Pao’s Privacy Policy

Thank you for reviewing Pao’s Privacy Policy! We hope you love reading it as much as we loved writing it.

Introduction

Pao is a product of Pao App Inc (the “Company,” “we,” “us” or “our”), the company behind the Pao service (Service). The Service is designed as an online and Smartphone application (App) providing user-generated, location-based recommendations for all sorts of experiences, including restaurants, things to do, and places to stay.  The individual or organization that subscribes to the Service will be referred to as the “Subscriber” or “you”.

This privacy policy (Privacy Policy) sets out the ways in which we collect and use your personal data (your Personal Information) in connection with our business. It also explains what rights you have to access or change your personal data.

By using our App you understand and agree that we are providing a platform for you to post content, including photos, videos, comments, historical location data and other materials (“User Content”), to the App and to share User Content publicly. This means that other Users may search for, see, use, or share any of your User Content that you make publicly available through the App, consistent with the terms and conditions of this Privacy Policy and our Terms of Service. Our Policy applies to all visitors, users, and others who access the App (“Users”).

Contacting Pao about privacy questions or concerns

If you have any questions about this Privacy Policy, or any queries, requests or complaints in regard to the Service or the use of your Personal Information, please contact Pao by sending an email to the following address (indicating “PRIVACY REQUEST” in the message line): admin@thepaoapp.com. You can also contact us through the Settings/Contact menu option within the App.

If you contact Pao by e-mail, we may keep a record of your correspondence or comments.  We may ask for your name, e-mail address and contact information in order to send you a reply.

Third party information and links

Information may be sourced from third parties by Pao and/or you in compiling and providing the Service.  Where such third party information forms or may form part of the Service, we have relied on the information provided to us by third parties. We do not guarantee the correctness or completeness of the information provided on the Service.

The Service may contain advertisements (which may be directed to Subscribers based on information you include in your personal profile when using the Service), plug-ins and links to other websites that are owned and operated by third parties. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. The information practices of those websites linking from or to the website are not covered by this Privacy Policy or the Terms of Use, and Pao is not responsible and cannot be held liable for the content or practices of any third party website. Please consult each website’s privacy policy. The provision of a link on the Service does not constitute an endorsement of that website or related any products or services.  When you leave our App or website, we encourage you to read the privacy notice of every website you visit.

Sharing Directly with Third Parties

You and other Subscribers may share content on the Service via a number of social media platforms (including, without limitation, Facebook, Twitter, Google+) and email.  When content is shared in this way, a link to that content is sent out via the relevant social media channel.

When you share Personal Information through the Service with third parties (including other Subscribers) and via other online services (such as Facebook), that information will remain under the control of the third party or other service in question. Pao has no control over the use of Personal Information that has been shared with third parties and this Privacy Policy Statement does not relate to such use of the Subscriber’s Personal Information. We recommend that you review the privacy policies of third parties to whom you share Personal Information with via the App.

Please be responsible with personal information of others when using Service. We are not responsible for your misuse of Personal Information, or for the direct relationship between you and others when takes place outside of the Service.

Personal Information

The Pao Privacy Policy concerns the use by Pao of Personal Information. Personal Information, or “personally identifiable information”, as it is sometimes known, is a reference to data that can be linked to or identified with a living individual.

This Privacy Policy does not apply to any data insofar as it is held, processed, disclosed or published in a form that cannot be linked to a living individual (such as anonymous data, aggregated data, or coded data which, in a given form, cannot effectively be used to extract Personal Information) (“Generic Data”). Pao reserves the right to generate Generic Data out of any databases containing Personal Information and to make such use as it sees fit of any such Generic Data.

We may collect personal data from you when you:

  • Create an account to use the App;
  • Update your profile and other account details;
  • Post content, including photos, videos, comments, tips and historical locations you’ve visited;
  • Subscribe to our newsletter and mailing lists;
  • Fill in a form, conduct a search, post content on the App, respond to surveys, participate in promotions or use any other features of the App;
  • Navigate through the App and use the Service generally.
Category
Examples of Personal Information in this Category
User Data
This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Service. This may include your username, email address, phone number, birth date, gender, street address, and country.

