Privacy Policy

Last Updated: January 16, 2019

Welcome to the POPin Privacy Policy. This Privacy Policy is meant to help you understand how POP Inc. and its affiliates and subsidiaries (“POPin”, “we”, “us”, “our”) collect, use, process, share and safeguard Personal Information gathered through our website (www.popinnow.com), our mobile applications, our other products and services, and via other means. In this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual.

This Privacy Policy applies when POPin is a “data controller”, which means that POPin decides why and how Personal Information is processed. POPin provides a crowdsourcing platform (the “Platform”) to companies and organizations (“Customers”), which enables Customer to invite employees or other individuals (“Platform Users”) to share information. When using the Platform, the Customer is the data controller and decides how and why Personal Information is processed. Please contact the relevant Customer if you are a Platform User and have questions about their privacy policies and practices.

We’re glad you’re taking the time to read this Privacy Policy. If after reading through this you still have additional questions, please contact us. We’re happy to help.

1. ANONYMOUS PARTICIPATION AT POPin
When participating in a POPin, you may elect not to disclose your identity to the company that organizes the POPin (our Customer). This is a key feature of POPin which we call anonymous participation. If you participate anonymously, whether answering a question, voting, or commenting, we will not share your identity with our Customer, unless required to do so by law. However, it is possible that the Customer could guess or infer that you provided a response based on the content of the response.

2. PERSONAL INFORMATION WE COLLECT
We obtain Personal Information relating to you from various sources described below. Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our products and services if that information is necessary to provide you with them or if we are legally required to collect it. The information we collect includes:

Personal Information You Provide:

- Website visitors. We may collect any Personal Information that website visitors voluntarily provide on our website. For example, we may ask you to provide your name, company, email address, phone number and job title to offer you a free trial of the Platform, to register you for webinars and events, or to enable you to download white papers and other materials.

Communications. If you contact us directly (e.g., via email, phone etc.) or fill out information on our website (e.g., to try our services for free, to ask a question via our online contact details, to create an account etc.), we collect your name, email address, phone, company, postal address, the content, date and time of your message and any attachments thereto, and other information you may directly provide to us.‍

Platform Users. Our Customers may offer you the opportunity to engage with the Platform we operate on their behalf, including via our website or mobile application. Any Personal Information relating to a Platform User that we process on behalf of a Customer (e.g. answers to questions, votes, comments, name, email address used to sign in, phone number, photograph etc.) is governed by the Customer’s privacy policy, even if you provide the information directly to us.
Business contacts. We may receive professional contact details of employees and other individuals associated with our Customers, partners, and vendors, such as first and last name, email address, phone number, title and department, and other information relevant to the particular business relationship.

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Personal Information Provided by Third Parties:

Customers and other Platform Users. If you are a Platform User, we may receive Personal Information about you from our Customers or other Platform Users. They may provide us with Personal Information about you, such as your name, email address, or phone number, so we can invite you to respond to questions. We process this Personal Information on behalf of, and as instructed by our Customers. To learn more about the processing of your Personal Information in that context, please refer to the relevant Customer’s privacy policy.
Other third parties. We may also obtain Personal Information about you from other third parties, such as business partners, marketing partners, and directory services, who may provide us with sales leads including professional contact information.
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Personal Information Collected via Automated Means:

When you visit our website, use the Platform, open our emails, or otherwise interact with our products and services, we and our third-party partners, such as analytics providers, may collect information, including Personal Information about you, by automated means, such as cookies (a small text file containing a string of alphanumeric characters), web beacons, web server logs and similar technologies.

Device information. We collect device-specific information, like your phone or computer model, device identifier, and operating system. With your permission, POPin may access and collect information from your device’s contact list and photo storage.
Log information. When you use our products and services, we automatically store some information in our server logs, including: system crashes, system activity, browser type, date and time, length of usage, details of how you interact with our products and services (e.g., how often you interact with a question), such as events or clicks, and IP address.
Analytics information. We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our products and services. We currently use Google Analytics cookies to collect and process certain website usage data. You can learn more about Google Analytics at www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
Opt out. You may be able to change browser settings to block and delete cookies. However, if you do that, you may not be able to benefit from certain features of our products and services.

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3. HOW WE USE PERSONAL INFORMATION:

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POPin uses your Personal Information for the purposes described below.

