Privacy Policy

For Panelope, giving you and all community members peace of mind is integral to everything we do. This Privacy Policy describes the types of information we gather from you (a Member or Community Leader) interacting with our App and how and why we collect, process, and de-identify such information, as well as how long we retain that information.

This Policy covers the Panelope App (“the Service” or “our Service,” or “the Platform”). This policy is incorporated into our Terms of Service, which governs your use of and access to our Services. Unless otherwise defined herein, capitalized terms shall have the meaning assigned to such terms in the Terms of Service. 

This Privacy Policy is effective immediately when you register for and use our Service.

We may modify and update this Policy from time to time.  We will notify you about significant changes to this Agreement with a prominent notice on our App or as may be required by law. Anytime you use the Service, this Policy will apply, and you hereby consent to any changes made to this Policy through continued use of the Service.  If you are a resident of California, please see the section titled “Information, Notices, and Rights Applicable To California Residents Only” for specific disclosures with respect to our collection, use, and disclosure of your information and additional rights you have under applicable California law.   

1. Information Collection

Panelope will not collect and store any Personal Information (defined below) for longer than is absolutely necessary to perform our obligations to you, as a Member or Community Leader.  We will promptly de-identify that information after it has served its purpose, which includes verification and payment, as outlined below. 

This means that after you register using Personal Information, that information becomes de-identified as soon as possible, in accordance with the agreements we make with third-party service provider and payment processors (like Persona and Stripe).  Therefore, that information will no longer be available to anyone, including Panelope. We take reasonable measures and precautions to ensure your privacy is not at risk, and that you never give more information about yourself than you expressly share with Panelope.

Personal Information refers to data that can be used to identify you or your household, including any documents and images you send us, as well as your birthday, physical street address, email address, telephone number, Social Security number, or any other information that would allow you to be contacted physically or online. 

Automatically collected Aggregate information is aggregate information and therefore not identifiable to any particular person or household. This is information that is collected automatically when you use our Service. Aggregate info can include information gathered through cookies that cannot be identified with a particular person or household, as well as public records including those available from federal, state, or local authority. 

A. Personal Information you Provide to Panelope

While we facilitate your submission of Personal Information on our App, we use a leading third-party payment and verification identity partner, Persona, to process and collect the information that is listed below.  We reserve the right to engage other third-party payment and identity verification vendors.  Our third-party data processors and service providers are contractually obliged to use your information according to this privacy policy. We do not collect any Personal Information unless you voluntarily share that information with us. 

  • Member Account set-up and registration:
    • Your full legal name, address, phone number, date of birth, photos (including photo of your government photo identification, or e-mail address and other such information that you choose to provide us. 
    • Specific Locational data will be used to verify your location only at the registration stage
    • Ethnicity, as well as pronoun preference and birthdate will also be collected (optional).
    • We may use Personal Information received from external sources (like an employer or Community Leader) during our registration process as well if appropriate.
    • Online identifiers such as IP type, IP host address, ISP address.
  • Community and organizational account registration:
    • Institutional or organizational legal name, Employer Identification Number (“EIN”) or any comparable identification number issued by a government (if applicable), proof of legal existence (including but not limited to: articles of incorporation, certificate of formation, business license, trust instrument, or other comparable legal document), and other proof of legal documents and credentials that we may deem fit for creation and representation of a specific community.
  • Subscription purchases
    • If you purchase subscriptions or services from us as a Community Leader, we will facilitate collection of additional information from you, including your credit card information, and information about the subscription or service you are purchasing. Panelope uses leading payment processor services like Stripe that utilize industry standards to handle payment information.

When Panelope anonymizes your Personal Information, it becomes “aggregate” or non personally-identifiable information. Panelope reserves the right to disclose or utilize any of this information to other Members, Community Leaders, or other trusted third-parties for any purpose permitted by law, in our sole judgment.

B. Automatically Collected Aggregate Information

This information will not identify or be identifiable to you due to our anonymization process. Panelope may collect this information automatically and without restriction when you use our Services. 

  • Device information
    • Browser type, operating system, physical hardware of computer like device type, make and model, carrier, user ID, similar device IDs.
  • Usage data
    • Duration and frequency of visits, log and event information related to how and when you use our Service (such as the pages, accounts, and Communities you visit).
    • Clickstream data and other social analytics and tracking measurements that do not identify any individual.1

Although we do our best to honor the privacy preferences of our visitors, we are not able to respond to Do Not Track signals from your browser at this time because currently Panelope is not browser based.  

