Privacy Policy
Effective as of July 11, 2025

This is the Privacy Policy for Pogo Technologies, Inc. and its affiliates and subsidiaries. In this policy, we call ourselves “Pogo,” “we,” “us,” or “our.” We refer to you, the person using our app or Chrome extension or visiting our website, as "you" or “your”.

Pogo offers a service that allows you to earn rewards from your everyday purchases, identify financial savings opportunities, and get paid for sharing your data with Pogo and certain third parties (e.g., sharing under the Data Dividends program).

To the extent you have opted out of Data Dividends, then, going forward:

Market Research: We will not use your Personal Information covered under Data Dividends to share anonymized data and insights with Participating Businesses for market research.

Personalized Ads: We will not share your Personal Information covered under Data Dividends with Participating Businesses for personalized advertisements on or off the Service.

Opting in or opting out of Data Dividends does not restrict us from using your Personal Information internally (including through our service providers) for research/model training purposes, to target you with personalized ads or offers, to provide you with other services on the Service, and for any other purpose set forth in our Privacy Policy. To stop our collection of certain Personal Information categories on a go-forward basis, you can unlink certain Personal Information sources; relatedly, within the Data Dividends Control Center, there are separate toggles for certain Personal Information categories that govern our go-forward collection of the data. We may still process the Personal Information previously collected before you unlinked/toggled off except where not permitted under applicable law. You may also have opportunities to separately consent to share certain Personal Information with third parties even if you are not enrolled in Data Dividends, such as to receive certain services (e.g., Location Rewards).

Learn more about Data Dividends (including what Personal Information is covered under Data Dividends) here.

We may keep your Personal Information for as long as needed to provide the Services or as required under applicable law, unless you have requested that we delete it by submitting a request through our Privacy Center, deleting your account through the Pogo App, or contacting us at privacy@joinpogo.com. We may not be able to delete your information in all circumstances.

What this Privacy Policy covers:
This Privacy Policy describes how Pogo collects, uses, discloses, and otherwise processes Personal Information in connection with the www.joinpogo.com website (the "Site"), the Pogo mobile application (the "App"), and the Pogo Chrome browser extension (the "Extension").

In addition, the Privacy Policy covers any other service that we provide to the extent it posts or links to this Privacy Policy (collectively, including the Site, the App, and the Extension, the “Pogo Service” or "Service"). This Privacy Policy does not address our privacy practices related to Pogo job applicants, employees, and other personnel.

1. The types of personal information we collect from you
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What is Personal Information?

When we use the term “Personal Information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

We collect Personal Information in connection with your visits to, and other use of, the Service. This collection includes information that you provide in connection with the Service, information from third parties, and information that is collected automatically such as through the use of cookies and other tracking technologies.

You may also opt in to Data Dividends, which is part of our Rewards Program, that allows you to earn rewards for the sharing of your Personal Information with Participating Businesses for market research or personalized advertisements. Learn more about Data Dividends (including what Personal Information is covered under Data Dividends) here. The Personal Information shared with Participating Businesses will depend on your settings and the relevant activities or surveys you choose to participate in as part of Data Dividends. For more information, please see the Opt In to Data Dividends and Control Over Your Personal Information section of this Privacy Policy.

You may also choose to upload or record videos to the Service.  Uploading or recording videos is entirely optional.  If you decide to upload or record a video, it may be shared with Participating Businesses in accordance with your Data Dividends opt-in.

What Personal Information is collected from you?

We collect Personal Information from you that you may provide to us through the Service or otherwise. The categories of information we collect may include:

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Contact information

For example, your first and last name, email and mailing addresses, and phone number.

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Account and profile information

For example, Personal Information you provide to us after you create a user account.  The Personal Information we collect could include contact information, date of birth, gender, credit score, income, racial/ethnic origin, Financial Account Transaction Data, Online Account Digital Purchase Data, Physical Receipt Data, Browsing Data, Survey Responses, Cashback Offer Data, Health Information, Location Data, Driving Data, App Usage Data and video uploads. We also collect additional information if you provide it.

