隐私政策

1.引言

Welcome to Continuity LLC DBA PalUpNow! (“Company”, “We”, “Our”, “Us”).

Continuity LLC DBA PalUpNow! operates the web application (referred to as “Platform”). Your Privacy is important to Us. Our Privacy Policy governs your visit Our Platform, and explains how we collect, use, safeguard, and disclose information that results from your use of Our Service. We use your data to provide and improve Our Service.

By using Our Service, you agree to the collection and use of information in accordance with this Privacy Policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service. Our Terms of Service (“Terms”) govern all use of Our Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).

Please read this Privacy Policy carefully to understand how we handle your personal information. Reading this will help you understand your privacy rights and choices. If you do not agree with Our policies and practices, please do not use Our Service. If you still have any questions or concerns, please contact us so that we can try to find a solution.

2. DEFINITIONS

PLATFORM means the web application operated by Continuity LLC DBA PalUpNow!.

SERVICE means the services rendered by Pals to our vulnerable community members.

BOT refers to automated systems ("BOTs") intended to operate on behalf of the PalUpNow! platform, where all or substantially all of the actions are not the result of a natural person, and they interact with team members and/or community members as and when need arises. These BOTs may include, but are not limited to, automated systems for data collection, member notifications, service optimization, or any other functionalities that impact platform operations and/or user experience. Their responsibilities have been indicated on the team page.

PERSONAL DATA means information that relates to an identified or identifiable natural person, who can be identified from those data (or from those and other information either in our possession or likely to come into our possession), and includes Personal Data, Personal Information, or Personally Identifiable Information (“PII”) in any applicable Data Protection Laws.

USAGE DATA is data collected automatically either generated by the use of Our Service or from Our Platform.

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purposes of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) mean any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of certain Service Providers (such as airtable.com) in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. INFORMATION COLLECTION AND USE

We collect several different types of information for various purposes to provide and improve Our Service to you. We not only collect information, data, and any other content, in any form or medium, collected, downloaded, or otherwise received, that you (or any person legally authorized on your behalf to do so) voluntarily and directly provide to us when you register for the Service, express an interest in obtaining information about us or our Service, when you use Service, or otherwise when you contact us, but also information that we automatically collect from your use of Our Platform, subject to any applicable terms and conditions including our Terms of Service and this Privacy Policy. 

4. TYPES OF DATA COLLECTED

个人资料

We firmly believe in fundamental Privacy Rights, regardless of your place of residence. Therefore, we treat any information that pertains to an identified or identifiable natural person or that is linked or linkable to them as Personal Data. This consists of information related to your access or use of Our Service, use of Our Platform, or that otherwise identifies you as a customer or end user of Our Service. 

While using Our Service, we may ask you to provide us with certain personally identifiable information (PII) that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

(a) 电子邮件地址

(b) 名称

(c) Contact Phone number

(d) 代词

(e) 年龄范围

(f) Address, Country, State, Province, ZIP/Postal code, City

(g) Occupation

(h) Cookies and Usage Data

Aggregated data (if collected) is regarded as non-Personal Data for the purposes of this Privacy Policy. 

We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link. 

We may also link to third-parties on our services. Our Privacy Policy does not apply to how third-parties define personal data or how they use it. We therefore encourage you to read their respective privacy policies and know your privacy rights before interacting with them. 

使用数据

We may also collect information that your browser sends whenever you visit Our Service or when you access Our Service by or through a mobile device (“Usage Data”). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, operating system, the web pages of Our Platform that you visit, the time and date of your visit, the time spent on those pages, features used, how you interact with Our Platform, unique device identifiers, and other diagnostic data. 

When you access Our Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

位置数据

We may use and store information about your location if you give us permission to do so (say, by consenting to our use of Cookies, or if you expressly communicate to us your location data through the sign-up forms, or through any other appropriate manner that may be used to collect location data as and when need arises) (“Location Data”). Such data may be used for varied purposes of enhancing Service accuracy, including relevant assistance services, or suggesting nearby Pals. 

追踪cookies数据

We use cookies and similar tracking technologies to track the activity on Our Platform and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from web servers and stored on your device. Cookies allow us to monitor and analyze visitor traffic on Our Platform. 

