves and our affiliates, licensors, officers, agents and representatives from legal claims and processes brought to us by third parties (including takedown notices).
· To defend the property, rights and integrity of any of our users, advertisers or licensors.
· To stop or cause to cease any actions that we may consider to cause –whether allegedly or factually– a contingency or liability.
Newsletters and Commercial Messages.
From time to time, we will ask you for express permission and consent to receive Commercial Electronic Messages (‘CEM’). A CEM is a message in an electronic format (e.g. email, SMS, push notifications and other form of communications) which is then sent to an electronic address (e.g. email, mobile device) and that contains a message asking recipients to participate in commercial activities (e.g. purchase of products, services and invitations to participate in user research).
Our optional email newsletters are considered CEMs, and therefore you may subscribe or unsubscribe from them at will, usually on your account settings, or by following the unsubscribe links contained therein.
Cookies & Web Beacons.
From time to time, we may place the so-called ‘cookies’ in your computer in order to track and collect data regarding your use of our products and services. Cookies are small text files that our services transfer to you and that allow us permit us to recognize you and obtain data such as the environment in which our products are operating, OS type and version.
We also use the so-called ‘beacons’, which are small files, sometimes only a pixel in size, embedded onto the pages of our websites. Beacons are used to identify each of our pages in order to be analyzed by our system tools.
We may also collect and use the data contained in log files, which may include your IP (internet protocol) address, your ISP (internet service provider), the browser you used to visit our platform, the time you visited our platform and which sections you visited.
We do not currently offer “do-not-track” or similar mechanisms.
Participating Third-Party Service Providers .
Our platform and our services may display hyperlinks to the websites of our commercial partners and other third parties. If you click on such links, you are choosing to visit such websites, and will be redirected there.
Please take into consideration that we are not responsible for the privacy and personal data practices undertook by such third parties (including any tools, cookies, information or content contained thereunto), and that we do not have control over the manner in which such third-parties may collect, process, treat or use your PI.
When you use such links to go to another website, our Policy and Terms are no longer into effect and your browsing thereof is in your own and final risk. In addition, any banner or ad that we may have on our platform does not constitute any endorsement of any third-party thereof.
Advertising , Opt-out Choice .
From time to time, we may use Google Analytics, Ad Words, Double Click and/or Ad Sense tracking codes, and other third-party software tools (such as remarketing codes) in order to collect information and marketing analytics about the manner in which you browse our platform and services.
The served ads will be targeted based on your previous browsing history, and may include retargeting codes. For example, third-party vendors may show you Go Polly’s ads on certain websites across the Internet, even after you leave our platform. The collected information is anonymized, meaning it cannot be tracked back to individuals. Using such tools, we learn how to optimize, and serve ads based on a user’s past visits, providing you with a better user experience.
You can learn more about how to opt-out by browsing Google’s opting-out and privacy pages located at www.google.com, or the Network Advertising Initiative website located at www.networkadvertising.org.
Your PI may be accessed by us or our affiliates, agents, partners, advertisers or third-party service providers in Cyprus, United Kingdom and other regions. Henceforth, and you hereby consent to such access and transfer by simple disclosure. If you are accessing our platform, products and services from other regions, you ought to know that you are thereby transferring your PI to such regions and, thus, you hereby consent to such transfer.
Upon the case where Go Polly specifically undertakes the process of personal data that has been duly disclosed by you to us, and that is subject to national legislation that implements the EU Data Protection Directive (95/46/EC), by clicking the "I Accept" button or otherwise accepting the terms and conditions of our services through a clickable action or similar action, you hereby acknowledge, agree and accept to such transfer.
California Online Privacy Protection Act
In compliance with CalOPPA, we have hereby posted this conspicuous Policy to the public, indicating the PI being collected and the manner in which it may be disclosed and with whom. Accordingly, our users can may visit our platform using anonymous browsing, read this Policy linked from our home page, with the link including the word ‘Privacy’ or similar. We also comply with Policy changes notification to our users, and provide mechanisms that allow our users to manage their PI personal information.
Through the simple use of the platform and our products and services, you hereby represent and warrant that you are at least eighteen (18) years of age --or older-- as of the date of first access thereof. If you are still a minor (which may depend on the jurisdiction where you reside), you cannot access our products and services, even under the direct supervision of your parent or legal guardian. Go Polly does not knowingly collect any kind of information from persons under the age of thirteen (13). If we learn or have reason to suspect that any user is under the age of thirteen (13), we will delete any PI under that user’s account.
We reserve the right to amend, change, suspend and/or update our platform, our products, our services, this Policy and/or our Terms, in whole or in part, from time to time and at our sole and final discretion. Your continued use thereof after the last effective date of modifications thereof indicates your acceptance of such modifications. We will post any updates on our platform, and may also send you an email or otherwise notify you of any material changes to this Policy.
From time to time, this Policy may be translated into other languages for your convenience. The English language version of each of these documents shall be the version that prevails and governs your use of our app, website and our products and services. Upon the case of any conflict between the English language version and any translated version, the English language version will prevail.
How to Contact Us.
Date of last effective update is 2017.