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Financial Account Transaction Data

This includes the data related to your linked bank accounts or credit or debit cards (each, a "Payment Credential"): account numbers and card transaction data collected and stored by our third-party providers (including credit or debit card transaction data collected by our third-party provider, Plaid, that covers the prior 24 months and all subsequent transactions until the card is unlinked from your Pogo account), bank fees and refunds, direct deposits, rent or mortgage payments, and bill payments (collectively, the "Transaction Data").

Transaction Data is automatically collected from Payment Credentials on a continuous basis except to the extent a Payment Credential is unlinked from your Pogo account. Given the nature of such collection, Transaction Data may include Health Information, such as payments for prescription medication and provider services. Pogo will only use such Health Information with your permission and in accordance with this Privacy Policy. For more information, please see the Health Information section below.

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Online Account Digital Purchase Data

We also collect purchase information, such as item/SKU-level data, through email accounts or digital consumer accounts (e.g., Amazon) that you link to your Pogo account (collectively, the "Linked Accounts"). We allow you to link email accounts or digital consumer accounts to your Pogo account, as directed by you, through the use of your login credentials to such accounts so that Pogo can retrieve purchase information from digital receipts from historical (up to 2 years prior) and future purchases in your digital consumer account or email ("Digital Purchase Data").

Given the nature of Linked Accounts, Digital Purchase Data may include Health Information, such as payments for prescription medication and provider services. Pogo will only use such Health Information with your permission and in accordance with this Privacy Policy. For more information, please see the Health Information section below.

In processing your Digital Purchase Data, Pogo may also retrieve Personal Information such as name, payment method, billing address, mailing address, and other information contained in the digital receipt email (collectively, the “Digital Account Data”).

The account credentials that you enter for these accounts are not stored with Pogo but are encrypted and stored locally on your device.

While linked, every time you open the Pogo app, Pogo will automatically collect Digital Purchase Data and Digital Account Data from your Linked Accounts.

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Physical Receipt Data

This includes information collected when you submit pictures of physical receipts to the App (the “Receipt Data”). For example, Receipt Data may include details of what was purchased, the merchant/store from which the goods/services were purchased, the amount spent, the date/time of the purchase, and the payment method used.

Given the nature of Receipt Data, it may also include Health Information, such as payments for prescription medication and provider services. Pogo will only use such Health Information with your permission and in accordance with this Privacy Policy.  For more information, please see the Health Information section below.

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Survey Responses

For example, information you provide when answering survey questions in the App, which may include information about your activities/interests, opinions about products/services, household information, and other demographic information.

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Chat Logs

If opted-in to sharing “Chat Logs”, we will collect your chat logs with large language models (LLMs) (e.g., ChatGPT) or other sources to the extent you’ve connected your account on such sources to your Pogo account.

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Health Information

With your permission, we may also collect your health information and use it to provide the Services, including, for example, to match you with surveys from pharmaceutical and other health-related companies for market research, to derive certain attributes and health information inferences about you based on the information we collect from you, to facilitate Data Dividends, to provide you with personalized advertising and other personalized content (including through location-based services where permitted by applicable law) – for more information on all our uses of Health Information please see "Health Information" in the "How we use and protect your Personal Information". section below and our Washington and Nevada Consumer Health Data Privacy Notice. Health Information may include information about your health conditions, prescription medication, health insurance claims, over-the-counter medication, health habits (such as frequency of exercise), use of health devices, vaccination history, and provider interactions (such as frequency of visits, preferred method of visits) (the "Health Information").

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Location Data

With your consent, Pogo and its third-party service providers collect precise location data from your mobile device, including when you are not using the App.

We share location data with third-party adtech companies, such as InMarket, to use in accordance with their own policies or practices, including for personalized advertising, ad campaign measurement and attribution, and analytics. You can learn more about how InMarket collects, uses, shares, and otherwise processes your data by reviewing the InMarket privacy policy available here.  

You may change your device or Pogo settings to restrict access or our sharing of location data, respectively.

We use the Google Maps API to gather information about your location, including verifying your self-reported home address. The use of the Google Maps features and content is subject to the Google Maps/Google Earth Additional Terms of Service available at https://maps.google.com/help/terms_maps.html and the Google Privacy Policy available at https://www.google.com/policies/privacy/.

