This Privacy Policy explains how Portal One, UG and its affiliates (“Portal One Affiliates”) (collectively “we” or “us”) collect, use, and share information from or about you when you use our websites, downloadable applications, other digital services, connected devices, and off-line services that link to this policy, or if you engage in business with us (“Portal One Services or Services”).
This Privacy Policy applies to the Portal One Services throughout the world. Any additional privacy terms that relate to specific Portal One products or services should be read in conjunction with this policy.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. BY USING THE SERVICES, YOU ACKNOWLEDGE YOU HAVE READ AND UNDERSTAND THE PRIVACY POLICY AND THAT WE WILL COLLECT, USE AND SHARE YOUR INFORMATION AS SET FORTH BELOW.
Personal information we collect and Purposes
Categories of personal information we collect
Contact information and account registration
For example: name, email, postal address, telephone number, account username and password, business contact information, and any information you may provide to us at an event or in person.
Purposes of use:
- Provide the Portal One Services; personalize your experience; end you marketing communications; provide seamless experience across platforms and devices
- Protect our users, services and properties
- Build and manage business-to-business relationships
- Market and advertise for third parties
Identification and demographics
For example: date of birth, gender, nationality, ethnicity, interests, lifestyle information, photos, social media credentials, including identification information about friends, contacts or referrals you provide.
Purposes of use
- Provide the Portal One Services; personalize your experience; send you marketing communications; provide seamless experience across platforms and devices
- Protect our users, Services and properties, market and advertise for third parties
User-generated content
For example: photos, videos, audio, and other information you may submit to us, such as comments on our forums.
Purposes of use
- Provide the Portal One Services; personalize your experience
- Send you marketing communications
- Protect our users, Services and properties
- Market and advertise for third parties
Research and feedback
For example: comments, that you send us through online forms and social media platforms, by email, over the phone, by mail, or in surveys.
Purposes of use
- Provide the Portal One Services; personalize your experience
Information you provide to us:
Categories of personal information we collect
Device information and identifiers
For example: IP address, cookie IDs, browser type and language, operating system, platform type, device type, and advertising and app identifiers.
Purposes of use
- Provide the Portal One Services; personalize your experience; provide seamless experience across platforms and devices
- Protect our users, Services and properties; market and advertise for third parties
Connection and Usage
For example: domain names, browsing activity, scrolling and keystroke activity, advertisements viewed, forms or fields you complete or partially complete, search terms, whether you open an email, content you view and duration, quality of the service and interaction with the content, logs, and other similar information. If these events occur while you are offline, they may be logged and uploaded to us when you next connect.
Purposes of use
- Provide the Portal One Services; personalize your experience; provide seamless experience across platforms and devices
- Protect our users, Services and properties; send you marketing communications; market and advertise for third parties
Geolocation
For example: city, state and ZIP code associated with your IP address or derived through Wi-Fi triangulation.
We will ask for your permission before using your precise location from GPS-based functionality on your mobile devices.
Purposes of use
- Provide the Portal One Services; personalize your experience; provide seamless experience across platforms and devices
- Protect our users, Services and properties; send you marketing communications; market and advertise for third parties
Information we collect automatically from you and/or your device:
Categories of personal information we collect
Information from public and commercial sources
For example: demographic including at a household level, contact information, inferences about your preferences, loyalty program membership, and purchasing data.
Purposes of use
- Provide the Portal One Services
- Personalize your experience
- Provide seamless experience across platforms and devices
- Send you marketing communications
- Build and manage business-to-business relationships
- Market and advertise for third parties
⠀Source of Information
- Advertising providers; analytics providers; marketers Partners (such as for sweepstakes partners); consumer data resellers; public records databases; related Companies
Social Media Information
For example: if you interact with us through a social media service or log in using social media credentials, depending on your social media settings, we may have access to your information from that social network such as your name, email address, friend list, photo, age, gender, location, birthday, social networking ID, current city, your comments about our Services, and the people/sites you follow.
Purposes of use
- Provide the Portal One Services; personalize your experience; send you marketing communications; provide seamless experience across platforms and devices
⠀Source of Information
- Social media networks; partners of social media networks
Information we collect from third parties:
Categories of personal information we collect
Business contact information
For example: company name, your name, email address, and job.
Purposes of use
Build and manage business relationships
Source of Information
You; your company; trade associations; social media; business data resellers
Due diligence information
For example: contact information, nationality, job title, age, date of birth, gender, country of residence, employment and education information, public, religious, political or trade union roles, personal and professional affiliations, connections to criminal activities or offences related to money laundering.
Purposes of use
Compliance and risk management activities for business relationships
Source of Information
You or your company’s responses to our due diligence questions; third-party compliance screening tools and databases, such as those provided by LexisNexis; risk Solutions. Click here for more information.
Additional information that we collect for business relationships only
Additional information on purposes of use
Provide the Portal One Services, for example:
- responding to your requests or inquiries, including technical support sending you service-related communications
- providing ticketing, payment services, mapping guidance, and offers displaying content you generate, such as video and comments
- carrying out research and analytics for uses including improving our Services and developing new ones
- processing your information for promotional campaigns such as sweepstakes and contests, and for surveys, online and offline panels and focus groups
Personalize your experience, for example:
- providing you with customized product experience, including personalized newsletters, viewing and other content recommendations from Portal One, our partners and other organizations
- providing you with advertising based on your activities and interests including at a household level
- creating and updating profiles and audience segments that can be used for analytics, interested-based advertising and marketing on the Portal One Services, television, third party services and platforms, mobile apps and/or websites, connected devices and offline
- using inferences about your preferences and interests for any and all of the above purposes
Send marketing communications (with consent if required), for example:
- sending you newsletters, surveys and information about products, services and promotions offered by Portal One
Provide a seamless experience across platforms and devices, for example:
- identifying you when you log into the Portal One Service on multiple devices or web browsers to provide continuity and to match your interests across devices for the purposes of analytics, advertising, reporting and to improve the Services identifying you if your devices have attributes suggesting that they may be used by the same individual or household for purposes of analytics, advertising, reporting and to improve the Services
Build and manage business relationships, for example:
- pursuing potential business opportunities, including identifying and contacting the correct person within the company
- sending communications for business purposes
- sending event invitations, marketing emails and campaigns, and tracking the effectiveness of such communications
- providing business contacts with access to our systems, and managing that access
Market and advertise for third parties, for example:
- send you newsletters, promotional emails, surveys and information about products, services and promotions offered by our partners and other organizations with which we work
- customize content that our third-party partners deliver on the Services (e.g., personalized third-party advertising)
- create and update inferences about you and audience segments that can be used for interested-based advertising and marketing on the Services, third party services and platforms, and mobile apps
- create profiles about you, including adding and combining information we obtain from third parties and matching your interests across devices, which may be used for third-party marketing and advertising on the Portal One Services, television, third party services and platforms, mobile apps and/or websites, connected devices and offline
Compliance and risk management activities for business relationships, for example:
- compliance with laws and regulations
- managing third party and other risks to our business protecting the reputation of our businesses
- following the principles of ethical business conduct set out in our Code of Conduct
Protect our users, Services and properties, for example:
- protecting the safety and security of users and visitors to the Portal One Services protecting our digital and physical properties
- detecting and preventing other activities that may be illegal or in violation of our Terms of Service for that respective Portal One Service
We may combine all the information we collect from or receive about you for the outlined purposes. We may aggregate or de-identify your information and may use, share, rent or sell aggregated or de-identified information for any purpose, and such information is not subject to this Privacy Policy.
When we share your information
We may share your information with:
- Related Companies: Portal One Affiliates to help better tailor services, products, marketing, and advertising to you and to other existing and potential customers. We may share identification and demographics, device information and identifiers, and research and feedback for purposes such as improving and tailoring services. In addition business information may be shared for business operational purposes.
- Advertisers, Advertising Networks, and Other Third Parties: We may share information about how you use the Portal One Services and interact with content or ads to better tailor services, products, marketing and advertising on our Services and on third-party platforms. To enable these purposes, we may share certain demographics information, user-generated content, device information and identifiers, connection and usage data, geolocation data, public and commercial information, and social media information. These third parties may use their own tracking technologies to collect or request information about you, please see our Cookie Notice.
- Partners: We may share your information with third party partners. For instance, if you enter a contest or sweepstakes sponsored by a third party, we may share the information you provide for that entry with the sponsor. Depending on the partnership, we may share certain information including contact information (at your direction), identification and demographic information, transactional information, user-generated content that you provide, research and feedback, device information and identifiers, connection and usage information, public and commercial information, and social media information.**Social Networks:**We may share your information with social media platforms for example, if you click on a Facebook “like” button on an Portal One Service, the “like” may appear on your Facebook account. To control this sharing of information, please review and adjust your privacy settings for the relevant social network. Depending on your privacy settings and actions on such network, we may share contact information, identification and demographic information, user-generated content, device information and identifiers, connection and usage data, and social media information.
