Last updated November 10, 2023

This Privacy Policy describes the types of Personal Information that Prolly Technologies, Inc. (“Prolly Technologies,” “Prolly,” “we,” “our,” or “us”) collects from and about you, how we may use and disclose such information, and your choices and legal rights with respect to such information. We ask that you carefully review this Privacy Policy, as it applies to the websites (each a “Site”) and mobile applications (each an “App”) as well as the services owned, operated, and/or provided by Prolly Technologies that display or link to this Privacy Policy (collectively, our “Services”).

By using our Services, you agree to our Terms of Services, and to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree, please do not use our Services.

For purposes of this Privacy Policy, “Personal Information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, and includes “personal data” or similar terms as defined in applicable law.  

1.             PERSONAL INFORMATION WE COLLECT

There are several ways we may obtain Personal Information about you, including through (A) information you provide to us; (B) information we automatically collect; (C) information we receive from third parties; and (D) combining information from different sources. This includes data that identifies you personally whether directly or indirectly.

A.             Information You Provide

We collect Personal Information as listed in the above Notice at Collection from you as follows: 

·         When You Create an Account.  When you create an account with us, we may collect your name, email address, phone number, username, password, and security questions or other authentication data.

·         When You Use our Services. We also collect any Personal Information you disclose in a public manner on our Services. If you choose to upload or add photos, videos, comments, reviews, or other content to our Services, your upload becomes public information[SE1] . Please exercise caution when disclosing personal information in these public areas.

·         When You Make a Purchase. Purchases through Apple App store are handled by Apple and the information is processed in accordance with Apple’s terms and conditions.

·         When You Provide Information Through Social Media. If you link a social media account through our Services, we may automatically receive certain information about you based on your registration and privacy settings on those third-party services. Depending on the social media platform, this may include, but may not be limited to, name, username, email address, demographic information, friends list, location, interests, and social media and online activity.

·         When You Use Our Mobile Application. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

·               Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's contacts, microphone, reminders, sms messages, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

·               Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

·               Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's app settings.

B.             Information We Automatically Collect

When you visit and interact with our Services, we or our third-party advertising and analytics partners and service providers may use a variety of technologies, such as cookies, tags, SDKs or scripts, to collect certain information regarding your activity. 

The specific types of information that we and our partners and service providers may automatically collect when you visit and interact with our Services include:

·         Device and Browser Information. This includes your device’s IP address and/or other unique identifiers, browser type, device type, internet service provider, and operating system.

·         Location Information. When you access our Services from a mobile device, your device’s approximate location (derived from your device’s IP address or other signals) may be collected.

·         Usage Information. When you interact with our Services, certain information may be collected, including the date and time of your visit, the pages you view immediately before and after you access our Services, the areas or pages of our Services that you visit, the amount of time you spend viewing or using our Services, and other Site usage information. We (or our third-party vendors) may use tools and software to monitor and record information (including screenshots and videos) about your interactions with our Services, including keystrokes, mouse movements, form field entries, and overall engagement with our Services.

·         Marketing Information. If you receive an email from us, information may be collected about your interactions with the message (e.g., whether you opened, forwarded, or clicked through to our Site).

·         Third-party analytics technologies. We may use third-party analytics and tracking tools to better understand who is using our Services, how people are using them, and how to improve their effectiveness as well as the effectiveness of any related content.

Cookies and Other Similar Technologies: “Cookies” are text files that are placed on your browser by the websites that you visit. Cookies are used for various purposes, including to distinguish you from other users, make your site navigation more efficient, help remember your preferences, enhance your browsing experience, and improve the use and functionality of our Sites and related content. They can also enable the delivery of relevant and personalized advertisements to you across the Internet.

PLEASE NOTE THAT COOKIES (AND OTHER SIMILAR TECHNOLOGIES) PROVIDED BY THIRD PARTIES MAY BE PLACED ON OUR SITES AND THE PROVIDERS OF THESE TECHNOLOGIES MAY COMBINE INFORMATION COLLECTED FROM YOUR INTERACTION(S) WITH OUR SERVICES WITH INFORMATION THEY COLLECT FROM OTHER SOURCES AND USE THE COMBINED INFORMATION FOR ANALYTICS AND/OR ADVERTISING PURPOSES.

To learn more about your choices regarding the automatic collection and use of your information as you browse our Services, please see the Your Choices and Opt Outs section below.

C.             Information We Receive from Third Parties

We may receive Personal Information from other sources. Our third-party sources may include:

·         Our Business Partners, including companies that co-sponsor our promotions

·         Our Marketing/advertising and analytics partners, including online advertising networks and analytics providers

·         Social Media Platforms (note that the information we receive from such platforms is dependent upon their policies and your settings on the platforms)

·         Other Companies that provide Personal Information to supplement what we already know about you, including data aggregators, and third party licensors.

·         Public Sources such as SEC filings and other publicly available information.

D.             Combination of Information

Please note that we may combine Personal Information that we receive from various sources. For example, we may combine Personal Information that we collect from you offline with Personal Information we collect from you through our Services. Similarly, we may combine Personal Information that we receive from third parties with Personal Information we already have about you. We use, disclose, and protect combined Personal Information as described in this Privacy Policy.

2.             HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose each category of your Personal Information to the following categories of recipients:

·         Our Service Providers. We disclose your Personal Information to our service providers that provide business, professional, marketing, analytics, or technical support services to us, help us operate our business and the Services, or administer activities on our behalf.

·         Our Business Partners. We disclose your Personal Information to other companies with whom we partner to provide services or other offerings to you and carry out other related activities. For example, we may disclose your Personal Information to a third party that co-sponsors a promotion.

·         Our Research Partners. We disclose your Personal Information to our research partners, including those partners that provide information in response to your question administer surveys or conduct research projects in partnership with us or on our behalf.

