PRIVACY POLICY

Last Updated: 03/31/2020

 

PocketCFO, PBC. ("PocketCFO ") is committed to respecting the privacy rights of its customers, visitors and other users of its services. We know that you care about how your Personal Information is used and shared, and therefore we take your privacy seriously. You have control over what information you share and whom you share it with. We do not share your Personal Information with people or services without your permission. We will work hard to be a responsible steward of the information we hold. Please read the following to learn more about our privacy practices ("Privacy Policy").
 
By using the services provided by PocketCFO, any other related services, or using the PocketCFO  Website at www.PocketCFOapp.com (collectively, the "Services"), you accept the practices outlined in this Privacy Policy.

If you do not accept any of the provisions of this Privacy Policy, please do not use the Services.

 

If you have any questions about this Privacy Policy, you may contact us at admin@PocketCFOapp.com or by writing us at: PocketCFO  (ATTN: Privacy), 1441 Ben Roe Drive, Los Altos, Ca. 94024, United States.
 
PocketCFO  complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and the United Kingdom to the United States. PocketCFO  has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. PocketCFO  commits to subject to the Privacy Shield Principles (https://www.privacyshield.gov/EU-US-Framework) all personal data received from the EU in reliance on the Privacy Shield. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.
 
The Federal Trade Commission has jurisdiction with enforcement authority over PocketCFO’s compliance with the Privacy Shield.

 

 

Conditions of Use

If you decide to access or use the Services, any possible dispute over privacy is subject to this Privacy Policy and our Terms of Service ("Services Agreement"), including limitations on damages, arbitration of disputes, and application of California state law. Provide that, if you are an EU individual, any possible dispute over privacy is subject to Privacy Shield Principles.
 

What Does This Privacy Policy Cover?

This Privacy Policy covers what information PocketCFO collects when you access or use our Services and how PocketCFO uses such information. This Privacy Policy does not cover (i) use of information by third parties we do not control, or (ii) information collected via third party mobile or software applications which utilize PocketCFO ’s development platform. If you’re accessing the Services via a third-party application or service that is integrated with PocketCFO, then such third party's privacy policy will govern the use, storage and disclosure of your data in connection with such application or service.
 

What Information Does PocketCFO Collect?

 

Personal Information

PocketCFO collects information that you provide us. For example, when you express an interest in obtaining additional information about the Services or registering to use the Services, PocketCFO may ask you to provide certain contact information such as name, organization name, address, email address, and phone number (collectively, "Contact Information"). When registering for the Services, you may be required to provide additional information that may include a credit card number or other banking or payment information ("Billing Information").


In connection with your use of the Services, PocketCFO may collect information that is created or provided by you for such purposes (collectively, "Service Information"). This may include but is not limited to: (a) personal data, such as information you provide about other people such as contact information, phone number, email address, first and last names, (b) message usage data, such as messaging history, transaction dates, read receipts, IP address and other messaging metadata and (c) call usage data, such as call history, call recipient information, call transaction dates, IP address and other call metadata. Contact Information, Billing Information and Service Information may include information that is "Personal Information," meaning data which directly, or used in conjunction with other provided information, enables the identification of a specific individual.

Site Information

As you navigate the PocketCFO  Website, PocketCFO may also collect information through the use of commonly-used information-gathering tools, such as cookies and Web beacons ("Site Information"). Site Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol ("IP") address, and the actions you take on the Site (such as the Web pages viewed and the links clicked). Contact Information, Billing Information, Service Information and Site Information may be collectively referred to as the "Data."


California Civil Code

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to admin@PocketCFOapp.com

 


How Does PocketCFO Use Information?


