Privacy Policy

This Privacy Policy delineates our procedures and policies concerning the collection, utilization, and disclosure of your information when you engage with our Service. It also clarifies your privacy rights and the protection granted to you under the law.

By engaging with our Service, you consent to the collection and use of information in accordance with this Privacy Policy.

Understanding and Definitions

Interpretation

In this Privacy Policy, terms with the initial letter capitalized have meanings defined under the following conditions. These definitions hold the same meaning whether they appear in singular or plural form.

Definitions

For the purposes of this Privacy Policy:

  • Account refers to a unique account established for you to access our Service or specific parts of our Service.
  • Company (referred to as either "the Company," "We," "Us," or "Our" in this Agreement) refers to POCO, located in Brussels, Belgium. For the purpose of the GDPR, POCO is the Data Controller.
  • Personal Data is any information that relates to an identified or identifiable individual. Under GDPR, Personal Data includes any information relating to you such as a name, an identification number, location data, online identifier, or factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity.
  • Cookies are small files placed on your computer, mobile device, or any other device by a website, containing details of your browsing history on that website among its many uses.
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to POCO as the legal entity which alone or jointly with others determines the purposes and means of processing Personal Data.
  • Device means any device that can access the Service such as a computer, a cellphone, or a digital tablet.
  • Do Not Track (DNT) is a concept advocated by regulatory authorities for the Internet industry to develop a mechanism allowing internet users to control the tracking of their online activities across websites.
  • Service Provider means any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by POCO to facilitate the Service, provide the Service on behalf of POCO, perform services related to the Service, or assist POCO in analyzing how the Service is used. For GDPR purposes, Service Providers are considered Data Processors.
  • Third-party Social Media Service refers to any website or social network website through which a User can log in or create an account to use the Service.
  • Usage Data refers to data collected automatically, generated either by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to POCO's Youflix, accessible from https://youflix.so.
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service. Under GDPR, You can be referred to as the Data Subject.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

In the course of using our Service, we may ask you to provide us with certain personally identifiable information that can be utilized for contact or identification. This personally identifiable information may comprise, but is not limited to:

  • Email address
  • First name and last name
  • Usage data
  • Phone number
  • Mailing address
  • Job title
  • Contact preferences

Usage Data

Usage Data is gathered automatically when using the Service. This may include details such as your Device's Internet Protocol address (e.g., IP address), browser type and version, the specific pages of our Service that you visit, the date and time of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When accessing the Service via a mobile device, we automatically collect certain information, including but not limited to, your mobile device type, its unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, and other diagnostic data.

We may also collect information sent by your browser whenever you visit our Service or when you access the Service through a mobile device.

Information from Third-Party Social Media Services

POCO allows you to create an account and log in to use our Service through various Third-party Social Media Services, including:

  • Google

When you register or grant access via a Third-Party Social Media Service, we may collect personal data already associated with your account on these services, such as your name, email address, activities, or contact list.

Should you opt to share additional information with POCO through your Third-Party Social Media Service’s account, you consent to our use, sharing, and storage of that information in accordance with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track activity on our Service and hold certain information. These technologies include beacons, tags, and scripts for collecting and tracking information to enhance and analyze our Service. The types of technologies we use are:

  • Cookies or Browser Cookies: A small file placed on your device, which you can manage through your browser settings. However, declining cookies may impact your ability to use certain parts of our Service.
  • Web Beacons: Small electronic files in our Service and emails, used for purposes like counting users who have visited specific pages or opened emails, and other website statistics.

Types of Cookies Used:

  • Necessary / Essential Cookies (Session Cookies): Crucial for the provision of services through the Website, aiding in user authentication and fraud prevention.
  • Cookies Policy / Notice Acceptance Cookies (Persistent Cookies): Indicate user acceptance of the use of cookies on the Website.
  • Functionality Cookies (Persistent Cookies): Remember your preferences like login details or language choice for a personalized experience.
  • Tracking and Performance Cookies (Persistent Cookies, Administered by Third Parties): Gather information on website traffic and user interaction with the Website, often linked to a pseudonymous identifier.

