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 Pogo or its service providers 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. In some cases, you may also 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.
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:
In addition, the Privacy Policy covers the related content, products, services, platforms, and other functionality offered on or through the online services and any other website or mobile application that we own or control and which 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.
For individuals in the United States, please refer to our Additional U.S. State Privacy Disclosures for additional information about the processing of your personal information and additional rights you may have under applicable U.S. state privacy laws. 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, and additional rights you may have in relation to such data, please see our Washington and Nevada Consumer Health Data Privacy Notice.
- The types of personal information we collect from you
- How we use and and protect your personal information
- The types of information we share—with whom and under what circumstances
- The choices you have regarding our collection, use and sharing practices
- Our policies on other sites, mobile apps and services
- Our policies on not collecting personal information from children
- How we’ll notify you of changes to this Privacy Policy
- How to contact us
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 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.
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:
For example, your first and last name, email and mailing addresses, and phone number.
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, and Health Information. We also collect additional information if you provide it.
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.
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.
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.
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.
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").
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/.
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").
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.
For example, information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
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.
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.
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.
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.
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.
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.
We may receive your information from Linked Accounts, including Digital Account Data.
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.
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.
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.
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.
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.
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:
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.
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.
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.
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).
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.
For more information on our and third-party partners’ data collection and online advertising practices, please see the “Our third-party data collection and online advertising practices” section of this Privacy Policy.
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.
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 GPC signals on the Site in certain applicable states (e.g., California), we do not currently respond to Do Not Track (DNT) signals received from Internet browsers.
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:
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.
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.
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.
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.
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.
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.
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.
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.
We may use your Personal Information for any other purposes with your consent, at your direction, or where notice is otherwise provided.
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.
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.
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:
We may share your Personal Information with our corporate parent, subsidiaries, and affiliates for purposes consistent with this Privacy Policy.
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, 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). 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.
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.
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.
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.
We may share your pre-qualification information (i.e., birthdate, credit score, gender, and income) with our loan and insurance partners.
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.
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.
We may share your Personal Information for compliance, fraud prevention and safety purposes.
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.
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.
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.
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 or email address or phone number, 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.
In this section, we describe the rights and choices available to all users:
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.
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. In some cases, you may also 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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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).
Please direct any questions or comments about this Privacy Policy or privacy practices to 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
Last Updated: November 1, 2024
Scope of Disclosures
These additional disclosures supplement the information contained in our Privacy Policy by providing additional information about our Personal Information processing practices relating to individual residents of the States of California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah, and Virginia.
As further described in the “Types of information we share” section of the Privacy Policy, and subject to any restrictions or limitations under applicable privacy laws, we may “sell” your Personal Information (as defined by the applicable privacy laws) to or share your data with third parties for cross-context behavioral advertising purposes (targeted advertising), subject to your right to opt out (see “Your Privacy Choices” below).
The categories of third parties to whom we may sell or share the Personal Information include: Business and Marketing Partners, Online Advertising Networks and Analytics Providers, and Social Networks.
We may also disclose Personal Information for the purposes described in the “Types of information we share” section of our Privacy Policy.
The following Personal Information elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”): personal data (including race and ethnicity), the contents of email, precise geolocation data, and personal information revealing mental or physical health diagnosis.
We use this sensitive information for the purposes set forth in our Privacy Policy.
Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to withdraw your consent for our processing of sensitive information (as described in the Your Privacy Choices section below).
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 any 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.
- Colorado Residents: If your appeal is denied, you may contact the Colorado Attorney General to address your concerns here.
- Connecticut Residents: If your appeal is denied, you may contact the Connecticut Attorney General to submit a complaint here.
- Montana Residents: If your appeal is denied, you may contact the Montana Attorney General to submit a complaint here.
- Oregon Residents: If your appeal is denied, you may contact the Oregon Attorney General to submit a complaint here.
- Texas Residents: If your appeal is denied, you may contact the Texas Attorney General to submit a complaint here.
- Utah Residents: If your appeal is denied, you may contact the Utah Attorney General to submit a complaint here.
- Virginia Residents: If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint here.
Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.
How to Exercise Your Additional State Privacy Rights
To Exercise Your Privacy Rights, please submit a request by either:
- Emailing privacy@joinpogo.com with the subject line “Consumer Rights Request,” or
- Submitting your request through the Pogo Privacy Center, or
- Calling (917) 473-3881.
Before processing your request, we will need to verify your identity and confirm you are a resident of the State of California, Colorado, Connecticut, Montana, Nevada, Oregon, Texas, Utah, or Virginia. In order to verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional Personal Information from you, including, but not limited to, your Pogo-linked email address and/or phone number.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
Unless you have exercised your Right to Opt Out, we may "sell" or “share” your Personal Information to third parties or process your Personal Information for “targeted advertising”. The third parties to whom we “sell” or “share” Personal Information (or disclose for “targeted advertising”) may use such information for their own purposes in accordance with their own privacy policies.
You do not need to create an account with us to exercise your Right to Opt Out. However, we may ask you to provide additional Personal Information so that we can properly identify you to track compliance with your opt-out request. We will only use Personal Information provided in an opt-out request to review and comply with the request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems. We may not process your request if we, in good faith, believe that the request is fraudulent. In such instances, we will send a notice to the requestor explaining our decision.
