PonyPal (also referred to as “we,” “our,” “us”) has one goal: Help people stay connected with friends and family, on their terms– at their speed.
What Information Do We Gather?
What Do We Do With the Information We Collect?
Who Can Use the Information We Collect and How?
How Do We Protect the Personal Information We Collect?
How Do You Opt-out of Personal Information Sharing with Our Business Partners?
How Do You Correct and Update Your Personal Information?
What Happens When You Link to a Third-Party Web Site?
What Happens If We Sell Our Business?
Your California Privacy Rights
What If You Have Questions?
1. What Information Do We Gather?
When you visit our Website, App and Portal (“Site”), we may gather the information necessary to identify your needs and to provide you with better service.Through your use of the site or registration as a new user, we may request personal information including, but not limited to:
·Identifiers: A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
·Personal Information: A name, address, telephone number.
·Protected Classification Information: Age, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions),
·Commercial Information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
·Internet Activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
·Geolocation Data: Your physical location or movement.
·Other information relevant to customer surveys and offers
·If you become a registered user or if you conduct transactions through this website, we will collect information about the transactions you engage in while on the website and your other activity on the site. This information may include, without limitation, areas of the website that you visit, transaction type, content that you view, download or submit, transaction amount, payment, and billing information as well as the nature, quantity and price of the goods or services you exchange and the individuals or entities with whom you communicate or transact business.
Some of this information, including name, company and contact information, will only be collected if you voluntarily provide it during the user registration process. We may also track information such as the domain name and the name of the web page from which you entered our Site, and how much time you spend on each of our pages.We collect information that is combined with other web visitors’ information, such as how many times visitors click on each web page and the methods by which our Site was found.We may collect IP addresses and website usage information from you when you visit our Site via the use of “cookies."An IP address is a number that is assigned to your computer when you are using your browser on the Internet.
2. What Do We Do With the Personal Information We Collect?
You will be asked to provide personal information in certain fields on this Site that allow you to be able to use our Services.The personal information we collect is used only for the purpose we state at the time of collection or for purposes contained below.For example, our uses may include, but are not limited to, the following:
·To process transactions. PonyPal uses personal information such as name, physical address, telephone number, email address, and company/institution to engage in interactions with you, including contacting you about your transactions with the site.
·To provide support or other services. PonyPal may use your personal information to provide you with support or other services that you have ordered or requested. PonyPal may also use your personal information to respond directly to your requests for information, including registrations for newsletters, webinars, or other specific requests, or pass your contact information to the appropriate PonyPal distributor or reseller for further follow-up related to your interests.
·To personalize services or provide information based on your needs and respond to your requests. PonyPal may use your personal information to provide you with notices of new product releases and service developments.
·To select content, improve quality, and facilitate use of the websites. PonyPal may use your personal information, including the information gathered as a result of site navigation and electronic protocols and cookies (including third-party cookies), to help create and personalize website content, improve website quality, track marketing campaign responsiveness, evaluate page response rates, conduct usability testing, and facilitate your use of the websites (for example, to facilitate navigation and the login process, avoid duplicate data entry, enhance security, keep track of shopping cart additions, and preserve order information between sessions).
·To serve personalized advertising to you. We don’t share your information with advertisers without your consent.
·To assess usage of PonyPal products and services. PonyPal may track your usage of PonyPal products and services to determine your level of usage, and those usage statistics may be made available to PonyPal’s content licensors and your company/institution.
·To communicate with you about events. We may communicate with you about events hosted or co-sponsored by PonyPal or one of our business associates. This may include information about the event’s content, event logistics, payment, updates, and additional information related to the event. Information you provide when registering for or participating in a conference managed or co-sponsored by parties, other than or in addition to PonyPal may be shared with those parties, and the treatment of such information is further subject to the privacy policies of those parties. PonyPal and its conference co-sponsors may contact you after the event about the event, subsequent iterations of the event and related events. Please note that PonyPal event organizers, co-sponsors, exhibitors, and other third parties may directly request your personal information at their conference booths or presentations. Providing your information to them is optional, and you should review their privacy policies to address your particular needs and concerns about how they will treat your personal information.
·To update you on relevant PonyPal benefits, programs, and opportunities. PonyPal may communicate with you regarding relevant PonyPal benefits, programs, and opportunities available to you.