C. Cookies

A ‘cookie’ is an alphanumeric identifier that we transfer to your computer’s hard drive through your web browser to help us collect information from users for purposes such as tracking Service visits and to measure visitor patterns. We may use two kinds of cookies:

  •  A temporary session ID cookie that expires when you close your browser, and
  •  a persistent cookie that remains active on your hard drive until they expire or are deleted.

When we use cookies, they will not track you across separate applications or internet application that you use. Rather—they are for tracking your activity on Panelope alone. You can modify your browser setting to accept or reject all cookies, or be notified when a cookie is set. If you choose to reject cookies or disable them through your browser settings, you may be unable to use those aspects of our Service that require registration and acceptance in order to participate. Cookies are not used to retrieve Personal Information from your device, or to retrieve other information from your device for purposes that are unrelated to the Service or your interaction with the Service.  You can learn more about cookies and how they work at www.allaboutcookies.org. 

We reserve the right to disclose or utilize any of this information in aggregate form to other Members, Community Leaders, or other third-parties for any purpose permitted by law, in our sole judgment.

D. Information we Receive from External Sources

We may receive information about you from other sources, including from other Members and Communities, that you submit or interact with on our Service. In addition, we may receive customized verification data sets from a representative of an exclusive group, which may include a predetermined set of names, emails, or other Personal Information that we use to verify a Member’s relationship with said group. 

We may retain and share your information, including Your Content, with law enforcement and private parties if we believe it is reasonably necessary to respond to a legal request, detect and prevent fraud and unethical or illegal activities, including security issues, enforce our Agreement between you and Panelope (including the Terms and this Policy), Protect the rights or safety of our Members or Panelope, and prevent physical harm to anyone. 

E. Locational Data

We may receive and process information about your location. For example, with your consent, we may collect information about the specific location of your mobile device (for example, by using GPS or Bluetooth). We may alternatively derive your approximate location from other information about you, including your IP address. When we collect specific locational data that uses gps or other highly accurate indicators, we use this information with our trusted third-party service providers to verify your residence or authenticity as part of a certain Community.  

2. Information Usage

A. Verification and Registration

We use your Personal Information only to the extent it is necessary to verify and authenticate our Members and Communities. When we ask for Personal Information upon registration, such as your address of residence and your telephone number, that information is transmitted directly to our trusted third-party partners, who use proprietary methods for ensuring that you are who you claim to be, and your inputs are accurate. Panelope will never directly store or collect any of this Personal Information requested upon registration.

For Communities, we will ask for institutional information relating to the entity from the representative creating and registering the community, not limited to proof of legal existence and other legal documents, as well as other credentials that will succeed in appropriately verifying a Community and authenticating an account on its behalf. In addition, we use contact information that may include Personal Information to communicate with an account that attempts to create a community on our Service. 

B. Meeting our Commitments to Panelope Members

We created Panelope with the intention of facilitating positive and meaningful interactions across multiple Communities and (eventually!) continents. To unlock the potential of Panelope, we allow information displayed on our Service by Members to be viewed and directly reported to Community Leaders who take action when relevant reports are sent by other Members. In addition, we allow Community Leaders to send reported information, including any Content and Member or Community Accounts involved, to Panelope’s support contact for additional help. Such Content may include your name and other information associated with your account. We also use this info to detect fraud and malicious activities.

C. Comply with legal and regulatory requirements

Along with our trusted service provider partners, we process your Personal Information as required by applicable laws and regulations. This includes complying with anti-money laundering requirements and other regulations.

D. To Contact You and Respond to Requests/Inquiries

Panelope will typically use your Account on our App to contact you regarding your Account or use of the Service. Upon request, we may also use email lists and other contact information such as your email or mobile phone number. In addition, we may use contact information when necessary to communicate with you or on behalf of you to ensure a successful verification, especially in the case of issues with our verification procedure. For example, when a Community Leader gives personal contact information on behalf of a Community account they are registering for, we may use that contact information to expedite or alleviate issues in the verification process, or to notify you that verification is successful. 

In addition, we use your information to respond to your questions about our Service, and to investigate bugs or other issues.

E. To improve our Service

Panelope may use any reports, comments, ratings, reviews and suggestions in any form regarding the Service that you provide (collectively, “Feedback”). We use this information to improve our Service, including providing insight as to how Members and Communities interact, how features in our Service are being used, and to otherwise understand and improve our Service. You grant Panelope a worldwide, non-exclusive, irrevocable, perpetual, royalty-free right and license to incorporate and use this Feedback. We use Feedback on an aggregated and anonymized basis and will never use this data to identify and/or contact individual respondents except on your request or where required by law. You agree that Panelope may use and share your Feedback in accordance with this policy and applicable data protection laws.

