This privacy policy (“Privacy Policy”) explains how we collect, use, disclose and transfer information collected from researchers and visitors, other than Participants, to the Poocho website, the Poocho application (the “App”), and any other website, widget, mobile application or other service that links to this Privacy Policy (collectively, the “Platform”).

Please note that this Privacy Policy does not cover information provided by or collected from Participants. Those privacy rights are governed by the Participant Terms and Conditions and Participant Privacy Policy. Personal Information shall mean and include any information belonging to the Researchers as well as information collected by the Researchers of their respective Participants and shared with us. The information includes but is not limited to, name, contact details including email address, mailing address, street address and/or telephone number, etc. We may collect these types of personal information directly from you or third parties.
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This Privacy Policy does not cover any information collected at any other web site, application or offline by Poocho (unless specifically stated). Under applicable law, Poocho is considered the “data processor” of information from our or about our Platform visitors. In other words, Poocho is responsible for deciding how to collect, use, share, and disclose this information.

Please review this Privacy Policy carefully. By accessing or using the Platform, you agree to this Privacy Policy. IF YOU DO NOT OR CANNOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE THE PLATFORM.

PLATFORM: shall mean and include the platform provided by Poocho to its Researchers and Participants as the case may be, to conduct and participate in applicable surveys.

PLEASE NOTE: THE APP COULD ALLOW POOCHO TO COLLECT AND USE YOUR DEVICE’S PRECISE LOCATION INFORMATION. If Applicable, this includes GPS-based, Wi-Fi-based and cell tower-based location information.

How we collect and store information depends on how you access and use the Platform. We collect information when you provide information directly to us when you permit third parties to provide information to us, and automatically, such as information collected from your browser or device. You can use certain areas of the Platform without providing any information other than that automatically collected as described below. The information is collected from the third-party apps in such events Poocho shall not be responsible for any data collected from such third-parties.

The Platform may contain hyperlinks to other websites or locations that we do not control and are operated and controlled by third parties (“Third-Party Websites”) in order to provide the service under these terms. Our Privacy Policy does not apply to these Third-Party Websites and we make no representations regarding the policies or business practices of any such Third-Party Websites. When you link us to a Third-Party Website to use our Platform, we shall use all the data available on such third-party platform, upon integration with that third-party in order to provide you with the services.

(a) Required Registration Information
Researchers must create an account in order to access the Platform.

‍(b) Project and Study Information
To build a Study, Researchers must provide certain information for the creation of the Study components, including but not limited to a Study name, overview, specs for each Study part, and survey questions.

‍(c) Automatically Collected Information
• Usage Information and Analytics. In addition to any information that you choose to submit to us, we and the third-party service providers, which include ad networks and analytics companies including Google Analytics, use a variety of technologies that automatically (or passively) collect certain information whenever you visit or interact with the Platform (“Usage Information”). This Usage Information includes the browser that you are using, the URL that referred you to the Platform, all of the areas within the Platform that you visit, and the time of day, among other information. In addition, we collect the IP address or other unique identifier (“Device Identifier”) from a User’s computer or other device used to access the Platform (a “Device”). A Device Identifier is a number that is automatically assigned to a Device used to access the Platform, and our computers identify a Device by its Device Identifier.

• Advertisements on Other Websites. We display advertisements for Poocho on other websites and services. When you click on a Poocho advertisement on these other websites and services, we receive information about the website or service that served the advertisement, and which advertisement you clicked. If you then interact with our Platform, we may combine the information about your activity with our advertisement with the information we subsequently collect and/or you subsequently submit on our Website.

• Email Receipt. If you receive an email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns. We collect Usage Information using, from methods including but not limited to, cookies, beacons and embedded scripts (and subsequent technology and methods hereafter developed).

(d) Information Third Parties Provide About You
We may, from time to time, supplement the information we collect about you online with outside records from third parties, including networking and marketing resources, in order to enhance our ability to serve you. We may combine the information we receive from those sources with information we collect through the Platform. In those cases, we will apply this Privacy Policy to any such information received, unless we have disclosed otherwise.

(e) Payment and Tax Information
If you are a Researcher, the Platform may collect payment information, such as credit card information and associated account information (name and contact information of your point of contact). Credit card information is stored by a trusted third-party payment processor. Our payment partner will share your payment information with credit card companies to process actual payments.

We may use your information:
• to create and maintain your account
• to provide you with information or the Access;
• to process transactions or payments;
• to process your registration to the Platform, including verifying your information is active and valid; To help you conduct research
• to establish and run Studies;
• to analyze and synthesize research findings;
• to enhance or improve the Platform;
• to customize your experience on the Platform, or to provide you with specific content that is most relevant to you;
• to contact you (such as via e-mail) with regard to your use of the Platform and, in our discretion, changes to the Platform and/or the Platform’s policies;
• to send offers and promotional materials related to the Platform and for other Poocho marketing purposes;
• for Poocho’s advertising, marketing, publicity and promotional activities;
• to transcribe interviews and/or videos;
• to analyze the use of the Platform;
• for internal business purposes;
• for other purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy;
• for research, statistical analysis and business intelligence purposes with the help of computer science technologies including without limitation, artificial intelligence and machine learning.

Such demographics will be in an aggregated or non-personally identifiable form thereby ensuring anonymity.

Finally, we will use or disclose your Personal Information if we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person or property, violations of the Platform’s other policies, or as otherwise required by law when responding to subpoenas, court orders and other legal processes.

