Pulpoar, Inc. (“hereinafter referred to as PulpoAR”, the “Company“, “We”, and through similar words such as “us”, “our”, etc.) provides to visitors (each, a “Visitor“, “you” or “your“) provides an informative platform that enables them to access on the www.pulpoar.com (the “Website”, “Platform”, “PulpoAR Platform”), get to know the services offered by PulpoAR, view and apply for available job vacancies, access Solution offerings, Solutions pricing and request demos (the “Service”).
The words in which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.
|Business||Business, for the purpose of complying with the CCPA, refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California|
|CCPA||The California Consumer Privacy Act of 2018, signed into law on June 28, 2018, by the State of California|
|Company||(referred to as either “the Company”, “We”, “Us” or “Our” in this Policy) refers to PulpoAR, Inc., ###.
For the purpose of the GDPR, the Company is the Data Controller
|Consumer||Consumer, for the purpose of the CCPA, means a natural person who is a California resident. A resident, as defined in the law, includes (i) every individual who is in the USA for other than a temporary or transitory purpose, and (ii) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.|
|Data Controller||For the purposes of the GDPR, refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data|
|Data Subject||A natural person who can be identified or rendered identifiable through the personal data related to|
|Device||Any device that is suitable to access the Service such as a computer, a cellphone, or a digital tablet|
|Do Not Track||(DNT) is a concept that has been promoted by U.S. regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites|
|GDPR||The General Data Protection Regulation, signed into law on May 25, 2018, by the European Union|
|Personal Data||Any information that relates to an identified or identifiable individual
For the purposes for GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity.
For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
|Personal Data Breach||A breach of security whether accidental or on purpose results in accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.|
|Sale||Sale, for the purpose of the CCPA, means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.|
|Sensitive Personal Data||Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership and; genetic and biometric information, information concerning data subject’s sex life or sexual orientation|
|Service Provider||Any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
For the purpose of the GDPR, Service Providers are considered Data Processors
|Third-Party||Any other natural or legal person that is not part of PulpoAR|
|Third-Party Social Media Service||Any website/app or any social network website/app through which a User can share its reviews regarding the Service|
|Usage Data||Data is collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit)|
|Website||refers to PulpoAR, accessible from www.pulpoar.com|
|You||The individual accessing or using the PulpoAR Platform, or the company, or other legal entity on behalf of which such individual is accessing or using the Platform, as applicable.
For the purpose of the GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service
PulpoAR obtains personal information concerning you from certain sources to provide the Services and to manage the PulpoAR Platform. “You” may be a Visitor, Potential Customer, or Applicant regarding our Services.
- PulpoAR Platform Visitors
If you access or visit our Platform, we may collect your personal information. For example, we collect Personal Data that you shared with us via chatbot, or when you contact us by e-mail.
- PulpoAR Users
When you visit our Platform, you may have different titles depending on the process you will carry out. Here are the User titles specified in our Platform:
- Visitor: It shall mean the natural person who may access the Platform contents by browsing the PulpoAR Platform, benefit from the instant message service via the Chatbot feature, and experience the augmented reality solutions provided by PulpoAR through the Try Now feature.
- Potential Customer: It shall mean the natural person who may perform all the transactions that the Visitor may perform on the PulpoAR Platform, and who may also request a demo of PulpoAR solutions on behalf of herself/himself or the organization she/he is affiliated with.
- Applicant: It shall mean the natural person who applies for the available and appropriate job positions in PulpoAR through the PulpoAR Platform.
- TYPES OF DATA COLLECTED
- Personal Data that We Collect from You
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
- First name and last name
- Email address
- Company Name
- Phone Number
- Usage Data
When you respond to PulpoAR’s e-mails we collect your e-mail address, name, and any other information you choose to include in the body of your e-mail or response. If you contact us by phone, we will collect the phone number you use to call PulpoAR.
