Last updated: November 23th, 2019
For purposes of data protection laws, Pleeco, Inc., located at 222 Broadway, Floor 19, New York, NY 10038, is the “data controller” of your information.
WHAT PERSONAL INFORMATION DO WE COLLECT?
This is how we collect Personal Information from our customers, users, and visitors of our Site:
Account Creation. If you create an account by registering with the Services (“Account”), we’ll collect certain Personal Information about you, such as your name, email address, physical address, and phone number.
Communications with Us. We may collect Personal Information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, request customer or technical support, or otherwise communicate with us.
Data Collected Via Our Services. We will collect any and all information, data files, and databases (including any of your or your customers’ Personal Information included in such data files or databases), provided by you to the Services whether directly by transferring such files, or indirectly by granting Pleeco access to your third party accounts where such files are stored.
Security Credentials Data. We collect user IDs, passwords, password hints, and similar security information required for authentication and access to our users’ accounts.
Surveys. We may contact you to participate in surveys. If you decide to participate, we may ask you for certain information which may include Personal Information.
Posting. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections. So please use discretion when posting anything on such platforms.
Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.
Automatic Data Collection. We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices. We also automatically collect some information regarding your use of the Services by placing cookies and other technologies on our Site. For more information on Cookies, please see below.
HOW DO WE USE YOUR INFORMATION?
We Process Personal Information about you for a variety of business purposes, including:
To Provide Services and Other Information Requested including to:
For Administrative Purposes including to:
To Market Our Products and Services. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest to you, including:
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as described below.
De-identified and Aggregated Information Use. We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Site and Services, or other analyses we create. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
Please note that in some cases, we need certain types of information so that we can provide you with the services you request. If you do not provide us with such information, or ask us to delete it, you may not be able to obtain these services.
LEGAL BASES FOR USE OF YOUR INFORMATION
The laws in some jurisdictions require companies to tell you about the legal ground they rely on to use or disclose your personal information. To the extent those laws apply, our legal grounds are as follows:
To honor our contractual commitments to you. Much of our processing of personal information is to meet our contractual obligations to our users, or to take steps at users’ requests in anticipation of entering into a contract with them. For example, we handle personal information on this basis to allow you to use the Services.
Consent. Where required by law, and in some other cases, we handle personal information on the basis of your implied or express consent.
Legitimate interests. In many cases, we handle personal information on the ground that it furthers our legitimate interests in commercial activities in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. This includes: operating our business and the Service; providing security for our websites, services, software, or applications; marketing; receiving payments; preventing fraud; and knowing the customer to whom we are providing the Service.
Legal compliance. We need to use and disclose personal information in certain ways to comply with our legal obligations (such as our obligation to share data with tax authorities).
WITH WHOM DO WE SHARE YOUR INFORMATION?
We may share your information as follows:
Vendors and Service Providers. We may share your information with our vendors and service providers. For example, we may share your information with providers of IT, web hosting, and related services, or with our third party payment processors, and other service providers that help us with the provision of the Site and Services.
Business Partners. We may provide Personal Information to our business partners with whom we jointly offer products or services. In such cases, our business partner’s name will appear along with ours.
Friends or Colleagues. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend and/or colleague to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Pleeco or any other third parties for any other purpose.
Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Pleeco may allow third party advertising partners to set Technologies (defined below) and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners for targeted advertising or interest-based advertising. You will be able to opt out of such sharing by following the instructions below.
Disclosures to Protect Us or Others. We may access, preserve, and disclose your Personal Information and other Account information, and content if we believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; respond to your requests; protect your, our or others’ rights, property, or safety; to enforce our policies or contracts; when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or if we, in good faith, believe that disclosure is otherwise necessary or advisable.
Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
Information Posted on our Blogs and Community Forums. If you post anything on any publicly accessible blogs, forums, social media pages, and private messaging features provided by the Services, you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.
INFORMATION WE PROCESS ON BEHALF OF OUR CUSTOMERS (AS DATA PROCESSORS)
Our customers may choose to use our Services to Process some of their data, which may contain Personal Information. The data that we Process through our Services for our customers is Processed by us purely as a data processor, on behalf of our customer, and in accordance with our customers’ instructions, and our privacy practices governing the Processing of such data will be in accordance with contracts that we may have in place with our customers.
