Privacy Policy
2022
Effective as of June 27, 2022

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 call you, the person using our app or visiting our website, “you.”

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.
What this Privacy Policy covers:
This Privacy Policy describes how Pogo collects, processes, uses, and discloses personal information in connection with the www.joinpogo.com website (the “Site”) and the Pogo mobile application (the “App”).

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 and the App, the “Service”). This Privacy Policy does not address our privacy practices related to Pogo job applicants, employees and other personnel.

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

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

We collect personal information in connection with your visits to and 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.

What Personal Information is collected from you?

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

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Contact information

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

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Account and profile information

For example, personal information you provide to us after you create a user account. The Personal Information we collect could include contact information, date of birth, gender, credit score, Transaction Data, and income. We also collect additional information if you provide it.

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Transaction Data

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 information in connection with retailers you link to Pogo (collectively, the “Linked Retailer(s)”), such as item/SKU-level data from purchases. Our Rewards Program allows you to link other 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 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 (the “Linked Retailer Account Data”).

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Feedback or correspondence

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

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User content

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

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Marketing information

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

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Other information

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

What Personal Information is collected from third-parties?

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

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Information we obtain from social media platforms

We may maintain pages for our Company on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

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Information we obtain from Linked Retailers

We may receive your information from Linked Retailers, including Linked Retailer Account Data.

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Information we obtain from service providers

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

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Referrals

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

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Information we obtain from other third parties

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

What information is automatically collected?

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

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Device Data

This includes your computer or mobile device operating system type and version number, your mobile advertiser ID, your device UUID, manufacturer and model, device identifier, browser type, screen resolution, IP address, the URL 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.

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Location Data

For example, geographic location we or our third-party providers may collect, such as via Wi-Fi or IP address.

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Analytics Data

This includes information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access and metrics on how many emails we send that are actually opened and which attachments or links are opened, clicked or viewed (such as via pixels).

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Advertising/Advertising Measurement Data

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

Note: we and our third-party partners may combine information that each of us collects automatically with other information about you, including information you choose to provide. Our service providers and Participating Businesses may collect this type of information over time and across third-party websites and mobile applications.

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Cookies and Other Tracking Technologies

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

2. How we use and protect your Personal Information
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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:

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Fulfill your requests and provide the Service to you

This includes

  • Making the Service available to you and 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;
  • Communicating about, and administering your participation in, events, conferences, programs, contests, surveys, polls, panels, questionnaires, and other offers or promotions; and
  • Providing support and maintenance for the Service.
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Personalize your experience on our Service

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

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Market our service

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

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Communicate with you

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

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Monitor, improve, and develop our products and services

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

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Prevent fraud

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

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

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

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Create anonymous, aggregated or de-identified data

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

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

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

Transaction Data
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In addition to the use cases described above, Pogo and Participating Businesses may use your Transaction Data in these ways to deliver the Service to you

  • To credit you with automatic cash back when you make qualifying purchases;
  • For market research and providing insights into consumer purchasing behaviors and conducting surveys based on past purchases;
  • To provide targeted offers that may be of interest to you;
  • To confirm a specific transaction occurred or rewards should be provided;
  • To create a record of your Transaction Data to use data in connection with the Service;
  • To respond to a request from government authority or a payment organization involved in a transaction with you or a Participating Business;
  • To analyze bank fees charged on your Payment Credential to: (i) generate an email you can send to your bank to request the bank to provide a refund of such fees, if applicable; and (ii) recommend a low interest loan from a partner to pay off high interest credit card debt;
  • To help identify ways you can save money on insurance, loans, bills, utilities, prescriptions and mortgage payments.
  • To provide you rewards relating to item/SKU-level purchases with Linked Retailers.
Security Practices
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We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect.

We do not store your payment card or bank account information, and we do not have control over 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.

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

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

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Affiliates

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

  • Making the Service available to you and 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;
  • Communicating about, and administering your participation in, events, conferences, programs, contests, surveys, polls, panels, questionnaires, and other offers or promotions; and
  • Providing support and maintenance for the Service.
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Participating Businesses

We may share your personal information with Participating Businesses, including our market research and personalized advertising partners.

