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 partners (“Participating Businesses”) for anonymous market research and personalized ads.
If you have opted out of Data Dividends, we will not share your Personal Information for market research or personalized advertisements.
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, Transaction Data, Digital Purchase Data, Physical Receipt Data, Browsing Data, Survey Responses and Cashback Offer Data. We also collect additional information if you provide it.
This includes the data related to your linked bank account(s) or credit or debit card(s) (a “Payment Credential”): account numbers and card transaction data collected and stored by our third-party providers (including credit and/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 – the “Plaid Credit Card Data”), bank fees and refunds, direct deposits, rent and/or mortgage payments, and bill payments (collectively, the “Transaction Data”).
We also collect purchase information, such as item/SKU-level data, through email accounts or digital consumer accounts that you link to your Pogo account (collectively, the “Linked Account(s)”). Our Rewards Program allows 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 account(s) so that Pogo, as your agent, can retrieve purchase information from digital receipts from historical (up to 2 years prior) and future purchases in your digital consumer account or email. In processing your digital receipt data, Pogo may 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.
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.
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.
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.
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 following third parties:
We may receive your information from Linked Accounts, including Digital Account Data.
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 only submit a referral 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 marketing partners, 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 or mobile 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 entered and the referring page/campaign, 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.
For example, geographic location we or our third-party providers may collect, such as via Wi-Fi or IP address.
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, your speed, acceleration and braking habits (collectively, ”Driving 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).
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, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access, 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.
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. Our service providers and Participating Businesses may collect this type of information over time and across third-party websites and mobile applications.
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. We do not combine the information collected through the use of Google Analytics with personally identifiable information.
Do Not Track signals: We do not currently respond to Do Not Track (DNT) signals received from Internet browsers.
Broadly speaking, Pogo uses your Personal Information to deliver the Service to you, the goal of which is to help you earn money on everyday purchases and to identify relevant savings opportunities. This includes using your Personal Information to do the following:
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.
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 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.
In addition to the use cases described above, Pogo and Participating Businesses may use your Transaction Data, Digital Purchase Data, Physical Receipt Data, Browsing Data and Survey Responses (collectively, the “Purchase Data”) in these ways to deliver the Service to you
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 or responsibility for your payment card or bank account information. When you provide your payment card and/or bank account information through the Site or App, it is stored and/or processed by our third-party service providers.
Please note that security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your Personal Information.
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.
Please note if you have opted out of Data Dividends, we will not share your Personal Information in accordance with our market research or personalized advertisements initiatives.
For example, your information may be shared with
We may share your Personal Information with Participating Businesses, including our market research and personalized advertising partners. In these cases, we may limit the types of identifiers we share (i.e., hashed emails) and restrict the ways in which third parties may use this data. If you have opted out of Data Dividends, we will not share your Personal Information with Participating Businesses, in accordance with our market research or personalized advertisements initiatives.
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, and database management services).
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 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 anonymous market research and/or personalized advertisements.
Please see the section below to learn how you can opt out of interest-based advertising.
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.
If you opt in to sharing your Personal Information for anonymous market research and/or personalized advertisements, you will earn rewards in connection with this opt in (“Data Dividends”). To opt in to this information sharing, follow the prompts in the sign-up flow or visit the Data Dividends Control Center Data Dividends Control Center in the app. You may opt out of this information sharing at any time by visiting the Data Dividends Control Center (on mobile, the link will take you to the right section of the app, and on desktop, it will direct you to email firstname.lastname@example.org)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 opt out of the Service and unlink your cards or Linked Accounts, you must follow the steps below:
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.
You must repeat this process for every linked card or Linked Account you wish to delete.
If you do not want your browsing behavior to be collected, you can opt out of Data Dividends in the Data Dividends Control Center (on mobile, the link will take you to the right section of the app, and on desktop, it will direct you to email email@example.com).
If you log out of your Pogo account on the Pogo Extension, uninstall the Pogo Extension or browse the Internet using Incognito mode, Pogo will not collect any Browsing Data.
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 firstname.lastname@example.org. 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.
We make available certain privacy settings through the Data Dividends Controls Center Data 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.
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.
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 email@example.com.
We will usually store the Personal Information we collect about you for no longer than necessary to fulfil 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.
Pogo Technologies, Inc.
228 Park Ave S Suite 77949
New York, New York 10003
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 by clicking here (opens the Data Dividends Control Center on mobile or directs you to email firstname.lastname@example.org from desktop).
Last Updated: March 15, 2023
Scope of Disclosures
These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the California Consumer Privacy Act of 2018 defined in the CCPA. For the purpose of these CA Disclosures, personal information means “personal information” as defined by the CCPA (also referred to herein as “PI”).
In the last 12 months, we may have collected the following categories of PI:
The categories of third parties to whom we may sell or disclose for a business purpose may include: (i) other brands and affiliates; (ii) our service providers and advisors; (iii) marketing/advertising and strategic partners; (iv) analytics providers; and (v) social networks.
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.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the PI about you that we have collected (subject to certain limitations at law):
To exercise your right to access/know, right to deletion, and/or right to correction, please submit a request by
We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know, the right to deletion, and/or the right to correct to that personal information identified on the California Resident Rights Request Form, certain requests may require us to obtain additional personal information from you. In certain circumstances, we may decline a request to exercise the right to access/know, right to deletion, or right to correct particularly where we are unable to verify your identity.
To Exercise Your Right to Opt Out of Personal Information Sales or Sharing for Targeted Advertising
We “sell” personal information to third parties, as such term is broadly defined under the CCPA. The third parties to whom we sell personal information may use such information for their own purposes in accordance with their own privacy statements, which may include reselling this information to additional third parties.
To exercise your Right to Opt Out of Personal Information Sales, please submit a request by clicking the following link:
You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales or Sharing for targeted advertising. However, we may ask you to provide additional personal information so that we can properly identify you in our dataset and 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 chose 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.
As is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third party businesses to collect and disclose your personal information (including preferences, geolocation, commercial information and internet, network and device information) directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. These third parties use this information for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting and may sell that information to other businesses for advertising and other purposes. By visiting here, you can opt out from sales of this type of personal information by businesses that participate in the opt out tool. To make opt out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt Out Tool, you can download the appropriate app at https://www.privacyrights.info/.
In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth in these CA Disclosures where we can verify the authorized agent’s authority to act on your behalf.
For requests to access/know, delete, or correct PI, we require the following for verification purposes:
For requests to opt out of “sales” or “sharing”, we require a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
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 click the “Your Privacy Choices” link above.
In addition, we may offer you financial incentives for the collection, sale, retention and use of your PI as permitted by the CCPA 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.
Updates to These CA Disclosures
We will update these CA Disclosures from time to time. When we make changes to these CA Disclosures, we will change the "Last Updated" date at the beginning of these CA Disclosures. If we make material changes to these CA Disclosures, we will notify you through appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided in the notification.
Last Updated: March 15, 2023
Scope of Disclosures
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.
The following Personal Information elements we collect may be classified as “sensitive” under certain privacy laws (“sensitive information”): personal data (including racial/ethnic origin), precise geolocation data.
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:
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 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.
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.
To Exercise Your Right to Access, Right of Portability, Right to Correction, Right to Deletion, or Right to Appeal, please submit a request by
Before processing your request, we will need to verify your identity and confirm you are a resident of the State of Colorado, Connecticut, 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.
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.
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.
To exercise the Right to Opt Out of Personal Information sharing for targeted advertising purposes, certain profiling activities or data “sales,” you may submit a request by clicking on this link.