Last revised: March 16, 2021
1. YOUR CONSENT
2. WHAT TYPES OF INFORMATION DO YOU COLLECT?
- Non-Personal Information: “Non-Personal Information” is un-identified and non-identifiable information pertaining to a user, which may be made available to us, or collected automatically via your use of the Services which does not enable us to identify the person from whom it was collected. This mainly consists of technical and aggregated non-identifiable usage information, such as system data related to your operating system and browser, smart-phone version, duration of usage of the Services, a user's 'click-stream' activity, keyboard language, etc.
- Personal Information: “Personal Information” is information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or may be of a private or sensitive nature relating to an identified or identifiable natural person. Identification of an individual also includes the association of such individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc. Personal Information does not include information that has been anonymized or aggregated and can no longer be used to identify a specific natural person. Personal Information that is collected by us consists of the following types of information:
- Social Platform Information. We collect login credentials to Social Platform of Users who wish to access Content published by other Users and/or publish their own Content through our Services. In addition, we may collect Personal Information associated with your Social Platform account, such as your username, picture, bio and email (all provided that such information was provided by you to Social Platform).
- Financial information. Any payments and related financial information within the Services are processed via third-party payment services that Paygo decides to make available at its discretion, and to which we generally have no access to .
- Usage Information. Your pay-per-read choices, and the articles and other content made available to you, and/or consumed, viewed or accessed by you through the Services.
- Content. We collect and store the Content you upload through the Services, which may include or imply Personal Information about you. Any Content you publish in connection with our Services will also be publicly available through our integration with the Social Platform.
- Impression Information. We collect Information on your impressions of, and reactions to content that appear on the Services that we receive from devices and software you use when you access and\or use the Services. This information may include the following: IP address, Device ID or unique identifier, device type, ID for advertising, operating system, information regarding your clicks, views and engagement with our Services, information concerning your traffic to and from the Services.
3. HOW DO YOU COLLECT INFORMATION FROM ME?
- We collect information through your use of the Service. In other words, we are aware of your usage of the Service and may gather, collect and record the information relating to such usage, including by using “cookies” and other tracking technologies, as further detailed in Section 9 below.
- We collect information which you provide us voluntarily. For example, we collect Personal information which you voluntarily provide when you request to register as User and provide us with your login credentials to Social Platforms.
4. WHY DO YOU COLLECT AND PROCESS MY INFORMATION?
- To provide and operate our Services and related services, including to enhance our Services and to provide Users with technical assistance and support.
- To send you updates, notices, notifications, newsletters, and additional information related to the Services and related offers.
- To create cumulative statistical data and other cumulative information that is non-personal, with which we and/or our business partners might make use in order to operate and improve our Services and provide related services.
- To monitor against prevent and handle fraud, illegal behavior on the Services, or other misuse of our Services, including inter-alia detecting, preventing, or otherwise addressing fraud or abuse.
- To comply with any applicable rule or regulation and/or response or defend against legal proceedings versus us or our affiliates.
5. WHAT ARE YOUR LEGAL GROUNDS FOR COLLECTING MY PERSONAL INFORMATION?
6. WHO DO YOU SHARE MY INFORMATION WITH AND WHY?
We may share information with third parties (or otherwise allow them access to it) only in the following manners and instances:
- Third Parties & Business Partners – We may share your information with a number of selected service providers, whose services and solutions are required or otherwise facilitate achievement of the purposes of processing set forth under Section 4 above. These third parties serve in facilitating and enhancing our Services and related services, namely to allow cloud hosting services (e.g. AWS), and data analytics of the functionality and usability of our Services (e.g. Google Analytics). Our third party services providers act as our sub-processors and may only process your information according to our instructions (which are given in accordance with the terms hereof).
- Law Enforcement – We may cooperate with government and law enforcement officials to enforce and comply with the law. We may therefore disclose any information to government or law enforcement officials as we believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect our or a third party’s property and legal rights, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
For avoidance of doubt, we will NOT sell (as “sell” is traditionally defined) your personal data. That is, we will not provide your name and email or other personally identifiable information to third parties in exchange for money. We may share anonymized or de-identified information with any other third party, at our sole discretion.