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Driving Data

If opted-in to the "Drive to Save" program, we will collect information about your driving behavior, such as driving distance, the location of each trip, and your speed, acceleration, and braking habits (collectively, "Driving Data").

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App Usage Data

If opted-in to sharing “App Usage Data”, we will collect data related to your usage of mobile apps. This may include information about how much time you spend in apps installed on your device, app name, and the date and time of when the app was used.

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Feedback or correspondence

For example, information you provide when you contact us with questions, feedback, or otherwise correspond with us online.

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User content

For example, information about how you use the Service and interact with us, including information associated with any content you submit to us, and information you provide when you use any interactive features of the Service.

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Marketing information

For example, your preferences for receiving communications about our activities, events, and publications, details about how you engage with our communications, and emails you receive from specific businesses.

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Biometric information

In order to verify a user’s identity in connection with a request to cash out, or to confirm that users have not created multiple accounts, we may request access to a user’s mobile camera and require them to take a real-time selfie image of their face. We use a third-party technology installed on Pogo’s servers to analyze the selfie image and, using a combination of machine learning tools and statistical algorithms, generate facial biometric information about the user’s face. We use this information to perform identity verification and confirm that there are not duplicate accounts on the Service.

We may store facial biometric information generated from the images by our third-party software only as long as necessary for fraud detection. We do not use, disclose, or retain facial biometric information for any other commercial purpose.

You may choose to upload or record videos to the Service.  Those videos will be stored as long as your account is active, unless you ask us to delete them.

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Other information

We may collect additional types of information which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.

What Personal Information is collected from third-parties?

We also obtain Personal Information from third parties, which we often combine with Personal Information we collect either automatically or directly from you. We may receive the same categories of Personal Information as described above from the types of third parties listed herein.

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Information we obtain from social media platforms

We may maintain pages 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.

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Information we obtain from Linked Accounts

We may receive your information from Linked Accounts, including Digital Account Data.

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Information we obtain from health trackers and apps

At your request, we may also collect Health Information gathered or generated by your use of any third-party health application, system, program, or device that you connect to the Service (the "Connected Health Systems").

For example, if you choose to connect Apple's Health app on your iPhone or Apple Watch, we may receive information such as Activity History (i.e., steps taken, workouts, sleep), Health Vitals (i.e., body temperature, heart rate), Self-Reported Characteristics (i.e., height, weight, body fat percentage, gender), Clinical Records (i.e., protein samples, lab results), and information about the source of such data.

The data we receive from these third-party sites is dependent upon that third party's policies and your privacy settings on that third-party application, system, program, or device. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Service.

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Information we obtain from service providers

Our service providers that perform services solely on our behalf, such as payment processors, video and audio providers, or survey and certain advertising/marketing providers, collect Personal Information and may share some or all of this information with us.

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Referrals

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

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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 advertising partners (e.g., mobile measurement partners, advertisers/agencies), publicly available sources, and data providers. Personal Information obtained from these third parties may include payroll information (e.g., hours worked, wages earned, and tax withholdings) and auto insurance information (e.g., car you own, your driving history, and auto insurance plan coverage and price). We also may obtain your information from brand partnerships or through transactions such as mergers and acquisitions.

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Deidentified information

Through the provision of our Service, we may also process deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. Pogo commits to maintain and use the information in deidentified form and will not attempt to reidentify the information, except in instances where necessary for determining whether the deidentification process used by Pogo satisfies the requirements under applicable law.

What information is automatically collected?

As is true of many digital properties, we and our third-party partners may automatically collect certain information from or in connection with your computer, mobile device, or other device when visiting or interacting with the Service, including but not limited to:

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Device Data

This includes your computer or mobile device operating system type and version number, your mobile advertiser ID, your device UUID, manufacturer and model, device identifier, browser type, screen resolution, IP address, the URL or page entered and the referring page/campaign, the URL or the page you are on, date/time of visit, other user agent string data, the time spent on our Service, and any errors that may occur during the visit to our Service. Device data may overlap with the other categories of data below.

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Browsing Data

When you browse the Internet while logged into your account on the Pogo Extension, we will collect information such as the URLs/timestamps/content/ads of the pages that you visit, terms or keywords you search, and your activity (i.e., active vs. idle time, clicks, views).

