POKET Inc.

Privacy Policy​

 

Effective Date: February 10th, 2020

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

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About the POKET App

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The POKET App is provided by POKET and facilitates crowdsourcing points of interest and generates retail insights around these points of interest. POKET App users (each a “User”) input information about points of interest, including information about local merchants (“Merchants”), into the POKET App. POKET then uses this information to create verified and publicly searchable online maps of points of interest and related content for POKET’s partners, including aggregated information about Merchants (“Public Content”).

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The Information We Collect, How We Collect It and How We Use It

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Information About POKET App Users

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The personal information we collect about Users of the POKET App includes:

• User’s name and username, phone number, location, and banking or prepaid phone card information (to pay rewards); 

• 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

• Other information that a User may provide when the User communicates with us.

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We also collect the information that Users input into the POKET App regarding Merchants. Users are required to obtain a Merchant’s consent before inputting any Merchant information 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.  For more information see our Terms of Service.

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How We Collect and Use Your Data

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We collect the above-mentioned information using forms, user device information and online communication channels.

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When you send email or other communications to us, we may retain those communications in order to process your inquiries, respond to your requests and improve our services. When you access our services, our servers automatically record information that your Device sends whenever you use our App.

 

We use information about Users to:

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• provide and administer the POKET App; 

• reward Users for entering information into the POKET App;

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

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

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

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

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

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Information in relation to POKET Merchants

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The Merchant information that POKET App Users may input into the POKET App includes Merchant business name, Merchant business address, photo of Merchant business or proprietor, Merchant business phone number, and information about the categories of products sold and their price and availability.

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We use Merchant information to generate, evaluate, analyze and publish the Public Content.  We may also use the Public Content to generate insights and trends, including about where products are available for sale, at what price and in what quantity (“Merchant Insights”).  

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When We Disclose Your Information

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We make Merchant information publicly available online through our publication and distribution of Public Content.  We may also share Merchant Insights with third parties, such as consumer product goods manufacturers. 

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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.

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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.

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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.
 

Legal Basis for Processing 

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We process personal information with consent and shall obtain consent to individual matters, where any document deals with other matters. If we use this information in a manner different than the purpose for which it was collected, then we will ask for  consent prior to such use 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 must be express, through a clear affirmative action of the data subject, depending on the circumstances and the sensitivity of the personal information in question. We rely on Users to obtain consent from Merchants on our behalf. 

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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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Security and Retention

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POKET has implemented reasonable physical, organizational and technological security measures to safeguard the personal information in our custody or control. These include safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. While we regularly evaluate and test the effectiveness of those safeguards to ensure security of our processing of personal data., 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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Personal information is retained in accordance with our record retention policies.  Our record retention periods are established taking into account requirements of privacy laws, the purposes for which the information was collected, legal and regulatory requirements to retain the information for minimum periods, limitation periods for taking legal action, and our business purposes.

 

International Transfers

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POKET is based in Canada and POKET’s service providers are located in Canada, Nigeria and other jurisdictions.  POKET’s Users and Merchants 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 Merchants to allow Merchant information to be processed and stored outside the Merchant’s jurisdiction of residence. 

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Access, Correction and Other Rights

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Individual’s have the right to request access to, or correction of, their personal information in our custody or control. We may need to verify the individual’s identity before searching for or providing access to personal information. In some circumstances, we may not provide access to personal information, for example, if it contains the personal information of other persons, if it constitutes confidential commercial information, if it is protected by solicitor-client privilege, or if it is otherwise not properly the subject of an access request.

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Individuals may also have the right, in specified circumstances, to object to our use of personal information, to request the deletion of personal information or restrict its use, to request a copy of the information they have provided to us, or to lodge a complaint with the supervisory authority. 

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Violation of Privacy 

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Poket has put in place procedures to deal with any suspected personal data breach and will notify you of (i) any personal data breach; (ii) the steps we have taken to remedy the breach and(iii) the security measures we have applied to render your personal data unintelligible. 

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All suspected breach of personal data will be remedied within 1 (one) month from the date of the report of the breach.

 

If you know or suspect that a personal data breach has occurred, you should immediately contact the Poket team at contact@poketapp.com

 

Poket will not be responsible for any personal data breach which occurs as a result of:

a) an event which is beyond the control of Poket;

b) an act or threats of terrorism;

c) an act of God (such as, but not limited to fires, explosions, earthquakes, drought, tidal waves and floods) which compromises Poket’s data protection measures;

d) war, hostilities (whether war be declared or not), invasion, act of foreign enemies, mobilisation, requisition, or embargo; 

e) rebellion, revolution, insurrection, or military or usurped power, or civil war which compromises Poket’s data protection measures; 

f) the transfer of your personal data to a third party on your instructions; and

g) the use of your personal data by a third party designated by you.

 

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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Changes to This Policy

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This privacy policy is effective as of the Effective Date above.  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.

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