Last updated on March 3, 2017

 

Introduction

 

Thank you for using ppl. We are committed to protecting your privacy; we have adopted this Privacy Policy to memorialize the data collection and disclosure practices for ppl and its related tools and services (collectively, the “Services”). The Services are owned and operated by ppl, Inc., a Delaware Corporation (“we”, “us”, or “our”). This Privacy Policy applies to information collected through the Services, as well as other information provided to use online or offline by customers or users of ppl; however, it does not apply to information collected from our employees, contractors, or vendors. This Privacy Policy describes, among other things:

 

  • Personal and other information we collect about you
  • How we use your information
  • How we may share your information with third parties, and
  • Your choices regarding the personal information we collect about you.

 

Consent

 

By using the Services, you consent to this Privacy Policy. If you do not agree with this Privacy Policy, please do not use ppl or the Services. Information gathered through the Services may be transferred, used, and stored in the United States or in other countries where our service providers or we are located. If you use the Services, you agree to the transfer use, and storage of your Personal Information (as defined below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Services or ppl are deemed to occur in the United States, where our servers are located.

 

 

Collection of Your Personal and Other Information

 

When you use our Services, we collect Personal Information. The term “Personal Information” refers to information that can identify an individual, such as:

 

  • Name(s)
  • Personal or business address(es)
  • Email address(es)
  • Phone number(s)
  • Birthdate
  • Gender, 
  • Your precise geographic location, and
  • Information contained in any image, photograph, content, or profile you submit to us.

 

Our Services integrate with social media platforms, including Facebook, Twitter, and Instagram. When you connect a social media account to ppl, then we will collect authentication information that permits us to connect to your social media account. We will also collect information from your social media account (such as your name, email address, friend lists, images, photographs, content, or profile). Certain aspects of the Services will also access certain features of your device including its camera, location services (GPS), microphone, and contacts, and collect information from those features, such as photographs, videos, your precise location, audio recordings, and contact information.

 

When we partner with advertisers, they may engage you by asking questions or asking you to fill out a survey about their products or brands. If you choose to answer their questions, your answers will be collected and stored along with your Personal Information. You may always choose not to provide Personal Information or prevent ppl from accessing certain features of your device, but this may prevent you from receiving certain Services. We also collect non-Personal Information, that is, information that does not personally identify an individual. The non-Personal information we collect includes how you interact with the Services, information generally collected or “logged” by Internet websites or Internet services when accessed or used by users, and information about your web browser or device accessing or using the Services.

 

Examples of the non-Personal Information we collect are:

 

  • Your Internet Protocol (IP address)
  • Information about your mobile device, such as its maker or operating system version
  • The features of ppl
  • What information, content, or advertisements you view or interact with using ppl
  • Language preferences
  • Your location, and
  • Unique identifiers, meaning arbitrary codes or series of characters we create to identify unique users with Personal Information.

 

We will not use non-Personal Information to try to identify you, and if we associate any non-Personal Information with information that personally identifies you, then we will treat it as Personal Information. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather non-Personal Information. Information collected by the Services may be collected by us or one of our service providers, but in either case, this Privacy Policy will govern the collection, use, and sharing of the information.

 

 

Use of Your Information

 

We use the information we collect to:

 

  • Assist us in providing the Services
  • Set up accounts
  • Improve online operations
  • Process transactions, such as providing promotions or gifts
  • Provide customer service
  • Provide you with newsletters, RSS feeds, and/or other communications or services which you have signed up for or otherwise agreed to receive
  • Send or display offers and other content that is customized to your interests or preferences
  • Send account- or transaction-related communications, such as welcome letters or notifications
  • Perform research and analysis aimed at improving our products and services, and
  • Mange our systems.

 

We will only use your Personal Information in the way we specified when it was collected (including as described in this Privacy Policy).

 

 

Disclosure of Your Information

 

We will not disclose your Personal Information to third parties except as described below. 

 

We will disclose certain Personal Information to provide the Services, which will be apparent when you use or access ppl, or when you authorize or instruct us to do so, for example when you use the Services for their location-based social functionality, to post content, or redeem a gift.  

 

We may also disclose Personal Information to companies, agents, contractors, service providers, or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our website, marketing of our products and services, conducting audits, and performing web analytics).

 

We may partner with advertisers to provide you with special promotions or gifts, or to advertise products or services to you. If you choose to redeem an offer, we may provide your Personal Information to the advertising partner, including your name, email address, sex, and year of birth. If you provided any information to an advertiser in ppl (for example, by answering a question or filling out a survey), we may provide your answers in addition to your Personal Information. The advertising partner’s privacy policy will govern their use of your information, which may include marketing of other products or services to you.

