Thanks for using Punchpass or visiting one of our websites. We take your privacy extremely seriously, and we never sell lists, email addresses, or any customer/client data. This policy explains the what, how, and why of the information we collect when you visit one of our websites, or when you use our Services. It also explains the specific ways we use and disclose that information.
These definitions should help you understand this policy. When we say “we,” “us,” “our,” and “Punchpass,” we are referring to Trillo, Inc. d/b/a Punchpass, a State of Vermont S Corporation. We provide online platforms that you may use to market to, sell to, keep track of data related to, or stay in contact with others, related to your customers (the “Services”). When we say “client,” we are referring to the person or entity that is registered with us to use the Services. When we say “you,” we are referring either to a client or to some other person who visits any of our Websites. A “customer” is a person you contact through our Services, or a person who you might choose to contact at some point in the future through the use of our Services. In other words, a customer is anyone on your customer list or about whom you have given us information. “Personal Information” means any information that identifies or can be used to identify you or a customer, directly or indirectly, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information. A “customer list” is a list of customers and all associated information related to those customers (for example, email addresses).
4. Questions & Concerns
If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please contact us by email at firstname.lastname@example.org
5. Information We Collect
(c) Email information: When you send an email with the Services, we have and may access the data about and the information in your email.
(d) Information from your use of the Service: We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. This type of information helps us to improve our Services for both you and for all of our users.
(f) Web beacons: We use Web Beacons (which are small blocks of code; also called pixel tags) on our Websites and in our emails. When we send emails to clients, we may track behavior such as who opened the emails and who clicked the links. This allows us to measure the performance of email campaigns and to improve our features for specific segments of clients. To do this, we include single pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include Web Beacons in the emails we deliver for you. We use the data from those Web Beacons to understand what actions your customers took. Reports are also available to us when we send email to you, so we may collect and review that information.
(g) Information from other sources: From time to time we may obtain information about you or your customers from third party sources, such as public databases, social media platforms, third party data providers and our joint marketing partners. The information we receive depends on which services you authorize and any options that are available. We may also get information from third party services about individuals who are not yet our users (…but we hope will be!), which we may use, for example, for marketing and advertising purposes. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.
6. Use and Disclosure of Personal Information
We may use and disclose Personal Information only for the following purposes:
(a) To promote use of our services to you and others. For example, if we collect your Personal Information when you visit our Website and do not sign up for any of the Services, we may send you an email inviting you to sign up. If you use any of our Services and we think you might benefit from using another Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send. In addition, we may use information we collect in order to advertise our Services to you or suggest additional features of our Services that you might consider using. In addition, we may use your Personal Information to advertise our Services to potential or other users like you.
- To provide our Services–for example, to set up and maintain your account, backup and restore your content, and provide support for the Services.
- To further develop our Services–for example by adding new features;
- To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
- To send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.
- To bill and collect money owed to us by our clients. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use a third parties for secure credit card transaction processing, and we send billing information to them to process your orders and credit card payments.
- To communicate with our clients about their account and provide customer support.
- To monitor and protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Punchpass and others.
- To protect the rights and safety of our clients and third parties, as well as our own.
- To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
- To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
- To prosecute and defend a court, arbitration, or similar legal proceeding.
- To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- To provide, support, and improve the Services we offer. This includes our use of the data that our clients provide us in order to enable our clients to use the Services to communicate with their customers. This also includes, for example, aggregating information from your use of the Services or visit to our Websites and sharing this information with third parties to improve our Services. This might also include sharing your information or the information you provide us about your customers with third parties in order to provide and support our Services or to make certain features of the Services available to you. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this policy.
- To provide suggestions to you. This includes using data to suggest products or services that you may be interested in or that may be relevant to you or your customers. We may communicate with you about offers and promotions offered by Punchpass and others we think will be of interest to you, solicit your feedback, or keep you up to date on Punchpass and our products.
7. Data Collected for and by our Users
As you use our Services, you may import into our system Personal Information you have collected from your customers or other individuals. We have no direct relationship with your customers or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission for us to collect and process information about those individuals. We may transfer Personal Information of you or your customers to companies that help us promote, provide, or support our Services or the services of our clients (“Service Providers”). As part of our Services, we may use and incorporate into features information you have provided, we have collected from you, or we have collected about customers. We may share this information, including customer email addresses, with third parties in line with the approved uses in Section 6.
If you are a customer and no longer want to be contacted by one of our clients, please contact the client directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the client of your request.
We will retain Personal Information we process on behalf of our clients for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
8. Public Information and Third Party Websites
(a) Social media platforms and widgets. Our Websites include social media features. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
9. Third Parties
We may disclose Personal Information to the following types of third parties for the purposes described in this policy:
(a) Service Providers. Sometimes, we share your information with our third party Service Providers, who help us provide and support our Services. For example, if it is necessary to provide you something you have requested (like enable sales via Stripe), then we may share your and/or your customers’ Personal Information with a Service Provider for that purpose. Just like with the other third parties we work with, these third party Service Providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this policy. Examples of Service Providers include hosting services and content delivery services, and payment processors.
10. Contest and Sweepstakes
We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on our Websites or through social media (collectively “Our Promotions”). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion.
11. Content of Email Deliveries
When you send an email using our service, it bounces from server to server as it crosses the Internet. Along the way, server administrators can read what you send. Email was not built for confidential information. Please do not use Punchpass to send confidential information.
YOUR LISTS & Customer Information
12. Your customer lists
Your customer lists are stored on a secure Punchpass server. We do not, under any circumstances, sell your customer lists. If someone on your customer list complains or contacts us, we might then contact that person. We will alert you if we have any communication with any of your customers explaining why. Only authorized employees have access to view customer lists. You may export (download) your customer lists from Punchpass at any time.
We will use and disclose the information in your customer lists only for the reasons discussed in Sections 6-9. Punchpass will never market directly to your customers, or use any of the customer information you have uploaded, for marketing purposes.
13. Notice of Breach of Security
If a security breach causes an unauthorized intrusion into our system that materially affects you or people on your customer lists, then Punchpass will notify you as soon as possible and later report the action we took in response.
14. Safeguarding Your Information
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.
Our credit card processing vendor, Stripe, uses security measures to protect your information both during the transaction and after it is complete. Stripe.com is a PCI compliant payment processor. If you have any questions about the security of your Personal Information, you may contact us at email@example.com.
Punchpass accounts and customer logins require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Because the information in your customer lists is so sensitive, account passwords are encrypted, which means we cannot see your passwords. We cannot resend forgotten passwords, and can only provide you a link you can use to initiate the reset process.
15. We Operate in the United States
Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy, including offering a data processing addendum. By using our Websites, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this policy. Punchpass is exploring becoming Privacy Shield certified in order to certify our compliance with data transfer to the United States.
16. Accuracy and Retention of Data
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. We will retain your information for as long as your account is active or as long as needed to provide you with our Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.
We will give an individual, either you or a customer, access to any Personal Information we hold about them within 30 days of any request for that information. Individuals may request to access, correct, amend or delete information we hold about them by contacting us at firstname.lastname@example.org. Unless it is prohibited by law, we will remove any Personal Information about an individual, either you or a customer, from our servers at your or their request. Please note we will need to confirm your identity in order to access, update, or remove any information. There is no charge for an individual to access or update their Personal Information.