Some of the personal data we will ask you to provide is required in order to create your account.; this can include username, name, and password. You also have the option to provide us with additional personal data in order to make your account more personalized. If you use a third party service to create an account, we will receive personal data via that third party service but only when you have consented to that third party service sharing your personal data with us.  Information and content you provide. This includes, without limitation, information you provide when you create an account, information within the content you provide (metadata) which may, for example, include the location of a photo or the date a photo was created. We collect information about the type of content you upload, along with the posts (also known as “Spots”) you save, and the people you connect with (and their posts/ spots), in order to provide a higher quality Service. We may collect information on the network or device you use (attributes, operations, identifiers, signals, GPS location, networks, etc.).
Usage Data
We collect information about how you use the Service, such as the types of content you view, which features you use and the actions you take, the people you add to your groups, and the frequency and duration of your activities.
Inferences drawn about your interests and preferences based on your usage of the Pao Service.
User Content that you post to Pao, such as photos, tips, and comments. Please note that we will only access your camera or photos from your device if you give us permission to do so, and we will only access images that you specifically choose to share with us and metadata related to those images, such as the type of file and the size of the image. We will never scan or import your device’s photo library or camera roll.
Certain technical data, which may include: URL information, online identifiers including cookie data and IP addresses, information about the types of devices you are using such as unique device IDs, network connection type (e.g. wifi, 3G, LTE, Bluetooth), provider, network and device performance, browser type, language, information enabling digital rights management, operating system, and Pao application version.
Your non-precise location, which may be derived or inferred from certain technical data (e.g., your IP address, language setting of your device, or payment currency), to comply with geographic requirements in our licensing agreements, and deliver personalized content and advertising to you.
Geolocation data
Internet protocol (IP) address, GPS location, longitude/latitude, city, county, zip code and region, and your location and your smart device’s proximity to “beacons,” Bluetooth networks and/or other proximity systems
Internet or other electronic network activity information
IP address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences
Audio, electronic, visual, thermal, olfactory, or similar information
Your visual image, likeness and voice recording (e.g., via photographs and/or video).
Contests, Surveys and Sweepstakes Data
When you complete any forms, respond to a survey or questionnaire, or participate in a contest, we collect the personal data you provide.

Third Party Analytics Use and Collection

We may collect information regarding visitor behavior and demographics to help us develop useful features. This analytics data is not tied to any Personal Information.
  • Location Data: the Service accesses your location via the GPS ability of your smartphone or other device for the purpose of locating convenient services, products and venues;
  • Google Analytics: the Service uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies” to help us analyze how users use Pao.  The information generated by the cookie about your use of the app (including your IP address) may be transmitted to and stored by Google on servers in various countries.  Google will use this information for the purpose of evaluating your use of the Service, compiling reports on in-app activity for app operators and providing other services relating to app activity and internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.  Google will not associate your IP address with any other data held by Google.  By using this App, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
  • Amplitude: the Service may use Amplitude, a web analytics service provided by Amplitude, Inc. Amplitude uses “cookies” and SDKs to help us analyze how users use Pao.  The information generated by the cookie or SDK about your use of the app (including your IP address) may be transmitted to and stored by Amplitude on servers in various countries.  Amplitude will use this information for the purpose of evaluating your use of the Service, compiling reports on in-app activity for app operators and providing other services relating to app activity and internet usage.  Amplitude may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Amplitude’s behalf.  Amplitude will not associate your IP address with any other data held by Amplitude.  By using this App, you consent to the processing of data about you by Amplitude in the manner and for the purposes set out above.
  • Appsflyer: the Service can use AppsFlyer, a web analytics service provided by AppsFlyer, a company based in Israel. AppsFlyer can use “cookies” and SDKs to help us analyze how users are driven from marketing campaigns to download the App.  The information generated by the cookie or SDK about your use of the app (including your IP address) may be transmitted to and stored by AppsFlyer on servers in various countries.  AppsFlyer will use this information for the purpose of evaluating your use of the Service, compiling reports on in-app activity for app operators and providing other services relating to app activity and internet usage.  AppsFlyer may also transfer this information to third parties where required to do so by law, or where such third parties process the information on AppsFlyer’s behalf.  AppsFlyer will not associate your IP address with any other data held by AppsFlyer.  By using this app, you consent to the processing of data about you by AppsFlyer in the manner and for the purposes set out above.

Purposes for which Pao uses Personal Information and Recipients of your Personal Information

