Last Updated: 6 July, 2017
PogenV offers a management consulting services, whether through our website or our mobile applications (“Platform”).
“Aggregated Information” means information about all of our users or specific groups or categories of users that we combine together so that it can no longer identify or reference an individual user.
“Data Controller” means PogenV, the company responsible for the use and processing of Personal Information.
“Personal Data” means information relating to a living individual who is or can be identified either from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of the Data Controller.
WHAT TYPES OF INFORMATION DOES POGENV GATHER ABOUT ITS USERS?
1. Information that you give us
We collect and use the following personal data that you make available to us when accessing or using our Platform and Services. This personal data includes:
Your personal details, including your name, phone number and email address, such as when you register or update the details of your user account, or when you supply ID verification information;
Personal data that you have provided to Third Party Websites or services (e.g. Facebook or Airbnb, iCal or gmail calendar) and connected or synced to your PogenV account to the extent that you have authorised and consented to such disclosure by the Third Party Websites or services; and
Any information you may have provided.
2. Mobile Data
When you use certain features of the Platform, in particular our mobile applications we may collect and use different types of personal data such as your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Platform or specific features of the platform). If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.
3. Log Data
We may also collect and use Log Data, which is information that is automatically recorded by our servers whenever you access or use the Platform, regardless of whether you are registered with PogenV or logged in to your PogenV account, such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent on particular pages.
4. Cookies and other Tracking Technologies
While you may disable the usage of cookies through your browser settings, we do not change our practices in response to a “Do Not Track” signal in the HTTP header from your browser or mobile application.
We may, either directly or through third party companies and individuals we engage to provide services to us, also continue to track your behavior on our own Platform for purposes of our own customer support, analytics, research, product development, fraud prevention, risk assessment, regulatory compliance, investigation, as well as to enable you to use and access the Platform and pay for your activities on the Platform.
We may also, either directly or through third party companies and individuals we engage to provide services to us, track your behavior on our own Platform to market and advertise our services to you on the Platform and third party websites.
Third parties delivering advertisements or services on our Platform may have their own privacy policies and may set their own or other third party cookies via these advertisements and services. Other than setting up the coding they request when we receive the advert we don’t have control over how these companies employ cookies.
Please note that if you have disabled cookies completely, you may not be able to access any or all of the features on the Platform, you may also still receive advertising on or about the Platform – it just will not be tailored to your interests.
HOW POGENV USES AND PROCESSES THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE
We collect and use personal data for the following purposes:
1. to enable you to access and use the Platform;
2. to operate, protect, improve and optimize the Platform, PogenV’s business, and our users’ experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and where you have given your consent for advertising and marketing;
3. to help create and maintain a trusted and safer environment on the Platform and Services, such as through fraud detection and prevention, conducting investigations and risk assessments;
4. to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
where we have your consent, to send you marketing and promotional messages and other information that may be of interest to you, including information about PogenV or general promotions for partner campaigns and services. You can unsubscribe or opt-out from receiving these communications by contacting us at info[at]pogenv.com;
5. to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by PogenV or our business partners; and
6. to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.
WHEN POGENV DISCLOSES OR SHARES PERSONAL INFORMATION, AND TO WHOM IMPORTANT:
When you use the Platform, your data may be sent to the United States and possibly other countries. We may transfer, store, use and process your information, including any Personal Data, overseas such as to the United States.
Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in, may be different from the privacy laws applicable to the place where you are resident.
1. Parts of your public profile page that contain some Personal Data may be displayed in other parts of the Platform to other users for marketing purposes or to the extent necessary to operate and manage referral and rewards programs.
2. As necessary to enable the linking of your account on a third party social networking site to your PogenV account. Do note that some features on the Platform may require the publication and display of information received from the third party social networking site, as well as the publication and display of information from the Platform to the third party social networking site. You will be able to control such disclosure through the settings and authorisation on the Platform and, to the extent possible, on the third party social networking site.
3. We may distribute parts of the Platform for display on sites operated by PogenV business partners and affiliates, using technologies such as HTML widgets.
5. We may also engage third party companies and individuals, to provide services to us, including but not limited to technology services and services to help verify your identity, to conduct checks against databases such as public government databases (where legally allowed), to otherwise assist us with fraud prevention and risk assessment, to assist us with customer service, and to facilitate the payments or reimbursements you request (such as Concur and American Express).
6. We may provide Personal Information about you to these third parties, or give them access to this Personal Information, for the limited purpose of allowing them to provide these services. We will ensure that such third parties have contractual obligations to protect this Personal Information and to not use it for unrelated purposes.
We may also publish, disclose and use Aggregated Information and non-personal information for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
HOW TO CHANGE OR DELETE YOUR INFORMATION, OR CANCEL YOUR POGENV ACCOUNT
You may review, update, correct or delete the Personal Information in your PogenV account. If you would like to correct your information or cancel your PogenV account entirely, you can do so by logging in to your account.
SECURING YOUR PERSONAL INFORMATION
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorized access, destruction or alteration. However, no method of transmission over the Internet, and no method of storing electronic information, can be 100% secure. So, we cannot guarantee the absolute security of your transmissions to us and of your Personal Information that we store.
YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES