Popl values the privacy of individuals who use our websites and related services.

 

In this Policy, “Popl”, “we” or “us” refers to Popl Co, a company established at PO Box 25667 Los Angeles, CA 90025, USA. We take privacy seriously and we have adopted technical and organizational measures designed to protect your data. This privacy policy (the “Policy”) explains how we collect, use, and share information from users of our Services. If you are located in the European Economic Area (“EEA”), this Policy informs you of your choices and our practices in relation to your Personal Information (as defined below).

For the purpose of this Policy, “Personal Information” means any information relating to an identified or identifiable individual. This includes Personal Information collected and processed by us when you access our websites (including popl.co) (the “Website”), the Popl app, and the services related to them (collectively, together with the Website, Popl app, and the related services, our “Services”). This Policy describes the Personal Information that we gather from you on our Services, how we use and disclose such Personal Information, your rights and choices with respect to your information, and how you can contact us if you have any questions or concerns. Beyond this Policy, your use of our Services is also subject to our Terms ofUse.

1. Personal Information We Collect

We may collect and use the following Personal Information about you:

2. Personal Information You Provide to Us.

Communications with us. When you contact us directly, we may receive additional information about you. For example, when you contact us for customer support, we may receive your name, email address, the content of a message or attachments that you may send to us, and other information you choose to provide. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

Transaction-related information.When you purchase something on the Website or the Popl app, you may be asked to provide us with your information such as your name, phone number, and address. Your payment-related information, such as credit card, or other financial information, is collected by our third party payment processors on our behalf.

Service-related information. When you use our Services, you can choose to provide certain Personal Information, including your contact information, social media links, and location.

Ambassador information.When you apply to become a Popl Ambassador in our affiliate program, you may provide us with additional information about you such as your name, email address, pictures of you, social media links, phone number, postal address and other information you choose to provide.

Product reviews.When you reply to our request to review and rate your experience with our Services, you may provide us with additional information about you. The information we collect from you varies depending on the review but typically includes your name, the Service you used, and your opinion about the Service.

3. Personal Information We Collect When You Use Our Services.

Location information. When you use our Services, we may infer your general location information, for example, when you use the Popl app.

Device information. We receive information about the device and software you use to access our Services, including IP address, web browser type, and operating system version.

Usage information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, purchases you make, and the dates and times of your visits.

Information from Cookies and Similar Technologies.We and third party partners collect Personal Information using cookies, pixel tags, or similar technologies. Our third party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. We may use both session cookies (which are deleted from your device after you leave the Website) and persistent cookies (which remain on your device for longer or until you delete them manually). A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from our Services, you may not be able to utilize the features of our Services to their fullest potential.

4. Personal Information We Receive from Third Parties.

Information from third party services. We obtain Personal Information from third parties, such as Facebook, Snapchat, YouTube, when you click on third party buttons or beacons (such as Facebook “like” or “share” buttons, or embedded YouTube video) on our Website. If you choose to link our Services to a third party account, such as Facebook, Instagram, or Snapchat, we may receive information about you, including your profile information and your photo. If you wish to limit the information available to us, you should visit the privacy settings of your third party accounts to learn about your options. If we combine or associate information from other sources with Personal Information that we collect through our Services, we will treat the combined information as Personal Information in accordance with this Policy.

  1. How We Usethe Personal Information We Collect

We use the information we collect for the following purposes:

  • Communicating with you. We may use your email address or other Personal Information we collect on our Services as necessary to contact you for administrative purposes such as to provide services and information that you request, respond to comments and questions, and otherwise provide customer support.
  • Providing the Services and personalizing your experience. We may use your Personal Information to provide and maintain our Services, including to facilitate transactions and payments or to enable you to connect to third party services or applications. When doing so, we may use your Personal Information to personalize your experience on our Services such as by providing tailored content and recommendations.
  • Understanding usage and improving the Services. We use your Personal Information that we collect through our Services to analyze trends and statistics, and to improve and enhance our Services.
  • From time to time, we may ask you to participate in surveys we conduct which are in our legitimate interest because they help us understand our userbase and improve our Services. If you participate, we process your registration information and any other information collected through the survey questions.
  • We may use your email address and other Personal Information to send marketing communications related to our Services. Generally, you have the ability to opt-out of receiving any promotional communications as described below under Your Rights and Choices. Where required under applicable law, we will only send you promotional emails with your opt-in consent.
  • We may use your usage information and other Personal Information to develop and provide you with promotional and advertising materials that may be relevant, valuable or otherwise of interest to you.
  • Legal obligation and Compliance. We use your Personal Information to find and prevent fraud, respond to trust and safety issues that may arise, and for compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
  • Other Purposes. We may use your Personal Information for other purposes for which we provide specific notice at the time the information is collected.

