Effective as of September 16, 2019
At SoPa, we strive to make our policies clear and our services easy to use. As a part of that commitment, we are concerned about privacy issues and want you to be familiar with how we collect, use, and disclose Personal Information (as defined below) in connection with our services.
1. Information We Collect
We, and our third-party service providers who perform services on our behalf, collect information in a variety of circumstances when you visit and use our Sites and use our services. There are two main reasons as to why we collect information about you:
(i) to comply with laws of applicable jurisdiction; and
(ii) to provide our Services and have our Sites functioning, as intended.
Legal basis for processing (for EEA and Switzerland residents only)
If you are a resident of the EEA or Switzerland please read the following paragraph carefully: it is applicable to our legal relationship. Said paragraph is not applicable to residents of any other countries or states.
Notice to California residents only
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (1) a list of the categories of information, such as name, address, e-mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties ‘direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please write to us with a reference to California Disclosure Information at the address listed below in the “Contact” section.
Types of Information
In both abovementioned instances, we may collect information:
• when you register for our service, sign up for our mailing list, or communicate with us;
• when you use and interact with our Sites and service, such as when you place an order, post a review, or interact with other users or with businesses on the Sites;
• when you make a payment for services;
• if you log in through a social network or authentication service, such as Facebook or Google, these services will authenticate your identity and may provide you the option to share Personal Information (such as your name, e-mail address, address book, and contacts, or other information) with us; and
• if you give permission for the Sites to access your address book or camera roll on your device, for example, to send an invitation to a friend or to upload a photo or a video to the Sites.
The information we collect includes Personal Information that can uniquely identify you (whether alone or in combination with other data or information), such as your full legal name, your profile pictures, postal address, telephone number, e-mail address, date of birth, gender, physical and legal address, or similar data. Personal Information also includes certain sensitive information related to your finances or, for business accounts, related to the finances of your business, such as a credit card number or other payment account number (including the digit validation code for your bank card or the credentials necessary to connect our digital wallet with your bank account). In order for you to take advantage of our Services, we may require that you furnish Personal Information.
We may also collect non-personal information from you, including information about your use of our Sites, but when such non-personal information is linked to your Personal Information, we will treat it as Personal Information. We may also receive information about you from third party sources, such as other users of our Sites, drivers, merchants, and other partners.
Information collected automatically when you visit our Sites and use our Services. We and our third-party service providers may collect certain types of usage information when you visit our Sites, read our e-mails, or otherwise engage with us. We may use this information to enhance and personalize your user experience, to monitor and improve our websites and services, and for other similar purposes. In some instances, we and our third-party service providers may combine this usage information with Personal Information. If we do combine any usage information with Personal Information, the combined information will be treated by us as Personal Information hereunder (as long as it is so combined).
We and our third-party contractors may use tracking technologies, including cookies, web beacons, embedded scripts, location-identifying technologies, file information, and similar technology, to automatically collect usage and device information, such as:
• Information about your device and its software, including your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to identify your browser, mobile device, or your account (including, for example, a persistent device identifier), and other similar information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools that permit us to recognize and contact you across multiple devices.
• Information about the way you access and use our Sites, for example, the site from which you came and the site to which you are going when you leave our Sites, the pages you visit, the links you click, whether you open e-mails or click the links contained in e-mails, whether you access the Sites from multiple devices, and other actions you take on the Sites.
• We may collect analytics data or use our platform or third-party analytics tools to help us measure traffic and usage trends for the Sites and to understand more about the demographics of our users. This information will be available to the registered businesses of our website for consideration.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the Sites, as some features and services on our Sites may not work properly. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.
Do Not Track Signals
We do our best to honor the privacy preferences of our users. We are still testing the platform and software engine of our Sites. Therefore, we are unable to state whether we can operate in a manner that would respond to No Track Signal of your device.
Geolocation – Directly and Indirectly
With your consent, we may obtain information about your physical location through geolocation features on your device, including GPS (e.g. latitude and/or longitude, with precise location, if possible). We may use this information to improve order efficiency and enhance your user experience and to provide you with certain information that we may not be able to provide otherwise (for instance, the nearest businesses and merchants of your choice). We may also infer your location based on other information we collect. For example, your IP Address indicates the general geographic region from which you are connecting to the Internet.
