Privacy Policy of pap!

Thank you for considering to be part of our community at we are pap!, Inc. ("Company", "we", "us", "our", “pap!”). When you visit our website https://joinpap.com/ (the "Website"), and more generally, use any of our services, product page, or other digital products that link to or reference this Privacy Policy (collectively with the Website referred to as the "Services"), you may provide to us your personal information. In this Privacy Policy, we seek to explain to you clearly what information we collect, how we use it and what rights you have in relation to it. Please take some time to read through it carefully, as it will help you understand what we do with the information that we collect. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately. We are always open to feedback and would love to hear from you: just email us at pap@visionholdings.org 

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This privacy notice applies to all information collected through our Services (which, as described above, includes our Website), as well as, any related services, sales, marketing or events. To use pap!, you must approve this privacy policy, our terms of use and provide a consent for us to access your emails and send from your email as further described below.

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Index

1. TYPES OF PERSONAL INFORMATION COLLECTED
2. HOW WE USE YOUR INFORMATION
3. DISCLOSURES OF YOUR INFORMATION
4. LINKS TO THIRD-PARTY WEBSITES
5. HOW LONG WE KEEP YOUR INFORMATION
6. HOW WE KEEP YOUR INFORMATION SAFE
7. YOUR PRIVACY CHOICES
8. COOKIES AND OTHER TRACKING TECHNOLOGIES
9. U.S. STATE-SPECIFIC NOTICE
10. CHILDREN'S PRIVACY
11. A NOTE TO USERS OUTSIDE OF THE UNITED STATES
12. UPDATES TO THIS NOTICE
13. CONTACT US

1. TYPES OF PERSONAL INFORMATION COLLECTED

Information collected directly from you:

We collect personal information that you voluntarily provide to us when you visit or register on the Website, use the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services or otherwise when you contact us. The personal information we collect may include the following:

• Account Registration and Login Details: In order to register for the Services, we will ask you to provide us with your existing email address, like the email address associated with your Google, Microsoft, Yahoo!, Apple or other email provider account. We will collect your email address, your name, your age, your birthday, your addresses, your gender, your organization, your phone numbers, and your shopping preferences. All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information. The purpose of this data collection is to give you tailored rewards on products and services you may like based on proprietary logic. Another purpose of this data collection is to get you money by automating price adjustment refund requests as retailers require us to verify your identity to act on your behalf. Finally, another purpose of this data is anonymized reporting to partners.
• Email Data: If you grant pap! consent to securely access your email inbox, pap! will collect and store receipts (and the information on them), order/purchase/shipping confirmations, invoices, shopping-related notices, your interests based on purchases, and deals found in your inbox through direct inbox access granted by you in connection with the Services, as further described below. The purpose of this data collection is to increase your productivity by tracking prices and automating submitting price adjustment refund requests, to create a better, more personalized customer experience for you and to identify products and services you may be interested in based on proprietary and third-party logic. If you login with or otherwise connect your Gmail account to access the Services, our collection of email data from your Gmail inbox via the pap! product falls under the 'reporting and monitoring' definition of the Google API restricted scope. pap!’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, Google's Privacy Policy & Google's Terms of Service, including the Limited Use requirements. In addition, in order for pap! to most effectively increase your productivity by automating submitting price adjustment refund requests, we require the consent to send emails from your account. We only use that access to communicate with retailers with whom we are actively getting you a refund from. This is necessary to secure you a refund on your behalf.
• Payment Data: We may process data you provide that is necessary to process your payment if you make purchases, such as your credit card number. All payment data is stored by Stripe and is not stored on our end. You may find their privacy notice link(s) here: https://stripe.com/privacy.
• Verification Data: pap! offers a service called ‘pap! for business’ that enables merchants to create a ‘pap! for business’ account and verify the identity of pap! users to create customized incentives. Select merchants will be able to send verified pap! users incentivized purchase recommendations, and any information provided at the time of login or payment will be associated with the verification.

Information automatically collected:

When You Grant Consent For Email Inbox Access

pap!  may collect Personal Information contained in email data when you consent to provide us access credentials or tokens for your email accounts (eg; through Gmail, Microsoft, Apple, or Yahoo!). pap! systems first capture email header data (sender, recipient, date and subject, not message bodies), in encrypted form. pap! then applies proprietary logic to identify emails that:

1. appear to be receipts from retailers, online sellers, or merchants engaged in ecommerce ("Merchant(s)"); or
2. appear to be order, purchase, or shipping confirmations from retailers, online sellers, or merchants engaged in ecommerce ("Merchant(s)"); or
3. appear to be promotional content from retailers, online sellers, or merchants engaged in ecommerce ("Merchant(s)"); or
4. relate to other potential savings opportunities.
5. relate to other potential rewards opportunities.

The next step is to then scan the body copy of these select emails which are then retrieved, decrypted, reviewed (possibly by a human), and stored to secure you price adjustment refunds, get you gift cards and rewards from select merchants, and notify you of potential savings opportunities through any of the marketing channels in which we communicate with you.