Other tracking technologies are also used such as beacons, tags and scripts to monitor and track information and to improve and analyze our Service. You can control cookie preferences through your Browser settings. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

Please see our Cookie Policy for more information about our use of Cookies and similar tracking technologies. 

其他数据

While using our Premium Service, our screening partner (an industry-standard service provider) may also collect the following information: sex, age, date of birth, place of birth, government IDs such as passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, non-disclosure agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location and other data.

5. USE OF DATA

Continuity LLC DBA PalUpNow! uses the collected data to provide, improve, and personalize Our Platform and Our Service, including various purposes such as:

(a) to provide and maintain Our Service;

(b) to notify you about changes to Our Service; 

(c) to allow you to participate in interactive features of Our Service when you choose to do so; 

(d) 提供客户支持。 

(e) to gather analysis or valuable information so that we can improve Our Service; 

(f) to monitor the usage of Our Service;

(g) 检测、预防和解决技术问题。

(h) 完成您提供的任何其他目的。

(i) 履行我们的义务，并执行我们与您签订的任何合同所产生的权利，包括开票和收款。

(j) to provide you with notices about and/or subscription, including expiration and renewal notices, email instructions, etc.;

(k) to provide you with news, special offers and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;

(l) 以我们在你提供信息时可能描述的任何其他方式。

(m) to notify you whenever there are updates to either this Privacy Policy, Terms of Service, or Cookie Policy;

(n) for any other purpose with your consent.  

Notwithstanding anything to the contrary in this Privacy Policy, we will not use or access your data except: to provide, maintain, improve, or optimize use of our Service; where you (or any person legally authorized to act on your behalf) explicitly approve access (e.g., during customer support inquiry) in response to lawful requests by law enforcement or government authorities; in response to subpoenas, court orders, or other legal process or requests, as required by applicable law as determined in our discretion; where necessary (in our sole discretion) to protect the rights, privacy, safety of you, us or others.

Notwithstanding the foregoing, you acknowledge and agree that we may retain, take possession of, delete, or deny your access to your data, if we believe or have reasons to believe, in our sole discretion, that some or all of your data, or use of the Service, violates our Terms of Service.

6. RETENTION OF DATA

We will retain your Personal Data only for as long as is necessary for the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

我们还将保留使用数据用于内部分析。使用数据的保留期限一般较短，除非这些数据用于加强我们服务的安全性或改进我们服务的功能，或者我们在法律上有义务将这些数据保留更长时间。

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data; and the applicable legal requirements. When we no longer require your data for any ongoing legitimate need, we will securely delete it. If deletion is not possible (for any reason whatsoever), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

(a) Flights

Flight Pals and Flyers can deactivate active profiles to pause match alerts and reactivate later with no reactivation fee. Or, they can delete their anonymized profile and data. There is no reactivation step for inactive profiles with flight dates in the past. 

Flights anonymized profiles will be automatically deactivated after 3 days. Their anonymized reviews, if any, will remain. Flights anonymized profiles will be automatically deleted after 1 year. Their anonymized reviews, if any, will be de-identified. The Flight Pal or the Flyer will be notified by email.

(b) Rides

Ride Pals and Riders can deactivate active profiles to pause match alerts and reactivate later with no reactivation fee. Or, they can delete their anonymized profile and data. 

Rides anonymized profiles will be automatically deactivated after 1 year. Their anonymized reviews, if any, will remain. The Ride Pal or the Rider will be notified by email with the option to reactivate within 1 month, after which their profile and data will be automatically deleted. Their anonymized reviews, if any, will be de-identified.

(c) Reminders

Anonymized Reminders will be deleted after 1 year if there are no more active reminders to be sent out. The sender will be notified by email. 

7. TRANSFER OF DATA

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. When required by law, we will ensure that we rely on an appropriate legal mechanism for the transfer, such as your consent, standard contractual clauses (or their equivalent), or adequacy decisions.

