Política de Privacidad

Last Updated: March 2017

 

BY CLICKING ON THE ‘I AGREE’ ON THE TERMS AND AGREEMENTS IN THE POKO APP, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS STATEMENT AND YOU FULLY AGREE AND ACCEPT ALL OF THE TERMS AND PROVISIONS SET FORTH IN THIS STATEMENT.

 

This Statement explains how we use your information and applies to all who use our Web site – www.getpoko.com (the “Site”), our mobile application known as Poko (“Poko”), as well as electronic services, social networking sites, interactive features, or any of our described online activities we own or control (collectively, as “Poko”). This Statement is incorporated in our Terms and Conditions, which also apply when you use Poko.

If you do not agree with this Statement, please do not provide us with your personal information and do not interact with Poko. By interacting with Poko and/or providing us with your personal information you agree with this Statement.

We may amend, restate and/or modify this Statement at any time and in any way whatsoever, in our sole discretion. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of notice on the Site prior to the change becoming effective. You can determine when this Statement was last revised by referring to the date it was “Last Updated” above.

 
This Statement is organized as follows:

 

Types of Information We Collect

 

Your Choices

 

How VC Uses Information

 

When and Why VC Discloses Personal Information and Non-Identifiable Information

 

How VC Collects Information

 

Security of Personal Information; Waiver and Release

 

Accessing and Correcting Personal Information

 

Social Networks

 

Privacy Practices of Third Parties

 

Notice to Residents of Countries outside the United States of America

 

Children’s Privacy

 

Contact Us

 

Glossary of Terms

 

 

1. Types of Information We Collect

 

We will collect information, including Personal Information and Non-Identifying Information, when you interact with us and/or Poko, for example when you:

access or use the Site and/or Poko;

register, subscribe, or create an account with VC;

open or respond to our e-mails or post comments on Poko;

contact our customer service or use other customer support tools;

provide information to enroll or participate in Other Programs provided on behalf of, or together with, Business Partners;

visit any page online that displays our ads or content;

review, use and/or redeem offers, vouchers or coupons published on Poko;

connect, use or link to Poko via social networking sites; and

provide user demographic information and purchase pattern data to Vendors advertising on Poko.

This Statement does not apply to the collection of information in any way other than as listed above.


2. Your Choices
 

We think that you benefit from a more personalized experience when we know more about you and what you like. However, you can limit the information you provide to VC, and you can limit the communications that VC sends to you.

 

(a) Commercial E-mails

 

You may choose not to receive commercial e-mails from us by following the instructions contained in any of the commercial e-mails we send, by unsubscribing directly on any email we send you or by notifying us by email. Please note that even if you unsubscribe from commercial email messages, we may still e-mail you non-commercial e-mails related to your account and your activities on Poko. You may update your subscription preferences at any time.

 

(b) Cookies and Tracking

 

You may manage how your browser handles Cookies by adjusting its privacy and security settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. Currently, we do not alter our data collection and use practices in response to Do Not Track signals.

We use Non-Identifiable Information to directly serve you interest-based ads on third party websites. Interest-based ads served directly by VC on third party sites will display the AdChoices icon. If you prefer not to receive interest-based ads from VC on third party sites, you can click on the AdChoices icon in the ad, which will direct you to the Your VC AdChoices page where you can opt-out of receiving interest-based ads served by VC.

 

(c) Device Data

 

You may manage how your mobile device and mobile browser share certain Device Data with VC, as well as how your mobile browser handles Cookies by adjusting the privacy and security settings on your mobile device.

 

(d) E-mails from Business Partners

 

If you wish to opt out of receiving offers directly from our Business Partners, you can follow the opt-out instructions in the emails that they send you.

 

 

3. How VC Uses Information

 

We (or our Vendors on our behalf), use information collected as described in this Statement to:

 

Operate, maintain and improve Poko and our services, and Other Programs;

 

Provide you with interest-based ads and offers for products from participating Business Partners;

 

Evaluate your eligibility for certain types of offers, coupons or vouchers that may be of interest to you, and analyze advertising effectiveness;

 

Answer your questions and respond to your requests;

 

Perform analytics and conduct customer research;

 

Communicate and provide additional information that may be of interest to you about Poko and our Business Partners, sometimes by combining your information with information from Other Sources;

 

Send you reminders, technical notices, updates, security alerts, support and administrative messages, service bulletins, marketing messages, and requested information, including on behalf of Business Partners;

 

Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored by us or our Business Partners;

 

Manage our everyday business needs, such as administration of the Site, forum management, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms and Conditions, or to comply with the law;

 

We also may use information collected as described in this Statement with your consent or as otherwise required or permitted by law.