If you have any questions or concerns about how such data is handled or would like to exercise your rights as a data subject, you should contact the person or entity who has contracted with us to use the Services to Process your data (i.e., the data controller). Our customers control the Personal Information in these cases and determine the details regarding their Account, including without limitation, how and for what purpose the data collected on their behalf should be Processed. We will, however, provide assistance to our customers to address any concerns you may have, in accordance with the terms of our contract with them. For a list of our sub-processors, contact us as described below.
COOKIES, PIXEL TAGS/WEB BEACONS, ANALYTICS INFORMATION, AND INTEREST-BASED ADVERTISING
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
You can opt out of collection and Processing of data by these individual analytics services by accessing the following links: for opting out of collection by Google, you can use the following link: http://tools.google.com/dlpage/gaoptout and for opting out of CrazyEgg’s collection, you can use this link: https://www.crazyegg.com/opt-out. In addition, you can exercise your choices by following the instructions below.
We use such Technologies for these purposes:
Operationally Necessary. This includes Technologies that allow you access to our Site, Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions such as saved search, or similar functions;
Performance Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services and so we can improve our Services;
Functionality Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign into our Site or Services or keeping track of your specified preferences, interests, or past items viewed;
Advertising or Targeting Related. We may use first party or third party Technologies to deliver content, including ads relevant to your interests, on our Site and Services or on Third Party sites.
THIRD PARTY WEBSITES, SOCIAL MEDIA PLATFORMS AND SDKs
The Services may contain links to other websites and other websites may reference or link to our Site or other Services. We do not control such third party websites or resources. So please read the privacy policies of each such website before you provide any information on it.
We may use third party APIs and software development kits (“SDKs”) as part of the functionality of our Services. APIs and SDKs may allow third parties including advertising partners to collect your Personal Information to provide content that is more relevant to you. For more information about our use of APIs and SDKs, please contact us as set forth below.
INTERNATIONAL DATA TRANSFERS
All information Processed by us may be transferred, Processed, and stored anywhere in the world- the European Union, the United States or other countries. Personal Information may be stored in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Accordingly, Your Personal Information may be transferred to and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction.
Where required, we will use appropriate safeguards when transferring your data outside of EEA. For more information about these safeguards, please contact us as set forth below.
General. You may opt out of certain uses of your Personal Information, or even withdraw your previously provided consent at any time and prevent further Processing by contacting us as described below. Please note, however, that the opt out does not apply to, and we may still collect and use, any non-Personal Information regarding your activities on our Site, Services and/or information from the advertisements on third party websites for other legal purposes as described above.
“Do Not Track”. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Sorry- we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. You may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs via the following links: www.aboutads.info/choices/, www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, and https://youradchoices.ca/choices/.
Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes.
RIGHTS OF ACCESS, RECTIFICATION, ERASURE, AND RESTRICTION – EEA RESIDENTS
Residents of the EEA can exercise certain data subject rights available to them under applicable data protection laws. Where such rights apply, we will comply with requests to exercise these rights in accordance with applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. If these rights apply to you, they may permit you to request that we:
If you would like to exercise any of these rights, please contact us as set forth below. We will process such requests in accordance with applicable laws.
You have the right to lodge a complaint with a supervisory authority if you believe our Processing of your Personal Information violates applicable law. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.
We keep your information for the time period required to complete the purposes for which it is processed or satisfy legal retention requirements. The length of time for which we retain information depends on the purposes for which we collected and use it or the requirements of applicable laws.
SECURITY OF YOUR INFORMATION
We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we’ll attempt to notify you electronically by posting a notice on the Services, by mail or e-mail.
The Site and Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect Personal Information from children. If you learn that your child has provided us with Personal Information without your consent, you may contact us as set forth below, and we’ll promptly take steps to delete such information and terminate the child’s account.
CALIFORNIA PRIVACY RIGHTS
“Personal Information” is any information relating to an identified or identifiable natural person.
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.