Privacy Policy

Effective as of March 24, 2021.

Pogo offers a Service that includes a rewards platform that allows users to earn cashback rewards from their everyday purchases and allows merchants who are members of the Pogo platform (“Participating Merchants”) to acquire, retain and engage with these users.  Pogo Technologies, Inc. (“Pogo”) is committed to treating your personal information with respect and sensitivity.   This “Privacy Policy” describes the privacy practices of Pogo and our subsidiaries and affiliates (collectively, “Pogo”, “we”, “us”, or “our”) in connection with the www.joinpogo.com website, the Pogo mobile application, and any other website or mobile application that we own or control and which posts or links to this Privacy Policy (collectively, the “Service”), and the rights and choices available to individuals with respect to their information. Pogo may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

If you have consented to participate in the Service, please visit the Terms of Use Agreement to learn more about the data collection, use, and sharing practices in connection with our Service.  If you would like to opt out of card linking and transaction monitoring in connection with the program, please refer to Your Choices below.

Table of Contents

  1. Personal Information We Collect
  2. How We Use Your Personal Information
  3. How We Share Your Personal Information
  4. Your Choices
  5. Other Sites, Mobile Applications, and Services
  6. Security Practices
  7. International Data Transfers
  8. Children
  9. Changes to this Privacy Policy
  10. How to Contact Us
  11. Your California Privacy Rights

Personal Information We Collect

Information you provide to us.  Personal information you provide to us through the Service or otherwise includes:

- Business and personal contact information, such as your first and last name, email and mailing addresses, phone number, gender, hometown, professional title and company name.
- Content you choose to upload to the Service, such as text, images, audio, and video, along with the metadata associated with the files you upload.
- Profile information, such as your username and password that you may set to establish an online account with us.
- Transaction Data, including bank account numbers and credit card transaction data collected and stored by our third party provider, Empyr (“Transaction Data).
- Other Credit Card Data, including up to 24 months prior and all subsequent transactions until the credit card is unlinked from your Pogo account acquired by our third party provider, Plaid (“Plaid Credit Card Data”).
- Digital Receipt Data, including consumer account or email log-in credentials and any personal information contained on digital receipts (for participants of the Digital Receipt RewardData Rewards Program).
- Registration information, such as information that may be related to a service, an account or an event you register for.
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
- Demographic Information, such as your city, state, country of residence, postal code, and age.
- Precise geolocation information, such as when you authorize our mobile application to access your location.
- Usage information, such as information about how you use the Service and interact with us, including information associated with any content you upload to the websites or otherwise submit to us, and information you provide when you use any interactive features of the Service.
- Marketing information, such as your preferences for receiving communications about our activities, events, and publications, and details about how you engage with our communications
- Tax Information, if we are required by law to send to you and file certain forms with tax authorities, in which case we may ask you to provide us or our service provider certain personal information, including but not limited to your Taxpayer Identification Number.
- Other information that we may collect such as your and other information that is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

Information we obtain from social media platforms. We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy. If you choose to login to the Service via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Service, we may collect information from that platform or network. For example, this information may include your Facebook username, user ID, profile picture, cover photo, and networks to which you belong (e.g., school, workplace). You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address.  You can read more about your privacy choices in the “Third party platforms or social media networks” portion of the “Your Choices” section.

Information we obtain from other third parties.  We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers.

Cookies and Other Information Collected by Automated Means  We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Service, including but not limited,  your computer or mobile device operating system type and version number, your mobile advertiser ID, your device UUID, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, general location information such as city, state or geographic area; information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access; and other personal information.  Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

On our webpages, this information is collected using cookies, browser web storage (also known as locally stored objects, or “LSOs”), Flash-based LSOs (also known as “Flash cookies”), web beacons, and similar technologies, and our emails may also contain web beacons. In our mobile application, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our App.

A “cookie” is a text file that websites send to a visitor‘s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. Browser web storage, or LSOs, are used for similar purposes as cookies. Browser web storage enables the storage of a larger amount of data than cookies. A “web beacon,” also known as a pixel tag or clear GIF, is typically used to demonstrate that a webpage was accessed or that certain content was viewed, typically to measure the success of our marketing campaigns or engagement with our emails and to compile statistics about usage of our websites. A SDK is third-party computer code that we may incorporate into our mobile applications that may be used for a variety of purposes, including to provide us with analytics regarding the use of our mobile applications, to integrate with social media, add features or functionality to our app, or to facilitate online advertising.

We may also use Flash LSOs on our website to collect and store information about your use of our website. Unlike cookies, Flash LSOs cannot be removed or rejected via your browser settings. If you do not want Flash LSOs stored on your computer or mobile device, you can adjust the settings of your Flash player to block Flash LSO storage using the tools contained in the Website Storage Settings Panel. You can also control Flash LSOs by going to the Global Storage Settings Panel and following the instructions. Please note that setting the Flash Player to restrict or limit acceptance of Flash LSOs may reduce or impede the functionality of Flash applications that we may use in connection with our website.

Web browsers may offer users of our websites or mobile apps the ability to disable receiving certain types of cookies; however, if cookies are disabled, some features or functionality of our websites may not function correctly. Please see the “Targeted online advertising” section for information about how to exercise choice regarding the use of browsing behavior for purposes of targeted advertising.

Referrals
‍Users of the Service may have the opportunity to refer friends or other contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.