Every email that does not get selected as defined above are pruned, not stored, and never accessed again.

There are no humans involved in the selection process, but, occasionally, we may also decrypt the email header data so that we can make sure our proprietary logic is working properly.

Humans may be involved in the refund request process and, hence, will have the ability to review the information relevant to the request (your name, your email, your phone number, and your purchased items)

In short, pap! will only access emails that are relevant to assist with your claim against the companies through which you have purchased products and are relevant to provide you with gift cards from merchants you may like. pap! will only access relevant emails on the basis of key words and proprietary logic described above in order to continuously and automatically be able to assist you as part of the Services.

When You Visit Our Website

We automatically collect certain information when you visit, use or navigate our Services. This information may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies, including cookies to help us correctly attribute affiliate links. See below for more information about our use of cookies.

Information collected from other sources:

In order to enhance our ability to better identify products, offers and services that you may be interested in, we may obtain information about you from other sources, such as affiliate networks, public databases, joint marketing partners, data providers, social media platforms, market research providers as well as from other third parties. This information includes transactions, advertising or promotions engagements, mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles.

If you interact with us on a social media platform using your social media account (e.g. Facebook or X/Twitter), we may receive information about you such as your name, handle, and gender. If you would like to opt out of sharing this information with us, please contact us directly at pap@visionholdings.org.

Information collected when you open emails we send you:

The emails we send you may contain so-called tracking pixels. Tracking pixels are integrated via the newsletters sent in HTML format to enable analysis via a log file. This enables pap! to perform a statistical analysis of whether an online marketing campaign or our emails in general generate the necessary interaction and attraction. Based on the integrated tracking pixel, we can thus see if and when an email has been opened by you, as well as which links in the email you have pressed.

2. HOW WE USE YOUR INFORMATION

We use the information we collect or receive:

• To facilitate account creation and logon process. When you consent to provide us with the email address associated with your email provider account (such as your Google, Microsoft, Apple or Yahoo! account), we use the information shared by those third parties to facilitate account creation and logon process for the performance of the Services.
• To automate price adjustment refund requests by identifying the products and services you purchased and the information relevant to that transaction, and by monitoring the prices of the purchased products.
• To send emails on your behalf, only to retailers with whom we are actively in the process of getting you a price adjustment refund from.
• To identify products and services that you may be interested in, and provide you with customized or personalized advertisements and marketing offers.
• To convince merchants to send you rewards via pap!
• To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at pap@visionholdings.org and be sure to include your name, testimonial location, and contact information.
• To deliver and improve the Services and your overall user experience.
• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
• To link or combine your information with other information.
• To compare and verify information for accuracy and update our records.
• To email, message, or otherwise contact you with information and updates about us and the Services.
• To respond to your comments and questions and provide customer service.
• To send you information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
• To analyze how you use the Services with tools such as Google Analytics and other tools to help us understand traffic patterns and know if there are problems with the Services.
• In connection with a merger, acquisition, reorganization or similar transaction.
• When required by law or to respond to legal process.
• To protect our users, other individual lives, and/or the rights or property of Company.
• To maintain the security of the Services.
• For any other purpose with your consent.

We may also use anonymous and/or aggregate information for any purpose.

Every information collected is used to improve your experience, increase your productivity, and send you rewards.

There are no automated decisions in the processing of personal data beyond what you have explicitly agreed to, or what is necessary to fulfill our obligations to you according to the terms of use.

3. DISCLOSURES OF YOUR INFORMATION

We share personal information in limited circumstances, as described below. In all circumstances, this does not include user-specific email activity from connected inboxes.

We shared personal information under the following circumstances;

• With vendors and service providers that support our core business functions and internal operations, which may include:some text
  • database administrators.
  • cloud computing services.
  • payment processors, and application services providers.
• With third parties that we have partnered with, such as to jointly create and offer a product, service or joint promotion.
• To support our audit, compliance, and corporate governance functions.
• In connection with a change of ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy).
• If we have a good-faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to detect or protect against fraud or security issues.
• If required or permitted by applicable law or regulation, including laws and regulations of the United States and other countries, or in the good faith belief that such action is necessary to: (a) comply with a legal obligation or in response to a request from law enforcement or other public authorities wherever Company may do business; (b) protect and defend the rights or property of Company; (c) investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities; or (d) enforce our Terms of Service or otherwise protect against any legal liability.
• With your consent or at your direction.

It is reassuring to remember that:

• When we contact companies on your behalf to secure your refunds, such companies already have access to your personal data since you initially made a purchase from them. Sharing of your personal data with these companies is necessary in order to fulfill the Services.
• When we work with partners to send you rewards, they can only interact with anonymized data via pap!’s interface

4. LINKS TO THIRD-PARTY WEBSITES

The Services contains advertisements from third parties that are not affiliated with us and which link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

5. HOW LONG WE KEEP YOUR INFORMATION

We will keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than three (3) months past the termination of the user's account or three (3) months after you withdraw consent to access your emails. Accessing your emails is thus necessary to provide the Services..

