Last Revised: August 29, 2019
Stoa USA, Inc. (“us”, “we” or “Company”) respect the privacy of our users (each, “you” or “User”) and are committed to protect the privacy of Users who access, engage, use, download, install or register to our mobile application (the “Application”), our website or any other online services we provide (collectively: the “Services”).
- What type of information we collect
- Cookies and Google Analytics
- How we use the information
- With whom we share the information and for what purpose
- International transfer
- For how long we retain the information
- Your privacy rights
- How we protect your information
- Advertising ID and Advertising Identifier
- How to contact us
What type of information we collect
We may collect two types of data and information from our Users.
The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services (“Non-personal Information”). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference , access time and the website’s domain name from which you linked to the Services, etc.), in order to enhance the functionality of the Services. We may also collect information about your activity on the Services (e.g., clicks, actions, how many times you visit the Application, dates, etc.).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Such information may include:
- Account Information: When you sign-up and register to the Services, you will be asked to provide us certain details about yourself. You may register to the Services directly through our website.
- Registering through our website: When you register to the Services through our website, we may collect from you the following information: full name, email address, phone number, home address, social security number, bank statements, incorporation documents, credit score, felonies, as well as any other information you agreed to share with us.
- Voluntarily Information: We may collect information which you provide us voluntarily. For instance, when you respond to communications from us, communicate with us via email or share additional information about yourself through your use of the Services. We may also collect the feedback, suggestions, complaints and reports which you send to us. Please note that we may also collect complaints about you from other Users, which may include your Personal Information.
- Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers (e.g., MAC address and UUID), as well as other information which relates to your activity through the Services.
For avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.
Cookies and Google Analytics
A “cookie” is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and may be used for various different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother.
We may use the following types of cookies:
- Session Cookies which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed.
- Persistent Cookies which are saved on your device for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to identify who you are for repeated visits (for instance, to allow us to store your preferences for the next sign-in).
- Third-Party Cookies which are set by other online services that run content on the page you view on your browser (for example, by third-party advertising companies who monitor and analyze our website access).
You may remove the cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of the Services may not operate properly and your online experience may be limited.
How we use the information
- To set up your account and to provide our Services;
- To identify and authenticate your access to certain features of the Services;
- To communicate with you and to keep you informed of our latest updates;
- To serve you personalized advertisements when you use the Services;
- To perform a research or to conduct analytics in order to improve and customize the Services to your needs and interests;
- To support and troubleshoot the Services and to respond to your queries;
- To investigate and resolve disputes in connection with your use of the Services;
- To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
- To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.
With whom we share the information and for what purpose
We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) affiliated companies; (iii) subcontractors and other third-party service providers (e.g., Google Cloud); (iv) auditors or advisers of our business processes; and (v) any potential purchasers or investors in the Company.
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.
Third-party collection of information
Since we operate globally, we may transfer and process personal information to and in other locations around the world where we or our partners maintain data processing operations as necessary to provide our Services. We will take steps to ensure that an adequate level of protection is given to personal information, including through adequate contractual measures.
For how long we retain the information
We retain the information we collect from you for as long as needed to provide our Services and to comply with our legal obligations, resolve disputes and enforce our agreements (unless we are instructed otherwise). We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion. Without derogating from the foregoing, in any other case we will retain the information for a maximum period of 15 years. We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
Your privacy rights
Certain jurisdictions provide Users with certain statutory rights to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have the right to certain actions to your Personal Information such as:
- Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
- Right to see what Personal Information about you we have;
- Right to request that we erase Personal Information about you (subject to any other legal obligation that may require us to keep that information);
- Right to restrict us from processing Personal Information pertaining to you (for example, you may request that we will stop using or sharing your Personal Information with third-parties); and
- Right to export Personal Information in a portable format.
If you wish to exercise any of these rights, contact us at: firstname.lastname@example.org. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Information). However, please note that if you choose not to allow us to process your Personal Information, we may be prevented from providing our Services.
If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: email@example.com.
If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can complain to the applicable data protection authority.
How we protect your information
We take great care in implementing and maintaining the security of the Services and safeguarding information that relates to you. We employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard such information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
We may use a third-party advertising technology to serve advertisements when you use the Services. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). We may also use our third-parties and share with them Users’ information to assist us in evaluating the success of our advertising campaigns and help us retargeting our Users.
You may opt-out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.
The Services are not designated to individuals under the age of 18. If you are under 18 years old, you should not download the Application, use the Services, or provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you by us. In the event that we become aware that an individual under the age of 18 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, it will be advisable to contact us at: firstname.lastname@example.org.
Advertising ID and Advertising Identifier
The Google Advertising ID is an anonymous identifier, provided by Google Play services. If your device has an Advertising ID, we may collect and use it for advertising and user analytics purposes. We may also use Apple’s Advertising Identifier (IDFA), which is a non-permanent device identifier provided by Apple, and any information obtained through the use of the Advertising Identifier, for the purpose of advertising.
By downloading the Application or using the Services you explicitly agree that we may associate your Advertising ID and your Advertising Identifier with your applicable persistent device identifier. This will facilitate our ability to improve your personalized experience. Further, we may use other persistent identifiers for non-advertising purposes. If your device does not have Advertising ID or Advertising Identifier respectively, we will use other identifiers.
How to contact us
If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at: email@example.com.
Information about us
The details of the Company are as follows: Stoa USA Inc.
15805 Biscayne Blvd., Suite 106
North Miami Beach,