Privacy Policy

PORTERS PRIVACY POLICY

Last Updated: February 25, 2023

Porters ("Porters", "we", "our", or "us") provides this Privacy Policy to inform you ("you" or "your") how we gather and use, and the circumstances under which we may disclose, information we collect from our users and members through our website with a homepage available at www.porters.io (the "Site") and other related software, interactive features, and/or services operated by us that post a link to this Privacy Policy (collectively, the "Service"). This Privacy Policy does not apply to our information collection activities outside of the Service (unless otherwise stated below or at the time of collection). By using the Service, you agree to our Terms of Service, and to our collection, use and disclosure practices, and other activities as described in this Privacy Policy. If you do not agree and consent, discontinue use of the Service or visit the Site.

COLLECTION OF INFORMATION

Personal Information

As part of your use of our Service, we may ask you to provide information directly to us. For example, we collect information when you register an account, communicate or transact with us, or submit feedback on certain products, by way of surveys, testimonials, ratings and reviews or other format through the Service.

The information we collect may include information that identifies you personally (whether alone or in combination), such as your name, address, phone number, email address, age, and gender ("Personal Information"). In some cases, we may collect information that you provide about others, including Personal Information, such as when you refer a friend. We will use the information you provide to fulfill your requests, such as sending information about our Service to your friend’s email address. By using this functionality, you acknowledge and agree that both you and your friend are based in the United States and that you have your friend’s consent for us to use his or her contact information to fulfill your request.

We may collect, use, transfer, and disclose information that has been "de-identified" for any purpose. Personal Information once de-identified is not subject to this Privacy Policy and we and our service providers may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.

Information Collected Automatically

When you access our Site or Service, we and our third-party service providers may use a variety of technologies, now and hereafter devised, that automatically record certain usage information about you ("Usage Information"). Usage Information may include your Internet Protocol address (and other unique identifiers for the particular device you use to access the Internet), browser type, your web or application request, your interaction with our Site/Service, the webpage or other feature you were using before you came to our Service, pages of our websites that you visit, information you search for via our Service, access times and dates, and other similar information. We use this information for a variety of purposes, including analyzing and enhancing our products and services, and to help personalize our Service for you. Your Internet Protocol Address and other items automatically collected may be considered Personal Information.

The methods that may be used on the Service to collect Usage Information may include:

Log Information: Log information is data about your use of the Service, such as IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps, and related data, which is stored in log files.

Information Collected by Tracking Technologies: We and third-party service providers may automatically collect information about your interactions with the Service or emails using various tracking technologies, including cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, device fingerprinting, in-app tracking methods, and other tracking technologies now and hereafter developed ( "Tracking Technologies" ).

Cookies: A cookie is a small data file transferred to your computer (or other device) when it is used to access our Service. Cookies may be used for many purposes, including to enable certain features of our Service, to better understand how you interact with our Service and to monitor aggregate usage by visitors and online traffic routing. Cookies may remain on your device for extended periods of time.

Web Beacons (“Tracking Pixels”): Web beacons are small graphic images, also known as "internet tags" or "clear gifs," embedded in web pages and email messages. Web beacons may be used to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.

Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Service, and deleted or deactivated thereafter.

Location-identifying Technologies: GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location. Device Fingerprinting: Device fingerprinting is the process of analyzing and combining sets of information elements from your device’s browser, such as JavaScript objects and installed fonts, in order to create a “fingerprint” of your device and uniquely identify your device and applications.

In-App Tracking Methods: There are a variety of tracking technologies that may be included in mobile apps, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps.

Some information about your use of the Site, Service and certain Third Party Services (defined below) may be collected using Tracking Technologies across time and services and used by us and third parties for purposes such as to associate different devices you use, and deliver relevant ads and/or other content to you on the Service and certain Third Party Services.

Information from Other Sources

We may obtain information about you from other sources, including service providers and third parties, and combine such information with information we have collected about you. To the extent we combine such third party sourced information with Personal Information we have collected about you on the Service, we will treat the combined information as Personal Information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.

USE OF INFORMATION

We may use your information, including Personal Information, either alone or in combination with other information, for any purposes consistent with our statements under this Privacy Policy, including so that we can provide, enhance and personalize our Service and related content, products, offers, and marketing efforts.

The following is a non-exhaustive list of ways that we may use your information:

to manage our Service, identify you as a user of the Service, and help authenticate any account you create with us; to communicate with you regarding campaigns, the Service, updates, offers, promotions or events and to deliver information to you (for information about how to manage these communications and marketing efforts); to help us develop, customize, deliver, support and improve our Site or Service and any related products, , and advertising and to provide you with the best user experience possible; provide customer service; to send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages; for our internal purposes (such as auditing, data analysis, and research to improve our services, and communications); and for any other purpose as may be disclosed to you at the point of collection or otherwise with your consent.

