Your privacy is very important to us at Pingo. Pingo is committed to respecting your privacy and the confidentiality of your Personal Information and the content of your communications. This Privacy Statement is meant to assist You and Visitors in understanding how We use and safeguard the information that We collect from the Website and in providing our services to You. To protect your privacy, the Personal Information that Pingo collects from You is used in the manner and for the purposes described in this Privacy Statement.
To help You better understand this Privacy Statement, We provide some basic definitions to use when reading and interpreting this document. The bold type terms used in this Privacy Statement shall have the meaning set forth below.
Customer or You means individuals to whom this Privacy Statement applies. Customers include anyone who registers with Pingo, uses Pingo's services, or voluntarily enters Personal Information on the Website.
Pingo or Us/We/Our means Pingo and, as applicable, the underlying provider of Pingo's services, iBasis, Inc. ("iBasis"). This Privacy Statement only applies to customers who register with Pingo, use Pingo's services, or voluntarily enter Personal Information on the Website. Additional information regarding iBasis is available at www.ibasis.com.
Non-Personally Identifiable Information - is aggregated or other information that cannot be associated with an individual person.
Personal Information or Customer Proprietary Network Information (also known as CPNI) is information about an identifiable individual that is recorded in any form and that We have about You solely by virtue of our carrier/customer relationship. Personal Information does not include information that is aggregated in such a manner that it does not identify an individual Customer or that cannot be associated with an individual Customer. Personal Information may include but is not limited to, a Customer's name, address, e-mail address, ID numbers, phone number(s), calling history, credit card information, credit history, payment and banking information, and marketing preferences.
Privacy Statement refers to the Privacy and Security Statement as updated from time and time and available on the Website.
Call Detail Information - is a type of CPNI that consists of records that contain your call history, including the numbers called, time location and duration of calls. You will have access to your Call Detail records via a password protected profile on the Website.
Website refers to the Pingo website located at www.pingo.com.
Why We Collect Personal Information
We collect and use Personal Information from Customers for the following reasons:
- to provide service, products, and support to Our Customers;
- to maintain commercial relations and to communicate with Our Customers (which may include, but is not limited to, billing, collection, advertising, promotion, account and credit verification, and other actions to customize, measure, and improve Our services);
- to identify the needs and preferences of Our Customers;
- to meet applicable legal and regulatory requirements;
- to administer and manage Our business operations and personal accounts;
- to resolve disputes and troubleshoot problems;
- to enforce Our Terms and Conditions and prevent improper or illegal use of Our Website and services.
Personal Information will not be collected, used, or disclosed for purposes other than as set forth in this Privacy Statement except with your consent or as otherwise required or permitted by applicable law.
What Information We Collect
We require You to provide certain Personal Information so that You can order services from Pingo, and We limit the collection of Personal Information to that information we believe is necessary or appropriate for the purposes identified in this Privacy Statement. Among the Personal Information that we require from You is your name, address, e-mail address, phone number(s), credit card information, and marketing preferences.
Customers who purchase services from Pingo are required to provide credit card or other payment information for billing purposes. Except as described in this Privacy Statement, all financial information is kept confidential. We may use a third party to process credit card orders, including card authorization and billing. Any such third party is contractually authorized to use the Personal Information provided by You solely for the purpose of conducting Pingo business. They may not release your Personal Information to any other person except as required or permitted by applicable law or court order or to defend the third party's rights in a legal dispute.
We also collect feedback information via feedback forms located on the Website. This information is used to measure and improve the quality of Our services and the Website. Pingo reserves the right to use this information, in an anonymous form, for marketing purposes, for instance, by displaying selected comments on the Website or in other communications. You are never under any obligation to provide feedback information.
Pingo may collect and use your IP address to improve Pingo's service and administer Pingo's Website. Your IP address may be used to identify You and to gather demographic information. IP addresses are also used to investigate alleged violations of Pingo's Terms and Conditions, spamming, improper use of the Website, or other improper or illegal activities.
Visitor Retargeting Program - We work with Google to display retargeted ads to Visitors on our behalf, across the Internet, using action tags. These action tags, an industry standard technology, collect Non-Personally Identifiable Information about Visitors' visits to the Website and enable Google to deliver targeted advertisements on other Internet sites. If Visitors do not want Google to collect this information to deliver targeted advertisements, Visitors may opt out of their services by clicking on the following link:
Google opt out section:
We work with a company called Rejoiner who may retain some of Visitor's Personal Information who do not complete the Pingo customer registration process. This information is only retained after a Visitor enters the data into Pingo's registration page fields. The Personal Information retained only includes the Visitor's first and last name as well as the Visitor's corresponding email address. No financial information is retained in this practice. The purpose of retaining this limited Personal Information is to follow up via e-mail with Visitors who did not complete the registration process, offer assistance in completing the process and offer Visitor promotional deals for Pingo's services. If Visitors do not want to receive such messages, Visitors may opt out of this practice by going to the following website, http://rejoiner.com/our-promise and entering the email address used during Your customer registration process.
