- Information We Collect or Track.
- How We Use Your Data.
- Information We Share With Others.
- Your California Privacy Rights.
- Cookies / Tracking Technologies.
- Links to Other Sites, Networks, Platforms, and Apps.
- Age Restrictions; Children’s Privacy.
- Choice / Opt Out.
- File a Complaint.
- Users in the European Union and European Economic Area.
- Retention of Personal Data.
- Contact Us.
(“Sites”), any applications, such as onb.io (“Apps”), and other online services we provide (collectively, the “Services”).
People use our Services to shop content from their favorite Influencers from either our Sites, Apps, screenshots, email, or other online products.
Our Services allow You to shop the looks you like from thousands of Influencers (individuals and entities with websites, blogs, social media presence, agents or agencies, digital publishers and other content platforms). You can simply screenshot a onb.io enabled look from your favorite Influencer from social media or mobile web. If you are a registered user, onb.io enabled images will be automatically displayed in your Likes in the App. As a registered user of the App, you can also find, follow, and shop influencer content directly in the App. Users can also shop influencer content directly via our Sites.
This Policy tells you, among other things, what information we gather from you when you visit our Sites or Apps, how we may use or disclose that information, how to review or edit it, and our efforts to protect it.
Please read this Policy carefully. By visiting, accessing or using any Services, you agree to this Policy. Among other things, you consent to the collection, tracking, and use of your personal information as outlined in this Policy, as such Policy may be amended from time to time.
2. Information We Collect or Track.
We may collect or track the following information:
|A. Identifiers.||Name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, or account name.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, physical characteristics or description, address, telephone number, education, or employment. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||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), or sexual orientation.||YES|
|D. Commercial information.||Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|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)).||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.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
- Registration Information
We collect the data that you provide voluntarily to us.
When you register for Pongo Services, we will request certain information from you, including your email address, password, and contact information (which could include name, address, phone number).
- Interaction With Services and Access
We collect data automatically when you interact with and use our Services and when you voluntarily share information from the Service with others.
As is true of most websites and apps, we gather certain information automatically. We may also collect information from the mobile phone, tablet, computer or other device that you use to access the Services. This information may include your domain and/or Internet Protocol (“IP”) addresses, browser type, Internet Service Provider (“ISP”), the referring or exiting website address, operating system, access times and history, information relating to your activities and preferences on the Services, device, unique device identifiers, mobile platform advertising identifiers (e.g., IFA/IDFA or Android ID), telephone number, mobile carrier, language, CPU, iOS, screen, display, plug-ins, Mime, font, storage, time, canvas, images or other posted content, downloaded content, communications on the Services with other users, posts in public forums, and information from cookies or other technology. See below for more information about Cookies.
We may also infer location from IP addresses or other information, for example, Wi-Fi access points and mobile towers. Among other things, this information allows the creation of device fingerprints and profiles about the possible relationships among different browsers and devices.
We also collect data when You interact with and use the Services. For example, we collect data on traffic, impressions, views, clicks, who you follow, what content you like or screenshot, and products you save or put on your wish list.
We may also collect data when You share information from the Services with others. For example, You may be able to send an invite to a friend to join Onbio or share an image with a friend via email or text message.
- Direct Marketing and Do Not Track Signals
We currently do not share personal data with third parties for their direct marketing purposes without your permission. WE DO NOT RESPOND TO “DO NOT TRACK” SIGNALS.
- Ad, Shopping and Purchase Data
We automatically collect data when you shop using our Services, including data on what you purchased through affiliate links and other tracking technology. We also collect data from other sites you visit and other apps on your device.
We collect and track data on the sites you visit, ads displayed to you and purchase data. This includes, without limitation: your online purchases; your visits and interactions with Influencers; your screenshot data; your “likes”; your visits and interaction with the “Discover”, “Wish List”, “Feed” and/or other tabs on the Apps as they may be available; how many times an ad has been served to you; what page an ad was served; and whether you interacted with the ad. We may also receive information about your visits and interaction with services on other sites you visit and other apps on your device and then associate them with your account.
