Peel Technologies, Inc.

Privacy Policy

Last Updated on July 13th, 2020

We at Peel Technologies, Inc. ("Peel," "we," "us," "our") know that our users ("you," "your") care about how your personal information is used and shared, and we take your privacy seriously. If you have any questions at all about this Privacy Policy, please do not hesitate to contact us at [email protected].

TABLE OF CONTENTS

 

Applicability of this Privacy Policy

This Privacy Policy ("Privacy Policy") applies to our website at www.peel.com (the "Site") and any other linked pages, features, content, mobile applications, or any other services we offer from time to time in connection with the Site (the "Services") and explains how we collect, use, share and otherwise process information relating to natural persons ("Personal Information"). All capitalized terms not herein defined will have the meaning set forth in our Terms of Use, which is hereby incorporated by reference. This Privacy Policy applies to any user or visitor to or of our Site and/or Services. Peel processes Personal Information in the role of a controller as described in this Privacy Policy.

We may update this Privacy Policy from time to time to reflect changes in our privacy practices, and to comply with country and region specific privacy regulation(for example GDPR). If we do, we will notify you of any changes by posting a notice on our Site or by sending notice to the primary email address specified in your account. Changes that materially affect your rights or our obligations will go into effect thirty (30) days following such notification, at which point we will update the "Last Updated" date at the top of the page. Non-material changes or clarifications will take effect immediately. We encourage you to periodically check the Site and this page for updates.

You acknowledge that your use of our Site or Services indicates to us that you have read this Privacy Policy and consent to the privacy practices described, and your continued use of our Site or Services after we publish or send a notice about any changes to this Privacy Policy indicates that you have read and consent to the updated Privacy Policy.

In addition to adhering to the privacy practices described in this Privacy Policy, we endeavor to adhere to the Digital Advertising Alliance's "Application of Self-Regulatory Principles to the Mobile Environment" (the "DAA Rules"), which can be located here. To the extent there are any contradictions or inconsistencies between the DAA Rules and this Privacy Policy, this Privacy Policy will control.

What Information Do We Collect?

We collect information, including Personal Information, only where we have a lawful basis. Lawful bases on which we rely include your consent where you have given it, contract where processing is necessary for us to perform our obligations pursuant to a contract with you, and legitimate interests of our business such as operating and providing the Site and Services to you.

We collect, store, and use the following categories of information, which includes Personal Information:

Information you give us, such as the following:

  • Profile Information. Your name, email address, zip code, country, telephone number, TV service provider, the manufacturer of your TV and/or other devices that can be set up through the Services, and any other information you share when you create an account on our Site or otherwise access our Services.

  • Survey Responses. Your responses to surveys that we may ask you to complete for research purposes or to help direct our activities.

  • Communications. Any information you share when you contact us, including feedback you provide and your email address.

  • Information You Post. Other Personal Information you voluntarily submit, which may include your device setup details, your profile picture, etc.

 

Information we get from your use of the Site and/or Services, such as the following:

  • Usage Information. Details of how you use the Site and/or Services, including content you consume (validated by audio content recognition), the channels that you visit, the links you click on, what you stream, the movies, videos, and/or other content that you download, connecting your Facebook or Google+ account, posting a comment, performing a search, the time, event log data (including clicks, access times, browser type and operating system, and frequency and duration of your visits to the Site and/or Services), and whether you interact with email messages or notifications (e.g., if you opened, clicked on, or forwarded the email message).

  • Device Information. Your internet protocol address (i.e., IP address), access times, your browser type and operating system, mobile and/or other device type (including your unique mobile device ID number and non-email authentication), anonymous identifiers for advertising, such as Apple's iOS Advertising Identifier and Google's Android Advertising ID ("AdIDs"), TV service provider, the manufacturer of your TV and/or other devices that can be set up through the Services, phone carrier and connection type (e.g., cellular, WiFi), device language, available or connected WiFi SSID and/or BSSID names, operating system version and type, unique identifiers such as Android Advertising ID, VIN, MAC address and Apple's iOS Advertising Identifier (IDFA), Apps installed on your device and location information (as further explained below).

