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Askaloo Privacy Policy

Last Updated: February 20, 2022

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  1. Introduction

This Privacy Policy describes how Askaloo, Inc. will gather, use, and maintain your personal information. It will also ayour legal rights to control our use of that information.

By using the Askaloo Platform, you confirm that you have read and understand this Privacy Policy, and our Terms of Service (together referred to herein as the “Agreement”). The Agreement governs the use of the Askaloo Platform. Askaloo will gather, use, and maintain information consistent with the Agreement.

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   2. General Terms

In this Privacy Policy:

  • Askaloo, Inc. may be referred to as "Askaloo," “we,” “our,” or “”

  • We call a user of the Askaloo Platform a “User,” or collectively, the “Users.”

  • "You"and "your" refer to an individual User of the Askaloo Platform.

  • The community platform that we offer at our website (www.askaloo.com) is referred to as the “Site.”

  • The platform and related services provided by Askaloo, the Site and mobile applications (whether on iOS or Android), including without limitation information provided by Askaloo to potential and actual Users in relation to the services, together are called the “Askaloo Platform.”

  • “Terms of Service” refers to our terms, which can be found at terms. This Privacy Policy is incorporated into, and considered a part of, the Terms of Service 

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   3. Users Outside Of The U.S

3(a) Important Information for Users Outside of the U.S. – Transfer of Data

We primarily store data about you, including personal information, on servers located and operated within the United States. If you reside or are located outside of the U.S., we may send and store your personal information (also commonly referred to as personal data) to the U.S. in order to provide and operate the Askaloo Platform. By accepting the terms of this Privacy Policy, you acknowledge the transfer to and processing of your personal information on servers located in the U.S. and other countries. If your personal information is transferred from the European economic area to Askaloo located in the U.S., please see the EU-US Privacy Shield section below. Our collection and use of the personal information of U.S. Users in accordance with the U.S. laws related to privacy and use of personal data and information, including what is determined to be “personal data and/or information,” are different and may be less protective than those afforded to EU Users under the GDPR.

3(b) EU-US Privacy Shield

Askaloo's commitment to comply with the Privacy Shield Principles

Askaloo is committed to compliance with the EU-US Privacy Shield (as set forth by the U.S. Department of Commerce) regarding the collection, use, and retention of personal information from European Union member countries. Askaloo has self-certified that it adheres to each of the Privacy Shield Principles:

  • Notice

  • Choice

  • Accountability for Onward Transfer

  • Security

  • Data Integrity and Purpose Limitation

  • Access

  • Recourse, Enforcement, and Liability

If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.

Accountability for onward transfers

The Privacy Shield Principles describe Askaloo’s responsibility for personal data that it receives from EU residents under the Privacy Shield and subsequently transfers to a third party processor. In particular, if third-party agents that process personal data on Askaloo’s behalf do so in a manner inconsistent with the Privacy Shield Principles, Askaloo will remain responsible and liable unless it can prove that it is not responsible for the event giving rise to the damage.

Right of access

You have a legal right to request a copy of the personal information that we have about you. You also have a right to correct, amend or delete such personal information where it is inaccurate or has been processed in violation of the Privacy Shield Principles.

Resolution of disputes and complaint mechanism

In compliance with the Privacy Shield Principles, Askaloo commits to resolve complaints about your privacy and our collection or use of your personal information. If European Union citizens have any queries related to the processing of your personal information under the Privacy Shield framework, we encourage you to contact us directly in the first instance at: privacy@askaloo.com or Askaloo Privacy, Postboks 22, 1375 Billingstad.

Binding arbitration

As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints regarding Askaloo’s Privacy Shield certification not resolved by any other means

Enforcement

Askaloo is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Disclosure of EU personal data to public authorities and law enforcement agencies

Askaloo may be required to share your personal information in response to lawful requests by public authorities.

3(c) EU users and our lawful bases for using your data

Data protection law in Europe contains a number of "lawful bases," which are legal justifications for allowing organizations like us to have your personal information in the first place. We have been careful to ensure we have a lawful basis for using all EU user data. Our lawful bases include:

  • Performing the contract we have with you: In certain circumstances, we need your personal data to comply with our contractual obligation to deliver access to the Askaloo Platform.