7. WHERE DO YOU TRANSFER OR STORE MY INFORMATION?
Your information may be transferred to, maintained, processed and stored by us and our authorized affiliates and service providers in the USA. Please note that USA data and privacy laws may not be as comprehensive as those in your country of residence. Residents of certain countries may be subject to additional protections, as set forth in below.
GDPR (EEA Users): This section applies only to natural persons residing in the European Economic Area (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is Paygo's policy to comply with the EEA's General Data Protection Regulation (“GDPR”). In accordance with the GDPR, we may transfer your Personal Information from your home country to the U.S. and/or other countries, provided that the transferee has provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available. Specifically, we may cause such transfer if we ensured that at least one of the following applies:
- The country to which Personal Information has been transferred, has been determined by the EU Commission to be a country providing adequate protection to the privacy rights of EU residents.
- Application of Standard Contractual Clauses (also known as "Model Clauses") where appropriate.
8. WHAT ARE MY RIGHTS?
If applicable to you under your country’s jurisdiction, you may have certain rights in connection with your Personal Information and how we handle it. You can exercise your rights at any time by contacting us via any of the methods set out in Section 15 below. Those rights may include, but are not limited to, the following:
- Right of access. You may have a right to know what information we hold about you and, in some cases, to have the information communicated to you. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.
- Right to correct Personal Information. We endeavor to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please let us know and we will correct it as soon as we can.
- Data deletion. In some circumstances you have a right to request that some portions of the Personal Information that we hold about you be deleted or otherwise anonymized.
- Data portability. In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.
- Restriction of processing. In some cases, you may have the right to request a restriction of the processing of your Personal Information, such as when you are disputing the accuracy of your information held by us.
We use certain monitoring and tracking technologies, including ones offered by third party service providers. These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide a better experience to our users. For example, these technologies enable us to: (i) keep track of our Users’ preferences and authenticated sessions, (ii) secure our Services by detecting abnormal behaviors, (iii) identify technical issues and improve the overall performance of our Services, and (iv) create and monitor analytics.
For avoidance of doubt - we do not “sell” your usage data, your personal data, your cookies tracking data to 3rd parties for advertising or targeting purposes. We do not share your personal data with the creator or publisher without your explicit approval
For example, we use the following third-party Cookies:
- Google Analytics - Google provides anonymized data about the visits made to our Services. For more information please read here: https://policies.google.com/privacy?hl=en&gl=uk
Learn more about your choices and how to opt-out of tracking technologies:
10. HOW DO YOU KEEP MY INFORMATION SECURE?
We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Information. Your information is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees, third party service providers or partners on a “need to know” basis, and strictly in order to enable us to perform the agreement between you and us.
Despite these measures, Paygo cannot provide absolute information security or eliminate all risks associated with Personal Information, and security breaches may happen. If there are any questions about security, please contact us at email@example.com.
11. HOW LONG WILL YOU RETAIN MY INFORMATION?
We will retain your Personal Information only for as long as necessary to achieve the purposes for collection and processing set forth above. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. If you withdraw your consent to our processing your Personal Information, we will delete your Personal Information from our systems (except to the extent retaining such data in whole or in part is necessary to comply with any applicable rule or regulation and/or to respond to or defend against legal proceedings brought against us or our affiliates).
12. HOW DO YOU PROTECT THE PRIVACY OF CHILDREN?
To use our Services, users must be over the age of thirteen (13). Therefore, we do not knowingly collect Personal Information from individuals under the age of thirteen and do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that individuals under the age of thirteen are not using the Services. If you believe that we might have any information from or about an individual under the age of thirteen, please contact us at firstname.lastname@example.org.
14. GENERAL INFORMATION
15. HOW CAN I CONTACT YOU?
If you wish to exercise any of the aforementioned rights or receive more information, please contact us using the details provided below:
Paygo Media, Inc.