We automatically collect data when you clink on web page sign up, when you download an app, when you log in to our Services, and through third parties.
Information we collect when you download the Apps, click on a web page sign up, sign in to Pongo Services, interact with our Services, as well as information we obtain about You from third parties, may be associated with your account. When information is associated with your account, we treat it in accordance with this Policy.
If you send us personal correspondence, such as an email or letter, we may collect such information into a file specific to you.
- Public/Sponsored Events
Pongo may participate in public events and events with multiple sponsors, such as trade shows and seminars. The events generally collect certain information from (automatically or voluntarily) all attendees and distribute this data in whole or in part to all the event sponsors including Pongo. We do not control and are not responsible for the practices of other sponsors for these events.
- Social Network Sites (“SNS”)
- Geo-location, Contacts and Camera Roll
With your permission, we will access your camera roll, geo-location, or contacts. In order to use the Services to analyze screenshots, you must allow access to your camera roll. Visit your settings to control.
With your permission, we may also access (1) your geo-location through GPS tracking, (2) your contacts, and (3) your camera roll or saved images, for example, to analyze screenshots. Please note that even if you turn-off or deny GPS tracking, we may still make inferences about geo-location from other information we collect (see subsections (b), (d) and (h) above).
- Push Notifications
With your permission, we will send push notifications. Visit your settings to control.
With your permission, we may send you push notifications and may track and collect information about your interaction with such notifications.
- Information Collected, Tracked or Analyzed by Third Parties
We collect data through cookies, other tracking technologies, and by using third party analytics. Links to these third parties’ privacy policies are provided in this section. See below for more information about Cookies.
We may permit advertisers or other third parties to collect information from the Services. For example, a third party may place cookies or similar tracking technologies (such as advertising IDs or deep linking technology) and may send its own cookies to your cookie file. We may also utilize third parties to analyze data collected from the Services. We may permit third parties to collect personally identifiable information over time and across different websites and across multiple mobile apps. Please see the following third party privacy policies for additional information: https://support.google.com/analytics.
3. How We Use Your Data.
We use your data to provide, develop, support, customize, market, and protect our Services. We also use your data to pay commissions to Influencers (so they can make a living providing the content you like) and to us (so we can provide this Service for free).
We use the information we collect or track about you to provide relevant, useful and customized Services for free. In order to do that, we use your information in the following ways:
- Operate, maintain, and provide to you the Services, features and functionality of the Services;
- Help you quickly find information and prevent you from having to enter information more than once;
- Improve the quality and design of the Services;
- Provide customized content and services, including advertising and promotional information, such as targeted ads / retargeted ads, recommend content you might like, and cross-app / cross-site functionality across multiple third party mobile apps and websites;
- Market and promote our Services to you and others;
- Diagnose problems with the Services;
- Commission processing, payments, and reports;
- Create new features, functionality, and services;
- Communicate with you, including sending you emails regarding products or services that you have liked;
- Provide customer support;
- Create device fingerprints and profiles about the possible relationships among different browsers and devices;
- Creation of consumer profiles, which may combine Your personal information from one Pongo service with personal information and other data from other Pongo services or Pongo partners;
- Perform research and analysis on your use of the Services;
- Manage your account;
- Protect the security and integrity of the Services, as well as the property, rights and personal safety of Pongo, our users or others; and
- Enforce the End User License Agreement and Terms of Service, this Policy and any other agreements you have entered into with Pongo.
4. Information We Share With Others.
- Related Services and Service Providers.
We share your data across our Services and share certain information with Merchants, Influencers, and API Developers. We may also share certain information with other service providers, for example to assist us with data analytics for development of new and better services.