F. Improve analyses of Aggregated Data

After your Personal Information has been anonymized, we may continue to indirectly identify your account with certain criteria, including age range, ethnicity, and sex or preferred pronouns. This information is aggregated in a way that it is not identifiable to you or your account: no Personal Information will remain attached to you individually and the information will be aggregated on an anonymous basis.

3. Sharing Your Information

Panelope takes steps to make sure your information is never shared with undesirable parties, or without your consent and knowledge. The following is a list of all third-parties we share information with, why we share information with them, and to whom your Member Content can be viewed by.

A. With other Panelope Members

When you submit or post Member Content to the Service, you are telling us to share that Content with specific Communities or people, unless posted in a public space. When you share information to a Community, only that Community and its Members may view that Member Content. Community Leaders set certain permissions, and they control whether their Community requires an invite or is open and accessible to anyone. These permissions may change over time. Similarly, if you link your Panelope account with a third-party service (like another social media application) you may be telling us to share certain information with that service. 

 We may also share your information as you otherwise instruct us or provide us your consent to do so. You can control the sharing of your information as outlined in the “Member Privacy Controls” section below.  

B. With Our Service Providers

We share information with trusted third-parties to process and use that data for the specific purposes we demand of them. This includes payment processors like Stripe which processes transactions and Persona which authenticates data on our behalf. We share your data with our vendors with the understanding that all Personal Information will be redacted, and therefore deleted, typically within a week of verification on our App (as explained below in our data retention policy)

C. With Authorities

As stated, Panelope will comply with governmental authorities if and when they request certain information from our Service, if we believe the disclosure on our part is required by the law. We will try to notify your account when this occurs, and may take any response or input we receive from you into consideration. 

E. For Emergency Purposes

If we believe it is necessary for the prevention of serious harm to anyone, we may share any Member’s or Community Leader’s information.

F. To Enforce our Policies and Rights. 

We may share information if needed to enforce our Terms of Service, Community Guidelines, or other policies, or to protect the rights, property, and safety of ourselves and others.

G. With our Related Companies. 

We may share information with companies related to Panelope; including parents, affiliates, subsidiaries, and other companies under common control and ownership.

H. Sale, Acquisition, or Transfer of Assets. 

If Panelope is evaluating and/or engaging in a merger, acquisition, reorganization, bankruptcy, or sale, transfer, or change in ownership or any of its assets, we may share your information with other involved parties as appropriate.

I. Aggregate or Anonymized information. 

We may share information about you that has been aggregated or anonymized such that it cannot reasonably be used to identify you. For example, we may allow Communities to use and export for public consumption or marketing purposes aggregated user statistics–in order to (a) use data generated through our Service for the benefit of the public or public communities and (b) better illustrate the value and operations of Panelope to potential customers and business partners.

4. Data Retention Policy

We retain Personal Information for the shortest amount of time possible to reasonably achieve the purpose of retrieving such information. This means that upon your completion of our verification and registration process, Personal Information you submitted for this purpose will be typically redacted or deleted from any digital records as soon as reasonably practicable. It also means that, pursuant to our collection purposes stated above, Panelope or our service providers may need to retain certain information for longer if necessary, such as when the data is needed for legal compliance or health and safety of any individual. 

Aggregate and deidentified data regarding our Members will be retained until this information is no longer useful or necessary for Panelope to best operate. We reserve the right to retain this information as long as we deem necessary, but we will NEVER reidentify this information or attempt to do so.

In addition, we will delete your Member account if it remains inactive for an extended period of time, after making several attempts to notify you.

5. Member Privacy Controls

We encourage Members and Community Leaders to set your account privacy settings according to what makes you comfortable. The following setting are adjustable for every Panelope Member:

  • your profile WILL/WILL NOT be searchable by other Members
  • Other Members CAN/CANNOT add you as a friend
  • Location IS/IS NOT visible
  • Profile picture IS/IS NOT visible

The following setting are adjustable for every Community Leader:

  • Any Panelope Member CAN/CANNOT search for your Community
  • Any Member CAN/CANNOT view your Community
  • Your Community IS/IS NOT invite-only
  • Community Leader identity IS/IS NOT visible to Members
  • Invites CAN/CANNOT be sent to peers for this Community

6. Security

We take measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. In addition, we encourage our Members to take appropriate measures to ensure their account information remains protected from exploitation by others.

We adhere to industry standard practices and procedures to help safeguard and secure the information we collect. However, due to the inherent open nature of the Internet, we cannot ensure or warrant the security of any information provided online, and you assume this risk by using the Service. We may aggregate anonymized Personal Information and retain it for analytical purposes. We may retain this information for as long as your inquiry is active (as determined by us) and for a reasonable time thereafter. We also may retain your Personal Information for a longer period of time as needed to provide you access to Panelope or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. To the fullest extent permitted by law, please note that we will not be liable for disclosures of your data due to errors or unauthorized acts of third-parties, including third-party service providers.