如果您位于美国境外并选择向我们提供信息，请注意我们会将数据（包括个人数据）传输到美国并在那里进行处理。您同意本隐私政策并提交此类信息，即表示您同意该传输。 

Continuity LLC DBA PalUpNow! will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

8. DISCLOSURE OF DATA

我们可能会披露我们收集的或你提供的个人信息。

(a) Disclosure for Law Enforcement

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities, or as necessary to comply with applicable law otherwise to protect the rights, privacy, safety, or property of you, us, or others.

(b) Business Transaction

If we or our subsidiaries are involved in the event of a proposed or actual reorganization, merger, acquisition or asset sale, transfer, or other disposition, your Personal Data may be transferred, or for any other legitimate business purpose that does not conflict with the statements made in this Privacy Policy. 

(c) Other cases

We may disclose your information also:

(i) PalUpNow! partners;

(ii) PalUpNow! Charity;

(iii) contractors, service providers we use to support our business, including third parties who enable certain features or functionalities of Our Service that you have requested for; 

(iv) to fulfill the purpose for which you provide it;

(v) for the purpose of including your company’s logo on our web application;

(vi) for any other purpose disclosed by us when you provide the information;

(vii) with your consent in any other cases;

(viii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

9. PROTECTION OF VENDOR/PARTNER/CHARITY INFORMATION

We recognize that the personal and business information of our vendors, partners, and charitable organizations is as sensitive as consumer data. Accordingly, we apply the same level of protection to their information as we do for consumer data.

All vendor, partner, and charity information are securely stored in Airtable alongside consumer data and is subject to strict access controls. Our security measures ensure prevention of unauthorized access, alteration, or misuse. By engaging with our platform, vendors, partners, and charities agree to our data protection practices as outlined in this policy. 

10. SECURITY OF DATA

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. The security of your data is important to us but remember that despite our efforts to safeguard and secure your information, no method of transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. 

While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. Although we will do our best to protect your personal data, transmission of personal information to and from us is at your own risk.

11. HEALTH INFORMATION AND HIPAA COMPLIANCE

We recognize the sensitive nature of personal health information and are committed to respecting user privacy. While our Platform does not explicitly collect, store, or archive medical histories or other protected health information (PHI) as defined under the Health Insurance Portability and Accountability Act (HIPAA), users may voluntarily share health-related details through free-text fields, such as during sign-up or when setting up reminders.

If a user voluntarily shares medical or healthcare-related information with a Pal (e.g., regarding mobility needs, anxiety conditions, or medication schedules), such exchanges occur directly between the users. Users should exercise discretion when sharing sensitive health information and communicate only what is necessary for assistance. 

Any health-related information shared via free-text fields (e.g., in sign-up forms or reminders) may be temporarily stored within our system until the user deletes their anonymized profile or reminder. Sawyer, our BOT, also purges sensitive information in accordance with our data retention clause. PalupNow! does not process, analyze, or use such information for healthcare purposes, nor do we provide medical advice or services. Such information handled by the Pals is kept strictly confidential and protected.

12. YOUR PRIVACY RIGHTS

Depending on your State of residence in the US or in some regions such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. Certain rights under applicable data protection laws include the right 

(a) to request access and obtain a copy of your personal data, 

(b) to request rectification or erasure, 

(c) to data portability (if applicable), and 

(d) not to be subject to automated decision making. 

To exercise any of the above rights, you can submit a Data Subject Access Request (DSAR) by using Our DSAR Form. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you have evidence to believe that we are unlawfully processing your personal information, you also have the right to complain to your member State Data Protection Authority or UK Data Protection Authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner. 

13. YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. See details.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, you may submit your request using Our DSAR form.

You have the following data protection rights:

(a) Right to be Informed: You have the right to be informed in detail about the collection and use of your personal data. In addition, you have the right to be informed of any automated decision-making activities, including profiling.

(b) Right of Access: You have the right to request access to your personal data that is stored, to check the completeness and accuracy of the data, as also the right of rectification or erasure. Therefore, you have the right to access, update, or to delete the information we have on you. 

(c) Right to be Forgotten: You have the right to have your personal data be erased immediately when no longer needed for their original processing purpose, or if you have withdrawn your consent and there is no other legal ground for processing, you have objected and there are no overriding legitimate grounds for the processing, or erasure is required to fulfill a statutory obligation under the EU law or the right of the Member States. 