If you are using a shared computer or device, please ensure you log out of the Pogo Extension each time you are not using the device.

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Cashback Offer Data

This includes the data pertaining to each transaction you complete, including purchases and returns, through cashback links in the Pogo App and Extension. This may include date/time of each transaction, merchant information, transaction amounts, amount of rewards generated, discount or coupon codes used, and item/SKU-level data.

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Analytics Data

This includes information about your use of and actions on the Service, such as pages or screens you viewed or clicked, 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, length of access, rewards earned/redeemed and metrics on how many emails we send that are actually opened and which attachments or links are opened, clicked, or viewed (such as via pixels).

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Advertising/Advertising Measurement Data

This includes data associated with your view of, or click on, advertisements served on our Service, cookie IDs or other digital or proprietary identifier (e.g., iOS IDFA, Google AAID) assigned to such device, and device metadata, analytics data, and location data described above, in each case, for purposes of serving advertising (personalized or otherwise) or facilitating advertising measurement/attribution to better optimize or otherwise understand the effectiveness of ad campaigns.

Note: We and our third-party partners may combine information that each of us collects automatically with other information about you, including information you choose to provide.  The information collected by us and our third-party partners may be collected over time and across third-party websites and mobile applications.

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Cookies and Other Tracking Technologies

We and our third-party providers may use cookies that our Service uses to store information about users on the users’ devices and other tracking technologies, such as web beacons, pixels, SDKs, scripts, location-identifying technologies, and logging technologies to automatically collect the Personal Information described in this section (and otherwise expanded upon in other sections). See “The choices you have regarding our collection, use, and sharing practices” section below to learn more about how you may limit or disable cookies or certain other tracking technologies on your device.

How We Use Google Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. ("Google"), who may set cookies on your browser or mobile device or read cookies that are already there to collect information. Google Analytics may also receive information about you from apps you have downloaded that partner with Google. Google Analytics collects information such as how often you use our Site and how you use our Site. We use the information provided by Google Analytics to improve our Site and services.

For more information regarding how Google collects, uses, and shares your information please visit http://www.google.com/policies/privacy/partners/. By using our Site, you consent to the processing of data about you by Google as described here and in Google's privacy policy. You can control the information provided to Google and opt out of certain ads provided by Google by using one of the of the methods set forth in http://www.google.com/policies/privacy/partners/ or use the Google Analytics opt out browser add-on at http://tools.google.com/dlpage/gaoptout?hl=en

Do Not Track signals:  Except with respect to honoring GPC signals on the Site as required under certain U.S. state privacy laws (e.g., the California Consumer Privacy Act), we do not currently respond to Do Not Track (DNT) signals received from Internet browsers.

2. How we use and protect your Personal Information
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Broadly speaking, Pogo uses your Personal Information to provide the Service (e.g., Data Dividends, providing you with other rewards services), the goal of which is to help you earn money on everyday purchases, to identify relevant savings opportunities, and provide you with a personalized experience. This includes using your Personal Information to do the following:

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Fulfill your requests and provide the Service to you

This includes

  • Making the Service available to you, including in connection with Participating Businesses;
  • Coordinating access to your account and establishing and maintaining your user profile on the Service;
  • Enabling the security features of the Service, such as by sending you security codes via email or SMS and remembering devices from which you have previously logged in;
  • Responding to requests, suggestions, questions, and comments and providing other types of user support;
  • Sending you service/transaction-related messages, such as changes to your account;
  • To credit you with automatic cash back when you make qualifying purchases;
  • To confirm a specific transaction occurred or rewards should be provided;
  • Communicating about, and administering your participation in, events, conferences, programs, contests, surveys, polls, panels, questionnaires, and other offers or promotions; and
  • Providing support and maintenance for the Service.
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Personalize your experience on our Service

This includes providing you with content or other products or services you might be interested in and de-emphasize content you've already read or viewed.

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Market our service

We will send you communications about new features, updates, products, and special offers. We may also use your information to serve you ads about our products or other products or services we (or our advertising partners, such as other third-party brands) think you might find interesting. We may also use individual and aggregate information about you to inform our marketing and advertising campaigns.

