Propono Privacy Policy
Last Updated: July 8, 2024
1. Introduction
Welcome to Propono! This Privacy Policy describes how Propono LLC (“Propono”, “we”, “us”, or “our”) collects, uses, and shares information about you when you use our mobile applications, website, and other services (collectively, the “Services”).
By using the Services, you agree to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree with our policies and practices, please do not use our Services.
2. Information We Collect and How We Use It
We collect and use various types of information to operate, improve, and personalize the Services. Here’s what we collect and how we use it:
A. Account Information
When you create a Propono account, we collect:
- First and last name
- Email address
- Zip code (optional)
- Birth date (optional)
- Profile photo or other content you submit during account creation
We may publicly display your first and last name, as well as any photo or other content you submit, as part of your account profile. We use this information to create and manage your account, personalize your experience, and communicate with you about the Services.
B. Public Content
Your contributions to the Services are intended for public consumption. This includes:
- Photos
- Reviews
- Public and Shared Albums, including notes
- Compare Sets
- Place Check-ins, including notes and tagged friends
- Profile information you provide
- Edits to business page information
Your account profile (including your name, city, join date, and profile photo) is also publicly visible. We use this information to provide and improve the Services, including helping other users discover new places and experiences.
C. Usage Information
We collect information about how you use the Services, including:
- Search, filter and mapping activity
- Pages you view
- Date and time of your searches and browsing
- Compare sets or albums you create
- Place Check-ins
- Businesses you interact with across our Services
- Businesses you call using our mobile applications
- Other actions and interactions within the Services
We use this information to improve the Services, personalize your experience, and develop new features.
D. Device Information
When you access the Services, we automatically collect information about your device, including:
- Browser type
- Operating system
- IP address
- Device identifiers
- Mobile carrier (for mobile devices)
- Language settings
We use this information to ensure the Services function properly on your device, to analyze usage patterns, and to improve the Services.
E. Location Information
With your permission, we may collect precise location information from your device. You can control this through your device settings. We use this information to provide location-based services, such as showing you nearby restaurants and personalizing your experience.
F. Communications
When you communicate with us or other users through the Services, we may collect and store those communications. This helps us provide customer support, improve our services, and maintain the safety and security of our platform.
We use the information we collect for various purposes, including:
- Providing, maintaining, and improving the Services
- Personalizing your experience
- Communicating with you about the Services
- Analyzing usage patterns and trends
- Detecting and preventing fraud and abuse
- Complying with legal obligations
By using Propono, you agree to our collection and use of information as described in this Privacy Policy. In the next sections, we’ll cover how we use cookies, share information with third parties, and how you can control your personal data.
3. Cookies and Similar Technologies
Propono uses cookies and similar technologies in our mobile applications and future web services to enhance your experience, analyze usage patterns, and provide personalized content. Here’s what you need to know:
What Are Cookies and Similar Technologies?
Cookies are small text files that websites place on your device. In mobile apps, we use similar technologies such as device identifiers, pixel tags, and local storage. These technologies allow us to remember your preferences, understand how you use our Services, and improve your experience.
How We Use These Technologies
We use cookies and similar technologies for various purposes, including:
- Essential Functionality: To operate and maintain our Services, such as keeping you logged in or remembering your preferences.
- Performance and Analytics: To understand how users interact with our Services, which features are most popular, and where we can make improvements.
- Personalization: To remember your settings and provide personalized content and recommendations based on your interests and usage patterns.
- Security: To protect user accounts, prevent fraud, and maintain the security of our Services.
- Advertising: While we don’t currently display ads, we may use these technologies in the future to show you relevant advertisements and measure their effectiveness.
Types of Technologies We Use
- Session Identifiers: These temporary identifiers expire when you close our app. They help us track your interactions during a single session.
- Persistent Identifiers: These remain on your device for a set period or until you delete them. They help us remember your preferences and provide a more personalized experience over time.
- First-Party Identifiers: Set by Propono to provide essential functionality and improve our Services.
- Third-Party Identifiers: Set by our trusted partners to help us analyze Service usage and, in the future, potentially deliver relevant advertisements.
Managing Your Preferences
For mobile devices, you can manage how your device shares certain data by adjusting the privacy and security settings on your mobile device. This may include options to reset your device’s advertising identifier or opt-out of personalized ads.
When we launch our web application, you’ll be able to manage cookies through your browser settings. You can typically delete existing cookies, block certain types of cookies, or set your browser to notify you when cookies are being set.
Do Not Track
Some browsers have a “Do Not Track” feature that signals to websites that you don’t want to have your online activities tracked. Given the lack of a common standard for interpreting these signals, our Services do not currently respond to browser “Do Not Track” signals.
By continuing to use our Services, you consent to our use of cookies and similar technologies as described in this policy. If you have any questions about our use of these technologies, please contact us at [email protected].