Pingo may use some cookies that are not able to be controlled and limited by editing the privacy control settings on your Internet browser. These cookies, sometimes referred to as ‘flash cookies’, utilize Adobe’s Flash plug-in to track users and store information for various purposes including offering targeted advertisements. To remove these cookies, users should go to Adobe’s site (click either Global Privacy Settings or Website Privacy Settings) and follow the instructions provided.
Protection of Your Personal Information
Protecting the confidentiality of your Personal Information or CPNI is your right and our responsibility under federal law.
We have invested in and deployed technological and physical security measures to protect the Personal Information and other information that we collect. For instance, when Our registration form asks You to enter Personal Information, that information is encrypted and is protected with the encryption software most commonly deployed in the ecommerce industry, Secured Socket Layer ("SSL"). If you use an SSL-enabled Internet browser, such as used in the current versions of Microsoft Internet Explorer or Netscape Navigator, your transmissions of Personal Information to Us through them will be secured through SSL technology. You can verify whether the information that is transmitted is using SSL encryption by confirming the presence of a "closed lock" (for users of Microsoft Internet Explorer) or a "solid key" (for users of Netscape Navigator) symbol on the bottom bar of your browser window. To learn more about SSL, follow this link http://ssl.comodo.com/.
Disclosure of Personal Information
Use/Disclosure of Personal Information to Support and Promote Pingo Services
As We describe in more detail below, We do not sell or disclose your Personal Information to anyone outside of Our company or with anyone not authorized to perform service related functions on Our behalf, except as may be required by law or as authorized by You.
Generally, we are permitted to use CPNI to assist us in our provision of your Pingo services, including billing and collection of those services, or to provide you with information on new discounts or special offers relating to the Pingo services. If we use a third party to assist us in the performing any of the above functions on our behalf, We require that they only use Your information for the purposes provided and protect Your Personal Information consistent with our privacy policies described in this Privacy Statement. We do not provide Your Personal Information to third parties for the marketing of their services to You.
We may, however, use or disclose your Personal Information for legal or regulatory reasons as necessary or required to investigate fraud, to protect other users, or to otherwise protect against the unlawful use of the Pingo Service.
Customer acknowledges that it is Pingo's policy and prerogative to respond to all governmental inquiries regarding its service or its Customers. In the event a competent governmental authority asks Pingo to retain and provide Personal Information about a Customer, Pingo reserves the right to provide any and all assistance and information necessary in its opinion to fulfill the request.
We also may be required to disclose Personal Information in connection with a merger, acquisition or bankruptcy if We should ever file for bankruptcy or merge with another company, or if We should decide to buy another business, or sell or reorganize part or all of our business. We may be required to disclose Your Personal Information to prospective or actual purchasers and other parties. By agreeing to this Privacy Statement, You agree to any such transfer of Your Personal Information that may occur. It is Pingo's practice to obtain appropriate protections for Personal Information disclosed in these types of transactions. Pingo cannot, however, guarantee that Our Privacy Statement will remain unchanged if Pingo is sold or merges with or is acquired by another company.
Retention of Personal Information
Personal Information will be retained as long as necessary for the fulfillment of those purposes or as otherwise required or permitted by applicable law.
Use of Personal Information to Support and Promote PINGO Services - Opt Out Rights
By accepting this Privacy Statement, registering on the Website, or using Pingo's services, You consent to the collection, use, and disclosure of your Personal Information as set forth in this Privacy Statement. However, Pingo allows Customers to opt-out of receiving Pingo marketing communications from Us or Our affiliates during registration, and any time thereafter by sending an e-mail request to email@example.com or by following the unsubscribe procedures in any email marketing communication.
Even if You opt out of receiving Pingo marketing communications, You will still receive e-mail communications from Us regarding your Pingo account and services to which You have subscribed, including, but not limited to, communications regarding service issues. Pingo also reserves the right to use e-mail to notify You regarding any claims related to your use of Pingo services, including without limitation claims of violations of a third party's rights. You may permanently close your Pingo account and stop all communication by sending a request to firstname.lastname@example.org.