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Communicate with you

For example, we may communicate with you about your account activities, such as by providing you transaction confirmations or alerting you when a subscription is up for renewal. If you register with us, we may enroll you in our email newsletters or other periodic electronic communications and may also send you user surveys and promotional communications. We may communicate with you by email, postal mail, telephone, text message, or other means. For more information on how to adjust your communications preferences, see “The choices you have regarding our collection, use and sharing practices” section of this Privacy Policy.

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Monitor, improve, and develop our products and services

We may use your information to understand our visitors and customers and to tailor or optimize our Service. For example, we may analyze statistics and trends to make our Service better and to develop the Site or new services or features.

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Prevent fraud

We may use your Personal Information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to protect, investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.

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Protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law

We may use information to protect Pogo, our users, and our Service. We may also use information in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, protect and defend our rights and property, or the rights or safety of third parties, enforce our Terms of Use, this Privacy Policy, or agreements with third parties, detect and prevent fraud or for crime-prevention purposes, or for any other reason permitted by law. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets and may use information in connection with or as an asset in such a corporate business transaction. Personal Information may also be used in the event of insolvency, bankruptcy, or receivership.

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Create anonymous, aggregated or de-identified data

We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

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To perform analysis on your data using artificial intelligence

We may use AI tools to analyze your Personal Information.

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For any other purposes with your consent, at your direction, or where notice is provided

We may use your Personal Information for any other purposes with your consent, at your direction, or where notice is otherwise provided.

Health Information
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With your permission, your Health Information may be used by Pogo to deliver the Service to you, including for the following purposes:

  • For market research and providing insights into consumer health behaviors/conditions and conducting surveys based on health attributes;
  • To build and enhance consumer profiles;
  • To provide targeted ads or offers that may be of interest to you;
  • To surface clinical study or other research study opportunities for which you may be eligible to participate in.
Subject to limitations or restrictions under applicable privacy laws, we may also share your Health Information with Participating Businesses who may process your information pursuant to their own policies and practices. For more information about our processing activities in relation to "consumer health data" subject to Washington State's My Health My Data Act (MHMDA) and Nevada's SB 370, please see our Washington and Nevada Consumer Health Data Privacy Notice.
Security Practices
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We employ a number of organizational, technical, and physical safeguards designed to protect the Personal Information we collect.

We do not store your payment card or bank account information, and we do not have control over your payment card or bank account information. When you provide your payment card or bank account information through the Site or App, it is stored and otherwise processed by our third-party service providers.

3. The types of information we share — with whom and under what circumstances
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Pogo may disclose your Personal Information when you share content with others on the Service, when you consent or instruct us to share your information with third parties, or when we have a legitimate business or legal need to share your information. We may also disclose anonymous or aggregate information that does not reasonably identify you as an individual.

For example, your information may be shared with:

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Affiliates

We may share your Personal Information with our corporate parent, subsidiaries, and affiliates for purposes consistent with this Privacy Policy.

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Participating Businesses through Data Dividends

If you have opted in to Data Dividends, and subject to limitations or restrictions under applicable privacy laws, we will share your Personal Information covered under Data Dividends with participating businesses, such as marketing/advertising partners, analytics and research providers, LLM developers, social networks, brands, retailers, agencies, hedge funds and investment managers, and other business partners (collectively, "Participating Businesses"). If you have opted into “Personalized Ads” within Data Dividends, we will share your Personal Information so that they can display (either directly or via a third party) personalized ads on the Pogo Service or on third-party platforms, including through model training and inference based on such Personal Information. If you have opted into “Market Research” within Data Dividends, we will also send anonymized data and insights to Participating Businesses for market research purposes (e.g., consumer preferences, investment research, model training). All data categories covered under the Data Dividends program may be combined and used together for each use case. Participating Businesses may use any of the data that we provide under Data Dividends (e.g., Personal Information, anonymized data and insights) pursuant to their own policies or practices. Learn more about Data Dividends (including what Personal Information is covered under Data Dividends) here. To update Data Dividends preferences, see the Opt In to Data Dividends and Control Over Your Personal Information section of this Privacy Policy.