 

4. When and Why VC Discloses Personal Information and Non-Identifiable Information

 

We (or our Vendors on our behalf) may share your Personal Information as required or permitted by law:

with any VC Affiliate who may only use the Personal Information for the purposes described in this Statement;

to facilitate a direct relationship with you, including in connection with any program we administer on behalf of the Business Partner;

to enable electronic communications with you as part of an activity in which you have elected to participate;

to comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions;

to combat fraud or criminal activity, and to protect our rights or those of our Affiliates, users, and Business Partners, or as part of legal proceedings affecting VC;

in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate; or

with your consent.

We may also disclose Non-Identifiable Information:

for the same reasons we might share Personal Information;

with Business Partners for their own analysis and research;

to facilitate targeted content and ads; or

with Third-Party Ad-Servers to place our ads and/or ads of our merchants or Business Partners on the Site and on third-party sites, and to analyze the effectiveness of those ads.

We do not share Personal Information with Third-Party Ad-Servers; however, Third-Party Ad-Servers may automatically collect Non-Identifying Information about your visit to Poko and other websites, your device address, your Internet Service Provider and the browser you use to visit the Site. They do this by using Cookies, clear gifs and other technologies. Information collected may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visits to the Site and the other websites tracked by these third parties. This Statement does not cover the collection methods or use of the information collected by Third-Party Ad-Servers, and VC is not responsible for Cookies or clear gifs in third party ads. We encourage you to review the privacy policies or statements of these third party advertising companies to learn more about their use of Cookies and other technologies.

 

5. How VC Collects Information

 

You provide us with your Personal Information when you register, subscribe, create an account, or otherwise when you provide us with your Personal Information during your interaction with Poko and Other Programs. We also collect Personal Information when you contact us online for customer service and other support using self-help tools, such as email, text, or by posting to an Online Community.

We also receive Personal Information and other online and offline information from Other Sources. VC will use such information in accordance with applicable laws. Such information, when combined with Personal Information collected as provided in this Statement, will also be handled in accordance with this Statement. We also use cookies, tags, web beacons, local shared objects, files, tools and programs to keep records, store your preferences, improve our advertising, and collect Non-Identifying Information, including Device Data and your interaction with Poko and our Business Partners' web sites.

We use Cookies that allow us to connect your Poko activity with other information we store about you in your profile or as related to your interactions with Poko. You may decide to opt out of interest-based advertising using Cookies.

Device Data may be collected when your device interacts with Poko and/or VC, even if you are not logged into Poko using your device. If you have questions about the security and privacy settings of your mobile device, please refer to instructions from your mobile service provider or the manufacturer of your device to learn how to adjust your settings.

 

6. Security of Personal Information; Waiver and Release

 

VC has implemented an information security program that is designed to reasonably safeguard Personal Information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, you acknowledge and agree that we do not offer you any guarantee of any kind whatsoever as to the security of Personal Information. To the extent not expressly and specifically prohibited by applicable law, you hereby irrevocably agree to waive, release, defend, indemnify and hold us (including our shareholders, directors, officers, employees, affiliates, subsidiaries, partners, agents, contractors, representatives, consultants, successors and assignees) harmless from any and all obligations, liabilities, damages, losses, claims, suits, proceedings, investigations, actions, demands, causes of action, judgments, awards, and expenses, including but not limited to court costs, reasonable attorneys’ fees, experts’ fees, and other costs and expenses incident to or arising out of any claim or occurrence or investigation or the defense of any claim or occurrence (whether or not litigation has commenced), whether known or unknown, asserted or not asserted, whether absolute, accrued, contingent, fixed, determined or determinable, liquidated or unliquidated, and whether due or to become due, of any kind or nature whatsoever, asserted or claimed by anyone, that are, in each case, related to, arise from, or any in any way associated with or appurtenant to Personal Information.

 

7. Accessing and Correcting Personal Information

 

You can access, update and delete the information you provided to us by managing this information through your online account or sending us an email at cbruno@getpoko.com. Keeping your Personal Information current helps ensure that we, our Affiliates and Business Partners offer you the offers that are most relevant to you.

If you want to deactivate your VC account or have other questions or requests, please contact us. While we are ready to assist you in managing your subscriptions, deactivating your account, and removing your active profile, we cannot always delete records of past interactions and activities.

We will retain your Personal Information for as long as your account is active or as needed to provide you services and to maintain a record of your activities. If you wish to deactivate your account or request that we no longer use your Personal Information to provide you offers contact us at 787-782-3138. However, in our sole discretion, we will retain and use your Personal Information as necessary, including without limitation, in order to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

8. Social Networks

 

Social Community Areas

Poko may be accessible through or contain connections to areas where you may be able to publicly post information, communicate with others such as discussion boards or blogs, review products and merchants, and submit media content. Prior to posting in these areas, please read our Terms and Conditions carefully. All the information you post may be accessible to anyone with Internet access, and any Personal Information you include in your posting may be read, collected, and used by others. We recommend that you do not post any Personal Information in the social community areas.

