Privacy Policy

Last modified: June 26, 2020

Introduction

This Privacy Policy applies to users of Privola LLC (“Privola,” “we,” and “us”) websites, mobile applications and services (collectively, the “Service”). This Privacy Policy covers how Privola treats your Personally Identifiable Information (“PII”), and other data that you may share or authorize sharing when you use the Service (“Personal Data”) (PII and Personal Data collectively hereafter “Personal Information”). The purpose of this Privacy Policy to let you know what kind of information we may gather, why we gather your information, what we use your information for, how you can manage your information, and under what circumstances it may be disclosed.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE TO THE PRIVACY POLICY, INCLUDING ANY CHANGES THERETO, THEN YOU MUST NOT ACCESS AND USE THE SERVICES.

“Business” as used in this Privacy Policy includes businesses of any type as well as other organizations or agencies you may visit and places where you use the Service.

Types of Information Collected

Privola collects Personal Information when you register for the Service and from businesses where you use your Privola. Depending on how you use the Service, we collect different kinds of information about you.

Personally Identifiable Information (PII)

PII is any information that can individually identify you and includes your name, and contact information, such as e-mail address, telephone number, or postal address.

Non-Personally Identifiable Information

Non-personally identifiable information includes information that does not personally identify you, but it may be linkable to you, such as your Privola ID assigned when you register. If non-personally identifiable information is directly linked to personally identifiable information, it will be considered PII while it is linked. Aggregate or de-identified (anonymized) information that contains no PII and cannot be traced to you is not considered Personal Information.

Personal Data

Among the types of Personal Data that the Services may collect from the you, by itself or through third parties, is the dates and locations of businesses where you have used your Privola, as well as cookies, log data, and other location based data as described in more detail below.

Failure to provide the requested Personal Data or authorize its transmission may make it impossible for Privola to provide its Services to you. In cases where the Services specifically states that some data is not mandatory, you are free to withhold this data, although that may still limit some of the available features and functionality of the Service.

Data You Provide

When you install or use the Services it will be necessary to create a user account specifically for your use. You will be asked to provide PII and other personal information or if you are a business user, information about your business. You will know what information you are choosing to provide or authorize at that time. You will also be providing data on your location and businesses visited when you choose to use Privola at a business location.

Personal Data –Cookies, Log Data, and “Do Not Track” Signals

Whenever you visit our websites or use the Services through our mobile app, we receive and record information on our server logs which can include information from Cookies as well as information to identify your device and operating system. Cookies are automated data collection tools and other technologies that we use to collect data that enable us to better understand and improve the usability and performance of our Services. For instance, we may use session cookies (which expire once you close your browser) or persistent cookies (which stay on your mobile device until you delete them) to provide you with a more personal and interactive experience when using our Services. If you don’t accept cookies when prompted it may limit the functionality and features of the Services.

Privola also collects some information automatically that may be available depending on your use of our website or mobile application, such as device and operating system identification, Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data, and store it in log files as log data. We use this information to understand and analyze trends, to administer the site and Services, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Privola may also use this information in our marketing and advertising services.

Currently, due to a lack of industry acceptance and standardization, our Services do not recognize browser “do-not-track” signals.

Personal Data - Location-Based Data

When you use the Services at a business, our system will know the location of the business and when you were there. To provide location-based services and to improve and further develop the Services, Privola may collect, use, and share precise location data, including the real-time geographic location of your mobile device and the location of nearby businesses accepting Privola. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location.

Privacy and copyright protection

The main reason in collecting information we collect is to provide the Services to you that you request. In detail, Privola collects and uses Personal Information from you for the following purposes:

Registration

When you register for the Service, or when a third party registers you for the Service on your behalf, we collect your Personal Information as part of the registration process, including but not limited to your name, address, phone number, email address, sponsoring provider and program settings. SMS messages and email may be used during the registration process to send a one-time code and link to access the Service.

Personalization

We collect information such as your picture in order to personalize the Service and help you identify yourself as a Privola holder when you use the Service.

Notifications

Registered users of the Privola platform may receive push notifications according to their user settings. We may also use your contact information to send important notifications to you from the Service, such as a report of exposure at a business or organization that you recently visited when using Privola.

Customer Support

We may use your contact information to send you information about our Service or information relating to any risks the business may want to report, to respond to technical support inquiries, or to help prevent spam, fraud or abuse. When you enter Personal Information into a contact form in any portion of the Service, Privola uses the information provided to reply to requests for information or other requests as indicated by the form.

Managing Contacts And Sending Messages

We may use your contact information to send you information about our Service or information relating to your well being, to respond to technical support inquiries, or to help prevent spam, fraud or abuse. When you enter Personal Information into a contact form in any portion of the Service, Privola uses the information provided to reply to requests for information or other requests as indicated by the form.

Marketing Messages

We may use your contact information to provide you with information on products or services we think may be of interest to you. Emails we send you may include a technology (called a web beacon) that tells us whether you have received or opened the email, or clicked a link in the email. You can opt-out of email marketing messages we send by clicking on the “unsubscribe” link in the email message. Please note that we may send you one message to confirm you want to opt out. If you are a registered user of our Services, or if you have engaged in transactions with us, we may continue to send transactional or relationship messages reasonably needed in our operation and delivery of the Services to you.

