Data Policy

October 10, 2016

Privacy and Data Handling Policy, Inc. (“”) respects the data provided by our users and we are committed to protecting the personal information collected about, or provided by, you, your Agents and End-Users. To that end, we have designed the Privacy and Data Handling Policy (this “Policy”) to guide how we store, collect, manage and use the personal information we obtain in connection with our Services. This Policy applies only to information submitted and collected by through use of the Services and does not apply to information that may be collected offline or collected through any other method including your use of any website or its affiliated entities may operate.

By using and accessing the website and its Services, you agree to be bound by the terms of this Policy. may, from time to time, make changes to this Policy. If we make any material change to this Policy we will notify you of those changes by posting them on this site and we will indicate the date of last revision. Your continued use of the Services after changes have been posted to the Policy will constitute your acceptance of those changes.

Last updated: October 17, 2017

This Policy describes the treatment of information provided or collected on or through our website, which is currently located at (the “Site”). This Policy applies to the Service, but not to websites maintained by other companies or organizations to which we may provide links. When you connect to these websites via a link, this Policy no longer applies. We are, therefore, not responsible for the content or activities provided or created on such sites. If you have any questions about this Policy or our data practices, please do not hesitate to contact us.



Representatives that interact with Consumers on behalf of an Business Partners or Subscribers.

Business Partners or Subscribers

Business Partners are companies in the network that have registered for, or are subscribers of, the Services.


Consumers are those individuals who download, use or otherwise interact with the Service using tools and related services provided by This may include, but is not limited to, website users, social messaging users, or mobile application users.

Hashed Data

Hashing is a technique that anonymizes data. Storing information as hashed data allows to associate certain information with a Consumer without directly affiliating him or her with personal information. may store sensitive information in hashed form to help protect the privacy of such Consumers while providing the Services. Please refer to the Data Security, Integrity and Retention section of the Policy for additional information about how we use “hashing” to safeguard Consumer information.

Web Beacons

A web beacon (sometimes referred to as a “pixel tag”) is a programming code that can be used to display an image on a website, email or other communication. Web beacons are typically one-pixel, transparent images and are used to transfer an individual’s unique user identification (often in the form of a cookie) to a database in order to associate that individual with previously acquired information about him or her in a database. uses web beacons keep track of certain online behavior (e.g., the websites you visit, the mobile applications you use, your interaction with emails etc.) in order to help us to determine the types of things that you find the most interesting.

The Information We Collect

Personal Information is information that others can use to identify, locate, or contact you, including but not limited to, your name, email address, postal address, and phone numbers (collectively “Personally Identifiable Information” or “PII”). Specifically, may collect the following PII in connection with your use of the Services:

In addition to the PII listed above, may also collect:

In some cases we may assign an identification number to your device (“Device ID Number”). Device ID Numbers may be linked with PII only for the purposes of providing the Services or for internal reporting purposes. We will never rent or sell your PII.

You can enable or disable geolocation services when you use our services at anytime, through your mobile device settings.

For additional information regarding the steps we take to safeguard your information, please refer to the Data Security, Integrity and Retention section of the Policy.

How The Information Is Collected


Depending on the nature of your interaction with the Services, may collect information from you automatically and/or when you voluntarily choose to provide us with information. We may also acquire information from other trusted sources to update or supplement the information that you voluntarily provide to us or that we collect automatically.

By downloading and using a mobile application, or by using a website, you grant the application developer with permission to collect device information and share it with may track this information over time and across multiple applications (and may also combine the device information with anonymous information from other sources) in order to deliver the Services. In addition, may collect information from Consumers through use of a Cookie, Web Beacon or similar tracking technologies if the Consumer accesses the Services from a browser or is redirected to a browser by links provided through the Services. Certain links may redirect you to a browser where may use a Cookie to track Consumer activities.

A “cookie” is a small bit of record-keeping information that sites often store on a user’s computer or mobile device. Cookies are typically used to quickly identify a user’s device and to “remember” things about the user’s visit. For example, we may use cookies or a similar method to keep track of your app session. Information contained in a cookie may be linked to your personal information for this purpose. You can disable cookies or set your browser to alert you when cookies are being sent by your device or computer although this may affect your ability to use many of the features of the Service.

Business Partners:

If you are a Business Partner, we collect information that you voluntarily provide us during your interaction and registration with the Services. For example, you may choose to provide with information when you directly request information or services from us, submit or receive a payment, or complete the online forms available on the Site.

We may also collect certain types of information automatically, including through the use of Cookies, Web Beacons and other similar tracking technologies. These tracking technologies allow to personalize your experience with the Services and keep track of certain online behavior in order to help us determine the things that you find most interesting.

Third Party Sites

We may share certain personal information we collect about you with our service providers who perform functions necessary to providing the Services on our behalf. Examples include processing credit card payments, sending postal mail and email, analyzing data, and providing marketing assistance and customer service. These service providers are not authorized by us to use or disclose personal information except as needed to perform their functions or comply with legal requirements, and they may not use it for any other purpose. Further, they must process the personal information in accordance with this Online Privacy Policy. We do not disclose or transfer your personal information to third parties for any other purpose.

How We Use Information uses the information we collect about you to provide the Services and to gain a better understanding of the products and services that may interest you. For example, we may use your information in order to:

For additional information regarding choices you may have with respect to our use of your information, please refer to the Your Controls section of the Policy.

The Services may link to third party websites, applications and/or other third party content. Please note that cannot control the treatment of your information by such third parties, and that the privacy practices of third parties may differ from those described in this Policy.