4. How We Share Your Information
Propono is committed to protecting your privacy. We share your information only in limited circumstances and for specific purposes. Here’s how and why we might share your information:
A. Public Content
When you create public content on Propono (such as reviews, photos, public albums, or compare sets), that information is visible to other users and the general public. Your public profile information, including your name, city, and any content you choose to make public, is also visible to others.
B. With Your Consent
We may share your information when you give us explicit consent to do so. For example, if you choose to share your Propono content on other social media platforms.
C. Service Providers
We work with third-party service providers who perform essential functions for us. These may include cloud storage providers, analytics services, and customer support tools. These service providers only access the information necessary to perform their functions and are contractually obligated to protect your information.
D. Legal Requirements
We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). We may also share information if we believe it’s necessary to:
- Comply with legal obligations
- Protect and defend our rights or property
- Prevent or investigate possible wrongdoing in connection with the Services
- Protect the personal safety of users of the Services or the public
- Protect against legal liability
E. Business Transfers
If Propono is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Services of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
F. Aggregated or De-identified Data
We may share aggregated or de-identified information that cannot reasonably be used to identify you with third parties for various purposes, including to improve our Services and for business or marketing purposes.
G. Other Users
When you use certain features of our Services, such as creating a compare set or tagging another user in a check-in, the information you share may be visible to other specified users or the public, depending on your settings and the nature of the feature.
5. Your Choices and Rights
At Propono, we believe in giving you control over your personal information. Here are the choices available to you and the rights you can exercise:
A. Account Information
You can review, update, or modify your account information at any time by logging into your Propono account settings. This includes changing your name, email address, password, and other profile information.
B. Communications Preferences
You can opt out of receiving promotional emails from Propono by following the instructions in those emails or by adjusting your email preferences in your account settings. Even if you opt out, we may still send you non-promotional communications, such as those about your account, service updates, or our ongoing business relations.
C. Location Information
You can choose whether or not to allow the Propono app to collect and use real-time information about your device’s location through your device’s settings. If you block the use of location information, some parts of the Propono app may become inaccessible or not function properly.
D. Cookies and Similar Technologies
You can control the use of certain cookies and similar technologies through your device settings. Please refer to the “Cookies and Similar Technologies” section of this policy for more information.
E. Do Not Track
Currently, our systems do not recognize browser “Do Not Track” requests. You can, however, disable certain tracking as discussed in the “Cookies and Similar Technologies” section.
F. Access and Data Portability
You can request a copy of your personal information that we hold. We will provide this information in a structured, commonly used, and machine-readable format.
G. Correction
If you believe that any information we hold about you is inaccurate, you can request that we correct or update this information.
H. Deletion
You can request that we delete your personal information. Note that we may need to retain certain information for recordkeeping purposes, to complete transactions, or to comply with our legal obligations.
I. Restriction of Processing
In certain circumstances, you can request that we restrict the processing of your personal information.
J. Objection to Processing
You have the right to object to our processing of your personal information in certain circumstances.
K. Withdraw Consent
Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.
L. California Privacy Rights
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA). Please see the “Additional Information for California Residents” section for more details.
To exercise any of these rights, please contact us at [email protected]. We will respond to your request within a reasonable timeframe. We may need to verify your identity before fulfilling your request.
Please note that some of these rights may be limited where we have compelling legitimate grounds or legal obligations to continue to process your personal information.
6. Data Retention and Account Termination
A. Data Retention
Propono retains your personal information for as long as necessary to provide you with our Services, comply with our legal obligations, resolve disputes, and enforce our agreements. The length of time we keep your information depends on the type of data and the purpose for which we process it.
Here are some general principles we follow:
- Account information: We retain your account information for as long as your account is active or as needed to provide you with our Services.
- Public content: Reviews, photos, and other public content you post on Propono may remain on our Services indefinitely, even after you delete your account, unless you specifically request their removal.
- Usage data: We may retain de-identified or aggregated data for analytical purposes for a longer period.
- Legal requirements: We may retain certain information for longer periods if required by law or for legitimate business purposes.
B. Account Termination
You can choose to terminate your Propono account at any time. Here’s what happens when you do:
- To terminate your account, please email us at [email protected] with your request.
- Upon receiving your request, we will deactivate your account and begin the process of deleting your personal information from our active databases.
- We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
- Public content you’ve posted (such as reviews or photos) may remain on the Services unless you specifically request their removal. However, this content will no longer be associated with your personal account.
- Copies of some information may remain in our system for a period of time as part of our backup processes.
C. Data Retention After Account Termination
Even after you terminate your account, we may retain certain information:
- To protect our business, systems, and users from fraudulent activity.
- To address technical issues that may arise.
- To comply with legal requirements.
- To defend against legal claims.
- For research and analytical purposes (in a de-identified form).