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Advertising and Analytics Partners

We may share your Personal Information with third-party marketing/advertising partners and analytics and research partners (e.g., brands, agencies, demand-side platforms, ad networks, mobile measurement platforms) or permit these partners to collect information about you, in either case, to facilitate advertising (personalized or otherwise), related measurement/attribution, or analytics activities.

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Service providers

We may share your Personal Information with third-party companies and individuals that provide services on our behalf or help us operate the Service (such as customer support, hosting, analytics, email delivery, advertising, marketing, research, and database management services), such as:

  • Microblink. Information collected by Microblink is used to digitize, process, and validate Digital Purchase Data and Physical Receipt Data, which may include items such as the merchant where a purchase was made, product descriptions, quantities, time of purchase, total purchase cost, and payment details. Microblink may use this data to improve its products and services. You may find out more about how Microblink provides services by accessing Microblink's privacy policy (see https://microblink.com/privacy-policy/).
  • Plaid. As a user of our Service, one of our service providers, Plaid, may access and transmit your data as reasonably necessary for Plaid to provide services to us. You may find out more about how Plaid provides services by accessing Plaid’s privacy policy (see https://plaid.com/legal/#consumers).
  • Tremendous. We use Tremendous to process your redemption request, which collects your contact information and cash out method preference to issue payment. You may find out more about how Tremendous provides services by accessing Tremendous’ privacy policy (see https://www.tremendous.com/privacy).
  • Twilio. We use your Personal Information to verify user identities to prevent fraud and abuse of the Service. We do this through our service provider Twilio, which verifies the phone number that you provide to us via its Verify API, sends an SMS to the provided phone number with a verification code that you are then asked to input in the Pogo application. Pogo sends this verification code to Twilio to validate your ownership of the phone number. You may find out more about how Twilio provides services by accessing Twilio’s privacy policy (see https://www.twilio.com/legal/privacy).
  • Zendrive. If you opt in to participate in the “Drive to Save” program, we may share your account and profile information and Driving Data with Zendrive, its affiliates and their partnered insurance companies in order to provide you with the Service.
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Pharmaceutical and healthcare partners

At your direction, and subject to limitations or restrictions under applicable privacy laws, we may share your Personal Information, including your Health and Location Data, with our pharmaceutical and healthcare partners.

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Lending and insurance partners

We may share your pre-qualification information (i.e., birthdate, credit score, gender, and income) with our loan and insurance partners.

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Other users of the Service and the public

We may enable you to disclose Personal Information to other users of the Service or the public at your direction. For instance, you may be able to maintain a user profile with information about yourself that you can make available to other users or the public. You may also be able to submit content to the Service (such as comments, reviews, surveys, blogs, photos, and videos), and we will display your name, username, and a link to your user profile along with the content you submit. We do not control how other users or third parties use any Personal Information that you make available to such users or the public.

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Professional advisors

We may disclose your Personal Information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

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For compliance, fraud prevention and safety

We may share your Personal Information for compliance, fraud prevention and safety purposes.

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Law enforcement, regulators, and other parties for legal reasons

We may share your Personal Information with third parties as required by law or subpoena or if we reasonably believe that such action is necessary: (a) to comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; or (c) to exercise or protect the rights, property, or personal safety of Pogo, our users, visitors, or others.

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Business transfers

We may sell, transfer, or otherwise share some or all of our business or assets, including your Personal Information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

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With your consent or according to your instructions

We may share information in other ways if you give us consent or direct us to do so, such as sharing your Personal Information for market research or personalized advertisements.

More on our third-party data collection and online advertising practices

Pogo participates in interest-based advertising or otherwise personalized advertising and may use third-party advertising partners to collect information from visitors to the Service for the purpose of displaying such ads on our Service and other websites, apps, or services, social networks, or on other devices you may use. Typically, though not always, these third-party advertising partners use cookies, SDKs, APIs, and other tracking technologies to recognize your browser or device and to collect information about your visit to our Service to provide you with customized content, advertising, and commercial messages which may be more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. In some cases, we may provide these third-party advertising partners with unique identifiers, such as a user ID, email address, phone number, or alternative ID (e.g., LiveRamp RampID) via pixel or other mechanisms (e.g., API, direct file upload, server-to-server integration) for the purposes set forth herein.

