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Privacy Policy

 

Overview

This Privacy Policy describes how Pinger treats information that it collects and receives related to your use of Pinger's products, services, and websites. Our primary goal in collecting information is to provide and improve our products and services.

Children's Personal Information

All Pinger products, services and websites are not intended for children under the age of 13, so children under the age of 13 should not use them at any time.

Pinger complies with the Children's Online Privacy Protection Act ("COPPA"), including the COPPA rules effective July 1, 2013, and does not knowingly collect any information from children under the age of 13. In the event that Pinger discovers that it has received personal information (as defined under Section 312.2 of the COPPA rules effective July 1, 2013) from a child under the age of 13, Pinger will promptly delete such personal information in a secure manner.

Safe Harbor Frameworks

Pinger complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland (the "Safe Harbor Frameworks"). Pinger has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Pinger's certification, please visit http://www.export.gov/safeharbor/

Information Pinger Collects and Uses

Pinger collects information when you use and access Pinger's products, services and website. We categorize the information we collect into three categories (collectively referred to as "Customer Information"): Personal Information, App Data and Share Data.

"Personal Information" is information about you that is personally identifiable, including your full name, business or residential address, email address, land-line or existing mobile phone number, or billing information.

"App Data" is information about the nature of your usage of Pinger's website and products and services and non-personal demographic information. App Data can include: IP addresses, domain servers, referring/exit pages, operating system information, unique device identifiers, such as UDID and/or Ethernet MAC address, date/time stamp, clickstream data and information about actions taken by you through interaction with Pinger's products and/or advertising displayed within Pinger products, messages sent and received using Pinger services, information about those messages (date, duration, recipients, size, attachments), type of device, location information, age, gender, type of web browser, one or more cookies that identify your browser, and telecommunications carrier information.

"Share Data" is data and information you provide for use with Pinger's products or services, such as text, audio, and photos you make available through the Apps or contacts you add or import for use with Pinger products, and which may be made available to third parties by your actions when using Pinger products or services.

Information Sharing and Disclosure

Pinger uses Customer Information to enhance your use of the Pinger services by processing such information for various purposes, including improving and providing Pinger's products and services, product notifications, delivering advertisements and related links, for sending, sharing and storing your Share Data as you direct through use of Pinger products and services, and other purposes relating to offering you Pinger products and services.

Pinger does not rent, sell, or share any Customer Information unless: you initiate the sharing through the Pinger products, services or website; you have provided your express consent; and in the following circumstances:

(i) Pinger may engage a trusted third party to perform limited functions on our behalf, such as fulfilling newsletter subscriptions, sending requested postal mail and e-mail, SMS, MMS, and voice communications, analyzing and processing data (such as billing information), and providing customer service. We require that these parties agree to use such information in a confidential manner. These third parties may have access to Personal Information needed to perform their functions, but we do not permit them to use it for other purposes.

(ii) Pinger may share App Data and certain aggregated, non-personal information with third parties, but such information does not include your name, email address or any other Personal Information.

(iii) Pinger may share Customer Information to respond to legal requirements, when legally required to do so, or at the request of governmental authorities.

 (iv) Pinger may share Customer Information to verify or enforce compliance with user agreements and applicable laws, to protect against fraud, to detect and prevent security or technical issues, to protect against misuse or unauthorized use of the Pinger products, services, computing systems, or website, or to protect against imminent harm to the rights, property or safety of Pinger, its subscribers or the public.

(v) Pinger may share Customer Information with a successor entity or in connection with a corporate merger, consolidation, sale of assets or other corporate reorganization provided that use of Customer Information is in compliance with this Privacy Policy.

(vi) Pinger may share your Customer Information with a third party if you have consented to receive information from that third party through Pinger products or services. Such third parties will handle, store, retain and access such user information in accordance with the terms and conditions of their agreements with you, if any, as well as their own privacy policies and as authorized and agreed upon by you as part of agreements for use of our products and services. It is your responsibility to carefully review such agreements and privacy policies. You acknowledge that Pinger shall have no liability to you for sharing of such information to such third parties as authorized by you and Pinger disclaims any and all liability relating thereto. If Pinger desires to use Personal Information for any purposes other than those described in this Privacy Policy, we will offer you the opportunity to opt out of such use for those other purposes.

Cookies

When you visit Pinger, we may send cookies to your computer that uniquely identify your browser or use pixel tags (sometimes referred to as web beacons) to record pages visited. We use cookies and tags to improve the quality of our service by storing user preferences and tracking usage information. Most browsers allow you to disable cookies or set your browser to alert you when cookies are being sent to your computer. We may also include tags in promotional materials in order to determine whether messages have been opened and acted upon. You hereby expressly consent that Pinger is entitled to place these cookies and tags for the above-mentioned services on your computer or device. If you disable cookies, you may not be able to utilize certain Pinger products and services.

Security and Data Integrity

We have physical, electronic, and procedural safeguards to protect the loss, misuse, and alteration of the Customer Information under our control. Customer Information we collect is stored in a secure manner that is accessible only by authorized Pinger personnel, contractors, and agents bound by confidentiality obligations and is only disclosed under the provisions of this Privacy Policy. Our processing of Personal Information is only for the purposes for which it was collected and in accordance with this Privacy Policy. Periodically, Pinger undertakes a review of its privacy practices to ensure that that the information we collect is needed to provide or improve the services we provide.

Links to Third Party Sites

As a convenience to you, we may provide links and/or connections to third-party web sites or services from within our website or our products or services. Pinger is not responsible for the privacy practices or content of these third-party sites.

Access/Removal of Your Personal Information

If you want us to remove your Personal Information from our database, or would like to access the Personal Information we have that was collected from you, you can contact us using the contact information provided below. Certain of our products and services require the use of App Data and such data is retained by Pinger and used as described in this Privacy Policy.

Modifications of Privacy Policy

Pinger reserves the right, at our discretion, to change, update or modify this Privacy Policy at any time by posting such change, update or modification on the Pinger website and in the app stores from which Apps are made available. Any such change, update or modification will be effective immediately upon notice, which Pinger may provide by any means, including, without limitation, posting on the Pinger website, notifications within Pinger applications, or electronic mail. Your continued use of the Pinger website and/or any Pinger products and services following the posting of changes will mean you accept those changes. Use of information that we gather is subject to the Privacy Policy in effect at the time of use.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, please send us an email at info@pinger.com or write to us at Pinger, Inc. 97 S. 2nd St, Ste. 210, San Jose, CA 95113. If we receive formal privacy-related complaints, it is our policy to use reasonable efforts to communicate with the complaining party about its concerns to resolve privacy complaints.

Dispute Resolution

If you have any complaints regarding our compliance with the Safe Harbor Frameworks, you must first contact us (as provided above). If contacting us does not resolve your complaint, Pinger will cooperate with JAMS pursuant to the JAMS International Mediation Rules. The dispute resolution process shall be conducted in English.

Last updated July 27, 2013