Penlo App Privacy Policy
1. INTRODUCTION
Pro App Company Limited Inc. ("Pro App Company Limited" "us" or "we") is committed to protecting and respecting your privacy.
Penlo operates a service that allows you to share your location with other users in your family or friends, which we make available through our apps (the "Service"). This Privacy Policy explains our practices regarding the collection, use, disclosure, transfer, storage, and protection of personal information that is collected through our Service, as well as your choices regarding the collection and use of information. Our Service is available in many countries, which may have different standards and requirements in respect of the information we provide in the Privacy Policy and how we use personal information.
Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in the part of this Privacy Policy that is relevant to you.
2. HOW WE COLLECT AND USE INFORMATION
Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Use.
We collect the following types of information about you:
Registration and Profile Information
When you create an account, we may collect your personal information such as your username, first and last name, email address, mobile phone number. We may collect a photo, if you or a Friend member associate a photo with your account. If you want to add a family member’s name to your account, we collect the family member’s name, email address, and mobile phone number. We may also collect billing information when you sign up for Premium service.
Data collected through use of the Service
After you set up your account, we may ask for other profile and demographic information, such as personal emergency instructions and information, and nickname. You may also customize your map by labeling locations, such as “work” and “home,” to make it easy to spot your favorite places and to provide alerts when family members leave and arrive.
Geolocation
We collect your location information through your IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device. We may also gather information about your location using other technologies and sensors which may provide us with information about nearby devices, WiFi access points and networks, and nearby cell towers. If you enable the mobile app to use your Bluetooth signal, we may be able to determine location based on nearby Bluetooth-enabled devices, which helps us to improve location accuracy, identify other Penlo users and devices that have been in proximity to each other, and improve location updates for all devices in the Penlo network. Depending on your device settings, we collect location information in the background, even when you are not actively using the app. We collect and maintain location data to provide you the features and functionality of the Service.
Driving Event Data
We collect, and may use a third party partner to collect, sensory and motion data from your smartphone or mobile device, including information from the gyroscope, accelerometer, compass and Bluetooth, in order to calculate and detect driving events such as speeding, hard braking, crash detection and other events. Your mobile device provider may refer to this information as “Motion and Fitness” data (description may vary according to device and platform). We may also share this information with third party partners for marketing, research, analytics and other purposes. If you want to opt-out of the collection of your sensory and motion, please adjust your settings in your mobile device to limit the app’s access to your sensory and motion data. Please see “Your Choices About Your Information” below to learn more.
Messages and User Content
We collect information when you message other members of your Friend through use of the service. We may also retain any messages you send to us.
We use this information to operate, maintain, and provide to you the features and functionality of the Service and to communicate directly with you, such as to send you alerts on the movements of your Friend, crime alerts in your neighborhood, etc.
Social Media
When you interact with our site through various social media, such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Penlo’s website or Service.
Identity verification
In limited circumstances, we may use identity verification services provided by a third-party provider Berbix to verify your age and/or to obtain verifiable parental consent for your child to use the Service. When identity verification is required, we will ask you to upload an image of your valid government-issued ID along with a selfie image. Our identify verification provider will use a combination of machine learning tools and optical scans to authenticate your identity document, and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provided to determine the likelihood that the images are a "match." Penlo does not receive the biometric identifier generated from the images. It is generated and held by our identity verification provider until the biometric identifier is no longer needed for the purposes described in this paragraph, which will occur no later than 60 days after your last verification interaction with us. For identity verification and security purposes, Penlo may have access to the information extracted from the identity scan of the ID document (such as a name and partial driver’s license number) as well as the results of the identity verification process. We may use this process and associated information to verify your identity, authenticate your identity documents, confirm appropriate parental consent, and protect against fraud and misrepresentation. We do not use, disclose or retain your biometric information for any other commercial purpose. Our third-party provider processes this information on our behalf strictly in accordance with our contractual agreements. Please note this service may not be available in all jurisdictions.
Information from third-party services
We collect information from third party services that you connect to your Penlo account. For example, if you link your Penlo account to a voice assistant platform to enable interaction with our service through voice commands, such as through the Penlo Google Action (“Action”) available on Google Assistant-enabled devices, we will collect the queries and commands applicable to Penlo that you make through the Action or other voice assistant platforms.
Information we collect automatically through the use of technology
When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information, such as:
- Information about how you access the Service, for example, referral/exit pages, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service.
- Information about how you use the Service, for example, the features you use, the links you click, the ads you view and click on, purchase transaction information, your location when you access or interact with our Service, and other similar actions.
- Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/ model/ manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, and other such information. With your permission, we may also access your photo or camera roll.
We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
We use this information to (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide custom, personalized content and information, including targeted content and advertising; (iii) track your location and movements; (iv) identify and contact you across multiple devices; (v) provide and monitor the effectiveness of our Service and our marketing campaigns; (vi) monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns; (vii) diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs; and (viii) detect or prevent fraud or other harmful activities; (xi) automatically update our mobile application on your system and related devices; and (x) otherwise plan for and enhance our Service.
If you prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. These browser settings that block cookies may have no effect on non-cookie technologies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time.
We and our third party partners may also use information collected through tracking technologies for advertising purposes. Please see “Third Party Tracking and Online Advertising” below to learn more.
4. HOW WE PROTECT YOUR INFORMATION
Penlo cares about the security of your information and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, 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 any applicable laws and regulations.
5. YOUR CHOICES ABOUT YOUR INFORMATION
You may, of course, decline to submit any personal information through the Service, in which case Penlo may not be able to provide its Services to you.
Modifying Your Account Information and Settings:
You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account. If you have any questions about reviewing or modifying your account information, you can contact us directly at [email protected].
Close Your Account or Delete Personal Information:
We retain your information for as long as your account is active or as reasonably necessary to maintain the Service, meet legal and accounting obligations, and for the other purposes described in this Privacy Policy. If you wish to close your account, and/or request to delete your personal information, please contact us at [email protected]. When account information is deleted or de-identified, certain residual information may remain within our archive records, such as for customer and technical support, billing and tax purposes.
Emails and Notifications:
You can control your receipt of email and text alerts by visiting “Settings” and “Alert Options” within the mobile app. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of Service-related emails (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the Service, technical and security notices). You may also unsubscribe from receiving SMS text messages by replying “STOP” to the number sending the message. We make every effort to promptly process all unsubscribe requests.
Location and Movement Data Collection and Sharing:
As described in Section 2, we collect precise location data and driving event and movement data (such as accelerometer data, magnetometer data, gyro data, etc.) from your device to provide the Penlo Services, and may share your personal information, including location and movement data, with other Penlo users in your Family or other Friend you belong to, and with third parties for crash detection, research, analytics, attribution and tailored advertising purposes. You have many options to control this data collection and sharing activity through the App Settings:
- Limit location sharing with your friends. You may turn location sharing “OFF” for one or more of your friends through your App settings. If you turn off location sharing in one or more of your friends, we will not share your location with such Friends; however, we will continue to collect your location information in order to provide the Service (for example, to provide our emergency services, to share your location with the other Friends, or to provide location-based advertising). Note: if you press “Check In” or “Automated SOS” in the App, your location will update in every one of your Friends even if location sharing is turned off for one or more of your Friends.
- Limit Drive Detection. You can limit the collection and display of location and movement data through the Drive Detection feature in the in-App Privacy settings. When you turn Drive Detection “off,” your location is not visible to your Friends and your location and drive history will not show on Individual or Family Driver Reports. Please note that your Penlo app may not be able to provide all of our Services to you turn off Drive Detection. When Drive Detection is turned “off,” Crash Detection services will be disabled and safety services like SOS Help Alerts and 24/7 Dispatchers will not be available.
- Limit data sharing with third party data partners through in-App Privacy Settings. To opt-out of Penlo sharing personal information (including location and movement data) with data partners for targeted advertising, research, attribution and similar purposes, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security settings. If you opt-out, Penlo will continue to collect your device location and movement data and to share such data with your Friends and with third parties as needed to support and provide the Penlo services or other services you engage, but we will no longer share data about you with our third party data partners for their own advertising and other commercial purposes. Please note, some third party data partners may continue to send you location-based ads based on your previous location or may approximate your location based on other data.
- Limit driving event sharing with Arity. We share data with our partner Arity to support important App features like driving behaviour and Crash Detection. Arity also uses data for research, to improve its analytics and predictive driving behavior models and improve its performance generally. To opt-out of permitting Arity to use and learn from your data for its own research and to develop and improve its predictive behavior models and products and services generally, you can opt-out through the Driving Services page in the in-App Privacy Settings. To opt-out of permitting Arity to use data for its own commercial purposes, including marketing, advertising, and for US users only to provide and service insurance company products and ads, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security Settings.
