PEPO PRIVACY POLICY

Last Updated:  21 October, 2016

This Privacy Policy explains how information about you is collected, used and disclosed by Pepo, Inc. ("Pepo") when you use our mobile apps, websites and other online services of Pepo (collectively, the "Services") or when you otherwise interact with us. This Privacy Policy does not apply to the Pepo Campaigns email marketing service, for which a different privacy policy applies.

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification).  We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us.  For example, we collect information when you create an account, participate in any interactive features of the Services, fill out a form, participate in a contest or promotion, communicate with us via the Pepo app or third party social media sites, request customer support or otherwise communicate with us.  The types of information we may collect include your name, phone number, email address, and any other information you choose to provide.

Information We Collect Automatically When You Use the Services

When you access or use our Services, we automatically collect information about you, including:

  • Channel and Message Information:

      We collect information about the channels you create or participate in and the messages you send and receive. All channels and messages are stored in our servers in the cloud. Your copy of the Pepo app stores a local cached copy of channels you are a part of and messages you are entitled to view, which is updated when the app connects to our servers via an Internet connection.
  • Log Information:

      We collect log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
  • Device Information:  

    We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
  • Location Information:

      We may collect information about the location of your device each time you access or use one of our mobile applications or otherwise consent to the collection of this information, such as when you search for channels near your location.  For more details, please see "Your Choices" below.
  • Contacts.

      With your authorization or permission, we collect information about your contacts on your mobile device.
  • Information Collected by Cookies and Other Tracking Technologies:

      We use various technologies to collect information, including cookies and web beacons.  Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits.  Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness.  For more information about cookies, and how to disable them, please see "Your Choices" below.

Information We Collect From Other Sources

We may also obtain information from other sources and combine that with information we collect through our Services.  For example, if you create or log into your account through a third party social media site or link your Pepo account with your account on a third party social media site, we will have access to certain information from that site, such as your name, account information and lists of friends and followers, in accordance with the authorization procedures determined by such social media site.

Use of Information

We may use information about you for various purposes, including to:

  • Provide, maintain and improve our Services;
  • Provide and deliver the products and services you request;
  • Send you technical notices, updates, security alerts and support and administrative messages, including via SMS;
  • Respond to your comments, questions and requests and provide customer service;
  • Communicate with you about products, services, offers, promotions, rewards, and events offered by Pepo and others, and provide news and information we think will be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Pepo and others;
  • Personalize and improve the Services and provide content or features that match user profiles or interests;
  • Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;
  • Link or combine with information we collect about you; and
  • Carry out any other purpose described to you at the time the information was collected.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

  • We share information about you with other users who you follow, who are following you, who are in the same channel as you, who have your phone number in their device phonebook, or with whom you share friends in common.  This information includes your public profile information (such as your username and name) profile photo and bio, a list of who you follow and who follows you, the social media accounts that you have integrated with our Services, and the public channels in which you’ve participated;
  • Content you post to a channel will be shared with other users participating in that channel in accordance with the privacy settings of that channel.  For information about the different channel privacy settings, please see our FAQ. If you submit any content to a channel marked “public,” your username along with the content you post may be broadcast publicly within or outside of the Services;
  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
  • If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Pepo or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
  • Between and among Pepo and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and
  • With your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

Social Sharing Features

The Services offers social sharing features and other integrated tools, which let you and other users share channel messages and other content or actions with other media.  For example, when you send a message in a channel, another user in the channel may be able to share your message with others or the public via Facebook. The availability of such sharing features depends on the settings that the creator of the channel established for the channel, and the settings that the other user established with the entity that provides the social sharing feature.  For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

Analytics Services Provided by Others

We may allow others to provide analytics services on our behalf across the Internet and in apps.  These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and apps, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, and links clicked.  This information may be used by Pepo and others to, among other things, analyze and track data, determine the popularity of certain content, deliver content targeted to your interests on our Services and other websites and better understand your online and in-app activity.  

Security

Pepo takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction, including by using reasonable measures to encrypt channel content in the cloud. Please note that we do not provide end-to-end encryption.

Transfer of Information to the U.S. and Other Countries

Pepo is based in the United States and the information we collect is governed by U.S. law.  By accessing or using the Services or otherwise providing information to us, you consent to the processing, transfer and storage of information in and to the U.S. and other countries, where you may not have the same rights and protections as you do under local law.

Your Choices

Account Information

You may change or hide information you have provided and information you have authorized us to receive from third party social media services, by logging into your account.

You may deactivate your account from the Settings page on your Pepo Profile or by emailing us at support@pepo.com. However, any channels you have created and any messages that you have sent prior to deactivating your account (that you have not otherwise marked for deletion as mentioned below) may remain viewable by other users after you deactivate your account. We may retain this content as required by law or for legitimate business purposes

Channel or Message Information

The Services provide a “delete” feature which enables you to remove a channel you have created (including all messages in that channel) or individual messages you have sent within a channel. Using this feature will cause the channel or message to no longer be visible by other users via the Services. However, a user’s copy of the Pepo app may have a temporary local cache of the channel or message that will remain available to the user until the app has a chance to connect to our servers via an Internet connection. Pepo may retain a copy of the  channel or message you mark for deletion on its servers for up to 365 days, except that we may keep it longer if required by law.

The removal of messages published to third-party social networking services is subject to the policies of those services, and outside the control of Pepo. If you have any questions about your deactivating your account or removing channels, please contact us at support@pepo.com.

Location Information

When you first use a feature in our mobile app that needs to know your location, such as when you search for channels near your location, you will be asked to consent to the app's collection of this information.  If you initially consent to our collection of location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device.  If you do so, the features that depend on your location will no longer function.  You may also stop our collection of location information by following the standard uninstall process to remove all our mobile app from your device.

Cookies

Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.  Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services accessed through a web browser.

Promotional Communications

You may opt out of receiving promotional emails or messages from Pepo by following the instructions in those emails or messages.  If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

Mobile Push Notifications/Alerts

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device.  You can deactivate these messages at any time by changing the notification settings on your mobile device.

Contact Us

If you have any questions about this Privacy Policy, please contact us at:  support@pepo.com