- Service Providers: We engage vendors to perform business purposes on our behalf and share information with them to enable them to provide us with such business purposes, including research and analytics, hosting, transaction and payment processing, promotion administration, fraud prevention, identity management, acquisition and other services. Service providers may use such information for their operational purposes in order to provide their services to us.
- Law Enforcement, Regulators, Anti-fraud Coalitions and other groups: We share any of the categories of information we collect, as appropriate, with these third parties in order to: protect and enforce the legal rights, privacy, and safety of ourselves and our visitors; protect against possible fraud or other illegal activity; respond to requests from government and other authorities; and otherwise comply with legal process.
Other Sharing
We may share information about you along with a hashed or masked identifier, with third parties so they may better personalize your experience with them and the offers they send you. With your appropriate consent when required, and consistent with applicable law, we may share your video viewing behavior with third parties including service providers, advertising companies, analytic partners, and social media sites.
Sale or transfer of all or part of our business or assets
In the event that Portal One or any Portal One Affiliate is involved in a merger, acquisition, transfer of control, bankruptcy, reorganization or sale of assets, or diligence associated with such matters, we may sell or transfer the information described in this Privacy Policy as part of that transaction.
Legal Bases for Use of Your Information
The laws of some jurisdictions, such as the European Union, require companies to tell you about the legal basis for using, sharing, or disclosing your information. To the extent those laws apply, we may rely on the following legal bases:
- Performance of a contract: where use of your information is necessary to provide you with Portal One Services under a contract, for example the relevant Terms of Service.
- Legitimate interest: where use of your information is necessary for our or others legitimate interests and where the use is not outweighed by your rights and interests. Below are some examples of such interests:
- providing Portal One Services
- improving our Services and developing new ones
- recognizing and better understanding our users
- including across platforms conducting security and fraud prevention activities
- marketing and promoting our content and services building and managing business relationships conducting compliance and risk management activities providing and managing access to our systems
- Legal obligation: where use of your information is necessary to comply with laws and regulations such as those relating to anti-bribery and corruption and anti-money- laundering, complying with requests from government bodies or courts, or responding to litigation.
- With consent: we may ask for your consent to process your information in a certain way. Where we rely on this basis, you have the right to withdraw your consent at any time – please see the Your Rights and Your Choices sections below to do this.
CHILDREN
Most of the Portal One Services are intended for users of all ages. If you are a parent or guardian and believe your child under 13 in the United States or under 16 in the European Union has provided us with personal information without consent, please contact us at contact@freque.io
YOUR RIGHTS
Depending on where you live, you may have certain rights with respect to your information. For example, under local laws, including in the European Union, you may be able to ask us to:
- provide access to certain information we hold about you, in some cases in a portable format, if technically feasible
- update or correct your information delete certain information
- restrict the use of your information
We will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations.
Some Portal One Services can only be provided if we have your information, therefore deletion of your information will result in termination of such Services.
We will take reasonable steps to verify your identity, including authenticating you through the email address. We may require further documentation such as a password and user ID before granting access to your information.
California residents with rights under the CCPA, for access or deletion requests may email info@freque.io.
U.S. residents who wish to learn more about access or deletion requests may email info@freque.io.
If you are based outside the U.S. and would like to exercise any individual right you may have please contact us at info@freque.io. Please include “My Rights” in the subject line and provide a clear explanation of which right you are exercising and your country of residence in the body of the email.
Your rights and our responses will vary based on your state or country of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.
If you have any unresolved concerns, you may have the right to complain to your local data protection authority.
“Do Not Sell My Personal Information” (California Residents only)
California residents may opt out of the “sale” of their personal information. California law broadly defines “sale” in a way that may include allowing third parties to receive certain information such as cookies, IP address and/or browsing behavior to add to a profile about your device, browser, or you. This profile enables delivery of interest-based advertising on the Portal One Services or other sites. Advertising, including interest-based advertising, enables Portal One to provide you certain content for free and provide relevant offers to you.
Depending on what Services you use, we may share the following categories of information for such advertising which may be considered a sale (as defined by California law):
identification and demographics; device information and identifiers, such as IP address, and unique advertising identifiers and cookies; connection and usage information, such as browsing history or app usage; geolocation information, such as city; and inference data.
