Privacy Policy

Last modified: August 26, 2020

In this Privacy Policy (“Policy”), we describe how Sagoon, Inc. (“Sagoon”) collects, retains, uses, and discloses information that we obtain about visitors to our websites (the “Sites”), users of our mobile application (“App”), and the services available through our App and Sites including, but not limited to, stories, Social Smart Card, Earning Smart Coins, and Gifting (collectively, the “Services”).

By visiting the Sites, using or downloading the App, or using any of our Services, you agree that you have read and understand that your personal information will be handled as described in this Policy. Your use of our Sites, App, Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Sagoon Terms of Service are incorporated by reference into this Policy.

Overview

We think transparency is important. In this overview, we summarize the personal information we collect and how we use it in California, which is further explained in our Policy below. Keep in mind that the actual personal information we collect and how we use it varies depending upon the nature of our relationship and interactions with you. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information.

Categories of Personal Information Collected. Generally, we may collect the following categories of personal information:

Category Data Examples
Identifiers

Direct identifiers, such as name, user ID, username, account number or unique personal identifier; email address, phone number, address and other contact information; IP address and other online identifiers; and other similar identifiers.

When you register we collect your name, email address and phone number and other information you choose to provide us. When you access our services, we may collect IP address, device ID, mobile advertising identifier and other unique identifiers.

Customer
Records

Personal information that individuals provide us in order to access our Services, such as name, account name, user ID, contact information, and account number.

When you create or update your account and profile, we may collect your contact information, as well as information about your connections.

We may also collect your contacts and photos from your device, if you give us permission to access them.

Commercial
Information

Records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies.

How many Smart Coins you earn and how you spend Smart Coins, as well as other transaction records related to your earning and redemption of Smart Coins, such as which products you redeem, frequency of shopping for products, frequency of sending gifts, etc.

Usage Data

Browsing history, clickstream data, search history, access logs and other usage data and other information regarding an individual’s interaction with our Sites and App and our marketing emails and online ads.

When you access the services, we collect log and usage data about your activities and interactions, such as:

  • the stories and other content and information you share through our Services
  • the content you view, and pages and features you use
  • how you interact with other users
  • date and time stamps for your activities
  • your IP address and general location information
Geolocation
Data

Precise location information about a particular individual or device.

If you grant us permission in the App, we will access your location information.

Audio,
Video and
Electronic
Data

Audio, electronic, visual, thermal, olfactory, or similar information.

If you share photos, video, audio or similar information through the services, we will collect and process such information as part of our services.

Inferences

Inferences drawn from other personal information that we collect to create a profile about your preferences, behavior, attitudes or other characteristics.

We may analyze personal information in order to identify your interests and preferences, so that we can better reach you with relevant content or make suggestions about content or connections you may be interested in.

Use of Personal Information. In general, we may use and disclose the personal information we collect for the following business and commercial purposes:

  • Providing our Services
  • Communicating with you
  • Personalizing content and experiences
  • Marketing and advertising
  • Analyzing and improving the Services and our business
  • Complying with legal obligations
  • Protection of rights
  • In support of our general business operations
  • Securing and protecting assets and rights

California residents: If you are a California resident, please refer to the “Additional Information for California Residents” section below for important information about the categories of personal information we collect and disclose, as well as your rights under California privacy laws.

You can review more detailed information about our privacy practices and your rights and choices below in our Privacy Policy.

Information We Collect About You

When you use our Services, we collect information about you directly from you and from third parties, and automatically through your use of our Sites and App. While the information we collect varies depending upon the circumstances and the Services you use, in this section we explain in general the personal information we collect.

Information We Collect Directly. We may collect the following personal information directly from you:

Information We Collect From Third Parties. We may collect personal information about you from third parties that we work with such as third-party providers of services to us (e.g., fraud detection, identity verification and security), advertising networks, analytics providers and marketing partners, social media platforms, as well as from public records and our affiliated companies. We work with these third-party providers to help us operate, provide, improve, understand, customize, support, and market our Services.

Information We Collect Automatically. We automatically collect information about your use of our Sites and App through various technologies. To the extent permitted by applicable law, we combine this information with other information we collect about you from other entities, including your personal information.

How We Use Your Information

While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use, disclose and process personal information for the following business and commercial purposes:

Aggregate, De-identified or Anonymous Data. We also create and use aggregate, anonymous and de-identified data to assess, improve and develop our business, products and the Services, and for similar research and analytics purposes. This information is not generally subject to the restrictions in this Policy, provided it does not identify and could not be used to identify a particular individual.

How We Share Your Information

We may share your information, including personal information as follows:

We also disclose information in the following circumstances:

Our Use of Cookies and Other Tracking Mechanisms

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities and use of the Sites and other Services. We may combine this “usage data” with other personal information we collect about you. We use this usage data to understand how our Services are used, track bugs and errors, provide and improve our Services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Some of the Services may not work properly if you disable cookies.

Pixel tags. Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use pixel tags (also referred to as web beacons, web bugs or clear GIFs), in connection with our Services to, among other things, help us manage ads and content, and compile statistics about usage of our Services. We may also use pixel tags in HTML emails to our customers, to help us track

Third-Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Sites, and to the extent permitted, our Apps. We also may use other analytic means to evaluate our Sites and Apps. We use these tools to help us improve our Sites’ and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third-Party Ad Network section.

Third-Party Ad Networks

We use third parties such as network advertisers to serve advertisements on our Site, App, and on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party's specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative ("NAI") Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies' delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site, Services, App, or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA's website at www.aboutads.info or the NAI's website at www.networkadvertising.org.