  • Providing access to our Service: administering, delivering, improving and personalizing the Service (on the basis of our legitimate interest to ensure our app and website is presented in an effective and optimal manner).
  • Providing you with Products: with the products and services that your request from us and deliver tailored content to you.
  • Providing you with a curated experience within the App and Service, including providing you with experiences that we believe may be of interest to you.
  • Communicating with you about our App and Service.
  • Subscriber support and relationship management: to provide customer service and support (on the basis of our contract with you) and to manage our relationship with you, which will including notifying you about changes to our terms of use or privacy policy, and asking you to leave a review or take a survey (on the basis of performing our contract with you, to comply with our legal obligations and on the basis of our legitimate interests to keep our records updated and study how our website and services are used);
  • Prize draws, competitions and surveys:  to enable you to take part in prize draws, competitions and surveys (on the basis of performing our contract with you and our legitimate interest in studying how our website and services are used, to develop them and grow our business);
  • Marketing: to keep in contact with you about our news, events, new website features products or services that we believe may interest you, provided that we have the requisite permission to do so (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so);
  • Advertising: to deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (on the basis of our legitimate interests in studying how our website/services are used, to develop them, to grow our business and to inform our marketing strategy);
  • Research: to carry out research about general engagement with our App (on the basis of our legitimate interest in providing the right kinds of products and services to our Users);
  • Compliance with policies, procedures and laws: to enable us to prevent, detect or investigate security concerns; comply with our policies and procedures; and enforce our legal rights, or to protect the rights, property or safety of our employees and share your information with our technical and legal advisors (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so;
  • We use this data to provide, personalize and improve our Service. We seek to personalize features and content, including your “For You” feed, and make suggestions to you. We need to use your connections, preferences, interests and activities based on the data we collect and learn from you in order to provide the best personalized Service. For example, we use location-related information (including your current location if you’ve allowed it, and the location of spots you upload and save) in order to deliver you relevant content. We also use the data to develop, test and improve our Service;
  • We may use the information we have to help advertisers and other partners measure the effectiveness and distribution of their ads and services;
  • Fulfill any other purpose that you have requested or consented to.

We will share your Personal Information when relevant with third parties such as:

  • Other Users: other Users who you use the Service and with whom you communicate via the Service;
  • Affiliates and Subsidiaries;
  • Partners and collaborators: these are the experience based companies accessible to you via the Service (for example, restaurants and concert venues);
  • Our service providers: service providers we work with to deliver our business, who are acting as processors and provide us with:
  • Subscriber support and relationship management: to provide customer service and support (on the basis of our contract with you) and to manage our relationship with you, which will including notifying you about changes to our terms of use or privacy policy, and asking you to leave a review or take a survey (on the basis of performing our contract with you, to comply with our legal obligations and on the basis of our legitimate interests to keep our records updated and study how our website and services are used);
  • Website development and hosting services;
  • IT, system administration and security services;
  • Marketing and advertising services (including the Google Adwords service), analytics providers (including Google Analytics, AppsFlyer, Amplitude and Firebase Crashlytics);
  • Research: to carry out research about general engagement with our App (on the basis of our legitimate interest in providing the right kinds of products and services to our Users);
  • Maps services (including Google Maps API);
  • Social media plugin services including Facebook;
  • Marketing parties: any selected third party that you consent to our sharing your information with for marketing purposes;
  • Prospective sellers and buyers of our business: any prospective seller or buyer of such business or assets, only in the event that we decide to sell or buy any business or assets; and
  • Other third parties (including professional advisors): any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.

Other forms in which Personal Information may be used

We may disclose Personal Information to third parties if we believe that such disclosure is reasonably necessary to enforce or apply the Terms of Use that a Subscriber has accepted in relation to the Service or to protect the rights, property, safety and integrity of Pao or the Service, or otherwise as provided by law or required by any court of competent jurisdiction or any regulatory authority acting under statutory powers. There may be limited circumstances in which Pao is obliged to disclose Personal Information to unrelated third parties such as:
  • In response to the following: (1) to satisfy a legitimate government request or direction or in response to a court order or in connection with legal proceedings; (2) in response to a third-party subpoena, if on legal advice such response is required; or (3) if necessary to defend Pao, or its partners or other Subscribers (for example, in a lawsuit).
  • If you request a specific service or product that is administered by a third party who is working with Pao, your Personal Information may be shared with such third party in order to respond to the request. The third party in question may also transmit back to Pao any new information obtained from you.
Pao will fully cooperate with law enforcement, investigation and security agencies and regulators to identify anyone who uses the Service or software for illegal activities. Pao reserves the right to report to law enforcement, investigation and security agencies and to regulators any activities that are believed to be unlawful.

Retention of Personal Information

ao reserves the right to retain records of your Personal Information for legal purposes, to investigate and respond to complaints, to enforce our Terms of Use or to defend ourselves against any claim or allegation, or if we require such data for other legitimate reasons. Copies of your Personal Information may remain stored for limited periods of time on back-up media which shall be cleansed from time to time. Following termination or deactivation of your account, we may retain Personal Information (including your profile information) and User Content for a commercially reasonable time for backup, archival, and/or audit purposes. Pao shall be entitled to retain any data in Generic Data obtained from your Personal Information.