A. What Are Cookies and How Do We Use Them.

Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer. 

Pixel tags and web beacons are tiny graphic images placed on web pages or in emails that allow us to determine whether you have performed a specific action. When you access these pages or open or click an email, the pixel tags and web beacons generate a notice of that action. These tools allow us to measure response to our communications and improve our Website and Services.


We use cookies, web beacons, pixel tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other users of our Services. This aids your experience when you use our Services and also allows us to improve the functionality of our Services. When you use our Services, we collect certain information by automated means, using technologies such as Cookies and browser analysis tools. In many cases, the information we collect using Cookies and other tools is used in a non-identifiable way, without any reference to personal data. We may use Cookies to make our Website usage more efficient and to tailor your browsing preferences and improve the functionality of our Website. Cookies can be used for performance management, collecting information on how our Website is being used for analytics purposes. They can also be used for functionality management, enabling us to make the user’s visit more efficient by, for example, remembering language preferences, passwords and log-in details.

Below is an overview of the types of Cookies that we and third parties may use to collect Personal Information.

  • Strictly necessary cookies. Some Cookies are strictly necessary to make our Services available to you. We cannot provide you with our Services without this type of cookie. For example, these cookies allow us to provide the login functionality.
  • Functional cookies. These Cookies are used to recognize you when you return to our Services. This enables us to adapt our content for you, and remember your preferences (for example, your choice of language or region).
  • Analytical or Performance cookies. We also use Cookies for website and app analytics purposes in order to operate, maintain and improve our Services. We may use our own analytics Cookies or use third party analytics providers such as Google tag manager, to collect and process certain analytics data on our behalf. These providers may also collect information about your use of other websites, apps, and online resources. You can opt out of Google tag manager without affecting how you visit our Services by going to google.com/dlpage/gaoptout or via Google’s Ads settings.

Where required by applicable law, we obtain your consent to use Cookies. You can find more information about your rights and choices, and how to block the use of certain Cookies in the section Your Rights and Choices below.

B. Our Use of European Personal Information.

If you are located in the European Economic Area, we only process your Personal Information when we have a valid “legal basis”, including when:

  • You have consented to the use of your Personal Information, for example to send you marketing communications or to use cookies and similar technologies.
  • Contractual necessity. We need your Personal Information to provide you with our Services, for example to respond to your inquiries.
  • Compliance with a legal obligation. We have a legal obligation to use your Personal Information, for example to comply with tax and accounting obligations.
  • Legitimate interests. We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

 

III. How We Share the Personal Information We Collect

Except as described in this Policy, we will not disclose your information that we collect on our Services to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

  • We may share any information we receive with our corporate affiliates for any of the purposes described in this Policy.
  • Vendors and Service Providers.We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.
  • Analytics Partners.We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting google.com/policies/privacy/partners/ .
  • Advertising Partners.We may work with third party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (networkadvertising.org ) or the Digital Advertising Alliance (optout.aboutads.info) . If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.
  • As Required By Law and Similar Disclosures.We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through our Services.
  • Merger, Sale, or Other Asset Transfers.We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
  • Product Reviews.Any information related to your experience with our Service that you provide via our review mechanism may be displayed for promotional purposes.
  • We may also disclose your information with your permission. 

1. Your Rights and Choices

Sharing Preferences.For Ambassadors, certain information such as your user name may always be publicly available to others, and other information may be made publicly available to others by default. You can revise, modify, or delete your account information.

Marketing Communications.You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you may continue to receive administrative messages from us.

How to block Cookies. You can block Cookies by setting your internet browser to block some or all the Cookies. However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of our Services. By using our Website you consent to our use of Cookies and our processing of information collected through such cookies, in accordance with this Cookie Policy and our Privacy Notice. You can withdraw your consent at any time by deleting placed cookies and disabling Cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse our Website using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our Website may not function properly if you do not accept Cookies or these technologies. Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device. We do not process web browser Do Not Track signals. To learn more about browser tracking signals and Do Not Track please visit http://www.allaboutdnt.org.

Your European Privacy Rights. If you are located in the European Economic Area, you have the additional rights described below.

  • You may request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
  • You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Policy. Before meeting your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

2. International visitors

Our Services are hosted in the United States and are intended for visitors located within the United States. If you choose to use our Services from regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the United States for storage and processing, which does not have the same data protection laws as your jurisdiction. When we transfer your Personal Information to the United States, we take steps to comply with applicable data protection law, in particular legal requirements regarding adequate protection for data transfers. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services.

3. European Visitors

If you are located in the European Economic Area, we will comply with applicable EEA data protection law when transferring your Personal Information outside of the EEA. We may transfer your Personal Information to countries which have been found to provide adequate protection by the EU Commission, use contractual protections for the transfer of Personal Information, transfer to recipients who have adopted Binding Corporate Rules, or rely on an appropriate legal derogation. For more information about how we transfer outside of the EEA, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us using the contact details given below.