We may offer you a referral service to tell a friend about us and invite her to have an account with us. If you choose to use our referral service, we will ask you for your friend’s name and e-mail address and/or other and further information reasonably related to the referral. Then we will automatically send your friend an initial e-mail inviting him or her to join us. Consequently, will store your friend’s name information so that your friend may be added to your “friend’s list,” and also to send reminders of the invitations. We may also provide your friend’s information to any third parties in the same manner as we can use your information. Please ask your friend an express consent to provide her/his contact information to us before doing so.
2. Manner of Use of Collected Information
We and our third-party service providers may use Personal Information in the following manner.
We collect and store information about you in connection with our Sites and Services. Such information may be stored or alternatively, processed and later deleted. We use that information to provide the Services functionality, fulfill your requests, improve the Services’ quality, engage in research and analysis relating to the Service, provide third parties for consideration with the results of said research and analysis, personalize your experience, track usage of the Services, provide feedback to third party businesses that are listed on the Services, display relevant advertising, market the Services, provide customer support, message you, back up our systems, allow for disaster recovery, enhance the security of the Services, and comply with legal obligations.
Additionally, we may store any information in connection with your use of the Services and the Sites, such as your search history, businesses viewed by your profile, transactions, reservations, cancellations, account settings preferences, etc. We may additionally collect any and all available information about your device when we use the Sites or the Services including the information about the type of device, the language of the operating system of the device, IP address, the information about the phone number and mobile carrier, unique device identifiers, Wi-Fi information, location, including the GPS location. You may be able to limit or disallow the use of certain data by our Sites in your device settings.
We may need to evaluate your eligibility to any types of special offers, promotions, or products in connection with the Services in the manner consistent with such offer, promotion, or product.
Information with regard to your account
When you register with us, you create your account on our Sites. We store and use all the information you provide during that process. Further, whenever you modify such information, we also use the modified information. Specifically for your information in connection with an account on our Sites, please note that we reserve the right to use facial recognition technologies if available. Additionally, please note that if you believe that someone is illegally using your personal information to create an account with us, please contact us immediately and request its removal. Please note, that our actions in this regard may be limited by applicable laws and court orders. We may be obligated to verify your identity and request further information about you, should applicable law so provide.
Information with regard to your public activity on the Sites
When you register an account with us, you are granted with a unique opportunity to contribute to our platform and add content to it such as your order history, your photos, and videos, ratings, reviews, comments, posts, etc. Some of your account information, such as your first name, last initial, geolocation, photos are intended to be publicly available. Your account settings may limit your public exposure. Please read through your account settings thoroughly to customize the exposure of your information.
NEITHER WE NOR ANY THIRD PARTY IS OR SHALL BE RESPONSIBLE FOR ANY USE BY ANY UNAUTHORIZED PERSON OR ENTITY OF ANY PERSONAL INFORMATION YOU DISCLOSE IN THE MANNER OF YOUR PUBLIC ACTIVITY ON OUR SITES.
Our Sites do allow or will allow to certain features that provide an opportunity of communications between users and businesses and between you and us. Moreover, some of the communication, such as communication with regard to your transactions with businesses may be necessary for utilization of the Services and the Sites. Please note that we may also have access to information that was communicated through third parties but in connection with the Services, such as text messages that confirm your transaction in connection with your use of your digital wallet. We will have access, store, review, analyze any and all such information and may additionally disclose it to third parties. We reserve the right to review and edit or refuse to deliver any and all messages, including the cases where we suspect fraud, spam, or any unlawful or objectionable conduct. Any information that you provide through communications to us, including from phone calls, letters, e-mails, and other electronic messages, or in person, can be recorded and monitored by us. Our monitoring of all the aforesaid information includes processing of the information by our analytic tools or analytic tools of third parties in order to generate the reports about the users of our platform. We may also use information about you for communication purposes.
Contacts of your device
You may elect to send messages related to the services by allowing us to access your contacts information stored on your electronic devices. If you allow us to access such information we may process it in any manner allowed by applicable law.
