Effective Date: September 1, 2022
Piemob offers two different types of services. First, it offers prepaid wireless phone customers the ability to make their prepayments wirelessly (the “Wireless Services”). Second, it offers its Wireless Services customers an opportunity to download and use the Piemob App (the “App”) to sign up with various “Reward Programs,” which allow participants to earn credits (“Pie Slices”) that can be used to pay for all or part of their Wireless Services. The types of interactions involved with the App may include answering consumer surveys, watching video ads and playing video games. As explained more fully in 2 below, to benefit from the Reward Services, a consumer must consent to the collection, use and/or disclosure of personal information of such consumer to and by a particular “Adtech Platform,” and/or Advertiser, both as defined in 1 below.
“Adtech Platform” “ATP” “Supply Side Platform” or “SSP” means a company that offers Reward Programs directly to consumers through the App.
“Advertiser” means a company that provides content for consumers, who have agreed to participate, either through an ATP or directly, in a Rewards Program.
“Advertiser Content” means content provided by Advertisers.
“Advertiser Requirements” means requirements set by an Advertiser that a consumer must meet in order to participate in a Rewards Program.
“Business” means a company that collects consumers’ personal information and determines the purposes and processing of such information and meets the other criteria for that definition set forth in the California Consumer Privacy Act. We may or may not qualify as a Business under California law for purposes of applying the California Consumer Privacy Act.
“Consumers” “customers” or “users" means individuals, including you, who use our Wireless Services.
“Personal Information” or “PI” means any information that can reasonably be linked to an identified or identifiable individual except for the following:
“Personal Information” does not include publicly available information. For purposes of this paragraph, “publicly available” means information that is lawfully made available from federal, state, or local government records.
“Personal Information” does not include consumer information that is deidentified or aggregated, so that it is not linked or reasonably linkable to any consumer or household.
“Publisher” means a company that gives its customers the ability to participate in Reward Programs which provide various forms of consideration to compensate consumers for providing, and permitting the use of, their Personal Information.
“Software Developer Kit” or “SDK” means software provided by an ATP (Ad Tech Platform) to Piemob that is inserted into the App to allow a consumer to connect directly with an ATP.
“You” “User” “Consumer” or “Data Subject”, means an individual accessing or using a particular service.
“We” or “us” means Piemob.com, Inc.
2. Wireless Services versus Reward Programs.
As discussed more fully in 3 and 4 below, we collect, use and/or disclose your Personal Information relating to the Wireless Services subject to your rights which may include rights to opt out and view, correct and delete such information. Privacy Protections in connection with the Reward Programs are very different. We enter into an agreement with an Ad Tech Platform to permit the operators of that platform to enter into agreements with our users to offer credits that can be applied to amounts owed for prepayments for Wireless Services. Here is how it works.
3. Types of Personal Information We Collect.
In connection with providing Wireless Services to you we may obtain Personal Information from you, or from the connection of your device to our system. Examples of Personal Information that we may collect include:
name, email address, phone number, address, usage data, wireless carrier, customer support history, billing data, payment history, mobile device information, including, but not limited to, unique ID, the IP address, the mobile operating system used, your mobile Internet browser, Gmail address used for login to the Wireless Services, your Android Advertising ID, job titles, user names, passwords, contract preferences, contact or authentication data, billing addresses, Reward Services in which you participate, credits to which you are entitled, credits distributed to you, credits redeemed and access device ID or IP.
For another perspective, Categories of Personal Information we may collect include (categories may overlap):
(a) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.
(b) Any categories of Personal Information that would likely be maintained in government, health, financial or institutional records such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card, debit card number, or any other financial information, medical information, health insurance information.
(c) Characteristics of protected classifications under State or Federal law. The protected classifications could include such matters as race, religion, ethnicity, age and sexual orientation.
(d) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
(e) Biometric information.
(f) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
(g) Geolocation data.
(h) Audio, electronic, visual, thermal, olfactory, or similar information.
(i) Professional or employment-related information.
(j) Nonpublic education information, defined as information that is not publicly available.
(k) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
4. Sources of Information.
We obtain the types of Personal Information listed above from the following types of sources:
(a) Directly from you. Fo example, we may gather information from your application for Wired Services
(b) Indirectly from you. For example, we may gather data from the way you use our App.
(c) From Service Providers. For example, we may gather information from Service Providers who collect information on our behalf.
(d) Automatically from you. Examples would be by use of information cookies.
5. Use of Your Personal Information.
We may use your Personal Information for any of the following purposes:
(a) To provide and maintain our Wireless Services, including to monitor the usage of our Wireless Services and to improve the services.
(b) To manage your account with us.
(c) To perform a contract with you.
(d) To contact you by email, telephone calls, SMS or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications relating to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
(e) To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information.
(f) To manage your requests to us.
(g) To encourage you to extend your term with us and/or upgrade your Wireless Services.
(h) To distribute credits, in the form of Pie Slices him him him, to those consumers who have participated in a Rewards Program and completed their obligations.
(i) To support legal compliance.
(j) In legal proceedings.
(l) To support cybersecurity.
(m) For business transfers such as to evaluate, provide due diligence for or conduct a merger, acquisition, equity investment, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets or equity, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding in which Personal Information held by us about our customers is among the assets, or value of the equity, transferred.
(n) To obtain, and in connection with trying to obtain, loans or other financing.
(o) For other purposes that support and are in line with the above permitted uses such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our services, products, marketing and customer experiences.
