WOMPLY PRIVACY POLICY

Last updated: August 15, 2017

At Womply, we know that you care about how your information is collected and what happens with that information. We take your privacy seriously. Please read the following to learn more about our Privacy Policy. As used in this Privacy Policy, "Womply," "us," "we," or similar pronoun refers to Oto Analytics, Inc. doing business as Womply.

SCOPE

This Privacy Policy applies to information we collect when you access or use in any manner any Womply application, product, service, feature, technology, content, or website (collectively, "Services") directly from us or through our merchant customers or channel partners, or otherwise contact or interact with us. However, this Privacy Policy does not describe the practices of other users of our Services, including our third-party service providers that may collect information from you when you interact with them through our Services, merchant customers, and channel partners. Our merchant customers are generally retail or service businesses from whom you've purchased or considered purchasing goods and/or services or otherwise interacted with to obtain information from such entities or to provide your information to such entities. Our channel partners are generally card companies, payment services providers, payment processors, and financial institutions. Third party services providers are entities with which we've contracted to provide certain aspects of our Services.

CONSENT AND AMENDMENT

By using our Services, you accept the terms of this Privacy Policy and consent to our collection, use, disclosure, and retention of your information as described herein and for all other purposes permitted under applicable personal information privacy statutes, anti-spam legislation, and consumer protection laws.

We may amend this Privacy Policy from time to time by posting a revised version and updating the "Last updated" date above. The revised version will be effective at the time we post it. We encourage you to review this Privacy Policy whenever you use our Services to stay informed about our information practices and the choices available to you and to contact us if you have any questions about these changes.

INFORMATION WE COLLECT

"Personal Information" is information that can be used to identify you as an individual or (in some jurisdictions) which relates to an identifiable individual, as provided by applicable law. We may collect Personal Information any time you use or otherwise interact with our Services. The Personal Information we collect may include (1) information that you provide to us during the course of using the Services, (2) information about your browser or device, (3) information provided by other sources, including our merchant customers and channel partners, and (4) other information to enable new services and promotions, when you give your consent. Without information about you, we may not be able to provide you with the Services.

We do not knowingly collect or solicit information from anyone under the age of 18 or knowingly allow such persons to use our Services. If you are under 18, please do not attempt to register for the Website or send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 18 may provide any personal information to Womply or on the Website. In the event that we learn that we have collected personal information from a person under age 18 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us at .

INFORMATION YOU PROVIDE

We collect information you upload or send to or through our Services, including information you provide to our merchant customers. Information you provide to or through our Services may include:

  • contact information (e.g., name, address, phone number, email address);
  • birthday or birthdate;
  • third-party account information if you choose to connect to our Services using third-party accounts, e.g., Facebook;
  • order information, including order amount, payment account numbers, security codes, expiration date, payment type, device used;
  • responses to optional e-mail surveys regarding your experiences with Womply or our merchant customers;
  • your postings to third-party reputation and ratings services.
INFORMATION COLLECTED USING COOKIES AND WEB BEACONS

We use various technologies to collect information when you use our Services, including sending cookies to your device and using web beacons. Cookies are small data files that are stored on your hard drive or in your device memory when you visit a website or view a message. Among other things, cookies enable us to recognize your browser, retain your preferences and account settings, customize your experience in using our Services, and help evaluate and compile aggregated statistics about user activity. We also may collect information using web beacons. Web beacons are electronic images that may be used in our Services or emails. We may use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon. You also can learn more about cookies by visiting http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note, however, that by blocking or deleting cookies used in the Services, you may not be able to take full advantage of the Services.

We may allow third-party service providers to deliver content and advertisements in connection with our Services and to provide anonymous site metrics and other analytics services. These third parties may use cookies, web beacons, and other technologies to collect information, such as your IP address, identifiers associated with or applications on your device, the browsers you use to access our Services, pages viewed, time spent on pages, links clicked, and conversion information (e.g., transactions entered into). This information may be used by Womply and third-party services providers on behalf of Womply to analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your usage of our Services. The third-party service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons, or other tracking technologies, which are covered by such third parties' privacy policies. For more information, we encourage you to check the privacy policies of these third parties to learn about their privacy practices. For more information about targeted advertising specifically, please visit http://www.aboutads.info/choices.

INFORMATION WE COLLECT FROM OTHER SOURCES

We also collect information about you from third parties, including mailing list providers, publicly available sources, and third parties otherwise authorized to give us information about you.

HOW WE USE YOUR INFORMATION

We may use information about you to provide, maintain, and improve our Services, such as:

  • displaying historical transaction information, spending behavior, and your online reviews to our merchant customers with whom you've conducted business;
  • sending you news and information, or conducting surveys and collecting feedback, about our Services and to communicate with you about products, services, contests, promotions, discounts, incentives, and rewards offered by us, our merchant customers, and select partners, based on your communication preferences and applicable law;
  • contacting you to resolve disputes and provide assistance for problems with our Services;
  • protecting our rights or property, or the security or integrity of our Services;
  • investigating, detecting, and preventing security breaches, and other potentially prohibited or illegal activities;
  • complying with any applicable law, regulation, legal process, or governmental request;
  • for any other purpose disclosed to you in connection with our Services.

We may, and we may use third-party service providers to, process and store your information in the United States and other countries.

SHARING OF INFORMATION

We may share information about you as follows:

  • with our subsidiaries and other affiliates companies, for the purposes outlined above;
  • with third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf (e.g., fraud prevention, identity verification, and fee collection services), as well as financial institutions, payment networks, payment card associations, and other entities in connection with the payment process;
  • with third parties that run advertising campaigns, contests, special offers, or other events or activities in connection with our Services;
  • with other users of our Services with whom you interact through your own use of our Services. For example, we may share information about you with our merchant customers with whom you conducted business or their payment service providers;
  • in connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business;
  • if we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process, or governmental request (e.g., from tax authorities), (ii) to protect our rights or property, or the security or integrity of our Services, or (iii) to protect us, users of our Services or the public from harm or potentially prohibited or illegal activities; or
  • with your consent.

We also may share aggregated information with third parties that does not specifically identify you or any individual user of our Services.

DATA RETENTION

We may retain information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our rights under applicable agreements or policies, or to take any other actions consistent with applicable law. You may access, change, or correct information about you by making a request to us using the contact details below, in which case we may need to verify your identity before granting access or otherwise changing or correcting your information.

PROMOTIONAL COMMUNICATIONS

You may opt out of receiving promotional messages from Womply by following the instructions in those messages or by making a request to us using the contact details below. If you decide to opt out, we may still send you non-promotional communications.

CALIFORNIA PRIVACY RIGHTS

California law permits residents of California to request certain details about information we disclose to third parties for direct marketing purposes. If you are a California resident and would like to request this information, please contact us at the address listed below.

SECURITY

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold information about you at our third-party service providers. We restrict access to personal information to those Womply employees, contractors, and agents who need to know that information in order to transmit, store, or process it, who are subject to contractual confidentiality obligations consistent with this Privacy Policy, and who may be disciplined or terminated if they fail to meet these obligations. Our third-party service providers store and transmit personal information in compliance with appropriate confidentiality and security measures.

Nevertheless, Womply cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. In the event that any information in our possession or under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps in accordance with applicable laws or regulations.

CONTACT

If you have any questions or concerns regarding our privacy policy, please send a message to or write to us at:

Oto Analytics, Inc.
548 Market Street, #73871
San Francisco, CA 94104

We will make every effort to resolve your concerns.