PocketCFO uses the Data for the following purposes:
●      to provide, monitor, further develop, and improve the Services;
●      to manage payments – PocketCFO uses a third-party credit card processing provider to manage credit card and ACH processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing and ACH on our behalf, and is subject to confidentiality obligations restricting the disclosure of information collected to other third parties;
●      to provide the Services and perform tasks you request. For example, we will use Service Information and Contact Information to provide you with customer support and, together with Site Information, technical support.
●      to communicate with you about your interest in and use of the Services. For example, if you provide your Personal Information in your account, PocketCFO will use that information provided to contact you about your interest in the Services. You may opt-out of those communications by following the email opt-out instructions contained in each email or by sending an email request to admin@PocketCFOapp.com
●      to administer your account and communicate with you about your comments and inquiries. For example, we will use Service Information, Billing Information, and your Contact Information to provide you with access to the Services you have ordered, as well as support services, technical updates or updates on changes in PocketCFO's policies. PocketCFO may also use your Contact Information to send you company updates and marketing information.
●      to provide and administer our community of users. PocketCFO may provide bulletin boards, blogs, or help forums on PocketCFO Website. Any Personal Information you choose to submit in such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. We use Data to analyze and identify whether certain functions or features of the Services might interest you and, together with our third-party advertising partners (including third-party ad networks) (our "Advertisers"), to show you ads that might be more relevant or interesting to you. We do not share information with Advertisers that would enable them to easily identify who you are; rather, we use generic criteria about you (e.g., city of residence, age range, industry, etc.) for a specific ad campaign. We do use Personal Information for our own internal marketing purposes, such as to send you promotional emails. Please refer to the "Choices" section for information on how to opt-out of marketing communications and tracking technologies relevant to our Advertisers.
●      to produce training data derived from Service Information for research, development, and business analysis purposes;
●      to link your PocketCFO account to third-party accounts such as Google, GitHub, or Facebook.
 
Please note that PocketCFO's use of the Service Information is also governed by the agreement you enter into with PocketCFO in connection with the Services Agreement. Please refer to the Services Agreement for specific provisions concerning confidentiality and data protection. In the event of any conflict between this Privacy Policy and the Services Agreement, the Services Agreement will control. Except with respect to PocketCFO’s dispute resolution obligations under the EU-US Privacy Shield Framework noted above.

 

Choices


Opt-Outs (including Marketing and Cookies and Other Tracking Technologies)


You may opt-out of marketing communications by following the email opt-out instructions contained in each email. However, you may not opt-out from non-marketing communications, including company updates, service notifications and other operational updates.

Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. Our Services do not involve browser based tracking as that term is generally understood. We therefore do not additionally provide a Do Not Track option at this time.

If you have any questions about your choices with respect to opting out of certain collection, use, or disclosure practices, please contact us at admin@PocketCFOapp.com


Accessing and Correcting Your Personal Information

You have the right to access, correct or delete your Personal Information including Contact Information or Billing Information you provided us. You may access your Personal Information by logging into your account and making necessary changes. Or you may request such changes to your account by sending an e-mail to admin@PocketCFOapp.com. California consumers and EU data subjects may have additional access and deletion rights described below.

 


How Does PocketCFO Secure Your Information?


PocketCFO is committed to safeguarding your Personal Information from unauthorized access. Your account is protected by a password for your privacy and security. If you access your account via a third-party site or service, you may have additional or different sign-on protections via that third-party site or service. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.


We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

 


Will PocketCFO Share Any of the Information it Receives?


Subsidiaries and Affiliates

We may share your Data or Personal Information with our subsidiaries or affiliated companies to provide you the Service or to improve the Service.  We do not rent, sell or disclose your Data to anyone – except for the following limited purposes:


Agents


We may employ or enter a business contract with other companies and people to perform tasks on our behalf ("Agents") - meaning they are helping us provide our Services. We may share your Data with such Agents solely as necessary for them to help us provide our Services. Unless we tell you differently, PocketCFO’s Agents do not have any right to use Data we share with them beyond what is necessary to assist us. PocketCFO may be liable for the appropriate onward transfer of EU personal data to third parties.
PocketCFO uses a third-party credit card processing provider to manage credit card and ACH processing.
PocketCFO uses a third-party cloud storage provider to assist users in storing the messages communicated through the Services.
PocketCFO uses a third-party analytics tool provider to understand how users interact with PocketCFO Website.
PocketCFO uses a third-party marketing service provider to contact and attract new users. To understand the target users of PocketCFO, PocketCFO may share the Data with the marketing service provider.


