Privacy Policy

Privacy Policy

Last Updated: October 19th, 2018

 

This Privacy Policy (the “Privacy Policy”) explains how Palm Ventures Group, Inc. and our affiliates (“Palm Ventures Group,” “we,” or “us”) collect, use, process, and disclose information about you when you access or use our products and services, such as our devices (the “Device”), websites, mobile applications, and online services, or when you interact with us.

 

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this Privacy Policy, and in some cases, we may provide you with additional notice (such as adding a statement to our website’s homepage or sending you an email notification). We encourage you to review this Privacy Policy frequently to stay informed about our information practices and the choices available to you.

 

Collection of Information

 

Information You Provide to Us: We collect information that you provide directly to us. For example, we collect information when you sign up to receive information about our products or services, register your Device with us, create an account or profile, use interactive features of our products or services, make a purchase, participate in our contests, promotions, and surveys, communicate with us via third-party social media sites, apply for a job, request customer support, or otherwise communicate with us. The types of information we may collect directly from you include your name, username, email address, phone number, billing and shipping address, demographic information, and any other information you choose to provide. Additionally, if you use our products or services in connection with products or services offered by a third-party partner, you may provide us with information about your account with the third party in order to enable this functionality, such as the email address and password associated with your account.

 

When you make a purchase from us, we will collect and store limited payment information from you, such as payment card type, payment card expiration date, and a limited subset of your payment card number in order to process your payment. We do not collect or store full payment card numbers and all transactions are processed by a third-party payment processor.

 

When you register your Device with us or use its internet connected features, information is collected. This may include information about your Device, such as your IP address, OS version, regional and language settings, and IMEIs and other unique device identifiers. It also may include information about how, when and for how long you use your Device.

 

Information We Collect Automatically: When you access or use our services or products, we automatically collect information about you, and we may associate it with other information that you provide directly to us. For example, we may collect:

 

  • Log Information: We log information about your use of our website, such as your IP address, web browser type and language, access times, referring and exit websites, and clickstream data.

  • Mobile Application Information: We collect information about your Device when you access or use our mobile applications, such as the hardware model, operating system version, unique device identifiers, Bluetooth signals, mobile network information, and performance and diagnostic data regarding your use of our applications. With your consent, we may also collect precise location information or access information stored in other applications on your Device, such as contacts from your address book or photos from your photo gallery.

  •  Device Information: We may collect information about your access to and use of the Device. For example, we may collect information about the following:

    • Device information, such as IP address, device settings and preferences, hardware model, operating system version, network carrier and network technology information, device serial number, Wi-Fi network password, account tokens, user ID, installed applications, device location, and third-party products and services you connect to the Device; and

    • Performance and log information, such as error logs, power status, app battery usage, system diagnostic logs, and reasons for reboots and network errors (for information about how to control the collection of this information, see “Usage and Diagnostics” below).

 

Note that we collect information from a Device only when it is connected to the Internet. Additionally, we may associate the information we collect from a device with your account.

 

  • Information Collected by Cookies and Other Tracking Technologies: We use cookies and other similar technologies (e.g., web beacons, pixels, mobile identifiers) on our websites, mobile applications, email messages, and advertisements, to help us understand user behavior, improve our offerings, customize your experience, see which areas and features of our websites and applications are popular, and understand usage and campaign effectiveness. Please refer to our Cookie Policy available at: https://palm.com/cookiepolicy.

 

Information We Collect From Other Sources: We may also obtain information from other sources and combine that with information we collect through our products or services. For example, we may collect information about you when you post content to our pages or feeds on third-party social media sites.

 

Use of Information: We may use information about you for various purposes, including to:

  • Develop, operate, and improve our products and services;

  • Provide and deliver the products and services you request, process transactions, and send you related information, such as confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;

  • Respond to your comments, questions, and requests and provide customer service and technical support;

  • Communicate with you about products, services, offers, promotions, rewards, and events offered by Palm Ventures Group and others and provide news and information we think will be of interest to you;

  • Monitor and analyze trends, usage, and activities in connection with our products and services;

  • Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Palm Ventures Group and others;

  • Personalize and improve the products and services and provide advertisements, content, and features that match user profiles or interests;

  • Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;

  • Link or combine with information we get from others to help understand your needs and provide you with better service; and

  • Carry out any other purpose conveyed to you at the time the information was collected.

 

Sharing of Information: We may share your information as follows and as otherwise described in this Privacy Policy:

  • With business partners (including without limitation, wireless carriers), vendors (including without limitation developers of third-party, pre-installed applications on the Device), consultants, and other service providers who need such information to perform services on our behalf (such as to send emails or process payments for us);

  • With our third-party partners, if you choose to connect your Device to their products or services (the information we share with these partners will be described in the authorization screen that is displayed prior to enabling the connection, and you have the ability to stop this sharing at any time by changing your device settings or by contacting our third-party partners);

  • In response to a request for information, if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;

  • If we believe your actions are inconsistent with our user agreements or policies or to protect the rights, property, and safety of Palm Ventures Group or others;

  • In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;

  • Between and among Palm Ventures Group and any current or future parents, subsidiaries, affiliates, and other companies under common control and ownership; and

  • With your consent or at your direction.

 

We may also share aggregated or de-identified information with third parties.

 

Third-Party Products and Services: You have the ability to install or connect third-party products and services (such as mobile applications) on or to your Device. When you use third-party products and services, their terms apply to your use of those products or services. This Privacy Policy does not apply to information collected by such third parties, and we encourage you to learn more about their privacy practices before using their products or services.