We may provide information about you to our affiliates and other businesses or individuals, including third-party retailers, advertisers and other businesses (“Merchants”), Influencers and Application Programming Interface (“API”) Developers. We share anonymized geo-location data, purchased item and amount of sale with Merchants and Influencers. We may combine information internally across different Services so that we may provide better and more customized services. We contract with companies who help with parts of our operations and/or to enhance our services and we require them to only use your personal information in connection with the services they perform. We may also share aggregated non-personally identifiable information publicly.
Please see the following third party privacy policies for additional information: https://support.google.com/analytics/answer/6004245?hl=en.
- Legal Compliance
We may share your data if required or necessary by law. We may also do so to exercise, defend, or protect our, your, or others’ rights.
Pongo will cooperate with law enforcement inquiries, other government agency inquiries and requests, and criminal or civil subpoenas. Pongo will also disclose your personal information when necessary to comply with state and federal laws and regulations. Pongo may also disclose information to exercise or defend our legal rights, to protect the security of our Services and business, to investigate and prevent illegal or tortious activity, to protect the property or safety of Pongo or others, and to enforce Pongo agreements or other policies.
- Sale or Other Transfer
We may share your data if some or all of our business is sold, acquired, or merged with another company.
As we develop our business, we may buy or sell some or all of our assets and, depending on the transaction, your personal information may be one of the transferred assets. Similarly, if Pongo should ever merge with or be acquired by another company, we may share your personal information with any entity resulting from such transaction. Any entity that acquires your data in this manner will have the right to use your data as set forth in this Policy. Separately, if Pongo should ever file for bankruptcy, the bankruptcy trustee has the right to sell the information you provide to us to a third party.
We cannot guarantee the security of your data. Please see the measures we take Security below.
We cannot ensure that all of your private communications and other personal data will never be disclosed in ways not otherwise described in this Policy. By way of example (without limiting the foregoing), we may be required to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmission of private communications, or users may abuse or misuse your personal information that they collect from the Services.
5. Your California Privacy Rights.
If you are a California resident, then you may have certain rights relating to whether any third parties have received your information for their direct marketing purposes.
For California residents: Under California Civil Code Section 1798.83, if you are a California resident and Pongo has an established business relationship with you, you may have the right to request information from Pongo, free of charge, regarding the manner in which Pongo shares certain categories of personal information with third parties for their direct marketing purposes (if any) and the names and addresses of the third parties with which we have shared such information during the immediately preceding calendar year. Alternatively, at our election, Pongo may provide you with a cost-free means to choose not to have your information shared. You may make two (2) request each year by emailing us at firstname.lastname@example.org or writing us at:
Pongo’s designated email address for such requests is email@example.com. You may also request this information by writing to:
ATTN: Data Requests
3102 Oak Lawn Avenue
Dallas, TX 75219
Deletion Request Rights: You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- 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 research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
If you are a California resident under age 16 and a registered user of the Service, you may ask us to remove content or information that you have posted to the Service by emailing us at firstname.lastname@example.org.
If you would like to opt-out of Pongo sharing your information with affiliates, service providers or customers please click HERE.
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires that third party to keep that personal information confidential and not use it for any purpose except performing the contract.
Under the CCPA, we are the “Business” that collects your personal information and determines the means and purposes of processing. The entity/person engaged to processed your personal information on our behalf is the “Service Provider”. The Service Provider processes your personal information for a business purpose pursuant to a contract with Pongo.
6. Cookies / Tracking Technologies.
- Providing custom, personalized content and information, including without limitation relevant ads, customized ads, interest-based ads and retargeted ads in Your future navigation;
- Providing cross-app / cross-site functionality across multiple third party mobile apps and websites;
- Collect device information which permits generation of device fingerprints and cross-device consumer profiles;
- Creation of user profiles;
- Remembering information so that you will not have to re-enter it during your visit or the next time you visit the Services;
- Analysis of your visits to / interaction with our Services, SNS services, Influencers’ sites, other sites and ads;
- Accumulating and reporting statistical information on Services usage, SNS services, Influencers’ sites and other sites;
- Determining which features users like best;
- Assessing the popularity and effectiveness of the Services;
- Determining whether and when an email was opened;
- Tracking sales;
- Facilitating commissions; and
- Improving our Services and creating new services.