·To engage with third parties. PonyPal may share your personal data with third parties in connection with services that these individuals or entities perform for or with PonyPal. These third parties are restricted from using this data in any way other than to provide services for PonyPal or for the collaboration in which they and PonyPal are contractually engaged (for example, hosting an PonyPal database or engaging in data processing on PonyPal’s behalf, or mailing you information that you requested). These third parties are carefully selected by PonyPal and obligated to keep your data secure. From time to time, we may also share your information with third parties whom we think might provide content, products, or services of interest to you.
·To get feedback or input from you. In order to deliver products and services of most interest to our customers, from time to time, we may ask members, customers, volunteers, and website visitors to provide us input and feedback (for example through surveys, usability studies, focus groups).
·To protect PonyPal information assets as well as your own personal data. The PonyPal Information Security Program protects the confidentiality, integrity, and availability of PonyPal information assets by following a risk management approach based on policies, standards, guidelines, and procedures to meet security objectives while supporting business and operational goals.
·To assist in Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of PonyPal’s assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, PonyPal will comply with such restrictions.
To the extent that we collect certain demographic information about you, we may use this information in our market research, but we will do so only after we “anonymize” the data, i.e., remove information that would confirm your identity.We will not use your personally identifiable information, however, to send commercial or marketing messages to you unless we have your continued consent for which you will have the ability to opt out by sending an email to email@example.com
This Site does not collect personally identifiable information when you browse the Site and request pages from our servers unless you voluntarily and knowingly provide such information to us.This means that we will not know your name, your email address, or any other personally identifiable information just because you browse the Site unless you:
access the Site from a link in an email that we have sent to you;
have created a profile and you either log-in to your account or choose to be remembered via your cookie or your web-enabled mobile device.
In these cases we will know who you are based on the information you previously supplied to us.When you request a page from our Site, our servers log the information provided in the HTTP request header including the IP number, the time of the request, the URL of your request and other information that is provided in the HTTP header.We collect the HTTP request header information in order to make our Site function correctly and provide you the functionality that you expect to see.We also use this information to personalize content presented to you, better understand how visitors use our Site and how we can better tune it, its contents, and functionality to meet your needs. We only use your personally identifiable information for those activities listed at the time you submit your information to us.For example, if you provide us with an email to inform you of special events, then that is what we will use your email address to do.If we would like to use your personally identifiable information for an unrelated activity, we will first request your consent to do so.
3. Who Can Use the Information We Collect and How?
We may provide your information to third parties, or third parties may collect information from you on our behalf if we have contracted with that third party to provide some part of the information or service that you have requested.Other than those who act on our behalf and except as explained in this Policy, information you provide at this Site will not be transferred to unrelated third parties, unless we have your permission to do so.However, please note that personal information provided to this Site is subject to disclosure pursuant to judicial or other government subpoenas, warrants or orders.We will only provide this information after approximately two weeks following receipt of a valid subpoena or other legal process in a civil case.
4. How Do We Protect the Personal Information We Collect?
Security of Personal Data
We are committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal data. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements.These measures include, but are not limited to, technical and organizational security policies and procedures, security controls and employee training.
Storage and Transfer of Personal Data
PonyPal also collaborates with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer your personal data within PonyPal or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal data is processed, secured, and transferred according to applicable law.
Disclosure and Sale of Personal Data
In the preceding twelve (12) months, PonyPal has not disclosed personal information for a business purpose.
In the preceding twelve (12) months, PonyPal has not sold personal information.
Retention of Personal Data
PonyPal retains personal data for as long as necessary to provide the services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g. statute of limitations). If your personal data is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.
5. What Are Your Rights Regarding Your Personal Data?
We respect your right to access and control your personal data. You have choices about the data we collect. When you are asked to provide personal data that is not necessary for the purposes of providing you with our Sites, Products and Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features, Sites, Products, or Services.
We aim to keep all personal data that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact firstname.lastname@example.org
Access to personal data: In some jurisdictions, you have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data is required to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the applicable law.
Portability: If you reside within the European Union, you have the right to ask for a copy of your personal data and/or ask for it to be ported to another provider of your choice. Please note that such a request could be limited to the only personal data you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures.
Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via e-mail, postal mail or telephone about PonyPal products, services and events that may be of interest to you, including newsletters.