  • Legal compliance: Sometimes the law says we need to collect and use your data. For example, we might pass on details of people involved in fraud or other criminal activity to law enforcement.

  • Legitimate interests: this is a technical term in data protection law which really means we have a good and fair reason to use your data and we do so in ways which do not materially impact your interests and rights. We sometimes require your data to pursue our legitimate interests in a manner that might reasonably be expected as part of running our business. For example, we will send you promotional communications about our service, subject to your legal rights to opt-out. We also analyse how Users interact with our Site and the Askaloo Platform so we can understand better what elements of the design are working well and which are not working so well. This allows us to develop and improve the quality of the online experience we offer all our Users.

Where we talk in this Privacy Policy about the different data we collect and how we use it, we aim to mention which lawful basis applies.

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  4. Information Received By Askaloo

Personal Information Askaloo collects certain information such as your name, address, approximate geographic location of your computer or mobile device, telephone number, email address and bank account and other Financial Information if you voluntarily choose to share such information with Askaloo. We do require that you furnish this information when you register with us , because we need the information in order to provide the Askaloo Platform. When you register your account, and through communications transmitted through our Site and your use of the Askaloo mobile application, we collect information including your name, address, phone number and email address. You also may choose to send Askaloo personal information in an email message containing inquiries about the Askaloo Platform. Certain offerings of the Askaloo Platform, such as newsletters, surveys, contests, and the like are optional and so you are not required to enter them or to give us your data in connection with them. Where you do choose to enter them, we will use your data to operate and manage the survey, contest or similar in connection with our legitimate interest in promoting our business and the Askaloo Platform.

Cookies and Other Technologies. When you visit websites on the Internet, your browser may automatically transmit information to the websites you visit throughout every visit, including ours. In a similar way, when you use our mobile applications, we will access and use mobile device IDs to recognize your device. Like many websites, we use “cookies” and equivalent techniques through our mobile applications to collect information. A cookie is a small data file that we transfer to your computer’s hard disk.

We utilize persistent cookies that only Askaloo can read and use, and access mobile device IDs:

  • to save your login information for future logins to the Askaloo Platform;

  • to assist in processing items during checkout;

  • to hold session information; and

  • to track user preferences.

We utilize session ID cookies and similar technologies:

  • to enable certain features of the Askaloo Platform;

  • to better understand how you interact with the Site and the Askaloo Platform;

  • to monitor usage by our Users and web traffic routing on the Askaloo Platform;

  • to track the number of entries in Askaloo promotions, sweepstakes and contests; 

  • to identify visited areas of the Askaloo Platform.

Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Askaloo Platform and then close your browser.

Third party advertisers on the Site may also place or read cookies on your browser, and we may use Flash cookies (or local shared objects) to store your preferences or display content based upon what you view on the Site to personalize your visit.

You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you will not be able to use all portions or all functionalities of the Askaloo Platform.

We and our service providers may also use "pixel tags," "web beacons," "clear GIFs," or similar means in connection with the Askaloo Platform and HTML-formatted email messages to, among other things, track the actions of Users and email recipients, to determine the success of marketing campaigns, and to compile statistics about Site usage and response rates. We also engage one or more third party service providers to serve online advertisements on our behalf. They may use a “pixel tag” which triggers a cookie to collect information about your visits to the Site and to other websites, and they may use that information and share and combine it with other information with their partners to show you advertisements for goods and services you might be interested in on the Site and on other websites and apps, including by observing the kinds of products and subject-matter you are interested in and certain demographic information about you.

