This privacy policy explains how Poket Inc. (“POKET”, “we”, “us” or “our) collects, uses, discloses and otherwise processes personal information in connection with our mobile applications (collectively the “POKET App” or the “App”) and website located at www.poketapp.com (the “Website”). As used in this privacy policy, “personal information” means information about an identifiable individual.

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About the Poket App 

POKET provides tools to help researchers and organizations (our “Clients”) crowdsource data for their projects. In doing so, we may collect personal information relating to Clients and their employees and representatives (“Client Data”). In connection with our Client’s use of our tools, we may also process and analyze personal information relating to our Client’s employees and representatives, including freelancers (“User Data”). We process User Data on behalf of our Clients as their service provider. Our Clients are accountable for the User Data that we process on their behalf. If you are a User participating in a project led by one of our Clients and have questions about how your User Data is handled, please contact the Client directly.

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Collection and Use of Information ​

The Client Data we collect includes: names username and password, contact information, payment information, and information about the Client’s project. 

The User Data we collect includes:

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• User’s name, username and password, e-maill address, phone number, location, and prepaid phone card information (for Client to send rewards); 

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• Information about a User’s activity in the POKET App, which may include when and where the User logs in from, what parts of the App the User uses and for how long, and User location (longitude and latitude); and

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• Other information that a User may provide when the User communicates with us 
  
  We also collect the information that Users input into the POKET App.  Users are required to obtain an individual’s consent before inputting any personal information about a third party into the POKET App.  If you fail to comply with this requirement, we may revoke your access to the POKET App and may terminate your ability to earn rewards. 

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We use Client Data and User Data to:

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• provide and administer the POKET App as requested;

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• determine suitability for our products and services; 

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• help Clients reward Users for entering information into the POKET App;

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• communicate with Users regarding the POKET App and other POKET services and respond to requests and inquiries;

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• develop, improve, and refine the POKET App and other POKET services; 

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• troubleshoot issues and measure the performance of the POKET App and other POKET services;

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• manage and administer our business, including to detect and prevent against error and fraud and enforce our agreements with Clients; and

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• otherwise with User consent or as permitted or required by law.

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Information Collected Automatically ​

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We collect the IP (Internet protocol) addresses of all visitors to our Website and other related information such as page requests, browser type, operating system and average time spent on our Website. We use this information to help us understand our Website activity and to improve our Website. 

 

When you use our App, we collect information regarding your device type, operating system and version, carrier provider, unique device identifier, language setting, and the date and time that the App accesses our servers. With your consent, we may also collect your location data. We use this information to help us understand the activity on our App and to monitor and improve our App.

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Our Website uses a technology called "cookies". A cookie is a tiny element of data that our Website sends to a user’s browser, which may then be stored on the user’s hard drive so that we can recognize the user when they return.  We use cookies to remember your preferences and to authenticate you. You may set your browser to notify you when you receive a cookie or to not accept certain cookies. However, if you decide not to accept cookies from our Website, you may not be able to take advantage of all of the Website features. 

We may use third party service providers like Google Analytics to collect information about your use of the Platform, such as the features used and time spent on the Platform, to help us better understand our users and improve our Platform. The information we gather is used in an aggregate, non-identifiable form. For information about the way information is processed in connection with Google Analytics please read the Google Analytics Policy here.

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Disclosure of Personal Information ​

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We may transfer personal information to service providers (including affiliates acting in this capacity) that provide services on our behalf such as data hosting and processing, marketing, analytics and payment processing. We require our service providers to use personal information only as necessary to perform the services we have hired them to provide. Some of these service providers may be located outside of Canada, including in Ireland, Singapore, South Africa, the United Kingdom, and the United States of America. While outside of Canada, personal information will be subject to applicable foreign laws, which may permit government and national security agencies to access your information in certain circumstances. 

 

We may also use and disclose personal information to parties connected with the proposed or actual financing, insuring, sale or other disposal of all or part of our business or assets, for purposes connected to evaluating and performing the transaction. Our successors and assigns may use and disclose personal information for the purposes described in this privacy policy.

 

We may disclose personal information in other circumstances with consent, to enforce our rights or agreements, to collect amounts owing to us, or where otherwise permitted or required by law.

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Our Clients will have access to User Data relating to their own projects. We are not responsible for our Client’s handling of User Data.  If you are a User and have questions about how your User Data is handled, please contact the applicable Client directly.