(a) Sharing Study Information
‍We share information about Studies to potential Participants.
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(b) Sharing with Third Parties Providing Services on Our Behalf
‍We may use third party vendors to perform certain services on our behalf, such as hosting the Platform, designing and/or operating the Platform’s features, tracking App or website analytics, and collecting mobile sensor data. We may provide these vendors with access to certain of your information to carry out the services they are performing for us. These third party vendors are not permitted to use your information other than for performing services for Poocho.

(c) Sharing for Administrative and Legal Reasons
We may access, use, preserve, transfer and disclose your information or information provided by you, including disclosure to third parties: (i) to satisfy any applicable law, regulation, subpoenas, summons, governmental requests or legal process if, in our good faith opinion, such is required or permitted by law, including to meet national security or law enforcement requirements; (ii) to protect and/or defend our agreements with our Users and our policies, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Platform, Poocho or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues. Such disclosures may be carried out without notice to you.

(d) Sharing for Business Transfer
‍We reserve the right to disclose and transfer all such Information: (i) to a subsequent owner, co-owner or operator of the Platform or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our equity and/or assets or other corporate change, including, during the course of any due diligence process.

(e) Sharing of User-Generated Content
The Platform may permit Researchers to submit ideas, photographs, videos, writings, pictures, data, questions, comments, suggestions or other feedback in a forum available to the public; this information will become publicly available. Poocho is not responsible for the use or misuse of any such content.

(f) Sharing with Your Consent
We may share your Information for any other purpose disclosed by us at the time you provide the information. For the information that you provide to Poocho, you represent and warrant that you have such person’s consent to provide the relevant Personal Information to us.

In situations during which we process personal data on behalf of the Researcher, we may refer the request to the relevant Researcher and cooperate with their handling of the request, subject to any special contractual arrangement with that Researcher. In addition to the rights above, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

You may deactivate your account by contacting Poocho and requesting that your account be deactivated. See “Contact Us” below in this Privacy Policy. If you deactivate your account, your account information, and/or your credit card information (as applicable) will generally be deleted within thirty (30) working days. However, we may retain certain information even after you have deactivated your account if retention is reasonably necessary to comply with our legal obligations.

The Platform (particularly, the web applications for Participants) is not intended for use by children under 13 years of age (or in the EU, children under the age of 16 years of age), and we do not knowingly collect personal information from children under 13 (or in the EU, under the age of 16 years of age) without the direct involvement of the minor’s parents or guardians. If we learn that we have collected or received Personal Information from a child under 13 or Personal Data from a child in the EU under the age of 16 without parental or guardian consent or legally-valid consent or other legal basis, we will take reasonable steps to delete that information.

If you believe that the information submitted by you might have any Personal Information from or about a child under 13 or Personal Data from a child in the EU under the age of 16, please contact us as provided in the “Contact Us” section below. The onus of the data uploaded on the Platform or relating to a Study entry of children concerning this age group shall be on the Researcher and Poocho shall have no responsibility for the use of the said information.

We use and implement physical, technical, and administrative measures to protect your Information stored within our databases, and we restrict access to such information to those employees who need access to perform their job functions, such as our customer support personnel and technical staff.

Despite these efforts, please note that we cannot 100% ensure or guarantee the security of your Information. Unauthorized entry or use, hardware or software failure, and other factors could compromise the security of your Information. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to the Platform and that any such transmission is at your own risk. Poocho shall not be held responsible in such events and you shall in no manner hold Poocho liable for any of the said failures.

We cannot guarantee the security of any information that is transmitted to or by us over the internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the Personal Information we process will not be disclosed in a manner that is inconsistent with this Privacy Policy.

‍The security of Personal Information is important to us, and we have implemented commercially acceptable means to protect the same. However, remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure as stated above, and we cannot guarantee its absolute security. We have appropriate industry practices and security policies, rules and technical measures to protect the data including Personal Information that is under Poocho’s control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the relevant electronic devices through which the users avail the Platform, we shall not be held liable for any loss whatsoever incurred.

In the event, our service providers and third parties distribute Personal Information outside the scope of our agreement with other such providers’ or third parties, Poocho cannot be held liable for the breach of confidentiality. Further, in case breach of security or actions including without limitation, computer hacking, unauthorized access to computer data and storage device, computer crashes etc., Poocho will not be held responsible for the same.

‍The information we obtain from or about you may be processed and stored in India. We comply with generally accepted industry standard regulations regarding the collection, use, and retention of data under the Information Technology Act, 2000. By using the Platform and/or Services, you consent to the collection, transfer, use, storage and disclosure of your information as described in this Privacy Policy. Sensitive information (“Sensitive Information”) means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation, sexual practices or sex life, criminal records, health information or biometric information.

We will not process sensitive information, without first obtaining necessary consents.As long as we are provided with the relevant consent, the Sensitive Information may only be used and disclosed for purposes relating to the primary purpose for which the Sensitive Information was collected. Sensitive Information may also be used or disclosed if required or authorised by law.

If you wish to be informed about what personal data we hold about you and if you want it to be removed from our systems, please contact us on the details as given below.

We reserve the right to change this Privacy Policy at any time. If we make material changes to this Privacy Policy, we would advise you to review such changes carefully. If you agree to the changes, simply continue to access the Platform. If you object to any of the changes and no longer wish to use the Platform, you may deactivate your account. Unless stated otherwise, our current Privacy Policy applies to all information we have about you or your account. Accessing the Platform after a notice of changes has been communicated to you or published on the Platform shall constitute consent to the changed terms or practices.

You should be aware that your browser may have settings for Do Not Track. Because there is no common understanding of how to interpret Do Not Track signals yet, Poocho does not honour Do Not Track signals from browsers.

If you have any questions about (a) access to your information; (b) the collection, use, management or disclosure of your information; or (c) this Privacy Policy, you should contact us by email at support@poocho.co.