- Disconnect Location Data and Movement Data in Device Settings. You may also be able to turn off device location data collection through your mobile device settings. For example, depending on your mobile device, you may be able to “Turn location services ‘off,’ which restricts access to your device location data. You can also adjust your device settings to withdraw permission for the Penlo app to access device location data and/or motion data (depending on the device type, this may be called “Fitness and Motion” data), and you can also adjust your device settings to limit the app’s access to WiFi and Bluetooth information. Please note that your Penlo App may not be able to provide all of our Services to you if you disable access to location and movement data through your device settings.
Third Party Tracking and Online Advertising:
We may share information about your use of our Services over time, including location information, with third party ad networks, social media companies and other third parties so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices or advertising channels. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third party ad partners collect and use information such as click stream information, timestamp, hashed email address, device ID or AdID, your use of third party applications and/or precise geolocation data and other information, and may combine this information with information they collect directly through tracking technologies or that they receive other partners, both online and offline, so that they may recognize you across other browsers or devices you use, including computers, mobile devices and Smart TVs. These third parties use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
- To opt-out or control third-party tracking and advertising: Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of the use of your personal information to inform and display targeted advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at aboutads.info/choices. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu.
- Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
- Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.
- Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt-out again.
- Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
- To opt-out of Penlo sharing data with third parties for advertising purposes. To opt-out of Penlo sharing personal information (including location and movement data) with data partners for their own targeted advertising, research, attribution and similar purposes, you can opt-out through the Do Not Sell My Personal Information page in the in-App Privacy & Security settings. Please note, some third party data partners may continue to send you personalized or location-based ads based on your previous location or data they have collected from other websites and mobile apps.
6. CHILDREN'S PRIVACY POLICY
Penlo takes special precaution to protect the privacy of our younger users. Penlo does not knowingly collect personal information from children under the age of 13 (a “child”) without verifiable consent of a parent or guardian and the Service is intended to be used by children under 13 only with significant parental involvement and approval.
If Penlo learns that we have inadvertently collected personal information of a child without parental consent, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with our Service without your consent, please alert us immediately by emailing [email protected] so that we may delete that child’s personal information from our systems.
By enabling your child to create a user account and permitting your child to use the Service, you expressly agree to the practices described in this Children's Privacy Policy and you consent to the collection, use, and disclosure of your child's personal information as described herein.
Personal information we collect
We take special precautions to collect only as much information as is reasonably necessary for the child to use the Service. As further described in our Privacy Policy above, we collect various types of personal information from all users of the Service. For example, we collect profile information (username, email address and mobile phone number) when a user creates an account and other types of personal information the user may provide during the course of using the Service, such as a nickname, favorite location, and emergency contact information. We collect information about a user’s device (e.g., IP address, device type/model/manufacture / operating system, and a unique ID that allows us to identify the browser, mobile device or account, such as a UDID, IDFA, Google AdID or similar) as well as certain usage information about the use of the Service (for example, whether the user opens emails) and we collect analytics data. We collect geolocation data through the device IP address, WiFi, Bluetooth and GPS coordinates available through the user’s mobile device and through technologies and sensors that may be nearby. We also collect driving event data through sensory and motion data sensors in the user’s mobile device (e.g., data from a smartphone’s gyroscope, accelerometer, compass and Bluetooth) in order to calculate and detect driving events such as hard braking, speeding and crash detection. Please review the section of our Privacy Policy called “How We Collect and Use Information” to learn more.
Information sharing
Penlo may share or disclose a child’s personal information our third party vendors, service providers and business partners as described in our full privacy policy, including, for example, with third parties as needed to analyze and detect driving behavior data, perform analytics or otherwise , support the features and functionality of our Service such as crash detection. However, we do not share or sell personal information collected from the accounts of children under 13 for marketing or advertising purposes, nor permit our third party partners to collect and use such information for advertising purposes. Please review the section of our Privacy Policy called “Sharing of Your Information” to learn more about how we share information with our vendors, service providers and others.
Sharing information with other Penlo users
The child’s profile information and location will be shared with other members of the Family and any other Friend the child joins. Please note that if your child joins any other Friends, the child will be able to share his or her location with other members of that Friend and may exchange messages with those Friend members. You are responsible for monitoring your child’s account and location-sharing activity through the Service and for blocking or permitting location sharing features.
7. LINKS TO OTHER WEB SITES AND SERVICES
We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.
8. CHANGES TO THE PRIVACY POLICY
Penlo may, in its sole discretion, modify or update this Privacy Policy from time to time, and so you should review this page periodically. When we change the policy, we will update the ‘last modified’ date at the top of this page. If there are material changes to this Privacy Policy or in how Penlo will use your personal information, we will notify you either by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification.
9. HOW TO CONTACT US
If you have any questions about this Privacy Policy, please feel free to contact us at [email protected].