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.


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): 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:

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.

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

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

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:
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

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.

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 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

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 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.