Pollen Mobile Privacy Policy

Effective Date: January 31, 2022

Welcome to POLLEN Mobile—a unique decentralized, high speed, open source, data-only wireless network designed with privacy in mind, enabled by a crypto-economy that is owned and operated by its user community. This Privacy Notice explains how POLLEN Mobile, LLC (“POLLEN”, “we”, “us” or “our”) collects, uses, and discloses personal information in connection with our website, pollenmobile.io, and its associated webstore (“Site”).

This Privacy Notice is not a contract and does not create any legal rights or obligations.

Our Collection of Personal Information
Sometimes we collect personal information automatically when an individual interacts with our Site, and sometimes we collect personal information directly from an individual. At times, we may collect personal information about an individual from other sources and third parties, even before our first direct interaction.

Personal Information Individuals Provide

We collect the following personal information individuals provide in connection with our Site:

- Contact Information, including name, mailing address, email address, and communication preferences.
- Order Information, including name, email address, billing address, shipping address, products purchased, and payment information. Note we use third-party payment processors to process your payments. Because we use third-party payment processors, we do not directly receive or retain any personally identifiable financial information such as credit card numbers. Rather, all such information is provided directly to the third-party payment processor. The payment processor’s use of personal information is governed by their privacy notice. Please review each payment processor’s privacy notice to understand how they will manage or otherwise process personal information, including financial information.
- Event Information, including whether an individual is eligible to attend or did attend a POLLEN Mobile event.
- Mobile Network Interest Information, including actual or inferred interest in POLLEN Mobile and our associated products and services.
- Inquiry Information, including information provided in custom messages sent through our Site or provided directly to a member of the POLLEN Mobile team.

Where an individual chooses to contact us, we may need additional information to fulfill their request or respond to their inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request or the personal information we require fall outside the scope of this Privacy Notice. In that case, additional privacy disclosures will govern how we may process the information the individual provides at that time.

Personal Information Automatically Collected

As is true of most digital platforms, we and our third-party providers may also collect personal information from an individual’s device, browsing actions, and site usage patterns automatically when visiting or interacting with our Site, which may include:

- Log Data, such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Site, and any errors that may occur during the visit to our Site.
- Analytics Data, such as the electronic path taken to our Site, through our Site and when exiting our Site, as well as usage and activity on our Site.
- Location Data, such as general geographic location based on the log data we or our third-party providers collect.  

For more information about our and our third-party partners’ use of cookies and related technologies to collect information automatically, and any choices individuals may have in relation to its collection, please see the Cookies and Related Technologies section below.

Personal Information from Third Parties
We also obtain personal information from third parties, which we often combine with personal information we collect either automatically or directly from an individual. We may receive the same categories of personal information as described above from the following third parties:

- Webstore Partners: We rely on third-party partners to power our Site’s webstore. We will have access to certain personal information from those third-party partners, including contact information and order information, that are relevant to the products and services we offer through our Site.  
- Payment Processors: We use third-party payment processors to process payments on our Site’s webstore. Although we do not receive any personally identifiable financial information, we may receive limited personal information from payment processors to help operate our Site, including to confirm payment for a particular order has been received.
- Social Media: When an individual interacts with us through various social media networks, such as when someone communicates with us through Twitter, YouTube, Facebook, or TikTok, we may receive some information about the individual that they permit the social network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the social network. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
- Service Providers: Our service providers that perform services solely on our behalf, such as Site hosting providers and communications providers, collect personal information and often share some or all of this information with us.
- Publicly Available Sources: We collect personal information about individuals that we do not otherwise have, such as contact information or an individual’s interest in our Site and services, from publicly available sources. We may combine this information with the information we collect from an individual directly.

Our Use of Personal Information
We use personal information we collect to:
- Manage our organization and its day-to-day operations;
- Communicate with individuals, including via email and social media;
- Market our Site and services to individuals, including through in-person events, social media, email, and other online venues;
- Administer, improve, and personalize our Site, including by recognizing an individual and remembering their information when they return to our Site;
- Facilitate individual benefits and services, including customer support;
- Process and fulfill orders placed through our Site’s webstore, as well as to track order status;
- Identify and analyze how individuals use our Site;
- Conduct research and analytics on our user base and our Site;  
- Improve and customize our Site to address the needs and interests of our user base and other individuals we interact with;
- Test, enhance, update, and monitor the Site, or diagnose or fix technology problems;
- Help maintain the safety, security, and integrity of our property and Site, technology assets, and business;
- Defend, protect, or enforce our rights or applicable contracts and agreements;
- Prevent, investigate, or provide notice of fraud or unlawful or criminal activity; and
- Comply with legal obligations.

Our Disclosure of Personal Information
We disclose personal information in the following ways:

- Data Analytics Providers. We share information with data analytics providers who analyze statistics and trends relating to the usage of and activity relating to our Site. These data analytics providers produce reports and make suggestions for our Site and business strategy based on the personal information and other information analyzed.
- Webstore Partners: We rely on third-party partners to power our Site’s webstore. We may share personal information with these partners for purposes of operating the Site’s webstore. Please note we use Shopify to power our Site’s webstore. More information about how Shopify uses personal information is available here: https://www.shopify.com/legal/privacy.  
- Payment Processors: We share personal information with or direct users to provide personal information to payment processors who process payment for orders on our behalf.  
- Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, and administrative services.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.  

Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud;
- to protect the health and safety of us and others; or
- as otherwise required by applicable law.
- Otherwise with Consent or Direction: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction.

For example, with an individual’s consent or direction we may post their testimonial on our Site.

Cookies and Related Technologies

Use of Cookies and Individual Choice
We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, similar technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect personal information and use or disclose the personal information for the purposes described in the sections above. For example, our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to collect and view reports about the traffic on our Site. More information on the use of Google Analytics can be obtained by visiting Google’s privacy policy, and Google’s currently available opt-out options.

If an individual would prefer not to accept cookies, most browsers will allow an individual to: (i) change their browser settings to notify the individual when they receive a cookie, which lets the individual choose whether or not to accept it; (ii) disable existing cookies; or (iii) set their browser to automatically reject cookies. Please note that doing so may negatively impact the experience on our Site, as some features and offerings may not work properly or at all. Depending on the individual’s device and operating system, an individual may not be able to delete or block all cookies. In addition, if the individual wants to reject cookies across all browsers and devices, they will need to do so on each browser on each device they actively use.

Additional Choice Relating to Third-Party Advertising Cookies
Please note certain of our third-party providers may directly collect personal information about an individual’s online activities over time and across different websites when individuals use our Site for purposes of providing online behavioral or interest-based advertising services to third parties. We support the self-regulatory principles for online behavioral advertising (“Principles”) published by the Digital Advertising Alliance (“DAA”). These Principles allow individuals to exercise choice regarding the collection of information about their online activities over time and across third-party websites for online interest-based advertising purposes.
More information about the DAA Principles can be found at www.aboutads.info. If an individual wants to opt out of receiving online interest-based advertisements on their internet browser from advertisers and third parties that participate in the DAA program and the related Network Advertising Initiative (“NAI”) program and perform advertising-related services for us and our advertising partners, they can follow the instructions at www.aboutads.info/choices and http://www.networkadvertising.org/choices/ to place an opt-out cookie on their device indicating that they do not want to receive interest-based advertisements. Opt-out cookies only work on the internet browser and device they are downloaded onto. If an individual wants to opt out of interest-based advertisements across all browsers and devices, they will need to opt out on each browser on each device they actively use. If the individual deletes cookies on a device generally, they will need to opt out again.

To opt out of receiving online interest-based advertisements from advertisers and third parties that participate in the DAA program on mobile apps, an individual can follow the instructions at http://www.aboutads.info/appchoices. Please note that when an individual opts out of receiving interest-based advertisements, this does not mean the individual will no longer see advertisements from us on our Site or third-party websites. It means that the online ads that they do see from program participants should not be based on that individual’s interests. We are not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about individuals’ use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles and other program requirements.

Children’s Personal Information
Our Site is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 13. If an individual is under the age of 13, they should not use our Site or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that personal information.

Links to Third-Party Websites or Services
Our Site may include links to third-party websites, plug-ins, and applications. Except where we post, link to, or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.

Updates to This Privacy Notice
We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by prominent posting on our Site or through other appropriate means. All changes shall be effective from the date of publication unless otherwise provided.

Contact Us
If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please visit support.pollenmobile.io to submit an inquiry.