Business Transfers


In some cases, we may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that are transferred. Moreover, if PocketCFO, or substantially all of its assets, were acquired, or in the unlikely event that PocketCFO goes out of business or enters bankruptcy, customer information would be one of the assets that is transferred or acquired by a third party.

Compliance with Law Enforcement

We may release Data when we believe in good faith that release is necessary to comply with the law, enforce or apply our conditions of use and other agreements, protect the rights, property, or safety of PocketCFO, our employees, our users, or others. Please note that we may be required to release the personal data of EU individuals in response to lawful requests from public authorities including to meet national security and law enforcement requirements. If your data request draws attention to an ongoing violation of our Services Agreement, we will take action to prevent further abuse, including actions that may notify the user that we are aware of their misconduct.

PocketCFO may receive orders, subpoenas or other legal demands for Personal Information that has been collected on behalf of third party providers integrated with PocketCFO through the use of their applications or services. In such cases, PocketCFO will refer the party requesting the Personal Information to the applicable third-party provider. That provider will respond in accordance with its own policies and may disclose your Personal Information in response to such subpoena or other demand for information. If you have questions about any such disclosures, you should contact the applicable provider directly, as PocketCFO is not responsible for the policies and practices of such third-party providers. PocketCFO will have no liability in connection with any act or omission of any such provider with respect to your data or information or otherwise.


Children


The Children’s Online Privacy Protection Act ("COPPA") requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13. We do not knowingly collect or solicit personally identifiable information from children under 16; if you are a child under 16, please do not attempt to register on the Services or send any Personal Information about yourself to us. If you are under 16 years of age, you are not authorized to use any of the Service and must immediately delete your information from PocketCFO Website and also from your devices. If we learn we have collected Personal Information from a child under 136, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Information, please contact us at admin@PocketCFOapp.com. We recommend that minors, who are at least 16 years old but under 18 years old, ask their parents or legal guardians for permission before sending any information about themselves to us or anyone else, whether by using the Service or PocketCFO Website.


Other Users With Whom You Share Your Information


We cannot control the actions of other users with whom you share your information. We cannot, and do not, control the information you share with other users using the Services, the PocketCFO Website (including via blogs, dashboards, forums), or how such other users will use or share such information. For example, if you share your information via forums, blogs, or dashboards where other users may have access to such information, we are not responsible for other users using such information. Also, if you share information with other users by using the Services such as message function or chat, PocketCFO do not control the information you share with other users or how such other uses will use or share such information. PocketCFO is not liable for such shared information with other users.
 


CALIFORNIA DATA SUBJECTS


Starting January 1, 2020, the California Consumer Privacy Act (CCPA) provides additional privacy protections for California data subjects and users, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) and c) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information). We do not discriminate against you if you exercise any of the above rights. Moreover, we may not be able to honor a right if doing so would violate applicable law.
 
If you are a customer or partner and have questions about your ability to see the data used to login to our systems, we ask that you direct your question to the person that owns the business relationship. If you are a consumer and want to see what data we may have on behalf of one of our customers, kindly reach out to that individual customer. PocketCFO is contractually prohibited from honoring such requests without specific written instructions from the applicable customer.
You may access those rights with respect to PocketCFO by sending us an email to admin@PocketCFOapp.com. As a California consumer, if you make a subject access request as set out in this policy, you are entitled to see and delete the personal information that we have about you. We will confirm your request within 10 days and make a good faith attempt to fulfill your request within 45 days.
 
The CCPA defines the term personal information broadly and as such, it includes pseudonymous identifiers such as cookie IDs and mobile advertising IDs. Under the CCPA, your request to see the personal information that we have about you may include: (1) specific pieces of personal information that we may have about you; (2) categories of personal information we have collected about you; (3) categories of sources from which the personal information is collected; (4) categories of personal information that we sold or disclosed for a business purpose about you; (5) categories of third parties to whom the personal information was sold or disclosed for a business purpose under the CCPA; and (6) the business or commercial purpose for collecting or selling personal information.
 