For detailed information on the cookies we use and your choices regarding them, please refer to our Cookies Policy or the Cookies section in our Privacy Policy.

Use of Your Personal Data

POCO may use Personal Data for the following purposes:

  • To Provide and Maintain Our Service: To monitor and manage the usage of Youflix, ensuring its optimal performance and security.
  • To Manage Your Account: Your Personal Data assists in managing your registration as a user of Youflix, granting access to various functionalities available to registered users.
  • For Performance of a Contract: To facilitate the development, compliance, and execution of the purchase contract for the products or services you have procured, or any other agreements you enter into with us via Youflix.
  • To Contact You: Utilizing various forms of communication like email, phone calls, SMS, or push notifications to update you about functionalities, products, or services you're using, including necessary security updates.
  • To Provide Offers and Information: To inform you about news, special offers, and information on other goods, services, and events similar to those you have shown interest in, unless you opt out of receiving such communications.
  • To Manage Your Requests: Addressing and managing any inquiries or requests you make to POCO.
  • To Deliver Targeted Advertising: Leveraging your information to develop and display personalized advertising, in collaboration with third-party vendors, based on your interests and/or location, and gauging its effectiveness.
  • For Business Transfers: Utilizing your information in evaluating or executing a merger, divestiture, restructuring, reorganization, dissolution, or asset sale or transfer, where user data held by POCO is among the transferred assets.
  • For Other Purposes: Employing your data for additional purposes such as data analysis, identifying usage trends, assessing our promotional campaigns' effectiveness, and improving our Service, products, and overall user experience.

Sharing Your Personal Information

POCO may disclose your personal information in the following scenarios:

  • With Service Providers: Your personal information may be shared with service providers who assist in analyzing how our Service is used, support advertising efforts on third-party platforms following your visit to our Service, process payments, and facilitate communication with you.
  • During Business Transfers: In events like mergers, acquisitions, sales of company assets, or during financial negotiations, your personal information may be transferred or shared as part of the business assets.
  • With Affiliates: We may disclose your information to our affiliates, ensuring that they adhere to this Privacy Policy. Affiliates include our parent company, subsidiaries, joint venture partners, or other companies under common control with POCO.
  • With Business Partners: Sharing of your information with our business partners may occur to provide you with specific products, services, or promotions.
  • With Other Users: If you engage in public areas of our Service or interact with other users, such information may be accessible to all users and might be publicly available outside our Service. Additionally, if you connect through a Third-Party Social Media Service, your contacts may see your activity, profile, and other related information. Other users may also see your activity descriptions, interact with you, and view your profile.
  • With Your Consent: We may disclose your personal information for any other purpose, provided we have your explicit consent.

Retention of Your Personal Data

POCO will retain your Personal Data only for the duration necessary for the purposes outlined in this Privacy Policy. We will maintain and utilize your Personal Data as needed to comply with our legal obligations (for instance, retaining data in accordance with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Furthermore, POCO will retain Usage Data for internal analysis. Typically, Usage Data is kept for a shorter period, unless it is necessary for enhancing security, improving the functionality of our Service, or when legal obligations necessitate longer retention periods.

Transfer of Your Personal Data

Your information, including Personal Data, may be processed at POCO’s operating offices and in any locations where the parties involved in the processing are situated. This means your information could be transferred to — and maintained on — computers outside your state, province, or country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction.

By consenting to this Privacy Policy and submitting such information, you agree to this transfer.

POCO will undertake all reasonably necessary measures to ensure that your data is securely handled in accordance with this Privacy Policy. No transfer of your Personal Data will occur to an organization or a country lacking adequate controls, including security measures for your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

In the event POCO is involved in a merger, acquisition, or asset sale, your Personal Data may be part of the transferred assets. We will notify you before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, POCO may be required to disclose your Personal Data if legally mandated or in response to valid requests by public authorities (such as a court or a government agency).

Other Legal Requirements

POCO may disclose your Personal Data in the belief that such action is necessary to:

  • Comply with legal obligations.
  • Protect and defend the rights or property of POCO.
  • Prevent or investigate possible wrongdoing in connection with our Service.
  • Ensure the personal safety of users of our Service or the public.
  • Protect against legal liability.

