1. COLLECTION OF INFORMATION.
a. Registration Information. When you create an account (“Account”), we collect the following personal information (“Registration Information”):
- Email address;
- IP address; and
- Login information for social media accounts you wish to connect to your account, including your Google or YouTube login, Facebook credentials, Twitter handle, and Instagram accounts (“Social Media Accounts”).
Some of this Registration Information, for example, your name and username, may be shown publicly, such as on your profile page when you log in via a social media account.
b. Additional Information. From time-to-time, you may provide us with additional information to make public, such as in connection with a Promotion. Providing the additional information is entirely optional. IF YOU PROVIDE A CELL PHONE NUMBER TO RECEIVE SMS MESSAGES FROM PALA, YOU EXPRESSLY CONSENT TO RECEIVING SMS MESSAGES FROM PALA THE PURPOSE OF WHICH IS TO MARKET PALA, THE SERVICE, AND OUR PRODUCTS AND OTHER SERVICES. ALTHOUGH THERE IS NO FEE ASSOCIATED WITH THIS SERVICE, YOUR CARRIER MAY CHARGE YOU FOR EACH MESSAGE YOU RECEIVE IN ACCORDANCE WITH YOUR CALLING PLAN. YOU AGREE THAT WE ARE NOT RESPONSIBLE IN ANY WAY FOR SUCH CHARGES. IF YOU DO NOT WISH TO CONTINUE TO RECEIVE ANY MESSAGES VIA YOUR MOBILE DEVICE, YOU MAY OPT-OUT AT ANY TIME. YOU MAY OPT OUT OF RECEIVING MARKETING MESSAGES BY TEXTING “STOP” IN RESPONSE TO A MARKETING SMS MESSAGE. FAILURE TO OPT-OUT CONSTITUTES YOUR CONSENT TO CONTINUE TO RECEIVE THESE MESSAGES UNTIL YOU ELECT TO OPT-OUT.
c. Messages, Posts, Scores and other Public Information. Our Service is primarily designed to help you share information with other users and to engage in Games and Promotions. Most of the information you provide to us is information you are asking us to make public. This includes any comments or information you provide. Our default is almost always to make the information you provide public but we generally give you settings to make the information more private if you want. Your public information is broadly and instantly disseminated. For example, your public messages may be searchable by search engines. You should be careful about all information that will be made public by Pala, not just your messages. What you say on Pala may be viewed all around the world instantly.
d. Location Information. If you turn on your location information functions, we may also save exact coordinates to help improve our service. You can control your location information settings by using your device’s settings to turn location services on or off for the Pala Social App. We may also use your location information to enable you to interact with Brands and other users.
e. Log Data. Our servers automatically record information (“Log Data”) created by your use of the Service. Log Data may include information such as your IP address, browser type, the referring domain, pages visited, your mobile carrier, device and application IDs, and search terms. Other actions, such as interactions with our App and advertisements, may also be included in Log Data.
f. Links. Pala may keep track of how you interact with links in messages across our Service including third party services and clients by redirecting clicks or through other means. We do this to help improve our Service, including advertising, and to be able to share aggregate click statistics such as how many times a particular link was clicked on.
g. Cookies. Like many websites, we use “cookie” technology to collect additional website usage data and to improve our Service, but we do not require cookies for many parts of our Service such as searching and looking at public user profiles or lists. A cookie is a small data file that is transferred to your computer’s hard disk. Pala may use both session cookies and persistent cookies to better understand how you interact with our Service, to monitor aggregate usage by our users and web traffic routing on our Service, and to improve our Service. Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.
h. Third Party Service. Pala uses a variety of services hosted by third parties to help provide our Service, such as hosting our various blogs and wikis, and to help us understand the use of our Service.