The following table sets out the different categories of cookies that the Askaloo Platform uses and why we use them. The lists of third party cookie providers are intended merely as illustrative not comprehensive:

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Social Media and Digital Advertising cookies and widgets

Mailgun: Email newsletters you elect to receive from us are transmitted through Mailgun. Mailgun uses pixel tag technology to determine whether an email has been opened. In addition, when you click on any link in an email newsletter or marketing message you have elected to receive, Mailgun recognizes that fact. This information is used in the aggregate to measure the rate at which emails are opened and various links are clicked, to measure user interests and traffic patterns, and to improve the content of the email newsletters and the services and features offered through the email newsletter and marketing messages. Because some of this information is linked to individual email addresses, it is personally identifiable. You can view Mailgun’s privacy policy at https://www.mailgun.com/privacy-policy/

Device Information. When you visit and interact with the Askaloo Platform or the Site, Askaloo may collect certain information automatically, including, but not limited to, the type of computer or mobile device you use, your mobile device’s unique device ID, the IP address of your computer or mobile device, your operating system, the type of Internet browser(s) you use, and information about the way you use the Askaloo Platform (“Device Information”). We may use Device Information to monitor the regions from which Users navigate the Site or the Askaloo Platform and for security and fraud prevention purposes. Tools with the goal of anonymizing certain Device Information (like the TOR network) are forbidden on the Askaloo Platform. While we respect your right to hide this information, we believe that doing so is in conflict with the spirit of our platform and our desire to host an open and honest marketplace. Use of such tools hampers the functionalities of the Askaloo Platform.

Identity Verification. We may collect personal information, such as your date of birth, taxpayer identification number, and address, to validate your identity or conduct background checks (“Identity Information”).

Financial Information. To help Creators set up a payment account and help Users make payments to Creators and pay fees, we may collect financial information, including name, address, credit card number, bank routing numbers, tax information, and any other payment information (“Financial Information”).

Location Information. When you visit the Askaloo Platform via a mobile application, we use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located in and display a location map to improve service for our Users. We will not share your current location obtained in this manner with other Users. If you do not want us to use your location for the purposes set forth above, you should turn off the location services for the mobile application located in your account settings or in your mobile phone settings and/or within the mobile application.

Public Areas. Your profile on the Askaloo Platform consists of information about you, and may include personal information, photographs, work history, skills, hourly pay rates, feedback/rating information, and other information, including your username (“Profile”). The information in your Profile may be visible to all Users and the general public subject to the privacy choices you make within your Profile. If you choose to post a Hangout or an Activity via the Askaloo Platform, the contents of such listing will be publicly viewable.

 

  5. Askaloo's Use of Personal Information

Askaloo uses Personal Information (including Identity Information and Financial Information) for the following purposes:

  • To operate and make available the Askaloo Platform. We use your data to connect you with other Users in order to enable the posting of, completion of, and payment for Activites;

  • For billing and fraud prevention, on the basis of our legitimate interests in ensuring a safe and secure environment in which Users and Creators can meet and conduct business;

  • To conduct identification, authentication, and background checks on Users, in order to advance our legitimate interests in ensuring the safety of our Users;

  • To analyze Site usage as necessary for our legitimate interest in improving the Askaloo Platform to grow our business;

  • To contact you and deliver (via email, SMS, push notifications, or otherwise) administrative notices, marketing notifications, offers and communications relevant to your use of the Askaloo Platform as necessary for our legitimate interests in proper communication and engagement with our Users and in promoting our business;

  • To provide you with customer support in order to fulfill our contracts with Users;

  • For internal market research, troubleshooting problems, and detecting and protecting against error, fraud or other criminal activity for our legitimate interests in ensuring a safe and secure environment in which Users can meet;

  • To assist Users in the resolution of complaints and disputes between them, as necessary for our legitimate interests in facilitating good relations among Users;

  • To enforce our Terms of Service in our legitimate interests in ensuring our rights are complied with; and,

  • As otherwise set forth in this Privacy Policy.

Advertising. Ads are a standard part of user experience on the Internet, and Askaloo believes that targeted advertising enhances this experience. Askaloo may use cookies and other technologies and personal information to place ads where they believe interested parties will see them. In addition to banner ads, Askaloo may advertise products, companies and events that we think might interest you through the email address you provide. Your choices regarding third party ads are set forth in the Choice/Opt-Out section below. Advertising and marketing is carried out as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.

Analytics and Market Research. Askaloo may analyze your information and web navigational data based on your interests, and may use the analysis from this information in a way that doesn’t reveal a name, email address or other "real-world" identity (“Market Analysis”) in order to market the Askaloo Platform, improve the likelihood of a sale to a group of potential Users, and increase the likelihood that a group's experience with the Askaloo Platform is relevant to its interests as a whole, as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.