Pongo or an affiliate network (each an “Affiliate Network Partner”) may drop cookies on your device and/or web browser or utilize other tracking technologies. For example, once you click on a particular link, you will be directed by Pongo or the Affiliate Network Partner to a merchant’s e-commerce site, at which point Pongo or the Affiliate Network Partner will drop a cookie on your browser. Among other reasons, these cookies are dropped so that our Services can monetize visits to Influencers and other actions.
Pongo may also utilize third party tracking technology, such as deep linking, to leverage cross-app and cross-site functionality.
Another tracking technology is a script that collects device information to permit what is known as device fingerprinting. (see, e.g., FTC Consumer Guide on Online Tracking – What is device fingerprinting?) For example, this data collection may permit generation of device fingerprints and cross-device profiles to better understand who visits particular Influencers, how often, unique visits, repeat visits, and more.
By agreeing to the terms of this Policy and by using our Services, you consent to the cookies and other tracking technologies referenced above. In order for you to be a registered and active user of the Services, you must agree to accept cookies and other tracking technologies. If you wish to opt-out of cookies and other tracking technologies altogether, then visit our Choice/Opt-Out Section
7. Links to Other Sites, Networks, Platforms, and Apps.
You may encounter Linked Technologies that have their own privacy policies.
The Services may contain links to third party sites, networks – including social network sites like Instagram, Snapchat, Facebook, Twitter, Pinterest or others, platforms or apps (“Linked Technologies”), including retailers and advertisers. However, please be aware that Pongo is not responsible for and cannot control the terms of service or privacy policies of such other Linked Technologies. We encourage you to be aware when you leave the Services, and to read the applicable agreements and privacy policies for each and every Linked Technologies. The Agreement applies solely to these Services. Pongo is not responsible for and makes no representations or warranties regarding Linked Technologies, including without limitation, the content, accuracy, opinions, functionality, or services provided in such Linked Technologies. Inclusion of any Linked Technologies on the Services does not imply approval or endorsement by Pongo. If You decide to access any Linked Technologies, then You do so at your own risk.
8. Age Restrictions; Children’s Privacy.
Our Services are not for use of anyone under the age of 13.
These Services are not for use for anybody under the age of 13. By using these Services, you verify that you are over the age of 13 and in compliance with this provision. Pongo will not knowingly collect or use personal information from anyone under 13 years of age. If Pongo obtains actual knowledge that it has obtained personal information about a child under the age of 13, that information will be permanently deleted from our records.
9. Choice / Opt Out.
You have choices about how your data is collected, the ability to delete certain data, and the ability to close your account.
Cookies. You may be able to delete and/or turn off cookies as your browser or device permits. Unless you block or control cookies going forward, deleting cookies will only address cookies on your device at that moment. If you disable cookies entirely, Pongo Services may not function properly. Please note that other tracking technologies, such as device fingerprinting, are not stopped or impacted by turning off or deleting cookies.
Flash Cookies. Some newer versions of browsers will let you control and/or delete Flash cookies. If you use a browser or device that does not let you delete Flash cookies, then try Adobe’s Website Storage Settings. Similar to regular cookies, deleting Flash cookies will only address the Flash cookies on your device at that moment. Please note that other tracking technologies, such as device fingerprinting, are not stopped or impacted by turning off or deleting Flash cookies.
Other Tracking Technologies. You may be able to turn off and/or delete some scripting functionality as your browser or device permits. If you disable scripting functionality, Pongo Services may not function properly. Please note that other tracking technologies, such as device fingerprinting, are not stopped or impacted by turning off some script functionality.
Opting Out for Application Data: To opt out of interest-based advertising on mobile apps, US residents may download the DAA’s AppChoices application from the Android or Apple app store.
Opting Out for Location Data: You may opt out of precise location data by using the location services controls in your mobile device’s settings. Please note that this does not impact geolocation inferences, which may be possible through IP address information.