VII. Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Policy does not apply to your activities on these third party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

VIII. Retention

We take measures designed to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.

IX. Security

We make reasonable efforts designed to protect your information by using physical and electronic safeguards to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

X. Children’s Privacy

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with Personal Information in violation of this Policy, then you may alert us at legal@popl.co .

XI. Update Your Personal Information or Pose a Question

As an Ambassador, you can update your account and profile information or close your account through your profile settings. If you have questions about your privacy on our Services or this privacy policy, please contact us at legal@popl.co .

XII. Changes to this Policy

We will post any adjustments to this Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share Personal Information previously collected from you through our Services, we will notify you through our Services, by email, or other communication.

XIII. Contact Information

If you have any questions, comments, or concerns about our processing activities, please email us at legal@popl.co or get in touch with us using the contact details below:
Popl Co
PO Box 25667 Los Angeles, CA 90025
United States of America


If you are located in the EEA, please contact our EU representative via legal@popl.co .

Information for California Residents

This section provides additional information for residents of California under the California Consumer Privacy Act (CCPA). The terms used in this section have the same meaning as in the CCPA. This section does not apply to information that is not considered "personal information," such as anonymous, deidentified, or aggregated information, nor does it apply to publicly available information as defined in the CCPA.

Personal Information Collected in the Last 12 Months

We collect the following categories of personal information about Marketing Subscribers:

  • Personal Identifiers, including name, email address, and telephone number
  • Online Identifiers, including unique personal identifier
  • Internet Activity, including interactions with websites, apps or ads, email open and click-through rates, browsing history, and search history
  • Commercial and Financial Information, including purchases

We collect the following categories of personal information about Product Purchasers:

  • Personal Identifiers, including name, email address, postal address, and telephone number
  • Online Identifiers, including unique personal identifier, device identifier, and IP address
  • Internet Activity, including interactions with websites, apps or ads, email open and click-through rates, and browsing history
  • Commercial and Financial Information, including purchases, credit card or debit card number, and bank or other financial account number

We collect the following categories of personal information about Users:

  • Personal Identifiers, including name, email address, postal address, and telephone number
  • Online Identifiers, including unique personal identifier, device identifier, IP address, user alias, online identifier, and account login
  • Internet Activity, including interactions with websites, apps or ads
  • Commercial and Financial Information, including purchases, credit card or debit card number, and bank or other financial account number
  • Geolocation data

We collect the following categories of personal information about Website Visitors:

  • Personal Identifiers, including name and email address
  • Online Identifiers, including unique personal identifier, device identifier, and IP address
  • Internet Activity, including interactions with websites, apps or ads, email open and click-through rates, and browsing history
  • Commercial and Financial Information, including purchases

Sources of Personal Information

We collect personal information from the following sources:

  • You (the consumer)
  • Ad Networks
  • Data Analytics Providers
  • Operating Systems
  • Other consumers (e.g., referrals)
  • Social Networks

Business or Commercial Purposes for Collecting Information

We collect personal information for the following business purposes:

  • Provide Products or Services
  • Advertising and Marketing
  • Error Management
  • Quality Assurance
  • Security
  • Internal Research
  • Short-Term Transient Use

We also "share" and "sell" (as defined in the CCPA) personal information for commercial purposes, including to advertise and market our products.

Information Disclosed for Business or Commercial Purposes in the Last 12 Months, and Categories of Parties Disclosed To

Marketing Subscribers

Personal Information Disclosed Category of Party
Personal Identifiers, including name, email address, and telephone numberService Providers
Online Identifiers, including unique personal identifierService Providers
Internet Activity, including interactions with websites, apps or ads, email open and click-through rates, browsing history, and search historyService Providers
Commercial and Financial Information, including purchasesService Providers

Product Purchasers

Personal Information Disclosed Category of Party
Personal Identifiers, including name, email address, postal address, and telephone numberPayment Processors, Service Providers
Online Identifiers, including unique personal identifier, device identifier, and IP addressAd Networks, Service Providers
Internet Activity, including interactions with websites, apps or ads, email open and click-through rates, and browsing historyAd Networks, Service Providers
Commercial and Financial Information, including purchases, credit card or debit card number, and bank or other financial account numberAd Networks, Payment Processors, Service Providers

Users

Personal Information Disclosed Category of Party
Personal Identifiers, including name, email address, postal address, and telephone numberService Providers
Online Identifiers, including unique personal identifier, device identifier, IP address, user alias, online identifier, and account loginService Providers
Internet Activity, including interactions with websites, apps or adsService Providers
Commercial and Financial Information, including purchases, credit card or debit card number, and bank or other financial account numberService Providers
Geolocation dataService Providers