We will collect and store information about any and all transactions you performed through the Sites, whether completed or not, and any and all information reasonably related to such transactions including the information shared with third parties. We will encrypt and/or use the protective measures required by law prevent unauthorized access by third party to described information. We reserve the right to display the fact of any and all transactions with the business. We additionally reserve the right to use the information regarding any transaction for our analytics tools. For example, if you are a female of the age between 28 who made a transaction with a business, our analytics tool may note that female users of the age between 25 and 30 are interested in a particular type of goods or services at some particular time of the day.
Other instances of express consent
We may ask your consent to use the relevant information for the purposes we do not currently anticipate.
3. Disclosures to Third Parties
The following third parties may receive information about you:
• our third-party service providers that provide services on our behalf, such as payment processing, servers, and website hosting, data analysis, infrastructure provisioning, IT services, customer support, e-mail delivery services, targeted advertising and marketing, and other similar services.
• to third parties such as attorneys, collection agencies, governmental bodies, and agencies or any other and further third parties reasonably necessary to prevent or to mitigate any violation of law or to comply with applicable law.
• any party reasonably necessary to provide the Services (e.g., the applicable business).
• to businesses and brands from which you have placed orders through the Sites as well as their affiliates and third-party service providers. These businesses, brands, and their affiliates may use your information as permitted by their own privacy policies, which could include sending you marketing communications and other promotional content. We may also share Personal Information which has been aggregated or de-identified in a manner such that the end-product does not uniquely identify you or any other user of the Sites. By using our Sites and Services you acknowledge your consent with the privacy policies of the respective businesses.
• to businesses and brands which ordered our analytic services or to our business partners in connection with any offers or promotions available on the Sites.
• to identify you to any person with whom you interact through the Sites.
• to third party partners in connection with integration, co-marketing and certain other coordinated efforts.
• to governmental authorities and or agencies in the manner consistent with applicable laws, including but not limited to the laws of the United States. Such use includes our actions in order to enforce our rights and the agreement between you and us and any and all recordkeeping purposes.
4. Online Advertisement
We may elect to participate in interest-based advertising and use third-party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. Further, we may elect to permit third party online advertising networks, social media companies, and other third-party services to collect information about your use of our Sites over time so that they may play or display ads on our Sites, on other websites, apps, or services you may use, and on other devices you may use.
Although it is not always the case, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an e-mail address or user ID) or hashed data with our third-party advertising partners to help identify you across devices. We and our third-party partners may use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. As we earlier stated, we may provide the results of such research and analysis for consideration to third parties.
5. Standards of Protection of your Information
We and our third-party service providers use reasonable organizational, technical, and administrative measures designed to protect Personal Information under our control. However, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is not secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.
6. How to Unsubscribe
Although our notifications and informational e-mails are extremely useful, if you do not wish to receive certain marketing-related e-mails from us, you may unsubscribe from receiving them by clicking on the “unsubscribe” link at the bottom of any of those e-mails.
Additionally, please note, that you may control certain informational services, such as order-related messages.
7. Control over your Personal Information
You may review, correct, and/or update certain elements of your Personal Information by adjusting information connected with your account in the relevant sections of the Sites. However, neither we nor our third-party service providers are responsible for altering Personal Information from the databases and/or other records of third parties with whom we and our third-party service providers have previously shared your Personal Information.
8. Data Retention.
9. Note Regarding the Use of the Sites by Children
Under no circumstances are the Sites directed to and/or intended for use by individuals under the age of 18, and we do not knowingly collect Personal Information from children under age 18. If you believe that we might have any information from a child under 18, please contact us immediately so that we may delete it as soon as possible. Please note that some information may be used with parental consent.
10. Your Responsibility to Comply with Law
If you choose to access the Sites and use our Services, you do so at your own risk and are responsible for complying with all applicable laws, rules, and regulations. We may limit the availability of the Sites, in whole or in part, to any person, geographic area, and/or jurisdiction we choose, at any time and in our sole discretion. By using the Sites and submitting any Personal Information, you consent to the transfer of Personal Information to other countries, which may provide a different level of data security than your country of residence provides.
Society Pass Incorporated
55W 39th Street, 18F
New York, NY. 10018 U.S.A.
Please note that e-mail communications will not necessarily be secure; accordingly, please do not include credit card information and/or other sensitive Personal Information in your e-mail correspondence with us.