 

Social Sharing Features: Our websites and mobile applications may offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our services with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

 

Advertising and Analytics Services Provided by Others: We may work with third-party social platforms, such as Facebook, to serve ads to you as part of a customized campaign, unless you notify us that you prefer not to have information about you used in this way by sending an email to comms@palmventuresgroup.com the email address you wish to have removed from customized ad campaigns.

 

Security: Palm Ventures Group implements security safeguards to protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction.

 

Transfer of Information to the U.S. and Other Countries: Palm Ventures Group is based in the United States and the information we collect may be transferred, processed, and stored in the United States and other countries, where you may not have the same rights and protections as you do under local law. By accessing or using our products or services or otherwise providing information to us, you consent to the processing, transfer, and storage of information in and to the United States and other countries.

 

Your Choices

 

Data Retention: Our data retention periods are based on business needs and legal requirements. We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it, or as needed to provide the products or services to you, unless a longer retention period is required or permitted by applicable law.

 

You may request that we delete your information, but note that we may retain certain information as reasonably needed to comply with law, meet regulatory requirements, or for legitimate purposes. We may also retain cached or archived copies of information about you for a certain period of time. You may also ask us to provide you access to, or a copy of, your information, or correct the information we have about you.

 

If you wish to make these requests, please contact us at: comms@palmventuresgroup.com.

 

Usage and Diagnostics: You can turn Palm Ventures Group usage and diagnostic services on or off at any time by navigating to Settings on your Device. If you change your settings after we have initiated a data upload, your new settings will go into effect after that process has been completed. Note that even if you turn this feature off, your Device will still send certain Device information (such as Device serial number, network carrier information, country, and operating system version) needed for critical services such as system or security updates.

 

Promotional Communications: You may opt out of receiving promotional communications from Palm Ventures Group by following the instructions in those communications. If you opt out of receiving promotional communications, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

 

Mobile Push Notifications/Alerts: With your consent, we may send promotional and non-promotional push notifications or alerts to your Device. You can deactivate these messages at any time by changing the notification settings on your Device.

 

Residents of the European Economic Area: We will process your data where we have lawful bases to do so. Lawful bases can include consent (e.g., if you sign up for a promotion), to perform our responsibilities under our contract with you (e.g., to provide products and services to you, process payments), and for our legitimate interests, provided that the processing doesn’t outweigh your rights and freedoms. We rely on several legitimate interests in processing your data. For example, we process your data to detect and prevent fraud, understand our users and industry trends, develop and improve our products and services, and send you marketing communications.

 

Where we rely on consent to process your data, you have the right to withdraw your consent at any time. You may also have a right to object to, or request that we restrict, certain processing of your personal data. Residents of the European Economic Area may also lodge a complaint with the supervisory authority where they reside.

 

Third Party Links and Products on the Device: Our website may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by websites or other services. You should exercise caution, and review the privacy statements applicable to the third-party websites and services you use.

 

We also may make available to you certain products or services (e.g., apps available through Google Play Store or that are pre-installed on your Device) developed by third parties. Palm Ventures Group is not responsible for these third-party products or services.

 

Third Parties that Provide Content, Advertising or Functionality on Devices: Some of the content, advertising, applications, and functionality on your Device may be provided by third parties that are not affiliated with us. For example:

 

  • Third parties develop applications that are made available through the Google Play Store or are pre-installed on your Device;

  • Certain third parties may serve advertising or keep track of which advertisements users see, how often they see those advertisements, and what users do in response to them; and

  • We enable you to share certain materials with others through social networking services such as Facebook, Twitter, Instagram, Google +, and LinkedIn.

 

These third-parties may collect or receive certain information about your use of the Device (including any application downloaded to the Device), including through the use of cookies, beacons, and similar technologies, and this information may be collected over time and combined with information collected across different websites and online services. Palm Ventures Group does not control the data collection and use practices of these companies. Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising. Please visit the websites operated by the Network Advertising Initiative "http://networkadvertising.org" and Digital Advertising Alliance "http://www.aboutads.info/" to learn more.

 

If you connect with a social networking service, we may receive and store authentication information from that service to enable you to log in, as well as other information that you allow us to receive when you connect with these services.

 

Also, please note that if you choose to connect with a social networking service on a device used by people in addition to you, those other users may be able to see information stored or displayed in connection with your account on the social networking service(s) with which you connect.

 

Children: We do not knowingly collect any personal information from children under the age of thirteen (13) without parental consent, unless permitted by law. If we learn that a child under the age of thirteen (13) has provided us with personal information without parental consent, we will delete it in accordance with applicable law.

 

California Residents: California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of personally identifiable information to third parties for their direct marketing purposes in the preceding calendar year (e.g., requests made in 2013 will receive information about 2012 sharing activities). We comply with this law by giving users the ability to tell us not to share personally identifiable information with third parties for their direct marketing purposes. To make such a request, send an email to comms@palmventuresgroup.com. We may need additional information to process your request.

Do Not Track: Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates, although web browsers incorporate and activate this functionality in different ways, and it is not always clear whether users intend for these signals to be transmitted. There currently is disagreement, including among participants in the leading Internet standards-setting organization, concerning what, if anything, websites should do when they receive such signals. Palm Ventures Group currently does not take action in response to these signals, but, if and when a standard is established and accepted, we may reassess how to respond to these signals.

Contact Us: If you have any questions about this Privacy Policy, please email us at comms@palmventuresgroup.com or write us at Palm Ventures Group, Inc., 461 2nd Street, #337, San Francisco, CA 94107, United States.