You may also opt-in to submitting information through other methods, including:
- By participating in an offer, program, or promotion
- Through our social media accounts or online forums,
- In connection with a real or potential business relationship with us,
- By giving us your business card or contact information.
- Sensitive Data that We Collect from You
As PulpoAR, we perform face-scanning while providing our augmented reality technology solutions to you. Required by our technology, the camera images and photographic data we process about you obtain the attribute of biometric data.
Therefore, if you want to experience our solutions instantly by using the Try Now feature on the Platform, we may process your sensitive data in accordance with the consent expression we have provided to you.
- Information that We Collect Automatically on Our Platform and Services
- Browser and Device Data, such as IP address, device type, internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, brand, model, technical specification, and operating system information of the device used, and the language version of the Platform you are visiting;
- Usage Data, such as time spent on the Platform, pages visited, links clicked, language preferences, Platform usage time, communication preferences, approaches to in-platform notifications/offers/campaigns, habits, favorites, likes, behaviors, preferences, search activities, segments, cookie records, cookie, and ad identifier and Device ID, and the pages that led or referred you to our Platform.
We also may collect information about your online activities on the Platform and connected Devices over time and across third-party sites, devices, apps, and other online features and services. We use web log analysis software (Google Analytics etc.) on our Platform to help us analyze your use of our Platform and diagnose technical issues.
While using our Service, in order to provide features of our Platform, we may collect, with your prior permission, pictures and other information from your Device’s camera; photo, and document library. We use this information to provide features of our Service, to improve and customize our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it be simply stored on your device. You can enable or disable access to this information at any time, through your Device settings.
- USE OF PERSONAL DATA
- Our Services
We rely upon several legal grounds to ensure that our use of your Personal Data is compliant with the applicable law. We use Personal Data to facilitate the business relationships we have with our Users, to comply with legal obligations, and to pursue our legitimate business interests.
Contractual and pre-contractual business relationships. We use Personal Data to enter business relationships with prospective Users and to perform the contractual obligations under the contacts that we have with Users. Activities that we conduct in this context include:
- Contacting you in order to provide you with a limited and non-exclusive license to use a demo solution and to provide you with a demo version
- Evaluation of your job application in order to establish an employee-employer relationship with you
Legal and regulatory compliance. We use Personal Data to verify the identity of our Users in order to comply with laws. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties and to submit to third-party verification audits.
Legitimate business interests. We rely on our legitimate business interests to process certain Personal Data concerning you. The following list sets out the business purposes that we have identified as legitimate. In determining the content of this list, we balanced our interests against the legitimate interests and rights of the individuals whose Personal Data we process.
- Mitigating financial loss, claims, liabilities, or other harm to Potential Customer and PulpoAR;
- Responding to inquiries, sending service notices, and providing customer support;
- Promoting, analyzing, modifying, and improving our products, systems, and tools, and developing new Services;
- Analyzing and advertising our Services;
- Sharing Personal Data with Third-Party Service Providers that provide services on our behalf and business partners who help us operate and improve our business;
- Ensuring network and information security throughout the Platform and our Services.
- Marketing and Events-related Communications
We may send you e-mail marketing communications about PulpoAR and its Services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. When we collect your business, contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and Services, and with your permission, include you on our marketing information campaigns.
- Interest-based Advertising
When you visit our Platform, both certain third parties and we collect information about your online activities over time and across different websites to provide you with advertising products and services tailored to your individual interests (this type of advertising is called “interest-based advertising”). These third parties may place or recognize a unique cookie or other technology on your browser. Where required by applicable law, we will obtain your consent prior to processing your information for interest-based advertising.
Since we also participate in advertising networks, you may see our ads on other websites or mobile apps. Ad networks allow us to target our messaging to users based on a range of factors, including demographic data, users’ inferred interests, and browsing context (for example, the time and date of your visit to our Platform, the pages that you viewed, and the links that you clicked). This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen one of our advertisements.