(d) Right of Rectification: You have the right to have your information rectified if that information is inaccurate or incomplete. 

(e) Data Portability: You have the right to be provided with a copy of your Personal Data in a structured, machine-readable, and commonly used format, and your personal data if transferred must be processed in a readable format. 

(f) Right of Notification: If you have provided information, you have the right to be notified of data breaches within 72 hours. 

(g) You have the right to consent to the storing and/or processing of your personal data, voluntarily through an affirmative action. 

(h) Right to Withdraw Consent: You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information. Note that we may ask you to verify your identity before responding to such requests.

(i) Right to Object: You have the right to object to the processing of your personal data at any time on grounds relating to your situation. 

(j) Right of Restriction: You have the right to request that we restrict the processing of your personal information. 

To exercise your GDPR data protection rights described above, please send your request(s) using Our DSAR form.

Note, we may not able to provide Service without some necessary data. Please also note that Our Service may be restricted subject to any restrictions you impose on the storing and/or processing of data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

14. YOUR DATA PROTECTION RIGHTS UNDER THE CALIFORNIA ONLINE PRIVACY PROTECTION ACT (CALOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. See details.

根据CalOPPA，我们同意以下内容。

(a) users can visit Our Platform anonymously;

(b) Our Privacy Policy is conspicuous and easy to locate

(c) Our Privacy Policy link includes the word “Privacy,” and can easily be found on the footer (common section below every web page) of our web application;

(d) users will be notified of any privacy policy changes on Our Privacy Policy page;

(e) users can change their personal information by using Our DSAR form. 

Our Policy on “Do Not Track” Signals

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track (DNT) is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the Preferences or Settings page of your web browser.

This Privacy Policy includes the effective date, lists out the categories of personal data that we collect, store, and process, states how changes to this policy will be communicated, explains whether the collected personal data will be shared with a third party, states how we will handle a DNT request, explains whether and how you can request to modify or delete their personal data from our database, thus being compliant in this regard.

15. YOUR DATA PROTECTION RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

The disclosures in this section are solely applicable to individual residents of the State of California and provide additional information about how we collect, use, disclose, and otherwise process personal information within the scope of the CCPA. Unless otherwise expressly stated, all terms in this Section have the same meaning as defined in the CCPA. If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to share/disclose it.

要行使您的数据保护权利，您可以向我们提出某些要求：

(a) What personal information we have about you. 

If you make this request, we will return to you:

(i) 我们所收集的关于您的个人信息的类别。

(ii) 我们收集您个人信息的来源类别。

(iii) The business or commercial purpose for collecting your personal information.

(iv) 我们与之分享个人信息的第三方的类别。

(v) 我们所收集的关于你的具体个人信息。

(vi) A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.

Note, our information is stored and processed on airtable.com, that being fundamental to how we operate. However, the sharing of information is not done for any monetary or other valuable consideration, and is instead done pursuant to a Data Processing Addendum (DPA) we have executed with them. We use airtable.com as our data processing service provider.

As part of our service operations, we use Zapier to facilitate automated workflows between our internal systems, besides Airtable. While Zapier does not store user data on our behalf, it processes limited portions of information strictly for specific operational purposes, such as task automation and service optimization. This is in alignment with applicable data protection regulations. 

Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purposes of inferring characteristics about you.

(b) To delete your personal information

If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same, subject to certain exceptions.

在某些情况下，可以通过消除信息的标识来实现删除。如果您选择删除个人信息，您可能无法使用某些需要您的个人信息才能运行的功能。 

Note, if you ask us to delete your data, it may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.

(c) To stop selling your personal information

We do not sell your personal information for monetary consideration.

(d) To request Correction of inaccurate personal information

You have rights under certain US State data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

(a) Right to Know: whether we are processing your personal data

(b) Right to access your personal data

(c) Right to correct inaccuracies in your personal data

(d) Right to request the deletion of your personal data

(e) Right to obtain a copy of the personal data you previously shared with us

(f) Right to non-discrimination for exercising your rights

(g) Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s Privacy law), or profiling in furtherance of decisions that produce legal or similarly significant effects (‘profiling’)

Depending upon the State where you live, you may also have the following rights: 

(h) Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s privacy law)

(i) Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)

You also have the right to be free of discrimination for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion request) we may no longer be able to provide you our services or engage with you in the same manner. 