2. USE OF INFORMATION.
a. Pala may use your Registration Information to help facilitate your transactions and participation in Games, Rewards, and Promotions, including with Brands, and, in our sole discretion, to resolve disputes between you and other users. We may also use your Registration Information as necessary to investigate fraud, protect our legal rights, and otherwise provide the Service.
b. Pala may use your information, including your Registration Information, to facilitate the provision of software updates, product support, marketing promotions, and other services to you (if any), including by sending email or text messages to your wireless phone, tablet, or other mobile device (each a “Device”). You also grant Pala an irrevocable, perpetual, royalty-free right and license to use your information to enhance our products and services and to develop new products and services.
3. DISCLOSURE OF INFORMATION.
We do not disclose the private elements of your Registration Information, such as passwords, or phone numbers, (“Private information”) except in the limited circumstances described here.
a. Your Consent. We may share or disclose your Private Information with your consent, such as when you use a third party web client or application to access your Pala account.
c. Law and Harm. We may preserve or disclose any of your information, including your Private Information, if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Pala’s rights or property.
e. Non-Private or Non-Personal Information. We may share or disclose your non-private, aggregated or otherwise non-personal information, such as your public messages or the number of users who clicked on a particular link (even if only one did).
f. Disclosure to Brands. We may share certain portions of your Registration Information with Brands for marketing purposes, specifically, your name and email address, along with information that we have collected about your interests and preferences based on the Game in which you choose to participate. You may opt out of receiving marketing messages from Brands by using the opt-out mechanisms and links provided by each Brand.
4. MODIFYING YOUR PRIVATE INFORMATION.
a. If you are a registered user of our Service, we provide you with tools to access or modify your Registration Information.
b. You can also permanently delete your Pala account. For up to 30 days it is still possible to restore your account if it was accidentally or wrongfully deactivated. After 30 days, we may delete your account from our systems.
5. OUR POLICY TOWARDS CHILDREN.
Our Service is not directed to people under 13. If you become aware that your child has provided us with personal information without your consent, please contact us at firstname.lastname@example.org. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information and terminate the child’s account within a reasonable time.
6. CHANGES TO THIS POLICY.
Pala takes commercially reasonable steps to help protect your information against loss, misuse and unauthorized access, or disclosure. HOWEVER, PALA EXPRESSLY DISCLAIMS ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING OR OTHERWISE OFFERING ANY DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR INFORMATION.
8. THIRD PARTY ACCOUNTS.
We only use the APIs, OAuth Tokens, Widgets, or other means provided by the applicable Social Media Account to integrate your Social Media Account with our App. As such, we only receive the limited information that each Social Media Account permits to be transferred.
9. CREDIT CARD INFORMATION.
When you use a credit card on our website, you are actually using a secure connection to a third party payment processor. WE DO NOT COLLECT STORE OR PROCESS ANY CREDIT CARD INFORMATION.
10. DATA TRANSFER.
The Service is hosted in the United States and all Promotions and Games take place within the United States. Accordingly, by submitting any personal information to the Service, you are transferring your personal information to the United States and you consent to such transfer.
11. CALIFORNIA USERS: YOUR CALIFORNIA PRIVACY RIGHTS.
We are in compliance with the California Online Privacy Protection Act. California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Unless you provide personal information in connection with a Promotion, we are likely exempt from the requirements of California Civil Code section 1798.83 because we do not share such personal information with third parties for direct marketing purposes. However, by providing personal information in connection with a Promotion or rewards program, you are expressly authorizing Pala to share your name and contact information with both the charity benefiting from such Promotion and the entity providing prizes for that Promotion. You expressly agree that these entities may use your information for marketing purposes. If you wish to find out about any rights you may have under California Civil Code section 1798.83, you may notify us in writing at email@example.com. If you want us to stop sharing your email contact information with third parties (if we have your email contact information), you may notify us at firstname.lastname@example.org. In order to fulfill certain rewards and prizes, we must share your information. Please follow the instructions provided to you by third parties to unsubscribe from their messages. If you have opted-out as described above, and thereafter you elect to use a service or promotion that requires us to contact you or share your information with a third party (e.g., you enter into a new Promotion after opting-out), then your previous opt-out preferences will not apply.
Last Updated: February 3, 2017