  • Location Information. Precise location information collected from, by or through third-party Software Development Kits ("SDKs") that are embedded directly into the Services. We will ask you for permission before we use GPS or other tools to identify your precise location. In addition, please see the section below entitled "Your Rights Regarding Your Personal Information" for more information about how you can opt out of data collection.

  • Social Media.Your social media account IDs and information shared with us via your social media accounts.

  • Tracking Technologies. Information collected through Tracking Technologies (defined below), such as cookies, pixel tags, and other technologies.

  • Personal Directory Data. Your Personal Directory Data (as such term is defined in the DAA Rules), which includes your calendar, address book (which may include personal information of your contacts), phone/text log, or photo/video data that you use, create and store through our Site and/or Services.

  • Information Collected from Third Parties. If you sign up for the Site and/or Services through a third-party application like Facebook or Google, you authorize us to collect your authentication information applicable to such third-party application account, such as your username and encrypted access credentials, and other information available through such account.

 

How Do We Use The Information We Collect?

We use the information we collect for a variety of purposes, including to improve the Site and/or Services, optimize our technology and algorithms, attribution (e.g. measuring ad performance), analytics and research, refine and customize our offerings and user experience, and deliver dynamic, relevant advertising from our partners to our users.

In particular, we use the information we collect for the following purposes:
 

  • Site and Services Administration. Administer the Site and provide the Services, enable you to use its features, and improve the overall user experience.

  • Location-Based Advertising. Use Location Information to provide geography-based targeted advertising, including selecting which ads to show you on behalf of advertisers, syncing or matching you to segments, and serving such targeted advertising.

  • Communication with You. Communicate with you through email, push notifications, text, SMS, message via social media platforms, telephone, or any other medium for which we have contact information so that we can provide you with information and updates about us, our work, and our community, and to make it easier for you to share such information about us with your social networks.

  • Sending Administrative Messages. Send information including confirmations, technical notices, updates, security alerts, and support and administrative messages.

  • Technical Support. Respond to comments and questions and provide technical support and customer support.

  • Traffic Analysis. Analyze how you use the Site and Services using tools like Google Analytics, Amplitude, Mixpanel and other tools to help us understand traffic patterns and know if there are problems with the Site and/or Services.

  • Device Information Advertising. Use Device Information (including AdIDs) to create targeted advertising to promote the Site and Services and to offer related products and/or services based on your interests and measuring the reach and effectiveness of those advertisements, including whether you took action (e.g., to purchase a product).

  • Protecting Against Fraud.Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.

  • Linking. Link or combine user information with other Personal Information.

  • Information Comparison. Compare information for accuracy, update our records, and verify it with third parties.

 

Do We Share Your Personal Information?

We do not rent, sell, or share your Personal Information with other people or non-affiliated third parties, except in the following limited circumstances: as necessary to complete any transaction or provide with the Services or any specific service you have requested or authorized, or where Usage Information, Device Information, and/or Location Information we rent, sell, or share with third parties contains incidental Personal Information (as described below), or with your consent.

To help us do our work, we may provide limited access to some of your Personal Information to the following third parties:

  • Partners. We share the data collected about you (including Usage Information, Location Information, and Device Information), whether by itself or in hashed, aggregated, or de-identified forms, with advertisers, advertising service providers and other trusted business partners (collectively, our "Partners") to provide relevant Services and to measure the reach and effectiveness of such Services, including by serving ads based on your interest and to measure the reach and effectiveness of such ads, such as by measuring advertising, frequency capping, tracking advertising conversion events, to power tailored advertisements, aggregated research, location-based analytics, attribution, other civic, market and scientific research about traffic and crowds, and estimating the number of unique users. In order to keep the Services free for our users, we may rent, sell, or share Usage Information, Device Information, and Location Information to our Partners as described in this subsection, who may then use or further share such information pursuant to the terms of their privacy policies. When we do so, we will only do so pursuant to a written agreement that provides at least the same level of protection to that Usage Information, Device Information, and Location Information as provided by this Privacy Policy. 

  • Collaborating Organizations: We may share your name, contact information and other details you provided when making an account with our content partners to help them understand how the content they are providing is performing, including insights about general user viewing trends and preferences.