To exercise your California data protection rights described above, please send your request(s) using Our DSAR form. 

Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020. 

16. CALIFORNIA’S “SHINE THE LIGHT” LAW

California Civil Code Section 1798.83, also known as the “Shine the Light” Law, permits our users who are residents of California, to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request using Our DSAR form.

17. DISCLOSURES TO RESIDENTS OF COLORADO, CONNECTICUT, MONTANA, OREGON, TEXAS, UTAH, AND VIRGINIA

The disclosures in this section apply solely to individual residents of the States of Colorado, Connecticut, Montana, Oregon, Texas, Utah, and Virginia. Privacy laws in Colorado, Connecticut, Utah, and Virginia give residents certain rights with respect to their personal data, and privacy laws in Montana, Oregon, and Texas will give residents certain rights with respect to their personal data when they take effect over the course of 2024. 

Those rights include:

(a) Right to Access Information. You have the right to access and obtain a copy of your personal data.

(b) Right to Request Deletion. You have the right to request that we delete personal data provided by or obtained about you.

(c) Right to Correct. You have the right to correct inaccuracies in your personal data.

(d) Right to Opt-Out of Targeted Advertising. You may ask us not to use or disclose your information for the purposes of targeting advertising to you based on your personal data obtained from your activity across different businesses, services, websites, etc.

To submit a request to exercise your access, deletion, or correction privacy rights, you may use Our DSAR form. 

Residents of Colorado, Connecticut, Montana, Oregon, Texas, and Virginia may appeal a refusal to take action on a request by contacting us.

Residents of Oregon may request that we provide a list of third parties to which we have disclosed personal data. To make such a request, please use Our DSAR form for submitting an access, deletion, or correction request.

18. NEVADA SPECIFIC DISCLOSURES

For residents of the State of Nevada, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. Although we do not currently sell covered information, please contact us to submit such a request using Our DSAR form. 

19. CANADA-SPECIFIC DISCLOSURES 

If you live in Canada, you have the following rights:

(a) Right to Access. 

You can ask us to: 

(i) confirm that we have personal information about you, and 

(ii) provide you a copy of that information.

(b) Right to Correct. 

You can ask us to correct any inaccurate or incomplete personal information that we have about you. You may submit such a request by using Our DSAR form.

20. SERVICE PROVIDERS

We may employ third party companies and individuals to facilitate Our Service (“Service Providers”), provide Service on our behalf, perform Service-related services, or assist us in analyzing how Our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We encourage you to read their respective privacy policies and know your privacy rights before interacting with them. 

21. ANALYTICS

We may use third-party Service Providers to monitor and analyze the use of Our Platform.

谷歌分析

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Platform. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. 

有关 Google 隐私惯例的更多信息，请访问 谷歌隐私条款.我们还建议您查看 谷歌的数据保护政策.

22. PAYMENTS

We may provide paid products and/or services within Service. We do not collect and store the sensitive data required to process payments when upgrading from PalUpNow! Basic to PalUpNow! Premium. In that case, we partner with industry-standard third-party vendors, who process payments globally on our behalf and take submission of your payment data directly.

That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processor we work with is:

Square: Read their Privacy Policy.

23. LINKS TO OTHER SITES

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

24. CHILDREN'S PRIVACY

Our Platform is not intended for use by minors under the age of 18 (“Child” or “Children”), unless supervised by an adult. We do not knowingly collect personally identifiable information from Children. By using Our Platform, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of Our Platform. If you become aware that a Child has provided us with Personal Data, please submit a DSAR.

If we become aware that we have collected Personal Data from Children without adult supervision or parental consent, we take reasonable steps to promptly remove that information from Our Platform.

25. CHANGES TO THIS PRIVACY POLICY

Any information that we collect is subject to this Privacy Policy in effect at the time such information is collected. We may however revise and update our Privacy Policy from time to time to reflect changes in our practices or the applicable law. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on Our Platform, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective from the date when they are posted on this page.

26. CONTACT US

If you have any questions or concerns about this Privacy Policy, please contact us.