Website Visitors

Personal Information Disclosed Category of Party
Personal Identifiers, including name and email addressAd Networks, Service Providers
Online Identifiers, including unique personal identifier, device identifier, and IP addressAd Networks, Data Analytics Providers, Service Providers
Internet Activity, including interactions with websites, apps or ads, email open and click-through rates, and browsing historyAd Networks, Service Providers
Commercial and Financial Information, including purchasesAd Networks, Data Analytics Providers, Service Providers

Information We Sell and Categories of Third Parties Sold To

We do not "sell" personal information as commonly understood (exchanging information for money). However, for business and commercial purposes we share certain personal information with third party vendors, as disclosed below. This sharing of information may be considered a "sale" under the broad definition of selling in the CCPA. You may opt-out here.

Website Visitors

Personal Information Sold Category of Party
Online Identifiers, including unique personal identifier, device identifier, and IP addressData Analytics Providers
Commercial and Financial Information, including purchasesData Analytics Providers

Information We Share and Categories of Third Parties Shared With

We “share” certain personal information with third party ad networks for purposes of behavioral advertising, as disclosed below. This allows us to show you ads that are more relevant to you. You may opt-out of sharing here.

Product Purchasers

Personal Information Shared Category of Party
Online Identifiers, including unique personal identifier, device identifier, and IP addressAd Networks
Internet Activity, including interactions with websites, apps or ads, email open and click-through rates, and browsing historyAd Networks
Commercial and Financial Information, including purchasesAd Networks

Website Visitors

Personal Information Shared Category of Party
Personal Identifiers, including name and email addressAd Networks
Online Identifiers, including unique personal identifier, device identifier, and IP addressAd Networks
Internet Activity, including interactions with websites, apps or ads, email open and click-through rates, and browsing historyAd Networks
Commercial and Financial Information, including purchasesAd Networks

CCPA Rights

Your CCPA rights are described below. You can make a Request to Know or a Request to Delete under the CCPA by submitting a Privacy Request at the top of this page, or by clicking here.

Right to Know

You have the right to request to know the following about the personal information we have collected about you in the past 12 months:

  • the categories and specific pieces of personal information we have collected about you
  • the categories of sources from which we collect personal information about you
  • the business and commercial purposes for which we collect personal information
  • the categories of third parties with whom we share the information
  • the categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose

If you make a Request to Know more than twice in a 12-month period, we may require you to pay a small fee for this service.

Right to Delete

You have the right to request that we delete any personal information about you that you have provided to us. We will permanently delete from our records any personal information that is not necessary for our business operations and direct our service providers to do the same.

We consider information to be necessary for our business operations if it is used to:

  • Complete an obligation to you that you have requested
  • Detect and resolve issues related to security or functionality
  • Comply with legal obligations

Right to Non-Discrimination

If you exercise your CCPA consumer rights:

  • We will not deny goods or services to you
  • We will not charge you different prices or rates for goods or services, including through the use of discounts or other benefits or penalties
  • We will not provide a different level or quality of goods or services to you

Right to Opt-Out

You have the right to opt-out of any selling and sharing of your personal information.

You may exercise your right to opt-out here.

Request Verification

Before we can respond to any CCPA requests, we will need to verify that you are the consumer who is the subject of the CCPA request. Verification is important for preventing fraudulent requests and identity theft.

The verification process depends on which type of request you make and how you make it. Typically, identity verification will require you to confirm certain information about yourself based on information we have already collected. For example, we will ask you to verify that you have access to the email address we have on file for you. If we cannot verify your identity based on our records, we cannot fulfill your CCPA request.

For a request that seeks specific personal information, we ask that you sign a declaration stating that you are the consumer whose personal information is the subject of the request, as required by the CCPA.

In some cases, we may have no reasonable method by which we can verify a consumer's identity. For example:

  • If a consumer submits a request but we have not collected any personal information about that consumer, we cannot verify the request.
  • If the only data we have collected about a consumer is gathered through website cookies (i.e., the consumer visited our website but had no other interaction with us), we are unable to reasonably associate a requester with any data collected; therefore, we cannot verify the request.

Authorized Agent

A California resident's authorized agent may submit a Request to Know or a Request to Delete under the CCPA by emailing us at privacy@popl.co. Requests submitted by an authorized agent will still require verification of the person who is the subject of the request in accordance with the process described above. We will also ask for proof that the person who is the subject of the request authorized an agent to submit a privacy request on their behalf. An authorized agent that has power of attorney pursuant to California Probate Code section 4121 to 4130 must submit proof of statutory power of attorney, but consumer verification is not required.

If you have trouble accessing this notice, please contact us at privacy@popl.co.

Contact Us

If you have any privacy-related questions, please send them to privacy@popl.co.