Providing our products and services. We use Personal Information to provide the Platform and related analytical reports and services, to operate our website and mobile application and to deliver other amazing products and services to you. We use Platform Users’ Personal Information to deliver the core functionality of POPin, which includes collecting and analyzing questions, answers, comments, and votes on behalf of our Customers.
Analytics and product development. We and our service providers use Personal Information, such as your interactions with our products and services, including questions, answers, comments and votes, to monitor and analyze usage of, and to improve and enhance our products and services, for example by rearranging or adding and removing features or capabilities to help you use the product.
‍‍Communicating with you. We may use your Personal Information to communicate with you for customer service or technical-support purposes, or about topics or content that we think may interest you, such as special offers, updates about the latest developments or features of our products and services. POPin may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
Tailored content. To provide you with tailored content and personalize your experience, for example by remembering your information so that you will not have to re-enter it the next time you use our products and services.
Advertising. We and our advertising partners may use your Personal Information, including your interactions with our products and services, to facilitate the delivery of advertisements.
Safety, security and compliance. We also use your Personal Information to comply with laws or to protect ourselves and others. For example, we might use Personal Information in investigating suspicious activity or violations in our Terms of Service, or to defend our legal rights.
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If you are located in the European Economic Area, we only process your Personal Information based on a valid legal ground, including when:

Consent. You have consented to the use of your Personal Information, for example to send marketing communications, or to collect information via cookies and similar technologies.
Contract. We need your Personal Information to provide you with POPin’s products and services, including for account registration or to respond to your inquiries.
Legitimate interest. We or a third party, have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for analytics and product development purposes, and otherwise to provide safety and security. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
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4. HOW WE DISCLOSE PERSONAL INFORMATION
POPin may disclose Personal Information about you in the following circumstances:

Anonymous participation. If you participate in a POPin and choose not to reveal your identity to the Customer who organized the POPin, we will not share your name, email address, or other identifiers with the Customer, unless required to do so by law. However, it is possible that the Customer could guess or infer that you provided a response based on the content of the response.
Customers. We may share Personal Information about you with our Customers when we process that information on their behalf as we provide them with the Platform and related analytical reports and services. Please refer to the Customer’s privacy policy to learn more about the disclosure of your Personal Information to other third parties.
Service providers. We engage third-party business partners to perform functions and provide services to us, like Amazon for data storage. Those business partners will be given limited access to your Personal Information as is reasonably necessary to provide us with those services.
Marketing. We do not rent, sell, or share Personal Information about you with other people or unaffiliated companies for their direct marketing purposes, unless we have your permission.
Compliance with the law. We may retain and disclose your Personal Information if we believe that it is appropriate or necessary in order to (a) comply with applicable laws, including laws outside your country of residence, such as to comply with a subpoena, regulation or legal request, respond to a government request, including from authorities outside your country of residence; (c) to enforce our terms and conditions; (d) to address fraud or security issues, to protect the safety, rights or property of any person, (e) to protect our own rights, operations and property; and (f) to allow us to pursue available remedies or limit the damages that we may sustain.
Business transfers. Your information may be transferred to a potential or actual acquirer, successor, or assignee as part of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in bankruptcy or similar proceedings) as part of that transaction. We may take steps to notify you via email and/or a prominent notice on our website of any change in ownership.
Anonymized information. Should we need to share data about POPin usage with third parties (such as investors or partners), we will aggregate it and strip it of all Personal Information.
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5. INFORMATION SECURITY
We take steps to protect the Personal Information we collect in our systems from unauthorized access, alteration, disclosure or destruction. We use appropriate administrative, physical and electronic measures designed to protect your Personal Information. We also evaluate, test, and improve our security infrastructure and processes. Please refer to our security policy at https://www.popinnow.com/security-policy

6. RETENTION PERIODS
We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrollment with our services, the impact on the services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

7. CHILDREN’S PRIVACY
We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of POPin is directed to children under the age of 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at privacy@popinnow.com. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

8. INTERNATIONAL DATA TRANSFERS
Your Personal Information may be transferred to computers located in California, or other states within the United States and thus outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those where you reside. By using POPin’s website, you agree to this transfer to the United States and globally.

9. YOUR RIGHTS AND CHOICES
Update and correct Personal Information. If you would like to request that we update or correct any Personal Information that you have provided to us through your use of our products and services, please send us an email at privacy@popinnow.com.

European data protection rights. If you are located in the European Economic Area, you may have additional rights, including the right to:

1. Request access to and receive information about the Personal Information we maintain about you; update and correct inaccuracies in your Personal Information; restrict or object to the processing of your Personal Information; have the information anonymized or deleted, as appropriate; and to easily transfer your Personal Information to another company (data portability);
2. Withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge (we will apply your preferences going forward and this will not affect the lawfulness of the processing before your consent withdrawal); and
3. Lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
These rights may be limited in some circumstances by local law requirements. You may exercise these rights by contacting us as indicated below.

THIRD PARTY LINKS

This Privacy Policy applies only to the processing of your Personal Information by POPin. It does not address, and we are not responsible for the privacy practices of any third parties, including any third party operating any website or service to which this website links. The inclusion of a link on this website does not imply endorsement of the linked website or service by us or by our affiliates.

CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may change from time to time. We will post any adjustments to the Privacy Policy on this website, and the revised version will be effective when it is posted.

CONTACT US

If you have any questions about this Privacy Policy, or if you would like to exercise your rights and choices with respect to your Personal Information, please contact us at:

POP, Inc.
300 Spectrum Center Drive, Suite 800
Irvine, CA 92618
privacy@popinnow.com

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