We work with advertising networks (Google AdWords, Facebook, etc.). To learn how to opt-out from behavioral advertising delivered by ### member companies, please visit the ### and ###. If you opt-out from interest-based advertising, you may see advertising that is not relevant to you.
- HOW WE SHARE PERSONAL DATA
PulpoAR may share your Personal Data to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Policy and our Terms and Conditions, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, our people and the public.
We share Personal Data with a limited number of our Service Providers. We have Service Providers that provide services on our behalf, such as website hosting, instantly message service, data analysis, information technology, and related infrastructure, customer service, e-mail delivery, and auditing services. These service providers may need to access Personal Data to perform their services. We authorize such service providers to use or disclose Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such service providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf. Our service providers are predominantly located in the European Union and the United States of America.
We may disclose information in the aggregate form to third parties relating to user behavior in connection with the actual or prospective business relationship with those third parties, such as advertisers and content distributors.
We will encourage our service partners to adopt and post transparent privacy policies. However, the use of your personal information by our service partners is governed by their privacy policies and is not subject to our control. You acknowledge that we are not responsible for the violations caused by our service partners.
We share Personal Data with third-party business partners when this is necessary to provide our Solutions and Platform features to our Visitors.
In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.
We share Personal Data as we believe necessary: (i) to comply with applicable law; (ii) to provide and maintain the Platform features; (iii) to protect the rights, privacy, safety, and property of PulpoAR, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
- GDPR PRIVACY
Your Rights and Choices Under the GDPR
PulpoAR undertakes to respect the confidentiality of your Personal Data and to guarantee you can exercise your rights.
Right of Access: You have the right to obtain confirmation from us as to whether or not Personal Data concerning you are processed, and, where that is the case, you have the right to request and get access to such Personal Data.
Right to Rectification: You have the right to request rectification by us of inaccurate Personal Data and you have the right to provide additional Personal Data to complete any incomplete Personal Data.
Right to Erasure (“Right to be Forgotten”): In certain cases, you have the right to request from us the erasure of your Personal Data.
Right to Restriction of Processing: You have the right to request from us restriction of processing, for a certain period and/or for certain situations.
Right to Data Portability: You have the right to receive your Personal Data from us in a structured format and you have the right to (let) transmit such Personal Data to another controller.
Right to Object: In certain cases, you have the right to object to the processing of your Personal Data, including with regards to profiling. You have the right to object to the further processing of your Personal Data in so far as such data has been collected for direct marketing purposes.
Right to be Not Subject to Automated Individual Decision-Making: You have the right to not be subject to a decision based solely on automated processing.
Right to Filing Complaint: You have the right to file complaints with the applicable data protection authority on our processing of your Personal Data.
Right to Compensation of Damages: In case we breach applicable legislation on the processing of your Personal Data, you have the right to claim damages from us for any damages such breach may cause to you.
Exercising of Your GDPR Data Protection Rights
You may exercise your rights of access, rectification, cancellation, and opposition by simply contacting us. Please note that we may ask you to verify your identity before responding to such requests. If You make a request, we will try our best to respond to you as soon as possible.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
- CCPA PRIVACY
Your Rights and Choices Under the CCPA
- Right to notice: You must be properly notified of which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
- The right to access / the right to request: The CCPA permits you to request and obtain from the Company information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third party for the third party’s direct marketing purposes.
- The right to say no to the sale of Personal Data: You have the right to ask the Company not to sell your Personal Data to third parties. You can submit such a request by visiting our Platform.
- The right to know about Your Personal Data: You have the right to request and obtain from the Company information regarding the disclosure of the following:
- The categories of Personal Data collected
- The sources from which the Personal Data was collected
- The business or commercial purpose for collecting or selling the Personal Data
- Categories of third parties with whom We share Personal Data
- The specific pieces of Personal Data we collected about You
- The right to delete Personal Data: You also have the right to request the deletion of your Personal Data that has been collected in the past 12 months.