Security of Your Personal Data

The security of your Personal Data is of utmost importance to us. However, it's important to acknowledge that no method of transmission over the Internet or method of electronic storage is 100% secure. While we are committed to using commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

Detailed Information on the Processing of Your Personal Data

Service Providers have access to your Personal Data only to perform specific tasks on behalf of POCO and are obligated not to disclose or use your data for any other purposes.

Analytics

To monitor and analyze the usage of our Service, we engage third-party Service providers, including:

  • Google Analytics: Google Analytics is a web analytics service by Google that tracks and reports website traffic. Google may use this data for contextualizing and personalizing the ads of its advertising network. You can opt-out of Google Analytics tracking by installing the Google Analytics opt-out browser add-on, which prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information about visit activities. Learn more about Google’s privacy practices at Google Privacy & Terms.

Email Marketing

We may use your Personal Data to send you newsletters, marketing materials, and other information that might interest you. You have the right to opt-out of receiving these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us directly.

To manage and send emails effectively, we utilize Email Marketing Service Providers.

In-app Features

When utilizing our AI feature on Youflix, we may send various types of data from our database, including but not limited to, the prompt you've submitted, to OpenAI's servers for processing. This data transmission is not limited to the prompt you submit; it may encompass a broader range of data stored in your account.

Please be aware that OpenAI may utilize the data we send as part of their AI model training processes. To understand more about how OpenAI handles this data and their privacy practices, you are encouraged to review the OpenAI Privacy Policy.

Payments

Our Service includes the provision of paid products and services. For these transactions, we employ third-party services for payment processing (e.g., payment processors).

Your payment card details are not stored or collected by us. Instead, this information is provided directly to our third-party payment processors, whose handling of your personal information is governed by their Privacy Policy. These payment processors comply with the standards set by PCI-DSS as managed by the PCI Security Standards Council. This compliance aids in the secure processing of payment information.

  • Cryptocurrency Payments: Payments made with cryptocurrencies are processed through our selected cryptocurrency payment gateway. The handling of your transaction data by this gateway is subject to their Privacy Policy. Please note that cryptocurrency transactions may also be recorded on public blockchains, which are not controlled by or exclusive to Youflix.
  • Stripe: Stripe's Privacy Policy can be viewed at Stripe Privacy Policy.

Cryptocurrency Payments and Wallet Extensions

Cryptocurrency Transactions: Our Service allows you to make payments using various cryptocurrencies. These transactions are processed through third-party cryptocurrency payment gateways. When you make a cryptocurrency payment, certain transaction details such as your wallet address and transaction ID may be recorded on a public blockchain, which is not owned or controlled by POCO. This public record of your transaction is a fundamental aspect of blockchain technology and is not governed by our Privacy Policy.

Browser Extensions for Wallet Connections: To facilitate cryptocurrency transactions, our Service may interact with browser extensions that enable you to connect your cryptocurrency wallet. These extensions are developed and maintained by third parties, and their use may allow them to access certain information related to your browser and wallet. We encourage you to review the privacy policies and security practices of any such extensions or wallet services to understand how they handle your data.

Security of Cryptocurrency Transactions: We are committed to ensuring the security of your transactions on our Service. However, the inherent nature of cryptocurrency transactions means that they are irrevocable and recorded on public blockchains. We advise you to take great care in securing your wallet and reviewing transactions before confirmation.

Third-Party Services and Privacy Policies: The third-party services involved in processing cryptocurrency payments, including wallet services and browser extensions, have their own privacy policies. These policies govern their use of your information, which may include personal data. We do not control these third parties and are not responsible for their privacy practices. We encourage you to review their policies to understand how they collect, use, and share your information.

Behavioral Remarketing

POCO employs remarketing services to advertise on third-party websites to you after your visit to our Service. We, along with our third-party vendors, utilize cookies and non-cookie technologies to recognize your device and understand your usage of our Service. This helps us enhance our Service to better align with your interests and to deliver advertisements more relevant to you.