Askaloo uses information to sell services to Users who express an interest in these services, through a poll for example, or to Users who can be presumed to have an interest based on results from our Market Analysis. We do this as necessary for our legitimate interests in providing an engaging and relevant experience, promoting our services, and growing our business.

  • Google Analytics: we use Google Analytics, a web analytics service. Google Analytics uses cookies to help Askaloo analyze how visitors use the Site. The information generated by the cookie about your use of the Site and the Askaloo Platform (including your IP address) will be transmitted to and stored by a Google server in the United States. Google uses this information for the purpose of evaluating your use of the Site, compiling reports on Site activity for Site operators, and providing Site operators with other services relating to Site activity and internet usage. You can prevent the storage of data relating to your use of the Site and created via the cookie (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

Financial Information. We use Financial Information solely as authorized by you in order to operate the Askaloo Platform and, in particular, to ensure that Creators are paid by Users. We do this as necessary for our legitimate interests in providing our platform and services. To keep your financial data secure, we do not store full credit card information on our servers. We have contracted with a third party to process your payment card information.

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  6. With Whom Does Askaloo Share Information?

We only share the information we collect about you as described in this Privacy Policy or as described at the time of collection or sharing, including as follows:

Third Party Agents. To operate the Askaloo Platform, including processing your transactions, we may share your information with our agents, representatives, contractors and service providers (“Agents”) so they can provide us with support services as follows:

  • Email origination,

  • Customer relationship management services,

  • Financial transaction fulfillment (in which we are currently supported by Stripe who process your information in accordance with their own privacy policy here: https://stripe.com/gb/privacy); and

  • To otherwise help us provide the Askaloo Platform, including all of the things described in the preceding section.

Third Party Partners. Some Askaloo content is "sponsored by" or "presented by" other companies. If you connect to the Askaloo Platform through a co-branded version of our Askaloo Platform through one of our third party service partners (“Partners”), or otherwise participate in one of our partner programs with such a Partner, we may share information about your use of the Askaloo Platform with that Partner in order to offer the integrated platform and to measure how the partnership performs. We may share your information with our Partners in order to receive additional information about you. We may also share your information with Partners to create offers that may be of interest to you. Please check such Partner’s privacy policy before revealing information about yourself. If you don't want these Partners to have your personal information, you can choose to not participate.

Other Users. Askaloo facilitates contact between Users and Creators and reserves the right to share a Creator´s contact information (e.g. phone number, or email and postal address) with a User and vice versa, or with their legal or other representative, in order to facilitate the resolution of a dispute related to or arising from an interaction between two or more Users of the platform. This exchange of information is a mandatory part of the Askaloo Platform.

Legal Obligations Askaloo may disclose personal information or User Generated Content, including location data or communication data, to a third party if required to do so by law or pursuant to a court order, warrant or subpoena. Askaloo reserves the right to disclose personal information from both private and public areas of the Site and the Askaloo Platform in the absence of a court order warrant or subpoena if we are given reason to believe, in our sole discretion, that someone is causing injury to or interfering with the rights of Users, the general public, or Askaloo or its partners, parents or affiliates.

It is our policy to provide notice to Users before producing their information in response to law enforcement requests unless (i) we are prohibited by law or court order from doing so, (ii) we have reason to believe the User’s account has been compromised such that the notice would go to the wrong person, or notice would otherwise be counterproductive or would create a risk to safety, or (iii) it is an emergency request and prior notice would be impractical (in which case we may provide notice after the fact).

Business Affiliates Finally, Askaloo reserves the right to transfer, sell and/or distribute all information collected through the Askaloo Platform to an affiliate, subsidiary, or third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets or stock. We will require the new entity to follow this Privacy Policy with respect to your personal information, as and to the extent required by applicable law.

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  7. Choice/Opt-Out

You may opt-out of receiving communications from us and our partners, remove your information from our database, choose to not receive future communications related to the Askaloo Platform, or cancel your account by logging on to the Site and clicking on the “Account” tab, or by contacting us at contacts.