7. Links to Third-party Services and Social Media Platforms

Our Service may contain links to other websites or applications. Other websites or applications may also reference or link to our Service. Some of our third-party website or technology partners may place their own cookies and/or other data collection tools on your Internet browser; however, we have no access to or control over these cookies and/or other data collection tools. These other domains, websites and/or Services are not controlled by us. We encourage our users to read the privacy policies of each and every website and application that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Our Service may also contain links to social media platforms, and you may be given the choice of connecting to one or more social media platforms from this Service. If you choose to do so, then depending upon your social media privacy settings, the Personal Information that you post, transmit, or otherwise make available on the social media platform may be viewed and/or used by others and we will have no control over such viewing and use. We do not control and are not responsible for any use of your information by or through any of the social media platforms. By linking to any social media platform, you will be assuming the risk that the information you provide on that platform may be viewed and/or used by third-parties for any purposes and agree that we have no control or responsibility for such third-party viewing and uses.

8. Information Relating to Children

Our Service is designed for those 16 years of age and older. This Service is not intended for, and we do not knowingly collect information from anyone under the age of 16 or anyone younger than the age of majority in their jurisdiction without parental consent.  We will take steps to ensure known violations of this Rule will be followed by removal of any unauthorized content from our records.

9. Terms and Conditions

Use of this Service is governed by, and subject to, the legal notices contained at the Terms of Service. Your use, or access, of the Service constitutes your agreement to be bound by these provisions.

10. Data Access Rights and Data Protection Officer

We use reasonable processes to ensure compliance with this privacy policy and periodically verify that the policy is accurate. We encourage you to raise any concerns using the contact information provided below, and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information. Subject to certain exceptions prescribed by law, you will be given reasonable access to your Personal Information, entitlement to challenge the accuracy and completeness of the information, and the ability to have it amended as is appropriate, as well as receive information on the collection and use of said information. You can help us maintain the accuracy of your information by notifying us of any changes to your Personal Information.

Panelope’s Data Protection Officer can be contacted at support@panelope.com.

Information, Notices, And Rights Applicable to CALIFORNIA Residents Only

California law provides California residents (as defined in Section 17014 of title 18 of the California Code of Regulations) (“Consumer”) with specific rights regarding information that identifies, relates to, describes, references, or is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (some of which may also constitute Personally Identifiable Information). The California Consumer Privacy Act of 2018 (“CCPA”) refers to such information as “Personal Information”. This section describes the rights that California Consumers have and explains how to exercise those rights, subject in all cases to any limitations set forth in the CCPA.

A. Information We Collect; How We Collect It; How We Use It

Category Personal identifiers (e.g., your first and last name, email address, pronouns, online identifier, IP address, etc.) Personal Information covered by the California Customer Records statute includes basic Personal Information (e.g., name, address, payment card information), commercial information (e.g., records of products or services purchased) Internet or other similar network activity.

The Service collects the following categories of Personal Information (as further specified above under Information Collection), and the Service has collected the following categories of Personal Information from its California Consumers within the last twelve (12) months, for the following categories of purposes and from the following categories of sources, and the Service shares Personal Information with the following categories of third-parties:

  • Identifiers that constitute Personal Information are collected directly from you. For example, we may collect your name, email address, residence, photos, IP address, and other information from forms you complete on the Service.
  •  Identifiers that do not constitute Personal Information are collected indirectly from you through website technology, including web servers, cookies and similar tracking technology that interacts with your browser/device when you visit the Service.
  • Personal Information covered by the California Customer Records statute is collected directly from you.
    •  For example, we may collect your name, and payment card information from forms you complete on the Service. Commercial information is collected in connection with purchases you make from us (e.g., subscriptions).
    •  Internet or other similar network activity is collected indirectly from you through website technology, including web servers, cookies and similar tracking technology that interacts with your browser/device when you visit the Service.

Categories of Third-parties With Whom We Share Personal Information See the sections above entitled “Information Usage,” “Sharing Your Information,” and “Links to Third-party Services and Social media Accounts” for more detail about the categories of third-parties with whom we share Personal Information.