 

Social Networks

You may log in to Poko using certain social network credentials. To manage the sharing of certain Personal Information with us when you connect with us through social networking platforms or applications refer to the privacy policy and settings of the social networking website or application.

You also have the option to link social networks, such as Facebook, to your VC account. Once you register with VC and connect with the social network, you will be able to automatically post recent VC activity back to your social network. You can enable and disable social network connections in your VC account.

By proceeding through any of the above steps, you grant VC permission to access all of the elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network’s terms of use and this Statement.

 

9. Privacy Practices of Third Parties

 

This Statement only addresses the use and disclosure of information by VC through your interaction with Poko. Other websites that may be accessible through links from Poko and Other Programs may have their own privacy statements and personal information collection, use, and disclosure practices. Our Business Partners may also have their own privacy statements. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of a sponsored offer or promotion.

 

10. Notice to Residents of Countries outside the United States of America

 

If you live outside the United States, and you use Poko or provide us with Personal Information via Poko, your information will be handled in accordance with this Statement. By using Poko or giving us your Personal Information, you are directly transferring your Personal Information and Non-Identifiable Information to us in the United States. The United States may not have the same level of data protection as your jurisdiction. However, you agree and consent to our collection, transfer, and processing of your Personal Information and Non-Identifiable Information in accordance with this Statement. You are solely responsible for compliance with any data protection or privacy obligations in your jurisdiction when you use Poko or provide us with Personal Information. Regardless of where we transfer your information, we will handle your information in the manner described in this Statement.

 

11. Children’s Privacy

 

VC does not intend that Poko will be accessed or used by children under the age of majority in the state or province in which they reside, and such use is prohibited. Poko is designed and intended for adults. By using Poko, you represent that you are over the age of majority in the state or province in which you reside and that you understand that you must be over the age of majority in the state or province in which you reside in order to create an account and use Poko. We will promptly delete information associated with any account that we obtain actual knowledge is associated with a registered user who is not at least the age of majority in the state or province in which he or she resides.

 

12. Contact Us

 

Please contact us if you have any questions or comments about our privacy practices or this Statement. You can reach us online at cbruno@getpoko.com. You can reach us via postal mail at the following address:

Virtual Coupons, Inc.

PO BOX 194919

San Juan, PR 00919

 

13. Glossary of Terms

 

“Affiliate” means an entity owned, directly or indirectly, by VC or that is controlled by or under common control with VC, and also includes joint ventures entered into by VC and/or its Affiliates.

“Business Partners” means, collectively, third parties with whom we conduct business, such as restaurants.

“Cookie” means a unique identifier, usually made up of small bits of text or code.

“Device Data” means information concerning a device you use to access, use, or interact with Poko, such as operating system type or mobile device model, browser type, domain, and other system settings, the language your system uses and the country and time zone of your device, geo-location, unique device identifier or other device identifier, mobile phone carrier identification, and device software platform and firmware information.

“Non-Identifying Information” means information that alone cannot identify you, including data from Cookies, Pixel Tags and Web Beacons, and Device Data. Non-Identifying Information may be derived from Personal Information.

“Online Communities” means, collectively, our social networking pages or accounts, forums, bulletin boards, discussion groups, chat rooms or other methods of communication that may be offered on or linked through Poko.

“Other Programs” means special programs, features and functionality on Poko or other co-branded websites with Business Partners that we reasonably control and that have special use terms applicable to such special programs, features and functionality.

“Other Sources” means sources of information that legally provide us with your information, and which are outside the scope of this Statement at the time of collection.

“Personal Information” means information about you that specifically identifies you or, when combined with other information we have, can be used to identify you. This includes the following types of information:

Contact Information: your name, email addresses, social networking website user account names, or other addresses at which you are able to receive communications.

Relationship Information: information you provide that enables us to determine lifestyle, interests, and activities, including location information related to your state/province, city, or neighborhood; areas of interest, the types of offers, coupons or vouchers that interest you, information collected through your interactions with social networks, demographic information (e.g., birth date, age, gender); information about persons for whom you have used offers, coupons or vouchers; and information about friends who refer you or whom you have referred.

Activity Information: information you provide when you interact with us and Poko, such as Poko offers, coupons or vouchers you are interested in, use and/or redeem; email and other communications; and how you interact with Business Partners and our Vendors.

“Pixel Tags and Web Beacons” means tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions.

“Third-Party Ad-Servers” means Vendors and other third parties that provide the technology to place ads on websites and track ad performance.

“Vendors” means, collectively, third parties that perform business operations on behalf of VC, such as mailing, communications services (e-mail, direct mail, etc.), marketing, data processing and analytics, servicing, collections, or ad management.

 

BY CLICKING ON THE ‘I AGREE’ ON THE TERMS AND AGREEMENTS IN THE POKO APP, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTOOD THIS STATEMENT AND YOU FULLY AGREE AND ACCEPT ALL OF THE TERMS AND PROVISIONS SET FORTH IN THIS STATEMENT.