Accuracy of Personal Information and Customer Access to Personal Information
Pingo takes reasonable steps to make sure that the Personal Information You provide is accurate, complete and up-to-date for the purposes for which it is collected and processed. Upon written request via a password-protected profile available on the Website, You can learn what Personal Information Pingo holds about You. You can also obtain access to Your Call Detail Information online via the password protected profile on the Website. You will not be charged for requesting such access. However, any information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available to you. If you notify Us that any Personal Information that We have is incorrect, We will review such information. If we agree that the Personal Information is incorrect, we will correct our records. We may charge You a reasonable fee to make corrections. If We do not agree that your Personal Information is incorrect, You may submit a short statement of dispute, which we will include in any future disclosure of disputed information. Pingo may refuse to correct, amend, or delete any Personal Information that We require to provide service to You or that we are required or permitted to retain by applicable law.
Transfer of Data
The Personal Information that We collect may be stored and processed on servers located in various countries, including servers located outside of your home country. The laws of other countries may not provide the same degree of protection for your Personal Information as your home country. By accepting this Privacy Statement, registering on the Website, or using Pingo services, You expressly acknowledge and consent to the transfer of your Personal Information to countries outside your home country, including to the United States. If You do not agree to the transfer of your Personal Information as provided in this Privacy Statement, We may not be able to provide service to You.
Links to Outside Websites
The Website may contain links that will let Customers leave the Website and access other websites. Linked websites are not under Our control. It is possible that these websites have privacy policies and standards that are different than those of Pingo. This Privacy Statement applies only to Personal Information that is acquired by Us on the Website. Pingo accepts no responsibility or liability for our Customers' use of other websites.
Refer a Friend
Pingo's Refer a Friend function on the Website allows You to recommend Pingo to your friends and family. To do so, You must provide the e-mail addresses of the persons You are referring. By providing the e-mail addresses, You are giving us permission to send an e-mail invitation in your name. Friends will be eligible to receive an e-mail invitation if they are not current or former Customers and they have not already been told about Pingo by another Customer through the Refer a Friend service. Information entered by You for Refer a Friend will be used only for the purposes of generating e-mail messages to these potential Pingo Customers, and all such messages will contain a functioning opt-out mechanism.
Refer a Friend is intended to be used only by our Customers to tell their friends and family about Pingo's service. Pingo does not condone spamming. Spamming includes, but is not limited to, providing Pingo with the e-mail addresses of people who are not known to You and entering e-mail addresses that are found on a mass mailing list.
If We determine that a Customer is improperly using Refer a Friend, We may, in our sole discretion, block the Customer from using the Website or cancel Customer's service, in addition to any other remedies permitted by applicable law.
Pingo is not liable for any direct, indirect, or consequential damages due to the use of the Refer a Friend service.
Children's Privacy Protection
Children under 13 years of age are not permitted to be Pingo Customers. Children under 13 should not send Us any information about themselves. If a child under 13 submits information through any part of Our Website, and We become aware that the person submitting the information is a child, We will attempt to delete this information as soon as possible. Because We do not knowingly collect any personal information about children under 13, We do not knowingly use or disclose such information.
Changes to This Privacy Statement
We reserve the right to change this Privacy Statement at any time. The revised Privacy Statement will be effective immediately upon its posting on the Website with the new effective date displayed. Any revisions will apply on a prospective basis only. You should periodically check Our Website for any such changes. By accepting the terms and conditions of this Privacy Statement, You agree that your continued use of Pingo's services after a revised Privacy Statement is posted on the Website constitutes your acceptance of the revised Privacy Statement except as follows. Specifically, if we intend to use Your Personal Information in a manner that is materially different from that described in the Privacy Statement when You subscribed to Pingo, we will send You a notice in advance of the change by using your provided e-mail address and You will be given a choice as to whether to accept or reject such a change.
Our Privacy Officer
We have designated one or more individuals who monitor Our compliance with this Privacy Statement. The individual responsible for Our compliance has been designated as Pingo's Privacy Officer and can be reached by sending correspondence to the following address:
ATTN: Legal Department
10 McGuire Road, Building 3
Lexington, MA 02421, USA
Other individuals may handle the day-to-day collection and processing of Personal Information. The Privacy Officer or Pingo's management may designate other individuals within Pingo to assist the Privacy Officer or to perform the Privacy Officer's responsibilities.
Questioning Pingo's Compliance With This Privacy Statement
ATTN: Legal Department
10 McGuire Road, Building 3
Lexington, MA 02421, USA
Pingo will investigate all such inquiries and will respond as appropriate. We may seek advice from internal and external advisors before providing responding to Your inquiry. If We determine that a complaint is justified, We will take appropriate remedial measures, in Our sole discretion, including modifying Our policies and practices.
Questions or correspondence regarding this Privacy Statement should be directed to Us at the following address:
ATTN: Legal Department
10 McGuire Road, Building 3
Lexington, MA 02421, USA
This Privacy Statement is effective as of January 12, 2016.