Interest Based Advertising

We may work with third-party ad networks, channel partners, measurement services and others (“third party ad companies”) to display advertising on our Services, and to manage our advertising on third-party sites, mobile apps, and online services. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect activity information on our Services (as well as on third-party sites and services), as well as IP address, device ID, cookie and advertising IDs, and other identifiers, general location information, and, with your consent, your device’s geolocation information; we and these third-party ad companies use this information to provide you more relevant ads and content and to improve and evaluate such ads and content.

In addition, we may share certain hashed customer list information (such as your email address) with third parties—such as Facebook and Google—so that we can better target ads and content to our users and others with similar interests, within their services. These third parties use the list information we provide to help us target ads and to enforce their terms, but we do not permit them to use or share the data we submit with other third-party advertisers.

Ad Choices. You can learn more about the information collection practices and "opt-out" procedures of many third-party ad companies at www.networkadvertising.org/optout_nonppii.asp. Opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or “contextual” ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.

Mobile. Some of our mobile games and apps may include third party advertising and analytics. You can opt out of targeted advertising from third parties in our mobile games by adjusting your device privacy settings. This means that you will no longer get targeted ads; however, you may still receive contextual or general ads.

User-Generated Content

We invite you to post content on our Sites and App, including your comments, pictures, and any other information that you would like to be available on our Sites or App. If you post content to our Sites or App, all of the information that you post will be available to all visitors to our Sites. If you post your own content on our Sites or App, your posting may be accessed and shared by others and Sagoon cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy. However, please note that when you share new content, you can choose to share with everyone, only with your connections, or only with a subset of your connections, and you can also choose to block other users.

Our Sites and App may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Security of My Personal Information & Sensitive Personal Information

We have implemented safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your login ID, password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Choices Regarding Your Personal Information

Additionally, we may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. If you opt-out of receiving promotional emails, we may still send you emails about your account or any Services you have requested or received from us.

Retention Period

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our regulatory obligations, professional indemnity obligations or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.

Children Under 13

Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems. Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at legal@sagoon.com or write to us at:

If in U.S.:
Sagoon Inc.,
1980 Teasel Ct.,
Woodbridge, VA 22192

If in India:
Privacy Officer/Grievance Officer
Sagoon India Private Limited,
Vatika Mindscapes, Tower B,
8th Floor, Sector 27 (D),
Faridabad-121003

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Sites and App. If we make any material changes to how we use your personal information, we will endeavor to provide you advanced notice, such as by emailing you or displaying a prominent notice to you within the App or on our Site.

Additional Information for California Residents

In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.

A. Categories of Personal Information Under the CCPA

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months (from the Effective Date above).

Categories and Sources of Personal Information Collected. The table below identifies, generally, the categories of personal information (as defined by the CCPA), we have collected about consumers. For more information about the business or commercial purposes for which we collect and use personal information, please see the “How We Use Your Information” section above.

Categories of Personal
Information Collected*
Do We Disclose this Information Categories of Third Parties to Whom We May Disclose
this Information
Identifiers

YES

  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • advertising networks
  • data analytics providers
  • social media platforms
  • internet service providers
  • operating systems and platforms
  • data brokers
  • business customer/client
Customer Records

YES

  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • advertising networks
  • data analytics providers
  • social media platforms
  • internet service providers
  • operating systems and platforms
  • data brokers
  • business customer/client
Commercial Information

YES

  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • advertising networks
  • data analytics providers
  • social media platforms
  • internet service providers
  • operating systems and platforms
  • data brokers
  • business customer/client
Usage Data

YES

  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • advertising networks
  • data analytics providers
  • social media platforms
  • internet service providers
  • operating systems and platforms
  • data brokers
  • business customer/client
Geolocation Data

YES

  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • advertising networks
  • data analytics providers
  • social media platforms
  • internet service providers
  • operating systems and platforms
  • data brokers
  • business customer/client
Audio,
Video and
Electronic
Data

YES

  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • advertising networks
  • data analytics providers
  • social media platforms
  • internet service providers
  • operating systems and platforms
  • data brokers
  • business customer/client
Inferences

YES

  • service providers
  • advisors and agents
  • government entities and law enforcement
  • affiliates and subsidiaries
  • advertising networks
  • data analytics providers
  • social media platforms
  • internet service providers
  • operating systems and platforms
  • data brokers
  • business customer/client

*See the Overview section above for further details regarding the categories of personal information we collect

Do We “Sell” Personal Information? Under the CCPA, a “sale” includes disclosing or making available personal information to a third party in exchange for monetary compensation or other benefits or value. While we do not disclose personal information to third parties in exchange for monetary compensation, we may disclose or make available certain categories of personal information to third parties in order to receive certain benefits or services, such as when we make browsing information available to third-party ad companies (through third-party tags on our Site and Apps) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. As defined by the CCPA, we may “sell” Usage Data and Identifiers to advertising networks, social media platforms, and data analytics providers.

Sources of Personal Information. As further described in the “Information We Collect About You” section above, we may collect personal information from the following sources:

B. California Residents’ Rights

CCPA Rights. In general, California residents have the following rights with respect to their personal information:

Do-not-sell (opt-out): to opt-out of our sale of their personal information. While we may “sell” personal information as defined by the CCPA, we do not sell personal information about California consumers who we know are younger than 16 years old.

Submitting CCPA Requests. California residents may submit CCPA requests to opt out of sales, requests to know (access) and requests to delete their personal information through one of the following methods:

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the verified user’s account phone number provided by you with the phone number we have in our records. You must provide your user account phone number to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

For more information about our privacy practices, you may contact us as set forth in the “Contact Us” section above.