- The right not to be discriminated against: You have the right not to be discriminated against for exercising any of your Consumer’s rights, including by:
- Denying goods or services to you
- Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties
- Providing a different level or quality of goods or services to you
- 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
In order to exercise any of your rights under the CCPA, and if you are a California resident, You can email us or contact us via PulpoAR Platform.
The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.
Do Not Sell My Personal Information
We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA.
If you wish to opt-out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.
You can opt-out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Platform:
- From Our “Cookie Consent” notice banner
- Or from Our “CCPA Opt-out” notice banner
- Or from Our “Do Not Sell My Personal Information” notice banner
The opt-out will place a cookie on your computer that is unique to the browser you use to opt-out. If you change browsers or delete the cookies saved by your browser, you will need to opt-out again.
Please note that any opt-out is specific to the browser you use. You may need to opt-out on every browser that you use.
Your mobile device may give you the ability to opt-out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:
- “Opt-out of Interest-Based Ads” or “Opt-out of Ads Personalization” on Android devices
- “Limit Ad Tracking” on iOS devices
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)
Our Service does not respond to Do Not Track signals.
However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.
- SECURITY AND RETENTION
We are making reasonable efforts to provide you with an appropriate level of security at the risk associated with the processing of your Personal Data. We take organizational, technical, and administrative measures designed to protect your Personal Data against unauthorized access, destruction, loss, alteration, or abuse. Your Personal Data may only be accessed by a limited number of personnel who need access to such information in order to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have a reason to believe that your interaction with us is no longer secure (for example, if you think your account is compromised), please contact us immediately.
Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
To Operate Our Platform: Some cookies are essential to the operation of our Platform. We use those cookies in several different ways, including:
- Site Features and Services
- Performing location submissions
To Analyze and Improve Our Services: Cookies help us understand how to make our Platform and Services work better for you. Cookies tell us how people reach our Platform, and they give us insights into improvements or enhancements we need to make to our Platform and Services.
For Better Advertising: Cookies can help us provide more effective advertising on our Platform. For example, we might use a cookie to help to prevent you from seeing the same advertisement multiple times or to measure how many times an advertisement is viewed or clicked on.
- How We Use Other Technologies
- First Party Cookies
|Cookie Name||Categories of Cookie||Retention Period|
|Marketing/Tracking||1 year 25 days|
|hubspotutk||Marketing/Tracking||1 year 25 days|
|messagesUtk||Marketing/Tracking||1 year 25 days|
- Third Party Cookies
|Cookie Name||Cookie Provider||Categories of Cookie||Retention Period|
- How to Manage Cookies
Your web browser may allow you to change your cookie preferences, including to delete and disable cookies. Please consult the help section of your web browser to understand your options, but please note that if you choose to disable the cookies, some features of our Platform or Services may not operate as intended.
- INTERNATIONAL DATA TRANSFERS
We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.
- USE BY MINORS
The Platform is not directed to individuals under the age of eighteen (18), and they shall not provide Personal Data through the Platform. If you have reason to believe that anyone under the age of 18 has provided us with any personal information, please contact us.
- UPDATES TO THIS POLICY AND NOTIFICATIONS
We may change this Policy from time to time to reflect new services, changes in our Personal Data practices, or relevant laws. The “Last Updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Platform. We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our Platform.
- LINKS TO OTHER WEBSITES
The Platform may provide the ability to connect to other sites. These sites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you to review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website, or the privacy practices of the operator of the website.
PulpoAR focuses on multinational compliance regulations including but not limited to United States Privacy Law and, the General Data Protection Regulation (“GDPR”) brought by the European Union to make sure privacy is a “go-to” rather than a thing to be worried about. You have the right to request further information on our personal data processing activities based on your country’s laws.
- CONTACT US
If you have any questions or complaints about this Policy, please contact us at [email protected].