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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.
Security and Data Integrity
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 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