SHARING OF INFORMATION

Except as described in this Privacy Policy, we will not share your Personal Information with other companies or individuals outside of Porters and its affiliates, unless we have received your consent. We may share your information as follows:

With Our Service Providers

We may engage third parties to perform services on our behalf, such as hosting and storage services, software maintenance services, email notifications, database management, analytics, fulfilment services, and other services. These third parties may have access to your Personal Information to perform certain tasks on our behalf but they are not authorized by us to otherwise use or disclose your Personal Information.

With Our Brand Partners

If you choose to submit any information or materials to us including, without limitation, testimonials, ratings and reviews, product feedback, data files, written text, computer software, music, audio files or other sounds, photographs, videos, and other images) (collectively, “Content”), we may share the Personal Information you include in that Content, if any, with our brand partners.

To Comply with Laws, Legal Process and Authorities and Protect Rights

We may disclose Personal Information or other information about you to government or law enforcement officials, in connection with subpoenas or judicial process, or to any other third party to protect the property and rights of us or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable.

For Business Transfers

We reserve the right to transfer or otherwise disclose your information, including Personal Information, in connection with a merger, acquisition, or other change in control, joint venture, reorganization or sale of assets or in the event of bankruptcy or liquidation proceeding.

With Our Affiliates for Internal Business Purposes

We may disclose information about you, including Personal Information, with our affiliates for internal business purposes.

For Direct Marketing Purposes

We may disclose information about you, including Personal Information, with our affiliates, business partners, and other third parties including, brand partners, for their own business purposes, including direct marketing purposes (California residents have certain rights set forth in “Your California Privacy Rights” below).

With Sponsors and Other Third Parties for Sweepstakes, Contests, Promotions

In addition, if you voluntarily participate in a sweepstakes, contest, rewards program or other promotion through our Site or Service, we may share your information, including Personal Information, with the participating sponsors or with third parties who assist us in using the content or other information you have posted or shared with us. By participating, you agree to the official rules that govern that promotion, and may, except where prohibited by applicable law, allow the sponsor and/or other parties to use your name, voice and/or likeness in advertising or marketing materials.

With your Consent

We may disclose information about you, including Personal Information, with your consent or at your direction, or for purposes disclosed at the time you provide the information.

Without limiting the foregoing, in our sole discretion, we may share aggregated information (including information collected for purposes of selecting relevant which does not identify you or de-identified information about you with third parties or affiliates for any purpose.

THIRD PARTY SERVICES, FEATURES, AND DEVICES

Our Site and Service contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third Party Services”). In addition, our Service contains features that allow you to interact with, connect to, or access our Service through certain Third Party Services and third party devices (“Third Party Features”). For example, you interact with a Third Party Service when you “like” or “share” content over social media through our Service or log into an account that you already have with a third party social networking platform (“SNP”), such as Facebook, via our Service. If you log into an SNP via the Service, you are allowing Porters to access the Personal Information in your SNP account, as well as other information associated with your SNP account, pursuant to the SNP’s applicable terms and conditions. The information we receive from an SNP may depend on the privacy settings you have with the SNP, so please check the SNP’s privacy policy. Remember that the SNP and other third parties may also have access to your data and use Tracking Technologies to independently collect information about you and solicit Personal Information from you.

Our Site and Service may also contain Tracking Technologies operated by third parties. For example, analytics services, such as Google Analytics, may use Tracking Technologies on our Service to help us analyze your use of the Service, compile statistic reports on the Service’s activity, and provide other services relating to Service activity and internet usage. Similarly, ad serving services, advertisers, and other third parties may use Tracking Technologies on our Service and Third Party Services to track your activities across time and services, and tailor ads to you based on your activities, which may include sending you an ad on a Third Party Service or third party device after you have left the Service (“Interest-based Advertising”).

This Privacy Policy does not apply to third party sites to which we may link or to the products or services of our business partners such as the brands that we work with who provide products or third parties who may host and/or deliver our data. The information collected and stored by third parties, whether through our Service, a Third Party Service, or a third party device, remains subject to their own policies and practices, including what information they share with us, your choices on their services and devices, and whether they store information in the U.S. or elsewhere. The fact that we link to a website or display an advertisement or other third party content is not an endorsement, authorization or representation of our affiliation with any of those third parties, nor is it an endorsement of their privacy or information security policies or practices. We are not responsible for and make no representations regarding third party policies and practices, and encourage you to familiarize yourself with and consult their privacy policies and terms of use. To the extent we combine information we receive from third parties with Personal Information we collect directly from you on the Service, we will treat the combined information as Personal Information under this Privacy Policy.