Please see the section below to learn to what extent you can opt out of interest-based advertising and other ads-related controls.

4. The choices you have regarding our collection, use and sharing practices
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In this section, we describe the rights and choices available to all users:

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Access or Update Your Information

If you have registered for an account with us, you may review and update certain Personal Information in your account profile by logging into your account and navigating to “Profile & My Information” in the App sidebar.

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Opt in to Data Dividends and Control Over Your Personal Information

To opt in to the sharing of certain Personal Information with Participating Businesses, follow the prompts in the sign-up flow or visit the Data Dividends Control Center in the app. You may opt out of Data Dividends through the Data Dividends Control Center.

Please note that, if you are not opted-in to Data Dividends, certain incentives and Services affiliated with the Pogo Rewards Program may not be available to you. To the extent you have opted out of Data Dividends, going forward:

Market Research: We will not use your Personal Information covered under Data Dividends to share anonymized data and insights with Participating Businesses for market research.

Personalized Ads: We will not share your Personal Information covered under Data Dividends with Participating Businesses for personalized advertisements on or off the Service.

Opting in or opting out of Data Dividends does not restrict us from using this Personal Information internally (including through our service providers) for research/model training purposes, to target you with personalized ads or offers, to provide you with other services on the Service, and for any other purpose set forth in our Privacy Policy. To stop our collection of certain Personal Information categories on a go-forward basis, you can unlink certain Personal Information sources; relatedly, within the Data Dividends Control Center, there are separate toggles for certain Personal Information categories that govern our go-forward collection of the data. We may still process the Personal Information previously collected before you unlinked/toggled off except where not permitted under applicable law. You may also have opportunities to separately consent to share certain of this Personal Information with third parties even if you are not enrolled in Data Dividends, such as to receive certain services (e.g., Location Rewards).

Learn more about Data Dividends (including what Personal Information is covered under Data Dividends) here.

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Opt out of the Service/Unlink a Card/Unlink a Linked Account
  • Go to the Accounts tab.

  • Click on “Unlink” (under the card or Linked Account you wish to unlink).

  • Confirm you want to unlink the card or Linked Account.

  • You must repeat this process for every linked card or Linked Account you wish to delete.

Note that opting out of the Service or unlinking your account does not delete historical data collected by Pogo from those accounts.  To delete your Personal Information, please submit a deletion request by submitting a request through our Privacy Center, deleting your account through the Pogo App, or contacting us at privacy@joinpogo.com. We may not be able to delete your information in all circumstances.

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Opt out of Health Trackers and Apps

To stop sharing Health Information with us that is collected through Connected Health Systems, follow the steps below:

  • Go to the Accounts tab.

  • Click on “Unlink” (under the Connected Health System you wish to unlink).

  • Confirm you want to unlink the Connected Health System.

  • You must repeat this process for every Connected Health System you wish to delete from Pogo.

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Opt out of Web Browsing Behavior Collection by the Pogo Extension

To stop future collection of Browsing Data by Pogo, log out of your Pogo account on the Pogo Extension, uninstall the Pogo Extension or browse the Internet using Incognito mode.

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Opt out of Marketing Communications

You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at privacy@joinpogo.com. You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to one of our marketing messages. For more information, please see our Terms of Use.

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Modifying or Deleting Your Information

If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our Service or publicly-displayed content, you can contact us directly at privacy@joinpogo.com. We may not be able to modify or delete your information in all circumstances.

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Cookies & Other Tracking Technologies

To manage cookies, an individual may have the ability to change their browser settings to (for example): (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies (or certain types of cookies, such as cookies set by third parties). Note that similar controls may exist for other tracking technologies, such as pixels, SDKs, and localStorage. Please check your device or browser settings and related documentation for more information. You can also manage certain cookies via the Cookie Management Tool, located on the bottom left corner of joinpogo.com.