E-mail communications you receive from PonyPal will generally provide an unsubscribe link allowing you to opt-out of receiving future e-mail or to change your contact preferences. E-mail communications may also include a link to directly update and manage your marketing preferences. If You have an online account with PonyPal, You can also change your contact preferences through emailing email@example.com. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts.
6. How Do You Opt-out of Personal Information Sharing with Our Business Partners?
For more information about how targeted Network Advertising works, please visit: http://www.youradchoices.com/ or http://www.networkadvertising.org/understanding-online-advertising.
You may opt-out of third party targeted advertising or analytics in two ways: 1) By directly notifying a Network Advertising service provider via its opt-out tools (Please see above) or 2) using your browser’s Do Not Track (DNT) settings to indicate that you do not wish to receive targeted advertising based on your overall internet usage. For more information about DNT and how it works, please visit the Future of Privacy Forum’s website: http://www.allaboutdnt.com/.
We will make a good faith reasonable effort to honor your DNT browser settings for opting out of receiving targeted third party advertising based on your overall Internet usage. Please note that various browsers frequently update technology or change their settings and business practices without advance notice, and we may not have the latest information on how to honor your preferences. If you exercise either opt-out option – the cookie opt-out or the browser opt-out – you will continue to receive advertising, but such advertising may not relate to your specific interests, previous purchases or search history.
However, you cannot opt-out of our contextual analytics and advertising, which is based on your usage of only our Services. We will continue to serve you contextual advertising. We will also continue to monitor your usage and search or transaction history to provide us with analytics on how well our Services, features and activities are functioning and used. We will also share this information in an aggregated form (meaning that no one individual person can be identified) within our company.
You can also opt out of our marketing emails at any time by contacting us at firstname.lastname@example.org with subject line “OPT-OUT.”
7. How Do You Correct and Update Your Personal Information?
You can change or correct your account information at any time.Just send an email with your old information and your corrections to email@example.com with “Correction" in the subject line.
We understand the importance of protecting the privacy of all individuals, especially the very young.Our services are intended for United States audiences over the age of 13.We neither target nor sell our products to children under the age of 13, and we do not knowingly collect personal information from them.
9. What Happens When You Link to a Third-Party Web Site?
We may on occasion update our Policy.Your acceptance of any minor changes to this Policy is indicated by your continued use of our Services.If we make any material changes to our Policy, we will post a notice about the change at a prominent location on our Site.We encourage you to periodically review our Site and this Policy for any changes.
11. What Happens If We Sell Our Business?
While we do not anticipate it, every business nowadays should plan for the possibility that it might sell certain or all of its assets to another company or individual, or that it might buy certain assets of another company or individual.If all or part of the company is sold, merged or otherwise transferred to another entity, the personal information you have provided to us may be transferred as part of that transaction.However, we will take steps to ensure that your personal information is used in a manner consistent with the provisions of our Policy.
12. Your European Union Privacy Rights
Under the General Data Protection Regulation (Regulation EU 2016/679) (also known as GDPR), if you are an individual protected by the GDPR you may have certain rights as a data subject. To request information about or avail yourself of those rights, please send an email to firstname.lastname@example.org with “GDPR Request" in the subject line. In the email please describe, with specificity, the GDPR right you are requesting assistance with. Please note additional information may be requested prior to initiation of a request and that PonyPal reserves the right to charge a fee with respect to certain requests. Upon PonyPal’s completion of its review you will be notified if your request has been granted, denied, or exemptions apply.
13. Your California Privacy Rights
The California Consumer Privacy Act of 2018 (CCPA) provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that PonyPal disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
·The categories of personal information we collected about you.
·The categories of sources for the personal information we collected about you.
·Our business or commercial purpose for collecting or selling that personal information.
·The categories of third parties with whom we share that personal information.
·The specific pieces of personal information we collected about you (also called a data portability request).
·If we sold or disclosed your personal information for a business purpose, two separate lists disclosing
·sales, identifying the personal information categories that each category of recipient purchased; and
·disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that PonyPal delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
·Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
·Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
·Debug products to identify and repair errors that impair existing intended functionality.
·Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
·Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
·Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
·Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
·Comply with a legal obligation.
·Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
·Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
·Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
·Deny you goods or services.
·Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
·Provide you a different level or quality of goods or services.
·Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com
14. What If You Have Questions?
If you have questions or concerns regarding this statement, you should first contact us via email at firstname.lastname@example.org