These third-party vendors gather information about your activities on our Service, enabling us to:

  • Measure and analyze traffic and browsing patterns on our Service.
  • Present advertisements for our products and/or services on third-party sites.
  • Evaluate and improve the effectiveness of our advertising campaigns.

It’s important to note that some of these third-party vendors may use non-cookie technologies, which might not be affected by browser settings that block cookies. Your browser may not allow you to block such technologies. However, you can use the following third-party tools to refuse the collection and use of information for interest-based advertising:

  • The NAI's opt-out platform: http://www.networkadvertising.org/choices/
  • The EDAA's opt-out platform: http://www.youronlinechoices.com/
  • The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

We may share hashed email addresses (if available) or other online identifiers collected on our Service with these vendors. This enables them to recognize and deliver ads across devices and browsers. For more detailed information on the technologies used by these vendors and their cross-device capabilities, please refer to each vendor's respective privacy policy.

Third-Party Vendors for Remarketing:

  • Facebook Remarketing: Provided by Facebook Inc. You can understand more about Facebook's interest-based advertising at Facebook Help and opt-out through Facebook’s Instructions. Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. Opt-out options are also available through the Digital Advertising Alliance in the USA (http://www.aboutads.info/choices/), Canada (http://youradchoices.ca/), or Europe (http://www.youronlinechoices.eu/), or via your mobile device settings. Facebook's Data Policy can be viewed at Facebook's Privacy Explanation.

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

POCO processes Personal Data under the following conditions, in alignment with the GDPR:

  • Consent: You have provided consent for the processing of Personal Data for one or more specific objectives.
  • Performance of a Contract: The provision of Personal Data is essential for the performance of an agreement with you, as well as for any pre-contractual responsibilities.
  • Legal Obligations: The processing of Personal Data is necessary to comply with legal requirements that POCO is subject to.
  • Vital Interests: The processing is crucial for protecting your vital interests or those of another individual.
  • Public Interests: The processing of Personal Data is linked to a task carried out in the public interest or under the exercise of official authority vested in POCO.
  • Legitimate Interests: The processing is required for the legitimate interests pursued by POCO.

In every instance, POCO is committed to clarifying the specific legal basis that applies to the processing. We will also specify whether the provision of Personal Data is a statutory or contractual requirement, or a necessity for entering into a contract.

Your Rights under the GDPR

POCO is committed to upholding the confidentiality of your Personal Data and ensuring you can exercise your rights granted under the GDPR.

As a user within the EU, you have the following rights:

  • Request Access to Your Personal Data: You can access, update, or request the deletion of your Personal Data. This can typically be done within your account settings section. If you cannot perform these actions yourself, please contact us for assistance. You also have the right to obtain a copy of the Personal Data we hold about you.
  • Request Correction: If any Personal Data we hold about you is incomplete or inaccurate, you have the right to have it corrected.
  • Object to Processing: Where we rely on a legitimate interest for processing your Personal Data and there’s something about your specific situation which makes you want to object to our processing on this ground. You also have the right to object if we process your Personal Data for direct marketing purposes.
  • Request Erasure: You can request the deletion or removal of your Personal Data when there’s no compelling reason for its continued processing.
  • Request the Transfer: We will provide your Personal Data to you or a third party you have chosen, in a structured, commonly used, machine-readable format. This right applies to automated information you initially consented to us using or where we used the information in performing a contract with you.
  • Withdraw Consent: You have the right to withdraw your consent at any time where POCO relied on your consent to process your Personal Data.

Exercising Your GDPR Data Protection Rights

You can exercise your rights of access, rectification, cancellation, and opposition by contacting us. We may request verification of your identity before responding to such requests. If you make a request, we will strive to respond as promptly as possible.

If you have concerns about our use of your Personal Data, you have the right to lodge a complaint with your local data protection authority in the European Economic Area (EEA).

CCPA Privacy

This privacy notice is specifically for California residents and supplements the information contained in POCO's Privacy Policy. It applies exclusively to visitors, users, and others who reside in the State of California.