·         Our Analytics Partners. We disclose your Personal Information to our partners that assist us in performing analytics and help us measure the effectiveness of our Service’s content as well as our marketing and advertising efforts.

·         Our Marketing and Advertising Partners. We disclose your Personal Information to third parties for marketing and advertising purposes, including social media platforms, third-party advertising networks, and other parties that assist us in serving and optimizing our advertisements.

·         Competent Governmental, Regulatory, and Public Authorities. We disclose your Personal Information to government and law enforcement authorities, in each case only to comply with legal or regulatory obligations or valid requests, including on an emergency basis.

·         Relevant Third Parties as Part of a Corporate Transaction. In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your Personal Information to certain third parties, such as the acquiring entity and its advisers.

·         Other Third Parties. We will disclose your Personal Information to other third parties at your direction or with your consent. Additionally, we will disclose your Personal Information as we believe necessary or appropriate to: (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.

We may disclose your Personal Information for other reasons that we will describe at the time of information collection or prior to disclosing your information.

Please note that we may de-identify or aggregate Personal Information so that it will no longer be considered Personal Information and disclose such information to other parties for purposes consistent with those described in this Privacy Policy.

3.             FOr what purposes DO WE PROCESS YOUR INFORMATION?

We process your Personal Information for a variety of reasons, depending on how you interact with our services, including:

·                To Facilitate Account Creation and Authentication and Otherwise Manage User Accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order and to provide the Service.

·                To Deliver and Facilitate Delivery of Services. We may process your information to provide you with the requested Service.

·                To Respond to User Inquiries/Offer Support. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested Service.

·                To Send Administrative Information to You. We may process your information to send you details about our Services, changes to our terms and policies, and other similar information.

·                To Request Feedback. We may process your information when necessary to request feedback and to contact you about your use of our services.

·                To Send You Marketing and Promotional Communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences.

·                To Deliver Targeted Advertising to You. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.

·                To Protect Our Services. We may process your information as part of our efforts to keep our services safe and secure, including fraud monitoring and prevention.

·                To Identify Usage Trends. We may process information about how you use our services to better understand how they are being used so we can improve them.

·                To Exercise Our Legal Rights, or to Prevent Harm or Death. We may process your information when necessary to exercise our legal rights, including to protect our company, property, as well as to take action when we have a good faith belief that doing so will protect an individual’s vital interest, such as to prevent harm or death.

·                YOUR PRIVACY CHOICES AND RIGHTS

You have the ability to make certain choices about how we use your Personal Information, as follows:

A.             Third-Party Opt Outs

You may be able to opt out of receiving certain targeted or interest-based advertisements using the browser opt-out tools and consumer choice mechanisms provided by advertising industry self-regulatory groups by following the links below:

·         Network Advertising Alliance (NAI): https://optout.networkadvertising.org/?c=1

·         Digital Advertising Alliance (DAA): https://youradchoices.com/control

You also can control whether you see interest-based advertisements on your mobile device(s) in the following ways:

·         Your device operating system may provide mechanisms that allow you to opt in or opt out of the use of information about your use of mobile apps to deliver interest-based advertising to your mobile device. For more information, consult your device settings.

·         The DAA offers a tool for opting out of the collection of cross-app data on mobile devices for interest-based advertising. To exercise your choices with respect to participating companies, please download the AppChoices tool at www.aboutads.info/appchoices. 

You will need to opt out separately on all of your browsers and devices, as each opt out will apply only to the specific browser or device from which you opt out. If you delete or reset your cookies or mobile identifiers, change browsers, or use a different device, any opt-out cookie or tool may no longer work and you will have to opt out again.

Even if you choose to opt out of receiving interest-based advertising, you may still receive advertising, but the advertisements may be less relevant.

Some of our partners may provide you with additional choices with respect to interest-based advertising. For example, certain social media platforms allow you to control your advertising preferences directly through their services. Please review the privacy policies of the third-party services you use for more information.

B.             Unsubscribing from our Marketing and Promotional Communications

From time to time, we may send you marketing and promotional communications, including special offers from us or our partners. If you no longer wish to receive promotional and marketing emails from us, you may opt out of such communications at any time by following the opt-out instructions included in any promotional or marketing email you receive from us.

4.             EXTERNAL LINKS

Our Services may have links to third-party services, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.

5.             CHILDREN’S PRIVACY

Our Services are intended for a general audience. We do not direct our Services to children under sixteen (16), nor do we knowingly solicit or collect any Personal Information from children under the age of sixteen (16). If you are a parent or legal guardian and think that your child has given us data, or you have you can contact us in writing or by email as provided below under the section titled “How to Contact Us.” Please mark your inquiries “Children’s Privacy Information Request.” If we learn that a minor has provided Personal Information through our Services, we will use reasonable efforts to remove such information from our files.

6.             DATA SECURITY

We have implemented physical, administrative, and technical safeguards to maintain the security, confidentiality, and integrity of your information. However, as no transmission of information over the internet is absolutely secure, we cannot guarantee the safety of your information.

7.             INTERNATIONAL TRANSFERS

Prolly is a US-based company, and information that you provide to us will be processed in the United States, which may not offer the same level of protection as the privacy or data protection laws of your jurisdiction.  By providing us with your information, you acknowledge any such transfer, storage or use.

8.             REVISIONS TO THIS PRIVACY POLICY

We reserve the right, in our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. When we do, we will post the change(s) to our Services. Your continued use of our Services following the posting of changes to these terms means you accept these changes. If we change the Privacy Policy in a material way, we will provide appropriate notice to you.

9.             HOW TO CONTACT US

If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us at contact@prolly.ai or by mail to Prolly Technologies Inc, 800 West Main Street, Suite 1460, Boise ID 83716

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