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De-Identified Data 

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We may use the information we collect, including Client Data, User Data and data collected automatically through tools such as cookies, to create de-identified data that cannot be associated with, or used to identify, a Client, or User.  We may use and share de-identified data with third parties in order to improve products or services, create new products or services and for research and marketing purposes.

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Legal Basis for Processing ​

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We process personal information with consent except where otherwise permitted or required by law.  For example, we may be permitted to collect, use or disclose personal information without consent in order to collect a debt owed, to comply with a subpoena or court order, or to comply with the rules of court regarding the production of records. Consent may be express or implied, depending on the circumstances and the sensitivity of the personal information in question. We rely on Clients and Users to obtain consent from third parties on our behalf.

 

Where personal information is processed with consent, individual’s may (subject to contractual and legal restrictions) refuse to provide consent, or choose to withdraw consent, to our processing of personal information by contacting us at contact@poketapp.com. Note that if an individual refuses consent, or withdraws consent, to certain processing of personal information, we may not be able to provide certain services.

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Third Party Sites​

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Our Platform may contain links to other websites that POKET does not own or operate. We provide links to third party websites as a convenience to the user.  These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

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We may offer you the opportunity to engage with POKET content on or through third-party social networking websites, plug-ins and applications. When you engage with us or our content on or through third-party social networking websites, plug-ins and applications, you may allow us to have access to certain information associated with your social media account (e.g., name, username, email address, profile picture, gender). We may use this information to personalize your experience on the Platform and on the third-party social networking websites, plug-ins and applications, and to provide you with other information you may request.

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Security of Personal Information 

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POKET has implemented reasonable physical, organizational and technological security measures to safeguard personal information. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. It should be noted, however, that absolute security is not possible and therefore we make no warranties as to the security of personal information.

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Retention of Personal Information 

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Personal information is maintained on our servers or those of our service providers and is accessible by authorized employees, representatives and agents who require access for the purposes identified in this Privacy Policy. We have personal information retention processes designed to retain personal information for no longer than necessary for the purposes for which such information was provided or to otherwise meet legal requirements.

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International Transfers

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POKET is based in Canada and POKET’s service providers are located in Canada, Ireland, Singapore, South Africa, the United Kingdom, and the United States of America. POKET’s Clients and Users may be located in other jurisdictions. By using the POKET App, Users acknowledge and agree that their personal information may be processed and stored outside of their jurisdiction of residence and agree to obtain consent from third parties to allow third party personal information to be processed and stored outside the Client’s jurisdiction of residence.

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Your Choices

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By providing us with personal information or otherwise using our services, you consent to the collection, use and disclosure of your personal information as described in this privacy policy.  If you provide us with personal information relating to a third party (for example, if you are a Client and you provide us with User Data) we will assume that you have obtained all necessary consents from the third party to provide their personal information to us for the purposes described in this privacy policy.

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You may unsubscribe from our promotional email communications at any time by using the unsubscribe feature included in those messages.  Please note that if you unsubscribe from our promotional email communications you may still receive transactional or business-related communications from us.

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You may withdraw your consent to our collection, use or disclosure of your personal information at any time, subject to contractual and legal restrictions, by writing to us as described below. Please note that if you withdraw your consent, we may not be able to provide some or all of our services to you.

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Access, Correction and Other Rights ​

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You may request access to or correction of your personal information in our custody or control, by writing to us as described below. You may also have the right, in specified circumstances, to object to our use of your personal information, to request the deletion of your personal information or restrict its use, to request a copy of the information you have provided to us to use for your own purposes, or to lodge a complaint with a supervisory authority. Your rights are subject to applicable legal restrictions and we may take appropriate steps to verify your identity before responding to your request. Please note that if you are an end user of one of our Clients, you must make all such requests directly to the applicable Client.

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Contact Us 

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To exercise any of the rights described above, or for questions or complaints about our personal information practices, please contact us contact@poketapp.com.

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Updates to Our Privacy Policy 

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This privacy policy is effective as of the Effective Date below.  POKET reserves the right to change this privacy policy at any time. We will take reasonable steps to advise you of any changes to this privacy policy, including by posting the revised policy in our App.  We recommend that you review this privacy policy from time to time to obtain the current version. You may contact us at the address, email address or telephone number above to obtain a current copy of this privacy policy.

 

Effective Date: April 13th, 2021

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