6. Disclosure of Your Personal Information.
We do not sell or share your Personal Information with others except as follows:
(a) If we take part in a merger, divestiture, restructuring, reorganization, dissolution, investment or other sale or transfer of some or all of our assets, or acquisition of some or all of our outstanding equity whether as a going concern or as part of a bankruptcy, liquidation or a similar proceeding, in which Personal Information held by us about our customers with another company or as part of a spin out or sale of substantially all the assets of our company, we may transfer any data we are holding to the merged entity or other acquiring or surviving party. We also may share your Personal Information as part of due diligence in connection with an attempt to accomplish any of the events specified above in this subpart.
(b) Service Providers. We may share your information with service providers to monitor and analyze the use of our services, for payment processing, to contact you or to otherwise assist us in providing services and/or running our business.
(d) Legal Requirements. We may share your information as required by law or as otherwise necessary to support compliance with applicable law.
(e) Legal Proceedings. We may disclose your Personal Information if reasonably needed in a legal proceeding.
(f) We may share your Personal Information to enhance or assist in providing and maintaining cybersecurity.
(g) Physical Harm. We may share your Personal Information to try to prevent physical harm to an individual.
(h) Damage to Property. We may share your Personal Information to try to prevent damage to property.
(i)We may disclose your Personal Information for any other legal purpose provided we have your consent.
WE DO NOT SELL YOUR PI TO OR SHARE YOUR PI WITH THIRD PARTIES FOR MARKETING PURPOSES WITHOUT YOUR CONSENT.
8. Aggregated Data.
We may use and share, without restrictions, PI that is aggregated, anonymized or otherwise de-identified sufficiently to reasonably prevent a person from linking, or otherwise identifying, any individuals as being the subject of the information.
9. Retention of PI.
10. Opt Out and Opt in.
You have the right to opt out from having your PI related to Wireless Services sold or shared with a third party for marketing purposes. However that would not be necessary inasmuch as we do not and will not sell your PI for marketing purposes without your consent. You have the right to opt in to a Reward Program which will require your consent.
11. Age Restrictions.
No consumer under the age of 16 is permitted to enter into a contract with an ATP or Advertiser through the Piemob App. If we know that a consumer’s age is 13 or more, but less than 16, we will not collect, use or disclose any Personal Information of the consumer without the consumer’s consent. Such a consumer may use our Wireless Services.
12. The following additional rights are hereby provided to residents of the State of California in connection with the providing of the Wireless Services as required to comply with the California Consumer Privacy Act.
(a) The right to review the Personal Information collected from you by us.
(b) The right to correct any errors in the Personal Information collected by us from you.
(c) The right to prohibit any transfer of PI for marketing purposes.
(d) The right to require deletion of any Personal Information collected from the consumer.
(e) The right not to be discriminated or retaliated against for exercising any of your privacy rights. Charging different amounts in proportion to the value of the Personal Information is permitted.
To exercise any of the above rights you must send an email to: firstname.lastname@example.org and provide what we reasonably determine is necessary to satisfy us that you are sending us a verifiable consumer request. Because we operate exclusively online and have direct relationships with our customers, we are not required to have a toll-free number and one other method for requesting these items. However, the right to delete or have PI deleted is subject to the following:
(a) A business that receives a verifiable consumer request from a consumer to delete the consumer’s personal information shall delete the consumer’s personal information from its records, notify any service providers or contractors to delete the consumer’s personal information from their records, and notify all third parties to whom the business has sold or shared the personal information to delete the consumer’s personal information unless this proves impossible or involves disproportionate effort.
(b) The business may maintain a confidential record of deletion requests solely for the purpose of preventing the personal information of a consumer who has submitted a deletion request from being sold, for compliance with laws or for other purposes, solely to the extent permissible under applicable law.
(c) A service provider or contractor shall cooperate with the business in responding to a verifiable consumer request, and at the direction of the business, shall delete, or enable the business to delete and shall notify any of its own service providers or contractors to delete personal information about the consumer collected, used, processed, or retained by the service provider or the contractor. The service provider or contractor shall notify any service providers, contractors, or third parties who may have accessed personal information from or through the service provider or contractor, unless the information was accessed at the direction of the business, to delete the consumer’s personal information unless this proves impossible or involves disproportionate effort. A service provider or contractor shall not be required to comply with a deletion request submitted by the consumer directly to the service provider or contractor to the extent that the service provider or contractor has collected, used, processed, or retained the consumer’s personal information in its role as a service provider or contractor to the business.
(d) A business, or a service provider or contractor acting pursuant to its contract with the business, another service provider, or another contractor, shall not be required to comply with a consumer’s request to delete the consumer’s personal information if it is reasonably necessary for the business, service provider, or contractor to maintain the consumer’s personal information in order to:
- (i) Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by the consumer within the context of an’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
- (ii) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
- (iii) Debug to identify and repair errors that impair existing intended functionality.
- (iv) Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
- (v) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
- (vi) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the achievement of such research the consumer has provided informed consent.
- (vii) Enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
- (viii) Comply with a legal obligation.
- (ix) Otherwise use the consumer’s personal information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.
13. Securing of Personal Information.
We use physical, technical, and administrative procedures designed to safeguard your information and data security and to prevent unauthorized access. These safeguards take into account the sensitivity of the information we collect, process and store and the current state of technology. Although we take such measures to safeguard against unauthorized access to such information, the Internet and the services we provide are not 100% secure so we cannot assure you that all information we collect or store will be protected at all times from all unauthorized access.
15. For Additional Information.
For technical support you can reach us at: email@example.com