2. COLLECTION AND USE OF PERSONAL INFORMATION
2.1. User Information
In order to use certain Services, Users must have a valid Penny App account to log into the Services (“Account”). Users have the option of signing up for an Account using a third-party login (through either Facebook or Google) or creating an Account using an email address. If you register using a third-party login, Penny App collects your name, email address, profile picture and location. When you register for an Account using email registration, Penny App collects your name, email address, location, information on the company you sell products for, customer information and social media information. This Personal Information is used for the following purposes:
* Verifying the User’s identity;
* Allowing Users to create a profile on the Platform;
* Storing log in credentials to allow Users to sync the Platform to their existing virtual back office; and
* Contacting Users about relevant information related to the Services.
Penny also collects Personal Information about our Users’ clients and prospects. Specifically, Penny can sync the following information about a User’s clients to the User’s Accounts in order to provide the services and provide product recommendations and suggestion:
* Users’ prospects’ names, collected from from Facebook (name and image);
* Users’ customers contact information and order history by allowing the User to log in and store credentials to sync the Platform to their existing virtual back office; and
* Users’ downline contact information by allowing the User to log in and store credentials to sync the Platform to their existing virtual back office. Personal Information collected about our Users’ clients is solely for the User's benefit within the Platform. Penny will not use the information to contact directly, share, or sell any data that has been collected. Users are responsible for ensuring that it has all the requisite permissions and consents to provide this Personal Information to Penny.
If you purchase a premium Account or any in-app purchases, Penny App will request credit card and billing information which is collected by our third-party payment processor. You hereby agree that all payments will be processed using Penny App’s third-party payment processor, Stripe, and that all such payments will be governed by Stripe’s terms and conditions available at https://stripe.com/ca/legal or as otherwise published by Stripe.
2.2 Transaction History
When Users use the Services, Penny App collects information about the User’s activity and transaction history. In particular, Penny App keeps track of the device used to log in, the time of day, the time spent on the app, location, actions completed and IP address. This Personal Information is used for the following purposes:
* To allow Users to keep track of their history;
* For Penny App’s accounting records;
* To enhance and customize User experience, including showing Users relevant contents; and
* To monitor compliance with our Terms of Service.
2.3 Marketing Communications
Penny App will use the contact information provided to notify Users of important information that is relevant to the Services and for marketing communications if the User chooses to opt in. Despite your indicated e-mail preferences, we may send you relevant notices where permitted by law.
2.4 Usage Data
Penny App may also collect certain information from Users of the Website and Services, such as Internet addresses, time spent logged into the Services and other usage data (“Usage Data”). This Usage Data is logged to help diagnose technical problems, and to administer our Website and Services in order to constantly improve the quality of the Website and Services.
3. SECURITY AND STORAGE
3.1 Storage Location
Penny App stores its data, including Personal Information, on Amazon Web Services servers located in the United States. By submitting any Personal Information or using the Services, you agree to this transfer, storing or processing of your Personal Information in the United States. You acknowledge and agree that your Personal Information may be accessible to law enforcement and governmental agencies in those countries under lawful access regimes or court order.
The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Information to us via the Internet. You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information or password for the Services to third parties.
4. DISCLOSURE OF PERSONAL INFORMATION WITH THIRD PARTIES
4.1 Disclosure to our Service Providers
We may from time to time employ or engage other companies and people to perform tasks on our behalf and need to share Personal Information with them to provide the Services. We reserve the right to use customer data to improve our products and services and to provide such third parties with the Personal Information that they need to perform their specific function. This includes third party companies and individuals employed or engaged by us to facilitate our products and services, including the provision of maintenance services, database management, customer relationship management, web analytics and general improvement of the Services, and businesses who engage our Services (to the extent provided for above). In particular, Penny App uses the following service providers: Stripe, Heroku, Datadog, Google Cloud Platform, Amazon AWS, Segment IO, Heap Analytics, and Google Analytics. Business Transfers If we (or any of our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Personal Information may be made available or otherwise transferred to the new controlling entity, where permitted under applicable law.
4.2 With Your Consent
4.4 As required by law
We may disclose your Personal Information to third parties without your consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Users, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. Further, we may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to:
* satisfy any applicable law, regulation, legal process or governmental request;
* enforce our contracts or user agreement (Terms of Service), including investigation of potential violations hereof; and
* detect, prevent, or otherwise address fraud, security or technical issues.
6. ACCESS, CORRECTION AND ACCURACY
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information, although in certain limited circumstances, and as permitted under law, we may not be able to make all relevant information available to you, such as where that information also pertains to another User. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner. We will make every reasonable effort to keep your Personal Information accurate and up to date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service.
9. Links to Other WebSites AND SERVICES
1. ADDITIONAL INFORMATION