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Privacy

Effective Date: January 1, 2020

Pocketstop values your privacy and is dedicated to transparency in how we use your personal information. This Privacy Policy describes the types of personal information we collect, how we use it, and to whom and under what circumstances we may disclose it.

If you have any questions about this Policy, please feel free to email us at privacy@pocketstop.com or write to us at:

Pocketstop, LLC
5646 Milton St.
Suite 100LL
Dallas, TX 75206

We encourage you to check this page periodically, as we may update this Privacy Policy from time to time to reflect changes in our services or applicable law. If we change this Privacy Policy, we will post those changes here and revise the Effective Date accordingly.

This Privacy Policy is organized as follows:

  • Key concepts
  • Overview of Pocketstop’s services
  • Personal information that we collect
  • How your personal information is used
  • How your personal information is shared
  • How to manage your personal information
  • Data retention
  • Cookies and tracking technologies on the website
  • Information security
  • Links to third party websites

KEY CONCEPTS

Pocketstop collects personal information from two categories of individuals and uses that information in different ways and for different purposes. The first consists of customers (and potential customers) who purchase our products and services and with whom we have a direct commercial relationship – referred to in this Policy as “Customers”. The second category is composed of our Customers’ end users, the individuals with whom our Customers communicate using Pocketstop’s products and services – referred to as “End Users”.

This distinction is important because under many jurisdictions’ privacy laws, our data protection obligations vary depending on whether the personal information belongs to a Customer or an End User. For example, [while our services are not currently intended for use in the EU, under the GDPR we would qualify as a “controller” with respect to our Customers’ personal information and a “processor” with respect to that of our End Users. Similarly,] under the California Consumer Protection Act (CCPA) we qualify as a “service provider,” which means that we process personal information for defined business proposes on behalf of our Customers who qualify as a “business” under that legislation. Practically, this means that we only process personal information in order to fulfill the specific business purposes for which we have been retained, and that this commitment is embodied in our Terms of Use. It also means that requests by End Users to exercise their rights under the [GDPR and] CCPA should be directed to the appropriate Customer which acts as a [controller or] business with respect to their personal information.

OVERVIEW OF POCKETSTOP’S SERVICES

A brief explanation of Pocketstop’s services can help illustrate the difference between Customers and End Users. Pocketstop offers its Customers the following services: RedFlag, Straightxt, Wi-Fi Alive and M360.

RedFlag facilitates the distribution of a Customer’s non-commercial, informational, and/or emergency communications to End Users over varying communication channels including email, SMS and voice calls.

Straightxt uses short message codes to advertise or promote a Customer’s property, goods or services, including special events, contests or sweepstakes, or other types of campaigns via text messages. Only End Users that text the designated key word in response to a specific call to action receive promotional messaging.

Wi-Fi Alive serves a similar function as Straightxt, except that End Users agree to receive promotional messaging when registering to use a facility’s Wi-Fi service.

M360 combines the features of Straightxt and Wi-Fi Alive and adds additional communication channels including email.

For each of the services, Pockestop provides its Customers with a means to communicate with End Users. In facilitating this communication, Pocketstop receives and processes personal information relating to End Users as described below.

PERSONAL INFORMATION THAT WE COLLECT

In providing the Services, we collect certain Personal Information from our Customers and End Users.

From Customers (and potential Customers) we collect:

  • Information necessary to create an account such as email address, name, street address, organization affiliation if applicable, and password.
  • Billing information.
  • Login times, pages visited, and data imported and exported.
  • Communications relating to customer support or other inquiries.

On behalf of our Customers, from End Users we collect:

  • Contact information including name, email address, phone number, and street address.
  • Demographic information such as gender and date of birth. You may choose not to provide such personal information, but there may be some services where demographic information is required to function properly.
  • Technical information such as device information (e.g., model, software, unique identifiers), geographic location data, and usage data (e.g., dates and times of service use, response to promotional messages). We may associate this information to other information we have collected from and about End Users.

It is the Customer’s responsibility to ensure that its collection of End Users’ personal information complies with all applicable laws and regulations. We are not responsible for personal information which Customers import into our systems from other sources or for the privacy disclosures which Customers make available to their End Users.

HOW YOUR PERSONAL INFORMATION IS USED
We use the personal information provided by Customers and End Users to provide them with our services, which can include:

  • Delivering commercial and non-commercial messages over various media (e.g., SMS, email, and voice calls) to End Users on behalf of our Customers.
  • Processing payments.
  • Responding to inquiries, troubleshooting issues that arise in the services, and providing customer support.
  • Identifying usage trends and generating analytics data to help Customers improve the effectiveness of their communications.
  • For our business purposes, such as to help us develop new products, enhance our website, and improve our services.
  • Protecting the security and integrity of our services.