If you or your authorized agent would like to opt out of Portal One’s use of your information for such purposes (to the extent this is considered a sale), you may do so.
Third Parties’ List – Shine the Light (California Residents only)
California residents can also request a list of all the third parties to which we have disclosed certain personal information (as defined by California’s Shine the Light law) during the preceding year for those third parties’ direct marketing purposes. California residents may contact us at info@freque.io. In the body of your request, you must include: “California Shine the Light Request”, your name, a current California address including, street address, city, state, and zip code, as well as sufficient information for us to determine if the law applies to you. You will need to attest to the fact that you are a California resident. We will not accept requests by telephone, email, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Nevada Residents
Portal One does not engage in the following activity, however Nevada law requires us to post the following: certain Nevada consumers may opt out of the sale of “covered information” for monetary consideration to a person for that person to license or sell such information. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.
If you are a Nevada resident who has purchased goods or services from Portal One, you may submit a request to opt out of any potential future sales under Nevada law by emailing us at info@freque.io. Please use “Nevada Do Not Sell” in the subject line. Note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
YOUR CHOICES
Cookies and Similar Technologies
We and our service providers, advertisers, and other third parties use cookies and similar technologies (e.g., HTTP cookies, HTML 5, flash local storage cookies, web beacons, GIFs, embedded scripts, ETags/cache browsers, and software development kits) to recognize you on, off, and across Portal One Services and your devices. For more information about the use of cookies and similar technologies on the Portal One Services (including your opt-out choices) please see our Cookie Notice.
Mobile App and Connected Devices
Depending on the device you use, you may be able to manage your advertising and location preferences through your device settings and as outlined in our Cookie Notice. Many operating systems provide their own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable platform operator allows you to manage personalized in-application advertisements. You should review your device manufacturer’s support materials and/or the device settings for the respective operating systems for more detail on how to manage such preferences.
You can stop all collection of information by a mobile app by uninstalling the app.
Third-Party Online Services
Portal One Services may contain links to third party services. These other sites (even if co- branded as Portal One) may collect information about you and use this information in accordance with their own privacy policies and terms of service. We do not control those third parties’ policies or practices. Where Portal One collects personal information on a co-branded website or service, we will provide a link to our privacy policy as appropriate. In some circumstances, Portal One may host some websites on behalf of others and those entities may place or permit the placement of cookies and other tracking technology.Portal One is not responsible for these tracking practices.
HOW WE PROTECT YOUR INFORMATION
We maintain organizational, technical, and physical safeguards to help protect the information we collect and use. These safeguards vary depending upon a variety of factors including the sensitivity of the information we collect and use. Despite all reasonable practices, no security method is infallible.
HOW LONG WE KEEP YOUR INFORMATION
We will keep your information only for as long as it is necessary to fulfill the purposes described above, unless a longer retention is required or permitted by law. We may delete or de-identify your information sooner if we receive a verifiable deletion request, subject to exemptions under applicable law. The retention period that applies to your information may vary depending on the Portal One Services you use and how you interact with them.
INTERNATIONAL TRANSFERS
Portal One is a global company and has its headquarters in Germany. We may transfer your information to Related Companies, service providers, and other third parties located outside your country of residence, including in the United States, as long as they are GDPR-compliant. This is necessary to provide our Services and for the purposes outlined in this Privacy Policy. Data privacy laws vary from country to country and may not be equivalent to, or as protective as, the laws in your home country. We take steps to ensure that reasonable safeguards are in place with the aim to ensure an appropriate level of protection for your information, in accordance with applicable law. These measures include data transfer agreements. By providing us with your information, you acknowledge any such transfer, storage, or use.
UPDATES TO OUR PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time to reflect changes to our practices or the law. We will make the revised Privacy Policy accessible through the Portal One Services. Please check the Portal One Services periodically for updates.The date at the top of the Privacy Policy tells you when it was last updated. If we make material changes to the way we collect or use your information, you will be provided with appropriate notice, including by, but not limited to, posting the updated Privacy Policy on this website, and providing notice in accordance with legal requirements.
Any changes to this Privacy Policy will become effective when the revised Privacy Policy is posted. By continuing to use the Portal One Services following any changes to this Privacy Policy, you acknowledge you have read and understand the updated Privacy Policy, and you understand that we will collect, use, and share information as stated therein.
CONTACT US
For any questions or complaints about this Privacy Policy or our privacy practices, please contact us at: contact@freque.io