D. Deletion of Specific Content
If you wish to delete specific content you’ve posted (like a review or photo) without terminating your entire account, you can usually do this through the Propono app. For content you can’t delete yourself, or if you need assistance, please contact us at [email protected].
We strive to delete your information as quickly as possible upon request. However, please note that deleted information may persist in backup copies for a reasonable period of time but will not be generally available to other users of the Services.
7. Children’s Privacy
Propono takes the privacy of children seriously. Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. Here’s our approach to protecting children’s privacy:
A. Age Restrictions
- Our Services are intended for a general audience and are not directed to children under 13 years of age.
- We do not knowingly collect personal information from children under 13.
- If you are under 13, please do not use the Services or provide any personal information to us.
B. Parental Consent
If we learn that we have collected personal information from a child under the age of 13 without parental consent, we will take steps to delete that information as quickly as possible.
C. Notification and Removal of Information
If you are a parent or guardian and you believe that your child under the age of 13 has provided us with personal information, please contact us immediately at [email protected]. We will take steps to remove that information from our servers.
D. Protection Measures
We have implemented measures designed to protect against the unauthorized access, use, alteration, or disclosure of personal information collected from children. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.
E. Changes to Children’s Privacy
We may update our Children’s Privacy section from time to time. We will notify users of any material changes by posting the new Children’s Privacy section on this page and updating the “Last Updated” date at the top of this Privacy Policy.
F. Compliance with COPPA
Our practices regarding children’s privacy are designed to comply with the Children’s Online Privacy Protection Act (COPPA). If you have any questions about our Children’s Privacy practices, please contact us at [email protected].
By using Propono, you represent that you are at least 13 years old. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we can take necessary action.
8. Security
At Propono, we take the security of your personal information seriously. We employ a variety of technical, administrative, and physical security measures to protect your information from unauthorized access, use, alteration, or destruction. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Our security measures include:
- Encryption of data in transit and at rest
- Regular security audits and penetration testing
- Access controls and authentication procedures for our staff
- Employee training on data protection and security practices
- Monitoring of our systems for possible vulnerabilities and attacks
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately at [email protected].
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we make changes, we will revise the “Last Updated” date at the top of this Privacy Policy.
For material changes to this Privacy Policy, we will notify you by email or through a notice on our mobile application before the changes take effect. We encourage you to review this Privacy Policy periodically to stay informed about our information practices and your privacy rights.
Your continued use of Propono after we post any modifications to the Privacy Policy will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.
10. Contact Us
If you have any questions, concerns, or comments about this Privacy Policy, our data practices, or your rights, please contact us at:
Propono LLC Attn: Privacy Officer39 East 13th Street, New York, NY 10003 Email: [email protected]
We will make every effort to resolve your concerns and address your questions promptly.
11. Additional Information for Residents of Certain States
A. California Residents
If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information. This section describes your CCPA rights and explains how to exercise those rights.
- Right to Know: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
- Right to Delete: 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.
- Right to Opt-Out of Sale: We do not sell your personal information, so there is no need to opt out of such sales.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.
To exercise your rights under CCPA, please submit a verifiable consumer request to us by emailing [email protected]. We will respond to verifiable requests within the timeframes required by law.
B. Virginia Residents
Under the Virginia Consumer Data Protection Act (VCDPA), Virginia residents have certain rights regarding their personal data:
- Right to Access: You have the right to confirm whether we are processing your personal data and to access such data.
- Right to Correction: You have the right to correct inaccuracies in your personal data.
- Right to Delete: You have the right to delete personal data provided by or obtained about you.
- Right to Data Portability: You have the right to obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format.
- Right to Opt-Out: You have the right to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
To exercise your rights under the VCDPA, please contact us at [email protected].
C. Colorado Residents
Under the Colorado Privacy Act (CPA), Colorado residents have certain rights regarding their personal data:
- Right to Access: You have the right to confirm whether we are processing your personal data and to access such data.
- Right to Correction: You have the right to correct inaccuracies in your personal data.
- Right to Delete: You have the right to delete personal data concerning you.
- Right to Data Portability: You have the right to obtain your personal data in a portable and, to the extent technically feasible, readily usable format.
- Right to Opt-Out: You have the right to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
To exercise your rights under the CPA, please contact us at [email protected].
D. Connecticut Residents
Under the Connecticut Data Privacy Act (CTDPA), Connecticut residents have certain rights regarding their personal data:
- Right to Access: You have the right to confirm whether we are processing your personal data and to access such data.
- Right to Correction: You have the right to correct inaccuracies in your personal data.
- Right to Delete: You have the right to delete personal data provided by or obtained about you.
- Right to Data Portability: You have the right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format.
- Right to Opt-Out: You have the right to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
To exercise your rights under the CTDPA, please contact us at [email protected].
For all state-specific requests, we may need to verify your identity before processing your request. We will respond to your request within the timeframes required by the applicable law.