To reject cookies across all browsers and devices, you will need to do so on each browser and device. You may also have options within your email to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

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Interest-Based Advertising (Self-Regulatory Opt-Outs)

To learn more about interest-based advertising and how you may be able to opt out of some of this advertising (to the extent the advertising partner or other entity participates in such industry opt-out pages), you may wish to visit the Digital Advertising Alliance’s (DAA) resources at www.aboutads.info/choices or the Network Advertising Initiative’s (NAI) online resources at http://www.networkadvertising.org/choices/. You can also opt out of receiving some interest-based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices. You may also be able to opt out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from these self-regulatory program participants (or other participants that may provide an opt-out mechanism) should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs, or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under those self-regulatory programs.

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Location Data

We make available certain privacy settings through the Data Dividends Controls CenData Dividends Controls Center in the app. If you use our App, you can decide whether to permit us to access your precise location data. Your device settings may provide the ability for you to revoke our ability to access location data. Withdrawing access to certain device information may affect the features and functionality of the Service and may inhibit our ability to provide you with the Service you have requested. For example, if you opted in to the "Drive to Save" program and your test drive is active, revoking our ability to access location data will put the test on hold. We also will not be able to provide you with Location Rewards.

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Choosing not to share your Personal Information

Where we are required by law to collect your Personal Information, or where we need your Personal Information in order to provide the Service to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our Service.

5. Your Privacy Rights
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In accordance with applicable privacy law, and depending upon the jurisdiction in which you reside, you may have some or all of the following rights in respect of your Personal Information:

Right of access. You may have the right to obtain:

  • confirmation of whether, and where, we are processing your Personal Information;
  • information about the categories of Personal Information we are processing, the purposes for which we process your Personal Information and information as to how we determine applicable retention periods;
  • information about the categories of recipients with whom we may share your Personal Information; and
  • a copy of the Personal Information we hold about you.

Right of portability. You may have the right, in certain circumstances, to receive a copy of the Personal Information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your Personal Information to another person.

Right to rectification or correction. You may have the right to obtain rectification or correction of inaccurate or incomplete Personal Information we hold about you.

Right to deletion or erasure. You may have the right, in some circumstances, to require us to delete or erase your Personal Information.

Right to restriction. You may have the right, in some circumstances, to require us to limit the purposes for which we process your Personal Information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the Personal Information is contested by you.

Right to opt out. You may have the right to opt out of certain processing activities. For example, you may have the right to opt out of the use of your Personal Information for targeted advertising purposes, or to “sell” or “share” your Personal Information with third parties in certain contexts.

Right to control over automated decision-making/profiling. The right to direct us not to use automated decision-making or profiling for certain purposes.

Right to withdraw consent. If you have provided consent for the processing of your Personal Information, you may have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your Personal Information before your withdrawal.

Right to limit. You have the right to direct us to limit the use of your sensitive personal information to certain purposes, including to perform the services or provide the goods reasonably by an average consumer who requests those goods or services.

Right to appeal. In the event that we decline to take action on a request exercising one of your rights set forth above, you have the right to appeal our decision.

6. Our policies on other sites, mobile apps and services
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The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your Personal Information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

7. Our policies on not collecting Personal Information from children
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The Service is not directed to, and we do not knowingly collect Personal Information from, anyone under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us and we will promptly delete such information. We encourage parents with concerns to contact us at privacy@joinpogo.com.

8. Retention
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We will usually store the Personal Information we collect about you for no longer than necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain Personal Information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.

To determine the appropriate duration of the retention of Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of Personal Information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Once retention of the Personal Information is no longer necessary for the purposes outlined above, we will either delete or deidentify the Personal Information or, if this is not possible (for example, because Personal Information has been stored in backup archives), then we will securely store the Personal Information and isolate it from further processing until deletion or deidentification is possible.

9. How we’ll notify you of changes to this Privacy Policy
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We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you including by updating the “Effective date” at the top of this Privacy Policy. Any modifications to this Privacy Policy will be effective upon our posting the new terms or upon implementation of the new changes on the Service (or as otherwise indicated at the time of posting).

10. How to contact us and exercise your privacy rights
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You may submit a request to exercise your privacy rights through the Pogo Privacy Center. You may contact us by emailing privacy@joinpogo.com. You may also write to us via postal mail at:

Pogo Technologies, Inc.

228 Park Ave S Suite 77949

New York, New York 10003