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Information relating to accounting material is kept for 5 years from the end of the financial year to which the data relate. 

Documentation of your marketing consent is kept for 2 years from the time you have withdrawn your consent to receive direct marketing material. 

The information can always be stored for a longer period in anonymised form. 

6. HOW WE KEEP YOUR INFORMATION SAFE

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology 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. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Your information is limited to Google Cloud Platform services like Firestore, BigQuery, and Firebase Storage. Our server also runs on Google Cloud Platform so no information ever leaves the GCP pipeline from a computing perspective.

7. YOUR PRIVACY CHOICES

You have the right to:

• Access the personal information we maintain about you.
• Delete the personal information we maintain about you.some text
  • Every pap! user can delete their account and data at any time by emailing us at pap@visionholdings.org with such a request. Deletion may take 24 hours to process.
  • Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements. We may also retain information in anonymised form.
• Correct the inaccurate personal information we maintain about you.some text
  • If you would at any time like to review or change the information in your account or terminate your account, you may email us at pap@visionholdings.org 
• Opt out of certain uses of your personal information.some text
  • Marketing Emails: To opt out of marketing e-mail communication, you may email us at pap@visionholdings.orgsome text
    • To opt out of service-related emails, you may email us at pap@visionholdings.org
• Marketing Text Messages: To opt out of marketing text messages, you may email us at pap@visionholdings.org.
• Tailored advertising using email addresses, third-party pixel tags or cookies: Refer to the 'Cookies and other tracking technologies' section below for more information.

8. COOKIES AND OTHER TRACKING TECHNOLOGIES

Like many companies, we use cookies, pixels, and other tracking technologies to collect information about your browsing activities, your interactions with our websites or emails, and to serve tailored ads on pap! or on our advertisers behalf through other websites. There are a number of ways to opt out of having your online activity and device data collected through these Services for our advertising purposes, which we summarize below.

• Tailored advertising using your email address. If pap! has collected your email address, it may be used for tailored advertising on other websites, including through social media. To opt out of this use, please email us at pap@visionholdings.org
• Blocking Cookies In Your Browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Advertising Industry Opt-Out Tools. You can also use these opt-out options to limit use of your information for interest-based advertising online or in apps by visiting http://optout.aboutads.info for U.S. residents, and https://www.youronlinechoices.ca for Canadian residents.
• Advertising and marketing companies offer opt out features that let you opt out of use of your information for interest-based advertising or profiling. We can guide you through the process of individually opting out of each if you email us at pap@visionholdings.org  

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Please note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

9. U.S. STATE-SPECIFIC NOTICE

Some U.S. states have enacted comprehensive privacy laws. The California Consumer Privacy Act, as amended by the California Privacy Rights Act or "CPRA" (collectively, the "CCPA"), the Virginia Consumer Data Protection Act ("VCDPA"), Colorado Privacy Act ("CPA"), the Connecticut Data Privacy Act ("CTDPA"), Utah Consumer Privacy Act ("UCPA"), Oregon Consumer Privacy Act ("OCPA"), Texas Data Privacy and Security Act ("TXDPSA"), and the Montana Consumer Data Privacy Act ("MTCDPA") create additional privacy obligations for businesses and provide Californians and Virginians with additional privacy rights.

Additional Privacy Rights:

In addition to the rights granted above, if you are a resident of California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, or Montana, you have the right to:

• Opt out of the 'sale or share' of your personal information for advertising purposes. We do not 'sell' or 'share' your personal information for monetary benefit. However, use of email addresses for tailored advertising, and some third party cookies placed on our website, advertiser websites or ads may be considered a 'sale or share' as used for our 'targeted' or 'cross-contextual' advertising campaigns under California or Virginia law. You may opt out of such email or cookie use by contacting us at pap@visionholdings.org.

Business/Controller Designation:

pap! operates as a 'Controller' (and a 'Business' under the CCPA).

10. CHILDREN'S PRIVACY

The Services are not directed to individuals who are under age of eighteen (18) and we do not solicit nor knowingly collect Personal Information from children under the age of eighteen (18). If you believe that we have unknowingly collected any Personal Information from someone under the age of eighteen (18), please contact us immediately at pap@visionholdings.org and the information will be deleted.

11. A NOTE TO USERS OUTSIDE OF THE UNITED STATES

Our Company is based in the United States. The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the laws of Australia. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

12. UPDATES TO THIS NOTICE

We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Last Updated' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may elect to notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to our Privacy Policy means that the collection, use and sharing of your information is subject to the updated Privacy Policy.

13. CONTACT US

If you have questions or comments about this notice, you may contact us by email pap@visionholdings.org.

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