For the Pogo Website
- Cookie-Based "Sales"/”Shares” & “Targeted Advertising” Opt Outs: To exercise your right to opt-out as it relates to the use of certain cookies and other online tracking technologies for targeted ads and related analytics on our website (joinpogo.com) except where an exception under applicable law might apply (e.g., where we have appropriately limited how our partners use your data), please update your preferences via the Cookie Management Tool located in the bottom left corner of the website. Alternatively, you may visit our Site with Global Privacy Control (GPC) enabled (learn more about GPC at www.globalprivacycontrol.org).
Please note this opt out is browser-specific and you must reset your preferences if you clear cookies or use a different browser or device.
For the Pogo Mobile Apps
- SDKs & Other Online Tracking “Sales”/"Shares" & "Targeted Advertising" Opt Outs: If you would like to exercise your right to opt-out as it relates to the use of certain SDKs and other tracking technologies in the Pogo mobile applications, you will have to delete your Pogo account. Pogo is a rewards program that relies on the exchange of information in order to provide you with Rewards. Online tracking technologies are essential to the exchange of such information and without tracking technologies, Pogo is unable to continue to provide the Service to you.
If you would like to delete your Pogo account in order to exercise your right to opt out of “sales” and targeted advertising, please do so via the App or submit a request through the Pogo Privacy Center. - Data Dividends “Sales”/"Shares" & "Targeted Advertising" Opt Outs: To opt out of the use and sharing of the Personal Information you've shared with Pogo for market research and/or targeted advertising, please visit the Data Dividends Control Center in the Pogo app and use the toggles to reflect your preferences.
Please note: Some of your earnings from Pogo are a direct result of the information you choose to share for Data Dividends. If you opt out of Data Dividends, you may not be able to access certain app features, like receipt scanning or linking your retailer accounts.
For the residents of the State of Nevada, to exercise your right to opt out of sales subject to the Nevada Revised Statutes, please submit your request here.
Submitting Authorized Agent Requests
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf. In order to verify the authorized agent’s authority, we generally require evidence of either (i) a valid power of attorney or (ii) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.
Financial Incentives
In addition, we may offer you financial incentives (such as Data Dividends) for the collection, sale, retention, and use of your Personal Information that can, without limitation, result in reasonably different prices, rates, or quality levels. The material aspects of any financial incentive will be explained and described in its program terms. Please note that participating in incentive programs is entirely optional, you will have to affirmatively opt in to the program and you can opt out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. We may add or change incentive programs, and/or their terms by posting notice on the program descriptions and terms linked to above, so check them regularly.
Each financial incentive or price or service difference related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business, taking into consideration the value of the offer itself and the anticipated revenue generation that may be realized by rewarding brand loyalty. We calculate the value of the offer and financial incentive by using the expense related to the offer.
Last Updated: November 1, 2024
If you are a California resident, these additional disclosures are required under the California Consumer Privacy Act (CCPA):
We collect personal information from and about you for a variety of purposes as set out in the “How we use and protect your Personal Information” section of our Privacy Policy. To learn more about the types of PI we collect and the purposes for which we use this information, please refer to our Privacy Policy.
In the last 12 months, we may have collected the following categories of PI:
- Identifiers, such as name, email address, residential address, or other similar identifiers.
- California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birth date, contact information, insurance policy number, medical information, and payment information.
- Protected Classification Characteristics, such as race, age, and sex.
- Commercial Information, such as payment and purchase history or tendencies.
- Internet/Network Information, such as device information, logs, analytics data, browsing history, search history and information on a consumer's interaction with a website, application, or advertisement.
- Geolocation Information, such as precise location information from your device or generated based on IP address or Wi-Fi.
- Profession/Employment Information, such as your employer or company, and payroll and tax information.
- Other Personal Information, such as information you answer in a survey, other accounts that you link or otherwise provide to us.
- Inferences, such as predictions about your interests and preferences.
- Sensitive Personal Information, such as precise geolocation data, racial/ethnic information, the contents of email, and personal information collected and analyzed concerning a consumer's health.
As described in the “The types of information we share” section of our Privacy Policy, we disclose personal information for business purposes or we may "sell" or “share” your personal information to third parties, subject to your right to opt out of those "sales" or “shares” (see below).
The categories of third parties to whom we may sell or “share” includes Participating Businesses (in the context of Data Dividends) or marketing/advertising and analytics and research partners.
In the last 12 months, we may have disclosed all of the categories of PI we collect (explained above) to third parties for a business purpose.
In the last 12 months, we may have "sold" or "shared" the following categories of personal information, according to your settings and your right to opt out: (i) Identifiers, (ii) Commercial Information, (iii) Internet / Networks Information, (iv) Geolocation Information, (v) Other Personal Information, (vi) Inferences and (vii) Sensitive Personal Information.
In addition, please see the “Third party data collection and online advertising practices” section of our Privacy Policy to learn how third-party advertising networks, social media companies, and other third-party entities collect and disclose your PI directly from your browser or device through cookies or other data collection technologies when you visit or interact with our Site, use our App, or otherwise engage with us.
Minors Under Age 16
We do not sell the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.
“Shine the Light”
California's "Shine the Light" law (Civil Code Section §1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of personal information to third parties for their direct marketing purposes. To opt out of having your personal information disclosed to third parties for their direct marketing purposes, please submit your request through the Pogo Privacy Center.