  • Affiliated Third Parties: We may share our subscriber list, which include user names, email addresses, postal addresses, phone numbers, social media IDs, comments, and/or action history, with our affiliates and/or subsidiaries.

  • Service Providers: We work with a wide range of third party providers, notably our database administrators, cloud computing services, advertising services, data analysts, application service providers, bulk SMS services, and other non-governmental organizations, some of whom may be located outside the European Economic Area ("EEA"). We do not authorize them to use or disclose your Personal Information except in connection with providing their services and they are contractually bound to implement appropriate organizational and technical security measures to protect against unauthorized disclosure of Personal Information, and only to process Personal Information in accordance with our instructions.

  • Third Party Applications: If you connect your account to other apps or social networks, such as Facebook or Google+, you may be sharing certain information with these apps or networks and the users on such apps or networks. Please make sure you trust these apps or services before sharing any information with them, as we are not responsible for these other apps or networks. For information on how to control the information you share, and how to disconnect your account from these apps, please see "Your Rights Regarding Your Personal Information" below.

 

We may also transfer your Personal Information to a third party as a result of a merger, acquisition, reorganization or similar transaction; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of the Site and/or Services; and to protect the rights or property of Company. In such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Information, give you an opportunity to consent to such changes.

We will also share Personal Information with companies, organizations or individuals outside of Company if we have a good-faith belief that access, use, preservation, or disclosure of your Personal Information is reasonably necessary to (1) detect or protect against fraud or security issues, to enforce our Terms of Service, (2) meet any enforceable government request, (3) defend against legal claims, or protect against harm our legal rights or safety, or that of our staff and/or Members.

Cookie Policy - What are Tracking Technologies, such as Cookies and Web Beacons, and How Do We Use Them?

We, or third parties we do business with, may use certain technologies to automatically collect log files and other information about your usage of, and the devices you use to access, the Site and the Services (“Tracking Technologies”). For example, we may use Tracking Technologies like cookies, log files, web beacons, session replay scripts, or similar technologies to help us analyze our web page flow, customize our services, content and advertising, measure promotional effectiveness and promote trust and safety.

You may delete and block all cookies from our Site and/or Services, but parts of the Site and/or Services will not work. We want to be open about our cookie use.

Even if you are only browsing the Site and/or Services, certain information (including computer and connection information, browser type and version, operating system and platform details, and the time of accessing the Site and/or Services) is automatically collected about you. This information will be collected every time you access the Site and/or Services and it will be used for the purposes outlined in this Privacy Policy.

How Do We Secure Your Personal Information?

We take reasonable steps to protect your Personal Information against unauthorized access, alteration, disclosure, misuse, or destruction. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  The safety and security of your Personal Information also depends on you. If you are a Member, you are solely responsible for keeping your membership details confidential, including any access credentials like passwords or mobile device PINs.

Your Rights Regarding Your Personal Information

You have certain rights with respect to the use of Personal Information on our Site and/or Services:

  • Changing or Deleting Your Personal Data All users may review, update, correct or delete the Personal Information furnished by a user in their user account by contacting us at [email protected], or by editing their profile via the Site or Services. If you completely delete all of your Personal Information, then your user account may become deactivated. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

  • Delete or Correct Your Content. You may access, correct, amend, or delete any text, images, photos, audio, video, location data and all other forms of data or communication that you submit or transmit to, through, or in connection with the Site and/or Services ("Your Content") by accessing your user account. You control all of Your Content. Content that you delete (including content containing Personal Information) may be retained in archived or backup copies. For instructions on how to permanently delete Your Content from your account, please contact us at [email protected]. Please note that permanent deletion of Your Content through this process will impair or disable those features with respect to that content.

  • Delete or Correct Personal Information. You may access, correct, amend, or delete Personal Information we have about you by logging into your account and navigating to your account page or by emailing us at [email protected]. For your protection, we may only share and update the Personal Information associated with the specific email address that you use to send us your request, and we may need to verify your identity before doing so. We will try to comply with such requests in a reasonably timely manner. If you wish to cancel your account, you may do so through your account page. If you do, personally identifiable information associated with your account will be deleted as soon as is reasonably practical or as required by applicable law. Please note that we may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations, or otherwise as required by law.