YOUR CHOICES

Changing or Deleting Your Information

To view and change Personal Information that you have directly provided to or via the Service, you can contact us by sending an email to service@porters.io. Please note that we are not required to respond to requests made by means other than through the provided email address or mail address. We may require additional information from you to allow us to confirm your identity. Please note we may retain server/backup copies of all such data, and that we may decline to process change or deletion requests that we deem to be unreasonable, require disproportionate technical effort, jeopardize the privacy of others, or are not required by law.

Tracking Technologies Generally

You may be able to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the online services you visit. Browsers offer different functionalities and options so you may need to set them separately. With respect to our mobile apps, you can stop all collection of information via an app by uninstalling the app. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device. If you do not accept cookies or disable these technologies, however, you may not be able to use all portions of our Site or Service, or all functionality of our Site or Service.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit http://www.allaboutdnt.com. Analytics and Advertising Tracking Technologies You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

You may choose whether to receive Interest-based Advertising by submitting opt outs. Some of the advertisers and Service Providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices and http://www.aboutads.info/appchoices for information on the DAA’s opt out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt out options for their members, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Interest-based Advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). We are not responsible for effectiveness of, or compliance with, any third-parties’ opt out options or programs or the accuracy of their statements regarding their programs.

YOUR CALIFORNIA PRIVACY RIGHTS

We may share Personal Information as defined by California’s “Shine the Light” law and the Consumer Privacy Act of 2018 (“CCPA”) with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes and as otherwise set forth in this Privacy Policy. Subject to certain exceptions and limitations, California’s “Shine the Light” law and CCPA permit consumers in California the right: • to request a list of what Personal Information (if any) we disclosed to third-parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties; • to know, from the prior twelve (12) month period, the categories of Personal Information we collected, used, disclosed and sold about you (if any), the categories of sources from which this Personal Information was gathered about you, and our business purpose for collecting or selling your Personal Information, the categories of your Personal Information that we have either sold or disclosed for a business purpose (if any), and the categories of third parties with whom we have shared your Personal Information; • to request that we delete the Personal information we have collected from you or maintains about you; • to opt-out of the sale of your Personal information to third parties (if any); and • to not receive discriminatory treatment for the exercise of the privacy rights provided by the CCPA.

If you are a California resident and wish to obtain information about our compliance with California’s laws pertaining to privacy, please email us at service@porters.io.

We will respond to a verifiable consumer request (as defined by the CCPA) in accordance with applicable privacy laws. We reserve and have the right to require authentication of the consumer in light of the nature of the personal information requested. Under the CCPA, Personal Information does not include (i) information that is lawfully made available from federal, state or local government records, (ii) de-identified or aggregated data or (iii) information excluded from the scope of the CCPA. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request (and will not be made more than twice in a 12-month period). If we cannot comply with all or part of a request, the response we provide will also explain the reason(s) we cannot comply.

DATA SECURITY

We employ reasonable security measures and practices appropriate to the nature of the information you provide to us and designed to protect your information, including Personal Information, from unauthorized access and disclosure. Please be advised that we cannot guarantee or warrant the security of any information you disclose or transmit to us online and are not responsible for the theft, destruction, unauthorized access by third parties or inadvertent disclosure of your Personal Information.

OTHER GENERAL INFORMATION

Public Posts on the Service

Any information that you voluntarily disclose for public posting to the Service becomes available to the public and may be seen or collected by other persons, including third parties that may not adhere to the standards set forth in this Privacy Policy. Do not submit information, comments, or other content that you want to keep strictly private. We are not responsible for events arising from the distribution of any information you choose to publicly post or share through our Service.

Data Transfers

We process information on our servers in the United States of America. Your information, including Personal Information, may be transferred to, and used by, entities located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Such export is a requirement of providing your information to us, and you consent to such transfer and use in all respects.

Our Policy Toward Children

To use the Service or Site, you must be over the age of 16. We do not knowingly collect personal information as defined by the U.S. Children’s Privacy Protection Act (“COPPA”) from children under 13 in a manner that is not permitted by COPPA, and do not target our online services to children under 13. If we discover that someone under the age of 13 has provided personal information, we will delete such information from our Site and Service to the extent required by COPPA. We encourage parents and guardians to prevent children from submitting information or data on our Service.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time at our discretion and will notify you of any material changes by posting an announcement notice on the Site or via email to our Members. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of our Site or Service indicates your consent to the Privacy Policy then posted. We encourage you to revisit this Privacy Policy.

If you have any questions about this Privacy Policy, please feel free to contact us by sending an email to service@porters.io.