Privacy Policy

EFFECTIVE DATE: November 1, 2018

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,” “we,” “Us,” “us,” “Our,” or “our”), the company behind the Pao service (the “Service”). The Service is designed as a mobile 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 “User,” “You,” 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 the App and the Service. It also explains what rights you have to access or change your Personal Information.

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 Use. Our Policy applies to all users of 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):

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 Users based on your use of the Service or 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 or 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 policy and terms of use of every website you visit.

Sharing Directly with Third Parties

You and other Users 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 Users) 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 does not relate to such use of the User’s Personal Information. We recommend that you review the privacy policies and terms of use 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.

Personal Information

Any limitations set forth in this Privacy Policy do 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 (“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 collect the Personal Information that you provide to us. This could include (depending on the circumstances):

•    Identity and contact data: title, names, addresses, email addresses and phone numbers;
•    Account profile data: if you’re registering for an account you may also provide a username, password, language preferences;
• Survey data: from time to time we might ask if you would be willing to participate in our surveys; if you agree, we will also collect information provided in such survey; and

•    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.
•    Networks and connections. 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.).
•    Your usage. 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.

We also collect the following information about you automatically when you use the Service:

•    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 help us analyze how users use Pao. The information generated by Google 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. 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.
•    URL, Device ID, advertising identifiers, unique device identifiers, internet protocol addresses and App usage information: we use this information to guard against possible abuses; diagnose problems with and administer the App and Service; provide you with curated content and promotions; gather demographic information; and to help prevent abuse or fraudulent use.

•    Your interactions with the App: we record your interactions with the App and Service in order to provide you with a curated experience.

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

We will use your information for the purposes listed below either on the basis of:

•    performance of your contract with us and the provision of our services to you;
•    your consent (where we request it);
•    where we need to comply with a legal or regulatory obligation; or
•    our legitimate interests – by this we mean our legitimate business interests in conducting and managing our business and our relationship with you, including the legitimate interest we have in personalizing, enhancing, modifying or otherwise improving the services and/or communications that we provide to you, including providing you with newsletters, mailings, surveys, contests, promotions and announcements and information regarding the App and Service.

Pao uses Personal Information provided by Users and accessed by the Service for the purposes of:

•   Providing access to our Service and delivering our Service: managing, administering, delivering and personalizing the App and Service and assessing the effectiveness of and improving our App and Service.
•   Providing you 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.
•   User support and relationship management: to respond to your inquiries and provide customer service and support 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;
•   Prize draws, competitions and surveys: to enable you to take part in prize draws, competitions and surveys;
•   Marketing: to keep in contact with you about news, events, promotions, new website features products or services that we believe may interest you (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;
•   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; and
•   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: Our 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:

• 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 and Firebase Crashlytics);
• maps services (including Google Maps API);
• social media plugin services including Facebook;

•    Marketing parties: selected third parties for marketing purposes;
•    Prospective sellers and buyers of our business: any prospective or actual seller or buyer of all or part of our 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 User 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 Users (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.

Special Information for California Consumers

California residents may request a list of certain third parties to which we have disclosed certain personal data for their own marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. 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.

Retention of Personal Information

Pao 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.

Privacy Policy Changes

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.

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.

Data portability: To the extent that we process your Personal Information based on consent or fulfillment of a contract and that Personal Information is processed by automatic means, you have the right to receive all such Personal Information that you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another data controller where this is technically feasible.

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.