Privacy Policy

 

Penny AI Technologies Inc. (“Penny App”, “We”, “Us”)”) has created this privacy policy (“Privacy Policy”) in order to set out how we collect, use, and disclose personal information through the Penny App platform and our related personal contact management services and applications (collectively, together with the Penny App platform, the “Services”) and website located at https://www.pennyapp.com/ (the “Website”). Any capitalized terms in this Privacy Policy shall have the same meaning as set out in our Terms of Service. The privacy of our users is of great importance to us. By visiting our Website or using the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy and you hereby consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.

1. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy covers our collection, use and disclosure of information about identifiable individuals (“Personal Information”), who visit our Website or use the Services (“Users”).

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.

2.5 Cookies

Tracking technologies, such as cookies, beacons, scripts and tags, are used by us and our third-party partners. These technologies are used in analyzing trends, administering the Website or Services, tracking Users’ movements around the Website or Services, gathering demographic information about our User base as a whole and collecting information about your browsing activities over time and across different websites following your use of the Website. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis. Various browsers may offer their own management tools for removing these types of tracking technologies. Standing alone, cookies do not identify you personally. They merely recognize your browser. Cookies come in two flavors: session and persistent-based. Session cookies exist only during an online session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you've closed your browser or turned off your computer. Penny App uses session cookies containing encrypted information to allow the system to uniquely identify you while you are logged in. This information allows Penny App to process online transactions and requests. Session cookies help us make sure you are who you say you are after you've logged in and are required in order to use the Service. Penny App uses persistent cookies that only Penny App can read and use, to identify the fact that you are a Penny App User. We are especially careful about the security and confidentiality of the information stored in persistent cookies. Users who disable their web browser’s ability to accept cookies will be able to browse our Website but may not be able to use all features of our Services. Our Website currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

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.

3.2 Security

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

If we need to use or disclose any Personal Information in a way not identified in this Privacy Policy, we will notify you and/or obtain your express consent as required under applicable privacy laws.

4.3 Affiliates

We may also share your Personal Information with our subsidiaries or other affiliated companies for purposes consistent with this Privacy Policy.

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.

5. RETENTION

We will keep your Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy.

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.

7. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of Personal Information we collect is subject to the Privacy Policy in effect at the time such information is collected, used or disclosed. If we make material changes or changes in the way we use Personal Information, we will notify you by posting an announcement on our Website or sending you an email prior to the change becoming effective. You are bound by any changes to the Privacy Policy when you use the Website or Services after such changes have been first posted.

8. CHILDREN

Penny App does not knowingly collect Personal Information from children under the age of 13. If you are under the age of 13, please do not submit any Personal Information through the Website or Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information on the Website or Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to Penny App through the Website or Services, please contact us, and we will endeavor to delete that information from our databases.

9. Links to Other WebSites AND SERVICES

This Privacy Policy applies only to the Website and Services. The Website or Services may contain links to other web sites or services not operated or controlled by Company (the “Third Party Services”). The policies and procedures we described here do not apply to the Third Party Services. The links from the Website or Services do not imply that we endorse or have reviewed the Third Party Services. We suggest contacting those third parties directly for information on their privacy policies.

10. EXCLUSIONS

This Privacy Policy does not apply to any Personal Information collected by Penny App other than Personal Information collected through the Website or Services. This Privacy Policy shall not apply to any unsolicited information you provide to Penny App through the Website or Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Website or Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Penny App shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

1. ADDITIONAL INFORMATION

You can help by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your Personal Information, if you have any questions, comments or suggestions about our Privacy Policy or practice, or if you find any errors in our Personal Information about you, please contact us at: privacy@pennyapp.com Last Updated: November 8, 2018