HOW YOUR PERSONAL INFORMATION IS SHARED

Pockestop will not rent, sell, or share your personal information with any other company for its own marketing purposes without your consent. To the extent analytics data is shared with multiple Customers, that data will be aggregated, and any identifying elements will be excluded.

We use third-party merchant services providers to assist with critical tasks such as data hosting and billing. These service providers may receive access to personal information. However, we require such service providers to enter into contractual agreements requiring them to handle personal information in a confidential manner, maintain adequate security, and only use personal information as needed to fulfill their specific business purpose.

Pocketstop may also share your personal information with other parties in the following circumstances:

  • If we determine that there has been a violation of Service policies.
  • If we have reason to believe that such disclosure is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference (either intentionally or unintentionally) with our rights or property, other users of the Service or anyone else that could be harmed by such activities.
  • To respond to judicial process and provide information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.
  • To provide information to a company that acquires, is acquired by or is merged with Pocketstop.

HOW TO MANAGE YOUR PERSONAL INFORMATION

Some Pocketstop services (such as RedFlag) may include a portal through which End Users can directly update or delete their personal information and control the types of communications they wish to receive.

Where such End User-facing portals are not included in the service, Customers have the ability to modify or delete personal information of End Users when so instructed in their administrator accounts. Customers are responsible for responding to privacy-related inquiries and requests from End Users.

Customers who wish to delete their own personal information from Pocketstop system may do from the appropriate panel in their administrator account or contact us for assistance.

You may choose to stop receiving promotional messages and newsletters from us our or Customers at any time by following the instructions included in all SMS and email communications. If you have questions or are experiencing problems unsubscribing, please contact us at support@pocketstop.com

DATA RETENTION
Pocketstop will retain Customer personal information for as long as your account is active or as needed to provide you with the services; to maintain a record of your transactions for financial reporting, audit, and compliance purposes; and to comply with Pocketstop’s legal obligations, resolve disputes, enforce its agreements, and as otherwise permitted by applicable law.

Pocketstop will retain End User personal information for as long as the account of the responsible Customer remains active and the Customer does not itself delete such information. Upon the termination of a Customer’s account, Pocketstop will delete the associated End User personal information within 30 days.

COOKIES AND TRACKING TECHNOLOGIES ON THE WEBSITE

The Pocketstop website uses cookies and web beacons to provide enhanced functionality (e.g., user ID and password prompts and various other user experience enhancements). These cookies may be delivered in a first-party or third-party context. We may also use web beacons in association with e-mails delivered by us on behalf of our clients. Web beacons are used to report information about e-mail opens, link clicks and various other campaign data. The website may also capture limited information (user-agent, HTTP referrer, last URL requested by the user, client-side and server-side clickstream) about visits to the website; we use this information to analyze general traffic patterns and to perform routine system maintenance.

We do not track visitors to our website over time and across third party websites to provide targeted advertising, and the website does not respond to all Do Not Track (DNT) signals.

The website also uses Google Analytics and/or other tracking and web analytics services provided by Google, Inc. (“Google”). Google uses cookies to help analyze how visitors use the website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google. Google will use this information for the purpose of evaluating your use of the website, compiling reports on the activity on the website for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of the website.

INFORMATION SECURITY
We utilize reasonable administrative, physical, and technical safeguards to protect the confidentiality, integrity, and availability of the information that we collect, receive, store, and transmit. However, no method of transmission over the Internet or method of electronic storage is 100% secure; therefore, we cannot guarantee its absolute security. While we work hard to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent “hackers” or other unauthorized persons from illegally accessing or obtaining information.

You are responsible for maintaining the confidentiality of any username and password you maintain in connection with our services. To help protect against unauthorized or improper use, make sure that you log out at the end of each session. If you share your username or password with others, they may be able to obtain access to your personal information at your own risk. If you believe that your username or password have been compromised, you should immediately change your password and contact support. We reserve the right to automatically lock accounts that suspend accounts that have attempted to log in multiple time with invalid passwords. Please contact support if you suspect this has happened.

LINKS TO THIRD PARTY WEBSITES

We are not responsible for the privacy practices employed by websites linked to or from our website or in communications from our Customers, nor the information or content contained in such websites, nor any third party’s use of such information. Please remember that when you use a link to go from the Pocketstop website or a message delivered by Pocketstop to another website, this Policy is no longer in effect. Your browsing and interaction on any other website are subject to that website’s rules, terms and conditions, and/or policies.

CONTACT US

If you have questions about this Privacy Policy, you can contact us at:

Pocketstop
5646 Milton St.
Suite 100LL
Dallas, TX 75206

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