B. Right to Know About Personal Information Collected, Disclosed, or Sold

As a California Consumer, you have the right to request that we disclose certain information to you about our collection, use, disclosure, or sale of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights), and subject to certain limitations that we describe below, we will disclose such information. You have the right to request any or all of the following:

  • The categories of Personal Information we collected about you.
  • The categories of sources from which the Personal Information is collected.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third-parties with whom we share that Personal Information
  • The specific pieces of Personal Information we collected about you (also called a data portability request).
  • The categories of Personal Information about you that we have disclosed for a business purpose.
  • We will never sell your data, so you never have to worry about the sale of your Personal Information!

C. Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. However, we may retain Personal Information that has been sufficiently de-identified, anonymized, or aggregated. Furthermore, we may deny your deletion request if retaining the information is necessary for us or our service provider(s) in order to perform certain actions set forth under CCPA, such as detecting security incidents and protecting against fraudulent or illegal activity.

In addition, we will be unable to delete your Personal Information twice; that is, upon our systematic redaction of your Personal Information following your registration on our App, we will be able to provide you with proof of redaction, but we will never be able to undo the deletion or anonymization of your information.

D. Exercising Access and Deletion Rights

To exercise the access and deletion rights described above, please submit a request to us at support@panelope.com. Only you, or a person or business entity registered with the California Secretary of State that you authorize to act on your behalf (an “authorized agent”), may make the requests set forth above. The request should include your contact information and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. In addition, you should provide sufficient information that allows us to reasonably verify that you are the person about whom we collected the Personal Information or an authorized representative of that person. For more information about verification, see Response Timing and Format immediately below.

E. Response Timing and Format

We will respond to consumer requests in a reasonably timely manner. If we require extra time to respond, we will inform you of the reason and extension period in writing. In order to protect the security of your Personal Information, we will not honor a request if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. The method used to verify your identity will depend on the type, sensitivity, and value of the information, including the risk of harm to you posed by any authorized access or deletion. Verification will be accomplished when you perform a specified task on your Panelope account that can only be performed by the account owner (you). 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 a request, or cannot fully comply with a request, the response we provide will also explain the reasons we cannot comply.

F. Personal Information Sales and Opt-Out

We do not sell your Personal Information. Under the CCPA, “sale” is broadly defined such that it may include allowing third-party advertising partners to receive certain limited categories of “Personal Information” (as such term is defined under the CCPA) such as cookies, IP address, device identifiers, internet or other similar network activity, to deliver targeted advertising on the Service or other services. We do not permit such third-parties to use Personal Information, and therefore Panelope does not use targeted advertising.

EU Residents Rights and Disclosures:

Data Subject Rights: Subject to local law, you may also have certain rights regarding information that we have collected and that is related to you. If you are located in the European Union with rights under the General Data Protection Regulation (“GDPR”), you have the right to withdraw previously provided consent for our processing of your “personal data” as such term is defined under the GDPR, by contacting us at support@panelope.com  Such individuals also have the following rights:

  • Right to access – This right allows individuals to obtain confirmation as to whether or not personal data concerning him or her is being processed and provides access to such personal data. It also allows individuals to request details of the processing of his or her personal data, including, without limitation, categories of recipients to whom the personal data has been or will be disclosed and the purposes of the processing.
  • Right to rectify – This right allows individuals to rectify any inaccurate personal data about him or her.
  • Right to restrict processing – This right allows individuals to block or suppress processing of personal data under certain circumstances.
  • Right to be forgotten – This right is also known as the “right to erasure.” It is an individual’s right to have personal data erased or to prevent processing in specific circumstances.
  • Right of data portability – This right allows individuals to move, copy or transfer personal data from one place to another in a secure manner without interrupting the integrity and usability of the information.
  • Right to object to processing – This right allows individuals to object to certain types of processing, including direct marketing, profiling and providing for purposes of scientific or historical research and statistics.

To exercise any of the above rights, please contact us at support@panelope.com

Legal Bases for Processing: We rely on the following legal basis to process your personal data: (i) it may be necessary for us to use and disclose your personal data for the performance and fulfillment of the contract between us and to provide you with our services; (ii) if you specifically consent to certain uses of your personal data, we may use your personal data in a manner consistent with that consent; and (iii) we will also process, transfer, disclose and preserve personal data when we have a good faith belief that doing so is necessary.

 A. Cross Border Transfers

The Service is maintained in the United States of America. By using the Service, you authorize the export of your information to the USA and its storage and use as specified in this policy. You understand that data stored in the USA may be subject to lawful requests by the courts or law enforcement authorities in the USA. 

B. Contact

For questions or concerns relating to this Privacy Policy or your information, we can be contacted using the information below. Our data privacy manager can be contacted at support@panelope.com. 

  

1. As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as “clickstream data,” can be collected and stored by a website’s server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Service. This information may be personally identifiable, but for purposes of our App, will never be linked to your identity or identifiable to you.