 

We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Services, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property, or safety of us, our users, or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security, or technical issues. Finally, we reserve the right to transfer information (including your Personal Information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to ppl, or in the event of a bankruptcy, liquidation or receivership of our business. You will be notified via email or prominent notice on our website for 30 days of any such change in ownership or control of your Personal Information.

 

Lastly, we may also disclose non-Personal Information, anonymously aggregated with information about our other users, to our clients, business partners, merchants, advisers, investors, potential buyers, and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

 

Automatic Gathering of Information

 

Every time you open or use the ppl App, we collect Personal and non-Personal Information (discussed above). For example, using the Services may trigger the transmission of information between the app and our servers, and each time that occurs, our servers collect Personal and non-Personal information.

 

Your Choices, Our Transparency

 

You may request access to your Personal Information by sending an email to legal@ppl.network. We will try to locate and provide you with you Personal Information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request. But in either case we may need to retain it for legal reasons or for legitimate business purposes. You may also remove any content that you post to ppl using the deletion or removal options within the app. If you need further assistance with removing any content you posted through ppl, you can email us at legal@ppl.network. Removal of your posted content may not ensure complete removal from our computer systems, but we will prevent it from being publicly accessible.

 

We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy or others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Please be aware that if you request us to delete your Personal Information, you may not be able to continue to use ppl or the Services. Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit, and/or dispute resolution requirements.

 

You can opt out of receiving marketing emails from us by clicking on the “unsubscribe” link in the emails. Please note that it may take up to ten (10) business days for your request to be processed. Also, even if you opt out of marketing emails, we may continue to send you certain account-related emails, such as notices about your account and confirmations of transactions.

 

 

Children

 

We do not authorize users under 13 years of age to use the Services or ppl. We do not knowingly collect Personal Information from users under 13 years of age. If we learn that we have collected Personal information from a user under the age of 13, we will delete that data from our systems.

 

Information Security

 

We utilize reasonable information security measures to safeguard your Personal Information. For example, we encrypt sensitive data that is transmitted over the Internet and use firewalls to help prevent external access into our network. Unfortunately, however, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security. We restrict access to Personal Information to our employees, contractors, service providers, and agents who need to know that information in order to operate, develop, or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

 

Your California Privacy Rights

 

A California resident who has provided personal information to a business with whom he/she has established a business relationship for personal, family, or household purposes (“California Customer”) is entitled to request information about whether the business has disclosed Personal Information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of Personal Information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom Personal Information was disclosed in the preceding calendar year, as well as a list of the categories of Personal Information that were disclosed. 

 

However, under the law, a business is not required to provide the above-described lists if the business adopts and discloses to the public (in its privacy policy) a policy of not disclosing customer’s Personal Information to third parties for their direct marketing purposes unless the customer first affirmatively agrees to the disclosure, as long as the business maintains and discloses this policy. Rather the business may comply with the law by notifying the customer of his or her right to prevent disclosure of Personal Information to third parties for direct marketing purposes and providing a cost free means to exercise that right. To prevent disclosure of your Personal Information for use in direct marketing by the third party for its own purpose, do not opt in to or authorize such use when you provide Personal Information on ppl. Please note that whenever you allow your Personal Information to be shared with a third party to communicate with you, your information will be subject to that third party’s privacy policy. If you later decide that you do not want that third party to use your information, you will need to contact the third party directly. You should always review the privacy policy of any party that collects your information to determine how that entity will handle your information. 

 

California Customers may request further information about our compliance with California’s privacy law by emailing legal@ppl.network. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address.

 

Third Party Websites

 

Please note that the Services may link or integrate with third party sites, services, or apps. We are not responsible for the privacy or security policies or practices or the content of such third parties. Accordingly, we encourage you to review the privacy and security policies and terms of service of those third parties so that you understand how those websites collect, use, share, and protect your information.

 

Changes to this Policy

 

We may modify or update this Privacy Policy periodically with or without prior notice by posting the updated policy on this website (www.ppl.network/privacy). You can always check the “Last Updated” date at the top of this document to see when the Privacy Policy was last changed. If we make any material changes to this Privacy Policy, we will notify you by email or post a notice of the changes on our website or through ppl prior to the changes becoming effective. We encourage you to check this Privacy Policy from time to time. IF YOU DO NOT AGREE TO FUTURE CHANGES TO THIS PRIVACY POLICY, YOU MUST STOP USING PPLAND THE SERVICES AFTER THE EFFECTIVE DATE OF SUCH CHANGES (WHICH IS THE “LAST UPDATED” DATE).

 

Questions 

 

If you have questions about our Privacy Policy or wish to lodge a complaint, contact us at:

 

ppl, Inc. 

Legal Department

Attn: Privacy Agent

100 Wilshire Blvd.

Santa Monica, CA 90401

legal@ppl.network