Do Not Track Disclosure

Currently, our systems do not recognize browser “do-not-track” requests. To learn more about do-not-track signals, please see https://allaboutdnt.com/

Data on Children

We do not knowingly collect, nor do we want to receive, Personal Information about individuals who are under 13 years of age. If you are under the age of 13, please do not access our Service at any time or in any manner. We will take appropriate steps to delete the Personal Information of persons under the age of 13. Changes to your Personal Information and unsubscribing from the Service It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your use of the Service. You may change the Personal Information that Pao retains about you by accessing the Service through the Settings Page.

International Transfer

We store personal data in the United States. If you provide us information, it will be transferred to, processed, and accessed in the United States. This Privacy Policy shall apply even if we transfer personal data from non-United States countries to other countries. You acknowledge and agree that it is necessary for us to transfer your personal data to the United States in order for us to perform our contractual obligations to provide you our services and the Sites.
YOU ALSO CONSENT TO ANY AND ALL INFORMATION YOU PROVIDE AND SUBMIT VIA THE SITES BEING SENT TO THE UNITED STATES OF AMERICA. YOU ARE INFORMED THAT THE UNITED STATES PRESENTLY DOES NOT HAVE AN ADEQUATE LEVEL OF PERSONAL DATA PROTECTION AS DETERMINED BY THE EUROPEAN COMMISSION’S ADEQUACY DECISION ON OCTOBER 6, 2015 (Case C-362/14) AND ARTICULATED IN THE EUROPEAN UNION’S GENERAL DATA PROTECTION REGULATION AND HAS NOT RECEIVED A SIMILAR DESIGNATION OF ADEQUACY BY ANY OTHER FOREIGN DATA PROTECTION AUTHORITY. YOU AGREE TO THE TRANSFER OF YOUR DATA AND PERSONAL INFORMATION TO THE UNITED STATES, HOWEVER, TO BE USED IN ACCORDANCE WITH THIS PRIVACY POLICY.

Your Data Subject Rights

In May 2018, a new data privacy law known as the EU General Data Protection Regulation (or the “GDPR”) became effective. To the extent the GDPR applies to you and subject to the conditions set forth in the applicable law, you have the following rights with regard to our processing of your Personal Information:

Right to access, correct and delete your Personal Information: You have the right to request access to a copy of your Personal Information and to request correction of any inaccurate Personal Information about you. You furthermore have the right to request deletion of Personal Information we hold about you.

Right to withdraw consent: In the event your Personal Information is processed on the basis of your consent, you have the right to withdraw consent at any time by sending an email to admin@thepaoapp.com specifying your request, without affecting the lawfulness of processing based on consent before its withdrawal.

Right to restrict Personal Information use: You have the right to restrict our use of your Personal Information where (i) you contest the accuracy of the Personal Information; (ii) the use is unlawful but you do not want us to erase the Personal Information; (iii) we no longer need the Personal Information for the relevant purposes, but you require it for the establishment, exercise or defense of legal claims; or (iv) you have objected to our Personal Information use justified on our legitimate interests pending verification as to whether we have indeed compelling interests to continue the relevant Personal Information use.

Right to object: To the extent that we are relying on our legitimate interests to use your Personal Information, You have the right to object to such use, and we must stop such processing unless we can either demonstrate compelling legitimate grounds for the use that override your interests, rights and freedoms or where we need to process the Personal Information for the establishment, exercise or defense of legal claims.

In order to exercise the rights stated above, please email admin@thepaoapp.com.

Right to Complain to Supervisory Authority

If you believe that we are processing your Personal Information in an incorrect or unlawful manner, please contact us at admin@thepaoapp.com. For those located in the European Union, you also have a right to file a complaint with a Supervisory Authority.

Additional California Privacy Disclosures

If you are a California resident, the processing of certain personal data about you may be subject to the California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws. Beginning January 1, 2020, the CCPA gives you certain rights with respect to the processing of your personal data (known as “personal information”, as described in under the CCPA).

This privacy policy (above) sets forth the categories of personal information that Pao collects and processes about you and a description of each category. Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months.  You have a right to delete your personal information, subject to certain exceptions.  You may request this information in writing by contacting us using the information in the Contact Us section below. Please allow up to thirty (30) days for a response. In your requests, please attest to the fact that you are a California resident and provide a current California address for your response.

We do not currently collect household data, and treat every account as an individual. You may designate in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights.  Before accepting such a request from an agent, we will require the agent to provide proof you authorized the request and you will have to verify your identity directly with us.

We do not “sell” your data, meaning we do not provide your personal data to a third party for valuable consideration.

Privacy Policy changes

This Privacy Policy was last changed on December 30, 2019. If Pao makes changes to the Privacy Policy, the new version will be posted on the Service. If material changes are made to the Privacy Policy we will notify you by email.  Pao may change, modify, add or remove portions of this Privacy Policy at any time, and any changes will become effective immediately upon being posted unless stated otherwise.