Categories of Personal Information Collected

Under the California Consumer Privacy Act (CCPA), we collect personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Below is a list of categories of personal information that we may collect or have collected from California residents in the last twelve (12) months.

Note that the categories and examples listed are defined in the CCPA. This does not imply that all examples from each category have been collected by POCO, but it indicates our good faith belief, to the best of our knowledge, that some information from these categories may have been collected. For instance, certain categories of personal information would only be collected if you directly provided such personal information to us.

  • Category A: Identifiers.
    • Examples: Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and other similar identifiers.
    • Collected: Yes.
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
    • Examples: Name, signature, Social Security number, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or other financial information, medical information, or health insurance information. Some personal information in this category may overlap with other categories.
    • Collected: Yes.
  • Category C: Protected classification characteristics under California or federal law.
    • Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information.
    • Collected: No.
  • Category D: Commercial information.
    • Examples: Records of products or services purchased or considered.
    • Collected: Yes.
  • Category E: Biometric information.
    • Examples: Fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
    • Collected: No.
  • Category F: Internet or other similar network activity.
    • Examples: Interaction with our Service or advertisements.
    • Collected: Yes.
  • Category G: Geolocation data.
    • Examples: Approximate physical location.
    • Collected: Yes.
  • Category H: Sensory data.
    • Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
    • Collected: No.
  • Category I: Professional or employment-related information.
    • Examples: Current or past job history or performance evaluations.
    • Collected: Yes.
  • Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
    • Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
    • Collected: Yes.
  • Category K: Inferences drawn from other personal information.
    • Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
    • Collected: Yes.

Under the CCPA, personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
    • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act ( FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Sources of Personal Information

POCO obtains the categories of personal information listed above from the following categories of sources:

  • Directly from You: For instance, from the forms you complete on our Service, the preferences you express or provide through our Service, or from your transactions on our Service.
  • Indirectly from You: For example, by observing your activities on our Service.
  • Automatically from You: This includes information collected through cookies and other similar technologies that we or our Service Providers set on your device as you navigate through our Service.
  • From Service Providers: We may receive personal information about you from third-party vendors who help us monitor and analyze the use of our Service, provide targeted advertising, process payments, or support other services we offer.

Use of Personal Information for Business Purposes or Commercial Purposes

POCO may use or disclose personal information collected for "business purposes" or "commercial purposes" as defined under the CCPA. This usage may include, but is not limited to, the following:

  • Operational Use: To operate and maintain our Service, including providing you with the Service.
  • Support and Inquiry Responses: To offer support, respond to your inquiries, address your concerns, and monitor and improve our Service. This includes using personal information to fulfill your requests or questions.
  • Transaction Fulfillment: To fulfill or meet the reason for which the information was provided. For instance, using your contact information to respond to queries about our Service, or utilizing payment information to process purchases.
  • Legal Compliance: To respond to requests from law enforcement and as required by applicable law, court orders, or governmental regulations.
  • As Informed at Collection: As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • Internal Administration and Auditing: For our internal administrative purposes, including auditing and quality assurance processes.
  • Security Purposes: To detect, prevent, and address security incidents and illegal or fraudulent activities, including prosecuting those responsible for such activities.

The above examples are illustrative and not exhaustive. For detailed information on how we use personal information, please refer to the "Use of Your Personal Data" section of this policy.

We reserve the right to update this Privacy Policy if we decide to collect additional categories of personal information or use the personal information we have collected for purposes that are materially different, unrelated, or incompatible with those outlined above.

Disclosure of Personal Information for Business Purposes or Commercial Purposes

In the past twelve (12) months, POCO may have used or disclosed, and possibly has used or disclosed, the following categories of personal information for business or commercial purposes:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity
  • Category G: Geolocation data
  • Category I: Professional or employment-related information
  • Category J: Non-public education information
  • Category K: Inferences drawn from other personal information

It is important to clarify that the categories listed above are defined in the CCPA. This does not imply that all examples of personal information in these categories were actually disclosed, but indicates our belief that some information from these categories may have been disclosed for business or commercial purposes.

