1. WHAT PERSONAL INFORMATION DO WE COLLECT?
We collect many kinds of Personal Information to operate effectively and provide you with the best services and user experiences we can. In particular:
- Account and Activity Information – To create an account on one of our Services, you must provide your full name and email address. You may also choose to update the profile associated with your account by sharing your address, birthday, age, gender, marital status, a photo of yourself, and other requested personal information. We may also collect information about your usage of our Services in association with your account, such as the campaigns you view, the challenges in which you participate, the links you click, and your search queries and results. If you participate in any campaigns or challenges, we will request a photo and description of your participation.
- Mobile Information – When you use our mobile applications, we collect your device’s unique identifier and other technical information about your device and application usage.
We may also collect Personal Information that allows us to be in contact with you (such as email address, phone number, and address), information about your user experience or opinions, and other Personal Information that you voluntarily provide to us when you contact us with a question or comment about our products and services.
2. HOW DO WE USE YOUR PERSONAL INFORMATION
We use your Personal Information to provide and optimize our Services. In particular, we use:
- Account and Activity Information to manage your account, identify campaigns and challenges that may be of interest to you, calculate your XO scoreTM (a measure of the positive impact you are making), communicate with you in relation to your account, personalize our Services for you, provide you with customer service, and monitor the performance of our Services.
We also use some of your Account and Activity Information to display a public profile of yours which contains your full name and photo, as well as your achievements and activities in connection with the Services. We also post the photo and description of your participation in a campaign or challenge to a publicly accessible portion of the Services.
- Website Information and Mobile Information to monitor the performance of our Services, analyze trends, usage and activities in connection with our Services, and ensure their technological compatibility with users.
We also use the Personal Information you provide us to respond to your comments and questions, better understand your needs, and generally improve and enhance our products and services.
We may wish to use your Personal Information to provide you with marketing communications promoting our products and services, or those of third parties. We will only do so with your consent and as permitted by law. We will not use Personal Information for any purpose incompatible with those outlined in this Policy.
3. WHAT PERSONAL INFORMATION DO WE DISCLOSE?
We do not sell or rent your Personal Information to others. If you create an account on our Services, we create a public profile that displays your full name and photo, as well as your achievements and activities in connection with the Services. Your public profile may be available to anyone on or off our Services and be seen or accessed through online search engines and other media. If you participate in a challenge or campaign, we post the photo and description that you upload to demonstrate such participation on a publicly accessible portion of the Services.
Apart from the above, we only share Personal Information with third parties who are bound by terms at least as restrictive as this Policy and only in the following ways:
- Affiliates – We may share Personal Information with any of our subsidiaries, or our ultimate holding company and its subsidiaries, for the purpose of providing our Services and improving our products and services.
- Service Providers – We share Personal Information with third-party service providers who perform a variety of functions to enable us to provide our Services, such as hosting our Services, and analyzing and improving our Services. These service providers only have access to the Personal Information necessary to perform their functions, only act on our behalf and under our instructions, and may not use it for purposes other than to perform such functions.
- Legal – We may disclose Personal Information to courts, law enforcement agencies, and other government bodies if we suspect that an individual’s use of our Services involves illegal activity or is otherwise inconsistent with any applicable terms and conditions. We may also disclose Personal Information where we believe that doing so would be in accordance with or required by any applicable law, regulation or legal process.
- Business Transfers – In the event of a reorganization, merger or sale, we may transfer any and all Personal Information we collect to the relevant third party involved in the reorganization, merger or sale, with the consent of data subjects if and as required under applicable privacy laws.
- With Your Consent – We may also share Personal Information with other third parties subject to your prior consent.
4. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We maintain reasonable administrative, technical and physical safeguards to protect Personal Information against loss, theft, misuse and unauthorized access, disclosure, alteration and destruction as required by applicable law. Unfortunately, the transmission of information via the Internet is not completely secure. Despite our safeguards, we cannot guarantee the security of information transmitted to us via the Internet. Once we have received your information, we will use all reasonable safeguards to protect it.
5. WHERE IS YOUR PERSONAL INFORMATION STORED?
If you use our Services from outside the United States, please be aware that your Personal Information will be transferred to, stored, and processed in the United States. The data protection laws of the United States may not be considered adequate by authorities in your home country, but please be assured that we take steps to ensure that your Personal Information is collected, processed, protected and transferred in accordance with applicable law.
7. COOKIE INFORMATION
To manage the cookies that are placed on your computer, you may configure your internet browser to refuse, accept or delete cookies from our websites at any time. The help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Please note that if cookies are disabled or removed, not all features of our websites will operate as intended.
8. EXTERNAL LINKS
This Policy does not apply to the collection, processing and use of Personal Information by companies that we do not own or control, or to people that we do not employ or manage (“External Parties“). Although some of our Services link to the websites and services of External Parties, such as those of our business partners and social media companies, we do not exercise control over the activities of External Parties. For more information about what Personal Information External Parties collect and how they use such Personal Information, please refer to their privacy policies.
9. ACCESS, CORRECTION AND OTHER RIGHTS
To exercise the statutory rights you may have under applicable law, such as to access, correct, update, delete, block or limit our use of your Personal Information, please contact us by the means noted below and clearly describe your request. We will try to comply with your request as soon as reasonably practicable and always under the timeframes set forth by applicable laws. Please note that we may need to retain certain information for certain purposes as required or authorized by law.
If you have any questions about this Policy, please contact our privacy officer at firstname.lastname@example.org or IOU Concepts Inc., 69 John Street South, Suite 430, Hamilton Ontario, Canada L8N 2B9.
10. REVISIONS TO THE POLICY
We may update this Policy from time to time. Any changes will be preceded by a notice posted on the relevant Service. If you disagree with our revisions to the Policy, you may de-activate your account or discontinue the use of our Services.
This Policy is effective April 4, 2016.