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Service providers

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

  • Plaid. As a user of our Service, you grant one of our service providers, Plaid, the right, power, and authority to access and transmit your data as reasonably necessary for Plaid to provide services to us. In addition, you acknowledge and agree that your personal information will be treated by Plaid in accordance with this Privacy Policy. You furthermore expressly grant Plaid the right, power and authority to (acting on your behalf) access and transmit your information, including personal information, as reasonably necessary for Plaid to provide services to you and to Pogo.
  • 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).
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Lending and insurance partners

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

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Other users of the Service and the public

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

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Professional advisors

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

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For compliance, fraud prevention and safety

We may share your personal information for compliance, fraud prevention and safety purposes.

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Law enforcement, regulators, and other parties for legal reasons

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; and/or (c) to exercise or protect the rights, property, or personal safety of Pogo, our users, visitors, or others.

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Business transfers

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

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With your consent or according to your instructions

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

Our third party data collection and online advertising practices

Pogo may participate in interest-based advertising and use third party advertising partners to collect information from visitors to the Service for the purpose of displaying interest-based advertisements on other websites, apps or services, social networks, or on other devices you may use. Typically, though not always, these third-party ad networks use cookies and 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.

Please see the section below to learn how you can opt out of interest-based advertising.

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

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Access or Update Your Information

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

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Opt-in for Data Dividends

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 privacy@joinpogo.com)Data Dividends Control Center.

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Opt-out of the Service/Unlink a Card

To opt-out of the Service and unlink your cards, you must follow the steps below:

  • Go to the Accounts tab.

  • Click on “Unlink Card.”

  • Confirm you want to unlink the card.

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

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Opt Out of Marketing Communications

You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at . 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 message. For more information, please see our Terms of Use.

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Modifying or Deleting Your Information

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

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Cookies & Other Tracking Technologies

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

Further, note that restricting the use of these technologies might negatively impact an individual’s experience using our Service, as some features or offerings may be less personalized or may not work as otherwise intended. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies or other tracking technologies described in this Privacy Policy. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser and device they use. An individual may also have options within their email client to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.

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Privacy Settings and Location Data

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.

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Targeted online advertising

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

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

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Choosing not to share your personal information

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

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

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

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

8. How to contact us
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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

For the residents of the State of Nevada, exercise your right to opt-out of sales subject to the Nevada Revised Statutes, please submit your request by clicking here here (opens the Data Dividends Control Center on mobile or directs you to email privacy@joinpogo.com from desktop).
For residents of the State of California, below are the Additional California Privacy Disclosures
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Additional California Privacy Disclosures

Last Updated: June 1, 2022

Scope of Disclosures

These Additional California Privacy Disclosures (the “CA Disclosures”) supplement the information contained in our Privacy Policy and apply solely to individual residents of the State of California (“consumers” or “you”).

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 efined in the CCPA. For the purpose of these CA Disclosures, personal information applies to “personal information” as defined by the CCPA (also referred to herein as “PI”).

Collection and Use of Personal Information

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, and payment information.
  • Protected Classification Characteristics, such as age and gender.
  • Commercial Information, such as payment and purchase history.
  • Internet/Network Information, such as device information, logs and analytics data
  • 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.
Disclosure and Sale of Personal Information

As described in the “The types of information we share” section of our Privacy Policy, we share personal information with third parties for business purposes or we may “sell” your personal information to third parties, subject to your right to opt out of those “sales” (see below).

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” 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 and (vi) Inferences.

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.

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):

The Right to Access/Know
You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity: The specific pieces of personal information we have collected about you; The categories of personal information we have collected about you; The categories of sources of the personal information we have collected about you; The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and The business or commercial purposes for collecting or, if applicable, selling personal information about you.
The Right to Request Deletion
You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.
The Right to Opt Out of Personal Information Sales
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
The Right to Non-Discrimination
You have the right not to receive discriminatory treatment for exercising any of the rights described above. However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.
“Shine the Light”
California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).
How to Exercise Your California Privacy Rights

To exercise your right to access/know and/or right to deletion, 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 and/or the right to deletion 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 and/or right to deletion, particularly where we are unable to verify your identity.

To Exercise Your Right to Opt Out of Personal Information Sales

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.  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.

Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time through the Data Dividend Controls Center Data Dividend Controls Center in our App or by emailing us at privacy@joinpogo.com.

Authorized Agents

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 or delete PI, we require the following for verification purposes:

  • a power of attorney valid under the laws of California from you or your authorized agent; or
  • sufficient evidence to show that you have:
    • provided the authorized agent signed permission to act on your behalf; and
    • verified your own identity directly with us pursuant to the instructions set forth in these CA Disclosures; or directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

For requests to opt-out of “sales,” 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 “Do Not Sell My Personal Information” link above.

Financial Incentives

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.