International Transfer of Collected Information

We primarily store personal information we collect within the United States, the European Economic Area (the “EEA”) and in other countries and territories. To facilitate our global operations, we may transfer and access personal information from around the world, including from countries other than those in which has operations.

If you are visiting our websites from the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal information to the United States and other countries and jurisdictions. By providing your personal information, you consent to any transfer and processing in accordance with this Policy.

Sharing With Third Parties

Our Services may contain links to websites operated by other companies. Some of these third-party sites may be co-branded with an logo, even though they are not operated or maintained by does not share your personal information with those websites and is not responsible for their privacy practices. Once you have left our website, including leaving the site for the processing of a credit card, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

Compliance with Laws and Law Enforcement Requests; Protection of Our Rights

In certain circumstances, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security and law enforcement requirements. We may disclose personal information in response to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Service Agreement, or as otherwise required by law.

Your Controls

If you are a Consumer to the Services or authorized as an Agent under a subscriber’s account to the Services and would like to opt-out of getting marketing communications from us please contact us at or follow the unsubscribe instructions included in each marketing email.

We process and store service data on behalf of our subscribers. We have no direct relationship with the individuals with whom our subscribers may interact using the Services. If you are an individual interacting with a subscriber of our Service and would no longer like to be contacted by that subscriber, please contact that subscriber directly.

Changes to this policy

If we are going to use your previously collected personally identifiable information in a manner materially different from that stated in this privacy policy at the time of collection, you will be notified via email if possible. You will have a choice as to whether or not we use your information in this different manner and instructions for how to make that choice will be included in the notification. We will not use personally identifiable information in a manner materially different from that stated in our privacy policy at the time of collection without notifying you.

Correcting, Updating and Removing Your Information

Upon request we will provide you with information about whether we hold, or process on behalf of a third-party, any of your personal information. To request this information please contact us at Subscribers to our Services may update or change their Account Information by editing their profile or customer record or by contacting To make a request to have personal information maintained by us returned to you or removed, please email Requests to access, change, or remove your information will be handled within thirty (30) days.

An individual who seeks access to, or who seeks to correct, update, or delete inaccuracies in personal information stored or processed by us on behalf of a Subscriber should direct their query to the Subscriber. Upon receipt of a request from one of our Subscribers for us to remove the data, we will respond to that request within thirty (30) days. We will retain personal information that we store and process on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at

If you are a Subscriber or otherwise provide us with personal information in connection with your use of our Websites or Services, we will delete this information upon your request, provided that, notwithstanding such request, this information may be retained for as long as you maintain an account for our Services, or as needed to provide you with our Services, comply with our legal obligations, resolve disputes and enforce our agreements.

Children’s Privacy

We do not use the Services to knowingly solicit data from or market to children under the age of thirteen (13). We request that such individuals do not provide personal information through the Services. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should promptly contact us and we will take reasonable steps to ensure that such information is deleted from our files.

Data Security, Integrity and Retention

Your privacy is very important to and we are committed to protecting your personal information from unauthorized access, use or disclosure. We have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards. For example, we use firewalls, encryption technology and other automated software designed to protect against fraud and identity theft.

In addition, we take steps to ensure that information is stored in an anonymous format wherever possible through “hashing”. When a Consumer downloads and uses an App or website that requests to provide the Service, we may collect and process information locally on the Consumer’s mobile or desktop device. This allows us to identify the sensitivity level of certain device information prior to transferring it to our servers for storage. Rather than sending sensitive device information as raw data that can be easily associated with the relevant Consumer, we only transfer anonymous hashed representations of certain types of information back to Our servers then associate the hashed representations with a unique anonymous identifier assigned to each Consumer by When a Consumer subsequently interacts with the Services, this process allows us to provide the Service without storing the sensitive information in a form that would be easily readable to unauthorized third parties. also protects Consumer privacy by seeking to minimize the amount of sensitive data that we store on our servers in the first place. You may also contact us anytime with your questions or concerns. retains the raw data it collects from Consumers for as long as needed to provide the Services. The information received from Business Partners is retained for as long as needed to provide you services. We will retain and use the information we receive for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

You acknowledge that all information, data, text, software, music, sound, photographs, graphics, video, messages, tags, or other materials (“Content”), whether publicly posted or privately transmitted, are the sole responsibility of the person from whom such Content originated, and that You, and not, is entirely responsible for all Content that you upload, post, email, transmit or otherwise make available via the Service. You understand that by using the Service, you may be exposed to Content that is offensive, indecent or objectionable. Under no circumstances will or its parent, holding, subsidiary or related companies, affiliates, officers, agents or employees, as the case may be, be liable in any way for any Content or any loss or damage, no matter the cause of the loss or damage, of any kind incurred as a result of the use of the Service.

Credit Card Payments complies with the Payment Card Industry Data Security Standard (“PCI”). However, we contract with a third party to collect and process credit card payments for the Service. We have ensured this company complies with the practices in this Online Privacy Policy but for specific information on the protection of your data through their service please visit their website.

Privacy Shield Frameworks complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

In compliance with the Privacy Shield Principles, commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact at: has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.

For residual Privacy Shield disputes that cannot be resolved by the methods above, you may be able to invoke a binding arbitration process under certain conditions. To find out more about the Privacy Shield’s binding arbitration scheme, please see:

The Federal Trade Commission has investigation and enforcement authority over our compliance with the Privacy Shield.

Contact Us

If you have any questions or comments about this Policy, please write to us at:, Inc.
Legal Department
278 Hope St, Unit A
Mountain View, CA 94041

You can also contact us via email at

Please be sure to include your name, address and email address in any correspondence to us so that we can respond to your inquiry in a timely manner.