System Logs And Maintenance

For operation and maintenance purposes, we may collect files that record your interactions with the Service (system logs) or other Personal Data (such as IP address).

Surveys and User Research

From time to time, we may send you survey questions or contact you with questions related to your experience to help us improve our Service. We collect any responses you provide. Participation in such surveys or user research does not impact your access to the Service.

Analytics

Privola may collect and use your device’s unique identifier for analytics purposes or to store your user preferences. Privola may use Google Analytics or other third party services to monitor and analyze user behavior.

Information Sharing and Disclosure

To Provide The Services

Privola will not sell or share your Personal Information with other people or non-affiliated companies, except to provide Services you have requested, when we have authorization from you to share such information, or when we provide information to subcontractors (such as hosting providers) or consultants working on behalf of or with us under strict confidentiality agreements. These companies and consultants do not have any independent right to use or share your Personal Information.

Law Enforcement, Legal Process, and Emergency Situations

We may disclose your Personal Information to third parties if required to do so by law or on the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or the Service; (b) protect and defend our rights or property, the Service or our users, or (c) prevent or stop any illegal or unethical activity.

Anonymous or Aggregated Data

We may disclose de-identified versions of your Personal Information and other data in aggregated or non-aggregated forms with partners, investors, contractors or prospective advertisers and research partners for any purposes related to our business practices.

Successor Businesses

We may share your personal information during a corporate transaction like a merger, or sale of our assets, or as part of the due diligence for such contemplated transactions. If a corporate transaction occurs, we will provide notification of any changes to control of your personal information, as well as choices you may have at that time.

Confidentiality and Security

We have taken reasonable and necessary steps consistent with accepted practices in the appropriate industries to ensure that all Personal Information collected will remain secure and confidential. These steps include physical, electronic, and administrative procedures to safeguard and help prevent unauthorized access or disclosure, maintain data security and correctly use the Personal Information that we collect.

The processing of the Personal Information we collect is carried out using computers and/or IT enabled tools, following organizational procedures and modes appropriate and necessary to providing the Service. Personal Information is processed at Privola’s operating offices and in any other places where the parties involved with the processing are located.

It is important that you help protect the privacy of your own information. We strongly recommended that you take precautions to protect the security of any Personal Information that you transmit by using device security features, encryption and other techniques to prevent unauthorized interception of your Personal Information. You are responsible for the security of your information when using unencrypted, public or otherwise unsecured networks.

Please understand, that while we try our best to safeguard your Personal Information once we receive it, no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.

Accessing, Changing, Opting-Out and Deleting Your Information

If you are a registered user of Privola, you may review and change some of your information by logging into your account and editing your profile. You can also request access, changes or deletions to your Personal Information by contacting us at hello@privola.com. Be advised that we may not be able to delete your Personal Information without also deleting your user account. We may not accommodate a request to change or delete Personal Information if we believe doing so would violate any law or legal requirement or cause the information to be incorrect.

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to correct information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your information in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the information you gave us to another organization, or to you, in certain circumstances.

Your right to opt-out – California residents have the right, at any time, to direct us not to sell the your personal information to third parties. We are not in the business of selling consumer information to third parties, we only use and share your personal information as described in this policy. You may still send a “Do Not Sell My Info” request to us at any time by clicking the email link below to make your request, or mail your request to our address listed under “Contact Us” below. California residents may also ask for a list of third parties that have received your personal information for direct marketing purposes during the previous calendar year. This list also contains the types of personal information shared. We provide this list at no cost. If you are a California resident and would like to request this information, please email hello@privola.com.

You are not normally required to pay a fee to exercise any of your rights. If you make a request, we will try to respond to you within fifteen days from receipt of your request. It may take longer if your request is complex or if you have made a number of requests. If this is the case, we will let you know and keep you updated.

Children’s Information

The Services are not directed to children under 18 years of age. Unless otherwise disclosed during collection and with parent or guardian consent, Privola does not knowingly collect Personal Information from children under 18 years of age. Should it come to our knowledge that we have collected Personal Information of a person under 18 years of age without verified consent from a parent or guardian, we will take action to remove the information from our systems.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time, without notice, by posting a new version online. You should check this page occasionally to review any changes. If we make material changes affecting you we will notify you by posting the revised Privacy Policy on our websites and, if you are a registered user of our platform, by providing notice through the Privola app or by email. This helps you always be aware of what information we collect, how we use it and under what circumstances, if any, it is disclosed. Modifications will be effective immediately. Your continued use of the Service and/or continued provision of Personal Information to us will be deemed as an acceptance of such modifications to this Privacy Policy.

Contact Us

If you would like to update your Personal Information, delete your account, change your preferences or have any questions or concerns about your privacy, you may contact us at hello@privola.com. Please note that some information may remain in our records after deletion of your account, including any information or records we are legally obligated to retain.


Privola LLC