When disclosing personal information for business or commercial purposes, POCO ensures that the recipients of such data are bound by a contract which specifies the purpose of the disclosure and obligates the recipient to maintain the confidentiality of the personal information and not use it for any purpose other than fulfilling the contract.

Sale of Personal Information

Under the CCPA, "sell" and "sale" refer to the exchange of a consumer's personal information by the business to a third party for valuable consideration, which may not necessarily be monetary.

In the last twelve (12) months, POCO may have sold the following categories of personal information:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category D: Commercial information
  • Category F: Internet or other similar network activity
  • Category G: Geolocation data
  • Category I: Professional or employment-related information
  • Category J: Non-public education information
  • Category K: Inferences drawn from other personal information

This list reflects our good faith belief that some of the information from these categories may have been shared in return for valuable consideration, as per the CCPA's definition of "sale."

Sharing of Personal Information

POCO may share your personal information, as identified in the categories listed previously, with the following types of third parties:

  • Service Providers: Entities that provide various services to facilitate the operation of our Service.
  • Payment Processors: Companies responsible for processing your payments for purchases made on our platform.
  • Affiliates: Companies that are part of POCO's corporate family and assist in providing our services.
  • Business Partners: Collaborative partners who contribute to or participate in our offerings or promotions.
  • Third-party Vendors: Organizations to which you or your agents have authorized us to disclose your personal information in connection with the products or services we offer.

Sale of Personal Information of Minors Under 16 Years of Age

POCO does not sell the personal information of consumers we knowingly identify as being less than 16 years of age. If we do engage in such activities, we would only do so after receiving explicit consent (“right to opt-in”) from a consumer aged 13 to 16, or from a parent or guardian of a consumer under the age of 13. Consumers who have opted in to the sale of their personal information have the right to opt-out at any time. To exercise this right to opt-out, you (or your authorized representative) can submit a request to us through our contact channels.

Should you believe that a child under the age of 13 (or 16) has provided us with personal information, please reach out to us with sufficient details to enable us to remove that information from our systems.

Your Rights under the CCPA

The California Consumer Privacy Act (CCPA) grants specific rights to residents of California regarding their personal information. As a resident of California, you are entitled to the following rights:

  • Right to Notification: You have the right to be informed about the categories of Personal Data being collected and the purposes for which the Personal Data is being used.
  • Right to Request Information: Under the CCPA, you have the right to request disclosure of information about our collection, use, sale, disclosure for business purposes, and sharing of personal information. Upon receiving and verifying your request, POCO will provide you with:
    • The categories of personal information we have collected about you.
    • The sources from which the personal information was collected.
    • The business or commercial purpose for collecting or selling your personal information.
    • The categories of third parties with whom we share your personal information.
    • The specific pieces of personal information we have collected about you.
    • If applicable, the categories of personal information sold and the categories of personal information disclosed for a business purpose.
  • Right to Opt-Out of the Sale of Personal Data: You have the right to direct POCO not to sell your personal information. To exercise this opt-out right, please contact us.
  • Right to Request Deletion: You have the right to request the deletion of your Personal Data, subject to certain exceptions. Once we receive and confirm your request, POCO will delete (and instruct our Service Providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our Service Providers to:
    • Complete transactions for which the personal information was collected, fulfill terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between the business and you.
    • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
    • Debug to identify and repair errors that impair existing intended functionality.
    • Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law.
    • Comply with the California Electronic Communications Privacy Act.
    • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent.
    • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
    • Comply with a legal obligation.
    • Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
  • Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising any of your CCPA rights. POCO will not discriminate against you for exercising any of your CCPA rights, which includes:
    • Denying you goods or services.
    • Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or by imposing penalties.
    • Providing you with a different level or quality of goods or services.
    • Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

To exercise any of your rights under the CCPA as a California resident, you can reach out to POCO:

Your request can be made by you personally, or by someone legally authorized to act on your behalf, registered with the California Secretary of State.

When making a request, please ensure it is:

  1. Sufficiently detailed to allow us to reasonably verify your identity or that of your authorized representative.
  2. Clear enough to enable us to understand, evaluate, and respond appropriately.