We may take reasonable steps to verify your request.  We will fulfill requests we are able to verify so long as we are not prohibited from doing so by applicable law and/or the information is not essential for us for billing, fraud prevention or security purposes. We will share our reason(s) for denying your request in the event that we are unable to fulfill your request.
 
You may make an access or deletion request via an authorized agent by having such agent follow the process below. Please note that we will request any authorized agent demonstrate that they have been authorized by you to make a request on your behalf. And we will attempt to verify your request. We require any authorized agents to provide us with contact details such as an email address and phone number so that we may ensure a timely response.
 


INDIVIDUALS IN THE EEA


Individuals located in the European Economic Area (“EEA”) are granted additional privacy rights under the General Data Privacy Regulation (“GDPR”). For example, an EU (or Swiss) individual who seeks access, or who seeks to correct, amend, port over and/or delete inaccurate data, or who wishes to limit the use and disclosure of their personal data, should send us an email at admin@PocketCFOapp.com. With respect to EU data subjects, personal data includes pseudonymous data such as an IP address, a mobile advertising ID or a cookie ID as well as data which will enable PocketCFO to identify you directly such as an email address, postal address or telephone number.
 
With the exception of the Website, PocketCFO provides the Services as a “data processor” under the GDPR. That means PocketCFO only processes data via our development platform as directed by our Clients and for no other purpose. We process certain Personal Data provided by Clients and partners under contractual necessity. For example, we require the billing details of our Clients located in the EU to process payment for the Services. Our sales and marketing team may obtain additional contact details for current and prospective Clients via our legitimate interest so long as they are not overridden by your data protection interests or fundamental rights and freedoms.
 


Changes to this Privacy Policy


PocketCFO may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes to this Privacy Policy, we will provide notice of such changes through a posting on the PocketCFO Website or through another reasonable means of communication. You are bound by any changes to the Privacy Policy when you use the Services after such notice has been provided. Therefore, we encourage you to check the date of this Policy whenever you access or use the PocketCFO Services to check if this Privacy Policy has been updated. You must review this Privacy Policy on a regular basis to keep yourself apprised of any changes. If you do not agree to any modifications to this Policy, your sole recourse is to immediately stop all use of PocketCFO Services, and PocketCFO Website. Your continued use of any Services or PocketCFO Website following the posting of any modifications to this Policy will constitute your acceptance of the revised Privacy Policy. Should you have any questions regarding this Privacy Policy, please contact us at the contact information listed at the end of this Privacy Policy. Please note that none of our employees or agents has the authority to vary any of our Privacy Policies.

 


Contacting Us


If you have any questions or concerns regarding our privacy policy, please contact PocketCFO at admin@PocketCFOapp.com.

 


Compliance with Privacy Shield


In compliance with the Privacy Shield Principles, PocketCFO commits to resolve complaints about our collection or use of your Personal Information. European Union individuals with inquiries or complaints should first contact PocketCFO at: admin@PocketCFOapp.com.

 


Independent Recourse Mechanism


Consistent with the Privacy Shield Principles, PocketCFO provides the following independent recourse mechanisms to resolve disputes with respect to PocketCFO’s Privacy Shield compliance.

Private Sector Dispute Resolution Provider


PocketCFO has further committed to refer unresolved Privacy Shield complaints to the BBB EU Privacy Shield, operated by the Council of Better Business Bureaus ("BBB"), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit (http://www.bbb.org/EU-privacy-shield/for-eu-consumers) for more information or to file a complaint. The services of BBB are provided at no cost to you.

Arbitration


As a last resort and under certain conditions, EU individuals have the possibility of invoking binding arbitration before a Privacy Shield Panel for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms.
 
 


Updated: March 31st, 2020
PocketCFO, PBC
1441 Ben Roe Drive
Los Altos, CA. 94024
 

 

 

 

 

 

 

 

 

 

 


 

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