  • Download or Access Personal Information. You can ask us for a copy of your Personal Information, as well as information about its processing, and can ask for a copy of your Personal Information (including in machine readable form) by emailing us at [email protected].

  • Opting Out of Data Collection. You can withdraw your consent to having your Location Information or other data collected by changing the settings on the Services and/or on your device (note that certain features of the Services may lose functionality as a result), and you can also activate your device's opt-out settings which will: (i) tell advertisers not to use your in-app information from that device for purposes of collecting and serving internet-based advertising and (ii) inform our SDK partners to halt further data collection and sharing from that device.

  • Opting Out of Email Communications.If at any time you would like to unsubscribe from our email list, you may do so by contacting us at [email protected].

  • Opting Out of Certain Communications:
  • Marketing Communications. We may use some of the information we collect for marketing purposes, including to send you promotional communications about new Company features, products, events, or other opportunities. If you wish to stop receiving these communications or to opt out of use of your information for these purposes, please follow the opt-out instructions by clicking "Unsubscribe" (or similar opt-out language) in those communications. You can also contact us at [email protected] to opt out.

  • Site Communications. We will periodically send you free newsletters and e-mails that directly promote the use of our Site or Services. When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly at [email protected]. Despite your indicated e-mail preferences, we may send you service related communications, including notices of any updates to our Terms of Service or Privacy Policy.

 

Links to Third Party Websites

We may provide links to other websites. We have no control over these websites and they are subject to their own terms of use and privacy policies. As such, we do not endorse and are not responsible for the availability of, or for any content, advertising, products, or other materials on or available from, these third party websites.
By using the Site and Services, you agree that we will not be liable for any damage or loss caused by your use of or reliance on any content, advertising, products, or other materials on or available from these third party websites.

How We Respond to Do Not Track Signals

Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser because we do not track our visitors to provide targeted advertising. To find out more about Do Not Track, please visit http://www.allaboutdnt.com.

Children Under 16

The Services are not directed to individuals who are under age of sixteen (16) and we do not solicit nor knowingly collect Personal Information from children under the age of sixteen (16). If you believe that we have unknowingly collected any Personal Information from someone under the age of sixteen (16), please contact us immediately at [email protected] and the information will be deleted.

Your California Privacy Rights

Your California Privacy Rights. If you are a California resident, you have the right to request information from us regarding the manner in which we share certain categories of your personal information with third parties for the third parties’ direct marketing purposes. California law provides that you have the right to submit a request to us at our designated address and receive the following information: (a) the categories of information we disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; and (b) the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed. You are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually. 

You have the right to request that we delete any Personal Data that we may have collected. When we receive a verified request to delete Personal Data, we will do so unless otherwise authorized by law.

You have a right to opt out of the sale of Personal Data. You may, at any time, direct us to not sell Personal Data about you to third parties.  Any Personal Data collected in connection with your request to opt-out of the sale of Personal Data about you will be used only to facilitate that request.

To make such a request, please use the contact information below. You can also make a request through the settings provided in our Application.

A Note to Users Outside the United States

Our Company is based in the United States. The Site and Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be collected, transferred to, stored and otherwise processed in any country where we have facilities or in which we engage service providers, and by using the Site and/or Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

We will ensure that transfers of Personal Information are provided an adequate level of protection as required by law, such as by entering into appropriate contractual arrangements (such as, where applicable, the standard contractual clauses for the transfer of data as approved by the European Commission), by complying with or relying on EU-U.S. Privacy Shield Framework certifications, or by asking for your prior consent.

Contact Us

If you have any questions about this Policy, your Personal Information, or the Site and/or Services, you can contact [email protected] or by emailing us at the below address:

Peel Technologies, Inc.
c/o Data Protection Officer
1999 S Bascom Ave
Suite 340
Campbell, CA 95008

Please contact us if you have any complaints or concerns with respect to your privacy. If you believe we are unable to assist you, you have the right to lodge a complaint with a supervisory authority in the relevant jurisdiction. However, we are committed to working with you to resolve any complaint or concern you may have with respect to your privacy.