Opting out of push / local notifications: We may send push or local notifications to your device to provide updates and relevant messages. You may be able to manage notifications from the Sites, Apps or through your device.
Effect of Opting Out: You will need to renew your opt-out choice if you use a different device, use a different browser, or erase cookies from your browser.
Unsubscribing from emails: You may opt out at any time by using the Opt-Out or Unsubscribe option at the bottom of most of our mass email communications, or by contacting us through the “Contact Us” section of the Services.
Account: You may also choose to close your account at any time.
Although we work to protect your data, we cannot warrant or ensure its ultimate security.
To protect your privacy and security, we take reasonable steps (such as requesting a unique password) to verify your identity before creating your account. The user who created the account is responsible for maintaining the secrecy of their unique password and account information at all times.
We use what we believe to be appropriate procedures to protect information against unauthorized access and disclosure. However, information you elect to post on our Services, emails and other information you send to us are not encrypted and such transmissions cannot be considered a secure means of transmitting sensitive information.
You should be aware of the limitations of security, authentication, encryption, and privacy measures used in connection with the Internet and that any information you transmit through the Services may be damaged, corrupted, “sniffed” and/or accessed by another person without your permission. Regardless of the precautions taken by you or by us, “perfect security” does not exist on the Internet. Third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your personal information that they collect from the Services. Therefore, although we work very hard to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private. We cannot ensure or warrant the ultimate security of any information you transmit.
11. File a Complaint.
12. Users in the European Union and European Economic Area.
If you are in the EU / EEA, then this section applies to you.
- Personal Data.
Personal Data is any information relating to an identified or identifiable natural person in the European Union (“EU”) and European Economic Area (“EEA”).
- Data Controller.
Pongo is the data controller of Personal Data you provide on our Services (within our Apps or on our Sites).
You may contact email at email@example.com
- Purposes of Processing and Legal Basis for Processing.
We have lawful bases to collect, use, and share your data.
As explained above, we process Personal Data in various ways depending upon your use of our Services. We process Personal Data on the following bases: (1) with your consent; (2) as necessary to perform a contract when you request Services; and (3) as necessary for our legitimate interests in providing you with our products and Services, enhancing and customizing our Services, conducting analytics and delivering relevant advertising as set forth above.
- Your Rights Regarding Personal Data.
If you are in the EU / EEA, then you have certain rights relating to your personal data.
- Access and Confirmation. You have the right to ask us if we process Personal Data about you, and in some circumstances, to obtain a copy of your Personal Data.
- Deletion and Blocking. Under certain circumstances, you may have the right to have your Personal Data deleted or blocked without undue delay.
- Direct Marketing. You have the right to object to our processing of Personal Data for direct marketing purposes.
- Consent. To the extent we are processing Personal Data on the basis of your consent, you have the right to withdraw consent at any time.
- Data Portability. Under certain circumstances, to the extent we are processing your Personal Data on the basis of consent, or that it is necessary to perform a contract with you, and the processing is carried out by automated means, you have the right to receive the Personal Data in a structured, commonly used and machine-readable format.
- Email: firstname.lastname@example.org
- Right to Lodge a Complaint. You have the right to lodge a complaint about our data collection and processing actions with the supervisory authority in your country. Contact information is provided on the following website: https://edpb.europa.eu/about-edpb/board/members_en.
We transfer, store, and process your data outside your country.
13. Retention of Personal Data
The Personal Data we obtain about you may be retained up to seven years.
14. Contact Us.
You can contact us for complaints or questions.
Any notices or communication sent to you by Pongo will be sent to your email address on file with Pongo, which may be updated by you in writing at any time. It is your responsibility for ensuring that Pongo has your current email address at all times. Any notice sent to you via such email address by Pongo shall be deemed given, received, and read by you, whether or not it actually is received and/or read.
Any notices or communications sent by you to Pongo pursuant to this Policy must be in writing and sent to the address specified herein or such other address as Pongo may specify in writing.