During registration you choose whether to receive marketing correspondence from Askaloo. This information remains on your Profile where you can, at any point, easily edit it to indicate that you have changed your mind. After logging on, go to “Settings” and the “Notifications” tab to make your selections. We may occasionally contact you with information about special events, sales, activities, promotions, contests, submission opportunities and programs. You always have the option to ask Askaloo not to contact you with this information again.

If you receive unsolicited email from a Askaloo domain, please contact us at contacts.

 

  8. Askaloo's Information Retention Policy

We retain personal data for as long as you are a User in order to meet our contractual obligations to you, and for such longer period as may be in our legitimate interests and to comply with our legal obligations. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Your rights

You have the right under certain circumstances:

  • to be provided with a copy of your personal information held by us;

  • to request the rectification or erasure of your personal information held by us;

  • to request that we restrict the processing of your personal information (while we verify or investigate your concerns with this information, for example);

  • to object to the further processing of your personal information, including the right to object to marketing as mentioned in the Choice/Opt-Out section above; and

  • to request that your provided personal data be provided to you in a structured, commonly used and machine-readable format.

Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time. You can also change your marketing preferences at any time as described in the Choice/ Opt-Out section above.

You can exercise your rights by clicking the “Notifications” tab to make your selections, or by contacting us at contacts.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/dataprotection/bodies/authorities/index_en.html ). The Information Commissioner is the supervisory authority in the UK and can provide further information about your rights and our obligations in relation to your personal data, as well as deal with any complaints that you have about our processing of your personal data.

 

  9. User Generated Content

Creators who have provided Askaloo with any videotape, film, record, photograph, voice, or all related instrumental, musical, or other sound effects, hereby consent to our use of these materials as User Generated Content in accordance with Section 9 of the Terms of Service.

 

  10. Askaloo’s Security of Collected Information

Your Askaloo account is password-protected so that only you and authorized Askaloo staff have access to your account information. In order to maintain this protection, do not give your password to anyone. Also, if you share a computer, you should sign out of your Askaloo account and close the browser window before someone else logs on. This will help protect your information entered on public terminals from disclosure to third parties.

Askaloo takes reasonable precautions to ensure that your information is secure on its system by backing up data in separate backup drives and using public key access encryption and firewalls on both our main and backup servers. Askaloo has staff dedicated to maintaining this Privacy Policy and other privacy initiatives, periodically reviewing security, and making sure that every Askaloo employee is aware of our security practices. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Askaloo cannot guarantee the security of any information you transmit to us, and you do so at your own risk. While Askaloo will use commercially reasonable efforts to ensure the security of all credit card and all other Personal Information, we expressly disclaim any liability for any unauthorized access to or use of our secure servers and/or any and all Personal Information and/or Financial Information stored therein, and you agree to hold Askaloo harmless for any damages that may result therefrom. If you have any further questions on this issue, please refer to the Terms of Service.

Askaloo expressly disclaims any liability that may arise should any other individuals obtain the information you submit to the Askaloo Platform.
 

  11. How Can Users Update Their Information?

You can update your Personal Information at any time by logging in and clicking on the “Personal information” under the “Account” tab. There you can view, update and correct your account information.

Our databases automatically update any Personal Information you edit in your profile. Information transmitted through boards, chats, polls or through any other means remains in our databases and becomes the property of Askaloo upon submission.

 

  12. Notification of Changes

Askaloo's Privacy Policy are periodically reviewed and enhanced as necessary. This Privacy Policy might change as Askaloo updates and expands the Askaloo Platform. Askaloo will endeavor to notify you of any material changes by email. Askaloo also encourages you to review this Privacy Policy periodically. If you do not understand any of the terms or conditions of any of Askaloo's policies, feel free to contact us at terms.

 

  13. Contacting Us?

If you have any questions about this Privacy Policy, the practices of the Site, your dealings with the Adskaloo Platform, or if you have technical problems, you may contact us here.

Askaloo's staff will respond to all requests sent through mail or email from Users and parents of Users with questions about privacy or the types of personal information is stored on the Askaloo database, or requests to nullify such personal information.

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