For us to respond to your request and provide the necessary information, we must be able to:

  • Verify your identity or authority to make the request.
  • Confirm the personal information pertains to you.

POCO will aim to respond to your verified request free of charge within 45 days of receipt. If necessary, this period may be extended by an additional 45 days, with prior notice and reasonable justification.

Disclosures provided will cover the 12-month period preceding the receipt of your verifiable request.

For requests involving data portability, POCO will provide your personal information in a format that is readily usable and facilitates the transfer of data from POCO to another entity without hindrance.

Do Not Sell My Personal Information

As a user, you have the right to opt-out of the sale of your personal information. Upon receiving and validating a verifiable consumer request from you, POCO commits to halt the sale of your personal information. To initiate your opt-out right, please reach out to POCO.

It’s important to note that third-party service providers engaged by POCO, such as analytics or advertising partners, might implement technologies on our Service that are considered a "sale" of personal information under CCPA legislation. If you desire to opt-out of having your personal information used for interest-based advertising and potential sales as defined by the CCPA, you can follow these steps:

Remember, opting out is browser-specific. You will need to perform the opt-out process on each web browser you use.

Website Opt-Out

You can opt-out of personalized advertising served by our Service Providers by following these steps on the Service:

  • Visit the Network Advertising Initiative’s (NAI) opt-out platform: http://www.networkadvertising.org/choices/
  • Use the European Digital Advertising Alliance’s (EDAA) opt-out platform: http://www.youronlinechoices.com/
  • Access the Digital Advertising Alliance’s (DAA) opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

Opting out will set a unique cookie in your browser specific to the browser you used for the opt-out. If you change your browser or clear its cookies, you will need to opt out again.

Mobile Device Opt-Out

Your mobile device settings provide options to opt out of interest-based ads:

  • On Android devices, choose "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization."
  • On iOS devices, select "Limit Ad Tracking."

Additionally, you can halt the collection of location data from your mobile device by modifying its settings.

"Do Not Track" Settings

POCO's Service currently does not have a mechanism to recognize the various "Do Not Track" signals communicated by web browsers. Despite this, it’s important to note that certain third-party websites may keep a record of your browsing activities. If you prefer that these websites not track your online browsing, you can set your preferences in your web browser. This setting allows you to inform websites that you wish not to be tracked. You can activate or deactivate this feature in the preferences or settings menu of your web browser.

Your California Privacy Rights (California's Shine the Light Law)

In accordance with California Civil Code Section 1798 (California's Shine the Light law), residents of California who have an existing business relationship with POCO are entitled to request information annually about the sharing of their personal data with third parties for direct marketing purposes of these third parties.

If you are a resident of California and would like to make such a request, please reach out to POCO using the contact information provided at the end of this document.

California Privacy Rights for Minors (California Business and Professions Code Section 22581)

California Business and Professions Code Section 22581 grants residents of California under the age of 18, who are registered users of online platforms, the right to request and obtain the removal of content or information they have publicly posted.

If you wish to request the removal of such data and are a California resident, you can contact POCO with the associated email address of your account. Please be aware that this request does not ensure the complete or comprehensive removal of the content or information posted online, and there may be circumstances in which the law does not require or allow removal.

Links to External Websites

Our Service may feature links to external websites not under POCO's control. If you choose to click on a link to a third-party website, you will be directed to that external site. It's highly recommended that you carefully read the Privacy Policy of each website you visit.

POCO does not exert any control over, and therefore cannot be held responsible for, the content, privacy policies, or practices of any third-party sites or services.

Updates to This Privacy Policy

POCO reserves the right to modify its Privacy Policy periodically. Any changes will be communicated by posting the revised policy on our website.

You will be notified of these changes via email and/or a clear notice on our Service, before the change becomes effective. The "Last updated" date at the top of this Privacy Policy will also be revised accordingly.

We encourage you to review this Privacy Policy regularly to stay informed about any updates. Changes to the Privacy Policy take effect when they are posted on this page.

Contact Information

For inquiries or concerns regarding this Privacy Policy, please reach out to POCO at: