Privacy policy

Last Updated November 30, 2023

INTRODUCTION.

Welcome to Pago Forward, Inc., doing business as Pago ("we," "us," or "our"). This Privacy Policy governs the collection, use, and protection of information obtained from individuals ("users" or "you") who visit our website, www.pagocommunity.com (the "Website"). This Privacy Policy outlines the types of information we collect, how we use and store that information, and your rights regarding your personal data. By accessing or using our Website, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.

We are committed to respecting your privacy and protecting your personal information. We understand the importance of maintaining the confidentiality and security of your data. This Privacy Policy explains our practices for handling your information and describes how we collect, process, store, and disclose your data. We comply with applicable privacy laws and regulations to ensure that your information is handled in a responsible and lawful manner.

Please review this Privacy Policy carefully. By using our Website, you consent to the collection and use of your information as described herein. If you do not agree with the practices outlined in this Privacy Policy, please do not access or use our Website.

By continuing to use our Website, you signify your acceptance of this Privacy Policy and your consent to the collection, use, storage, and disclosure of your information in accordance with this Privacy Policy and applicable laws and regulations. If you have any questions or concerns about this Privacy Policy, please contact us using the information provided in the "Contact Us" section below.

We may modify or update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Any changes will be effective upon posting of the updated Privacy Policy on our Website. We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.

INFORMATION COLLECTION.

At Pago Forward, Inc., we place paramount importance on understanding and transparently conveying the nature and scope of our information collection practices. We gather diverse categories of personal data to facilitate and enhance your experience on our Website and services. This encompasses, but is not limited to:

  • Identifying Data: Full name and email address, which form the crux of your user identity on our platform. We also collect shipping address and phone number to pass along to our partner’s fulfillment team so they are able to deliver goods directly to the receiver’s residence.
  • Demographic Data: Date of birth, gender, city, state, and country, offering insights that allow us to tailor our platform to cater to our user base efficiently.
  • Transactional Data: Tokenized credit card information necessary to execute and validate transactions made on our platform.

We underscore the need for accuracy and relevancy in the data we collect. Our endeavor remains to gather only that information which directly pertains to and enriches your user experience, ensuring optimal service delivery while respecting your privacy.

METHODS OF COLLECTION.

In our commitment to maintaining transparency and fostering trust, we believe it is essential to elucidate the methodologies employed in sourcing your information. Our collection strategies have been designed to be non-intrusive, efficient, and in alignment with best industry practices.

User Submissions: At various junctures, you may be prompted or choose to provide specific data:

  • Account Creation: During the registration process, we collect foundational information to establish your unique user identity.
  • Profile Customization: As you personalize your profile or add details, we store this information to refine your user experience and offer more tailored services.
  • Feedback and Queries: Should you reach out with inquiries, feedback, or concerns, we might retain parts of this communication for quality assurance and continuous improvement.

Systematic Data Collection: Leveraging cutting-edge technology, we obtain data seamlessly as you interact with our platform:

  • Activity Logging: This refers to the recording of actions, behaviors, and interactions you undertake while using our Website, enabling us to enhance site navigation, user interface, and overall user experience.
  • Analytic Tools and Cookies: We deploy analytic cookies that track user activities, garnering insights into user preferences, browsing patterns, and areas of interest. Such analytics assist us in strategic decision-making and continuous improvement.

Collaborative Third-Party Gathering: Collaborations with trusted external entities play a pivotal role in our service offerings. These entities operate under stringent data protection guidelines:

  • Payment Processors: To guarantee secure and efficient transactions, we liaise with esteemed payment processors who, during their operations, might share pertinent, non-sensitive transactional data with us.
  • Integration Partners: Occasionally, third-party tools or plugins that integrate with our Website may transfer data to us, always within the bounds of user permissions and consents.

It's worth noting that all methods of collection are pursued with the overarching intent of advancing the quality, security, and richness of your user experience, while diligently upholding your privacy rights.

PURPOSE OF COLLECTION.

At Pago Forward, Inc., our commitment to transparency compels us to clarify the rationale behind our data collection endeavors. We ensure that every fragment of data we gather serves an intentional and justifiable purpose, designed to both amplify the capabilities of our platform and enrich the user experience.

Service Provision & Optimization: Central to our operations is the facilitation of user accounts and tailored recommendations. The data we collect is instrumental in ensuring transactions are processed efficiently and aids in the continuous optimization of our platform's features.

User Support & Engagement: We're dedicated to maintaining an intimate connection with our user base. By collecting specific data points, we're better equipped to address inquiries, understand user preferences, and foster genuine interactions, especially between Givers and Receivers.

Security & Integrity: Upholding the sanctity of our platform is paramount. Data collection plays a pivotal role in fortifying against fraudulent activities, ensuring our community interactions remain genuine, and embedding robust authentication mechanisms.

Strategic Development & Innovation: As we aspire to redefine digital philanthropy, data insights shape our trajectory. Understanding platform usage trends guides our strategic decisions, empowers feature enhancements, and ensures our offerings resonate with the evolving needs of our community.

Regulatory & Legal Compliance: Ensuring our platform's adherence to legal standards is nonnegotiable. Data collection aids in our commitment to regulatory compliance, facilitates necessary audits, and positions us to enforce our legal rights when indispensable.

INFORMATION SHARING.

In the pursuit of our mission at Pago Forward, Inc., there are instances where we might share certain pieces of information with external entities. Our approach to such sharing is grounded in prudence, transparency, and a stringent commitment to safeguarding the privacy and security of our users' data.

Selective Sharing: We never engage in the arbitrary or frivolous dissemination of your data. Information is shared exclusively when necessary to facilitate our platform's core functionalities, enhance user experience, or comply with legal mandates.

Operational Necessities: Our collaboration with strategic partners and service providers allows us to offer an elevated platform experience. For instance, our trusted payment processors require select data to ensure secure and seamless transaction processing. Likewise, our IT Operations team, dedicated to the maintenance and optimization of our platform, may access certain data strictly for operational reasons.

Regulatory Compliance & Legal Proceedings: There are circumstances, albeit rare, where we might be legally obligated to disclose certain information. This could be in response to a court order, subpoena, or similar legal process, or when we believe in good faith that disclosure is essential to protect our rights, safeguard your safety or the safety of others, investigate fraud, or respond to a government request.

User Consent: Outside of the aforementioned scenarios, should there arise a situation necessitating the sharing of your data, we pledge to seek explicit user consent. We value and respect your agency in decisions concerning your personal information.

No Sale of Data: In line with our commitment to your privacy and trust, we categorically affirm that we do not sell, rent, or trade user information. Any information shared is purely in the service of our operational and legal obligations, always with the intent of preserving the integrity of user data.

STORAGE AND SECURITY.

Ensuring its safekeeping and the preservation of its integrity is not just a technical imperative, but a moral one. As such, we've implemented a comprehensive matrix of measures and protocols designed to meticulously safeguard your data.

Storage Infrastructure: All collected data resides within a secure cloud infrastructure, endowed with state-of-the-art encryption mechanisms. By leveraging leading hosting platforms, we ensure that your data enjoys a robust layer of protection against unauthorized access and potential breaches.

Data Encryption: Both in transit and at rest, your data undergoes rigorous encryption. This method ensures that even in the unlikely event of a breach, the intercepted data remains unintelligible and of no value to malicious entities.

Payment Security: In our commitment to financial integrity, all payment-related data is tokenized before processing. The actual payment details are securely stored within trusted payment gateways, beyond our direct access, ensuring an added layer of protection against potential vulnerabilities.

Routine Audits & Updates: We continuously assess and bolster our security infrastructure. Regular audits, vulnerability assessments, and penetration testing form an integral part of our security regime. Furthermore, timely updates and patches are applied to ensure that our defenses remain impregnable against emerging threats.

Limited Access: Access to user data within our organization is highly compartmentalized. Only personnel with a legitimate operational need—and under strict confidentiality obligations—are granted access. This policy minimizes potential points of exposure.

RETENTION OF INFORMATION.

We retain your information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The specific retention period for each type of information may vary based on the purpose of collection, legal requirements, and business needs.

We will retain your personal information for the duration of our business relationship and as long as necessary to provide you with our services. Once the purpose for which the information was collected is fulfilled, we will securely delete or anonymize your personal information, unless otherwise required by applicable laws and regulations.

Please note that even if you request the deletion of your personal information through our settings page or by sending us a direct message, we will disassociate your name and profile from any acts of kindness recorded on our platform, rendering them as attributed to "Anonymous." This allows us to maintain our indexing for analytics. However, the original association remains in our records. If you wish to completely delete this association, please reach out to us directly via email. Keep in mind, even with this extended deletion, we may still need to retain certain information as required by law or for legitimate business purposes, such as record-keeping, resolving disputes, enforcing our agreements, or complying with legal obligations.

We regularly review our data retention practices and implement appropriate measures to ensure that your personal information is not kept longer than necessary. If you have any questions regarding our data retention practices or wish to request the deletion of your personal information, please contact us using the information provided in the "Contact Us" section below.

DATA BREACH NOTIFICATION.

In the event of a data breach that compromises the security of your personal information, we are committed to taking prompt action to mitigate the impact and notify you in accordance with applicable data protection laws and regulations. We have implemented security measures to protect your information; however, no system is entirely immune to unauthorized access, and breaches may occur despite our best efforts.

If we become aware of a data breach that is likely to result in a high risk to your rights and freedoms, we will promptly assess the situation and take appropriate steps to address the breach. This includes, but is not limited to, the following:

  • Investigation and Remediation: We will conduct a thorough investigation to determine the scope and impact of the data breach. We will take immediate steps to contain the breach and prevent any further unauthorized access.
  • Notification to Affected Individuals: If we determine that the breach poses a significant risk to your rights and freedoms, we will notify you without undue delay. We will provide you with information about the nature of the breach, the types of information that may have been compromised, and any recommended actions you can take to protect yourself.
  • Notification to Authorities: In certain circumstances, we may be required by law to report the breach to relevant supervisory authorities. We will fulfill any legal obligations regarding data breach notification, including providing the necessary information to the authorities as required by applicable laws and regulations.

Please note that the method of notification may vary depending on the circumstances and legal requirements. We may use reasonable means to notify you, including email, postal mail, telephone, or prominent announcements on our Website.

DO NOT TRACK SIGNALS.

Our Website currently does not respond to "Do Not Track" (DNT) signals from web browsers. DNT is a privacy preference that you can set in your web browser to indicate your preference regarding the tracking of your online activities.

While many web browsers support the DNT feature, there is no standard interpretation or industry consensus regarding the meaning of DNT signals. As a result, our Website does not currently recognize or respond to DNT signals.

However, we respect your privacy preferences, and you have the ability to control the use of cookies and tracking technologies as described in our "Cookies " provision. For more information on how to manage your cookie preferences, please refer to that provision.

Please note that even if you have enabled the DNT feature in your web browser, certain thirdparty services integrated into our Website may still collect and track your online activities in accordance with their own privacy policies. We encourage you to review the privacy policies of these third-party services for more information on their tracking practices.

THIRD-PARTY LINKS.

Our Website may contain links to third-party websites or services that are not operated or controlled by us. These third-party links are provided for your convenience and reference only. Please note that we have no control over the content, policies, or practices of these third-party websites or services.

By clicking on these third-party links, you acknowledge and agree that we are not responsible for the privacy practices or the content of such websites or services. This Privacy Policy applies solely to the information collected by our Website. We encourage you to read the privacy policies of any third-party websites you visit to understand their data collection, use, and disclosure practices.

While we strive to include only reputable and trusted third-party links on our Website, we cannot guarantee the accuracy, completeness, or quality of the information, products, or services provided on these external sites. The inclusion of any third-party link on our Website does not imply our endorsement, sponsorship, or recommendation of the linked website or its content.

Please be aware that when you leave our Website and access a third-party website, your interactions and any information you provide are subject to the terms and policies of that website. We encourage you to exercise caution and review the privacy policies of any website you visit.

THIRD-PARTY SERVICES.

Pago Forward, Inc. recognizes that in today's interconnected digital realm, the services we provide are occasionally augmented and enhanced through partnerships and collaborations with third-party entities. While we meticulously curate these relationships to bring you an enriched platform experience, it's imperative that our users remain informed and discerning about these external interactions.

Careful Selection: Each third-party service provider we engage with is selected after a rigorous vetting process. Our criteria are not just limited to their service capabilities but also extend to their adherence to privacy standards, ensuring an alignment with our own stringent principles.

Data Exchange: Interactions with these third-party services might necessitate limited data exchanges to facilitate certain functionalities. However, such exchanges are conducted securely and are restricted to only the essential data required for the specific service in question.

Sovereign Policies: It's crucial to understand that these external entities operate under their own privacy policies and terms of service. While we endeavor to collaborate with entities that uphold similar privacy values, Pago Forward, Inc. cannot be held accountable for the independent actions, policies, or data handling practices of these third-party services.

User Interaction: There may be instances where you, as a user, directly interact with a third-party platform, such as through payment gateways. In such scenarios, we urge users to exercise caution and familiarize themselves with the privacy practices of these third-party platforms before sharing any personal information.

No Implied Endorsement: The integration or mention of a third-party service within our platform should not be construed as an endorsement of their entire suite of services or their privacy practices. It is simply an acknowledgment of their specific service that complements our offerings.

Continuous Monitoring: Our commitment to user privacy and data security doesn't end once a partnership is forged. We consistently monitor our relationships with third-party service providers, ensuring they continue to meet our elevated standards.

USER RIGHTS.

As stewards of your data, we are dedicated to upholding and facilitating the exercise of the rights you possess regarding your information. Below, we elucidate these rights and provide guidance on how they can be exercised:

  • Right to Access: Every user has the unequivocal right to request access to their personal information that we hold. Upon a verified request, we will provide a comprehensive report detailing the data we possess, its origin, and its uses.
  • Right to Rectification: Should you discern inaccuracies or omissions in the information we hold about you, we invite you to notify us. We will promptly rectify or supplement the data to ensure its accuracy and completeness.
  • Right to Erasure: Also known as the 'Right to Be Forgotten,' users can request the deletion of their personal information from our databases. Upon verification and unless mandated otherwise by legal obligations, we will expunge your data in its entirety.
  • Right to Restriction: Users have the right to restrict the processing of their personal data under specific circumstances, such as disputing its accuracy or objecting to its processing based on our legitimate interests.
  • Right to Portability: We recognize your right to obtain and reuse your personal data across different services. Upon request, we will supply your data in a structured, commonly used, and machine-readable format, enabling its seamless transfer.
  • Right to Object: You have the prerogative to object to the processing of your personal information based on our legitimate interests, direct marketing, or research purposes, unless we demonstrate compelling legitimate grounds that override those interests.
  • Right to Withdraw Consent: In instances where data processing hinges on your explicit consent, you retain the right to withdraw this consent at any point. Withdrawal will not affect the lawfulness of any processing carried out before your withdrawal.

Exercising Your Rights: To invoke any of the aforementioned rights, kindly reach out to our dedicated data protection contact detailed in the "Contact Us" section. We vow to address your request with the urgency, respect, and thoroughness it deserves, aiming for a resolution within 30 days of receipt. There may be situations where we are legally obliged to retain or process your data, in which case we will elucidate the specifics to you.

SELLING OF USER DATA.

We want to assure you that we do not sell your personal information to third parties for their direct marketing purposes. Your privacy is important to us, and we are committed to protecting the confidentiality and integrity of your information.

We do not engage in the sale, trade, or rent of your personal data to any third parties unless we have obtained your explicit consent or are required to do so by law.

COOKIES.

One of the tools we employ to achieve this objective is the use of cookies, which, while omnipresent in today's online landscape, merits a clear and comprehensive elucidation.

Definition and Purpose: Cookies are diminutive text files placed on your device when you visit our Website. Their function is manifold: they facilitate improved user experience, enable certain functionalities, and help us understand user behavior, thereby allowing us to refine and tailor our offerings.

Type of Cookies Deployed: Pago Forward, Inc. employs analytical cookies. These are designed to gather aggregate, non-personal data about user interactions, aiding us in discerning patterns, preferences, and areas of improvement.

Consent Mechanism: Upon your inaugural visit to our Website, a conspicuous notification will be presented, elucidating our use of cookies and soliciting your informed consent. Users have the liberty to accept or decline. It is pertinent to note that while declining won't impede your access, it might marginally diminish the optimality of your browsing experience.

Management and Control: Modern browsers offer users a range of controls concerning cookies, from viewing extant cookies, purging them, to defining preferences for their future deployment. We encourage our users to familiarize themselves with these controls, ensuring they navigate our Website in a manner most congruent with their comfort and preferences.

Third-Party Cookies: At times, our affiliations or integrations might lead to third-party cookies being placed on your device. While we ensure that such entities share our respect for user privacy, it is imperative to recognize that their cookies operate under their distinct policies. We recommend perusing their respective privacy policies for a comprehensive understanding.

Privacy Implications: Our use of cookies is sculpted by our unwavering commitment to privacy. The analytical cookies we deploy are devoid of personally identifiable information, ensuring that your anonymity remains uncompromised.

Updates and Revisions: The dynamic nature of technology and regulations might necessitate periodic modifications to this provision. Any substantial alterations to our cookie policy will be promptly communicated to our users.

MODIFICATION.

We reserve the right to modify or update this Privacy Policy at any time. Any changes we make will be effective immediately upon posting the revised Privacy Policy on our Website. We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your information.

If we make material changes to this Privacy Policy, we will provide notice through a prominent notice on our Website or by sending you an email notification. By continuing to use our Website after any changes to this Privacy Policy, you acknowledge and agree to the updated terms.

It is your responsibility to review this Privacy Policy periodically and ensure that you are aware of any modifications. If you disagree with any changes, you should discontinue your use of our Website and contact us if you would like to request the deletion of your personal information.

Please note that any provision of this Privacy Policy that imposes an obligation on you or grants us a right will survive the termination or expiration of this Privacy Policy or your use of our Website.

CHILDREN'S INFORMATION.

Our services are not intended for individuals under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13. If you believe that a child under the age of 13 has provided us with personal information without parental consent, please contact us immediately using the information provided in the "Contact Us" section below.

If we become aware that we have collected personal information from a child under the age of 13without parental consent, we will take prompt steps to delete that information from our records. We strongly encourage parents or guardians to monitor the online activities of their children and participate in their online experience to ensure compliance with applicable laws and regulations.

CONTACT US.

If you have any questions, concerns, or requests regarding this Privacy Policy, or if you need to contact us for any reason related to your personal information, please use the following contact information:

Email: [email protected] arrow-right-top.svg

We will make reasonable efforts to respond to your inquiries and address any concerns promptly. Please provide us with sufficient information to allow us to identify and respond to your request effectively.

If you wish to exercise your rights regarding your personal information, such as accessing, correcting, or deleting your information, please include the necessary details in your request, and we will handle it in accordance with applicable data protection laws and regulations.

Please note that while we strive to protect your personal information, communications via email or other electronic means may not be secure. Therefore, we recommend that you do not include sensitive or confidential information in your communications with us.