Privacy Policy
Last Updated: [October 20th, 2021]
- General Information
PLEASE READ THIS PRIVACY STATEMENT AND NOTIVE OF PRIVACY PRACTICES CAREFULLY.
The Possibility Movement, Inc. dba The Possibility Company , and our parent companies, subsidiaries and affiliates (collectively, the “Company”, “our”, “us” and “we”) respect your privacy and are committed to protecting it through our compliance with this privacy policy (“Privacy Policy”).
This Privacy Policy describes the types of information we may collect from you, the user, (“you” and “your”) or that you may provide when you visit the mobile application ([Zaahah Mobile]) (the “App”) the aHa digital wallet or the websites (www.possibilitycompany.com and www.zaahah.com),) and any affiliated third party websites that may contain a link to this Privacy Policy, including, without limitation, any pages, facilities, services, or capabilities accessible on or by any top-level domain owned by us or any subsite, subdomain, subdirectory, virtual site, or virtual directory thereof (the “Website” and, together with the App, the “Electronic Platforms”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This Privacy Policy applies to information we collect:
- on or through the Electronic Platforms;
- in email, text, and other electronic messages between you and the Electronic Platforms or us;
- when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this Privacy Policy; and
This Privacy Policy does not apply to information collected by:
- us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries) that does not link to this Privacy Policy; and
- any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Electronic Platforms.
Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, including our use and disclosure of your Personal Information, please do not use our Electronic Platforms and do not provide us with any of your information. By accessing or using the Electronic Platforms, you agree to the terms of this Privacy Policy and consent to our privacy practices described in this Privacy Policy, including our use and disclosure of your Personal Information as described in Section Error! Reference source not found. below. This Privacy Policy may change from time to time as described in Section Error! Reference source not found. below. Your continued use of the Electronic Platforms after we make changes is deemed and treated as your acceptance of those changes, so please check the Privacy Policy periodically for updates.
- Changes to Our Privacy Policy
We reserve the right to revise or update this Privacy Policy at any time, and You agree to be bound by those revisions or updates. It is our policy to post any changes we make to our Privacy Policy on this page [with a notice that the Privacy Policy has been updated on the Website’s home page]. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the primary email address specified in your account and through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of this webpage as the “Last Updated” date. When you use any Electronic Platform after any updates to this Privacy Policy, you agree to and accept the updates and the included revisions and modifications. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Electronic Platforms and this Privacy Policy to check for any changes.
- Contact Information and Electronic Communication
By using our Electronic Platforms or providing your personal information to us, You agree that we can communicate with you electronically regarding any legal, regulatory, technical, security, privacy and any administrative or consumer notification obligations that may be related to your use of the Electronic Platforms. If You have any questions about this Privacy Policy or about Electronic Platforms related to the Privacy Policy, you can contact us by e-mail at privacy@possibilitycompany.com.
- Children Under the Age of 13
Our Electronic Platforms are not intended for children under thirteen (13) years of age. No one under age 13 may register or provide any information to any Electronic Platform. We do not knowingly allow children under 13 or collect their information and do not direct our Electronic Platforms for use by individuals under the age of 13. If you are under 13, do not use or provide any information on the Electronic Platforms or on or through any of its features/register, make any purchases through the Electronic Platforms, use any of the interactive or public comment features of the Electronic Platforms or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at privacy@possibilitycompany.com and we will promptly remove the information.
- Information We Collect About You and How We Collect It.
We collect several types of information from and about users of our Electronic Platforms, including information:
- by which you may be personally identified, such as your name, postal address, e-mail address, telephone number, school, or any other information the Electronic Platforms collects that is defined as personal or personally identifiable information under any applicable law (“Personal Information”);
- that is about you but individually does not identify you; and/or
- about your internet connection, the equipment you use to access our Electronic Platforms and usage details.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through an Electronic Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, our business partners.
5.1 Information You Provide to Us. The information we collect, including Personal Information, on or through our Electronic Platforms may include:
- Information that you provide by filling in forms on our Electronic Platforms. This includes information provided at the time of registering to use our Electronic Platforms, posting material to or through an Electronic Platform, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Electronic Platforms or ask us a question.
- Records and copies of your correspondence (including email addresses), if you contact us. • Your responses to surveys that we might ask you to complete for research purposes. • Your search queries on the Electronic Platforms.
While it is your choice whether to provide the requested information or not, we cannot provide certain services you may request if you do not provide the requested information.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Electronic Platforms, or transmitted to other users of the Electronic Platforms or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although [we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile], please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Electronic Platforms with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. Any User Contributions you post or otherwise provide are at your own risk.
5.2 Information We Collect Through Automatic Data Collection Technologies and Do Not-Track Signals. As you navigate through and interact with our Electronic Platforms, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Usage Details. Details of your visits to our Electronic Platforms, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Electronic Platforms.
- Device Information. We may collect information about your computer or mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
- Stored Information and Files. The Electronic Platforms also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
- Location Information. The Electronic Platforms [collect/do not collect] real-time information about the location of your device. [●].
We also will not use these technologies to collect information about your online activities over time and across third party websites or other online services (behavioral tracking).
Do-Not-Track is a public-private initiative, http://www.w3.org/2011/tracking-protection/, that has developed a technical “flag” or signal that an end-user may be able to activate within their browser software to notify websites that they do not wish to be “tracked” by third parties as defined by the initiative. The initiative, however, has not reached a consensus as to exactly what technical or other actions those parties receiving the signal should take. As a result, Do-Not-Track has not yet been standardized and most websites, including us and our Electronic Platforms, do not alter their behavior or change their services when their websites receive a “do-not-track” flag or signal.
The information we collect automatically is statistical data and may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Electronic Platforms and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Electronic Platforms according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Electronic Platforms.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Electronic Platforms. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Flash Cookies. Certain features of our Electronic Platforms may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Electronic Platforms. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Section 9 below.
- Web Beacons. Our Electronic Platforms and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- How We Use Your Information.
We use information that we collect about you or that you provide to us, including any Personal Information:
- To present our Electronic Platforms and their contents to you.
- To provide you with information, products, or services that you request from us. • To fulfill any other purpose for which you provide it.
- To provide you with notices about your account, including expiration and renewal notices.]
- To carry out our obligations, including contractual obligations, and enforce our rights arising from any contracts entered into between you and us, including for billing and collection and to enforce our Terms of Use.
- To notify you about changes to our Electronic Platforms or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Electronic Platforms. • In any other way we may describe when you provide the information to us.
- As set forth in a separate agreement between you and us.
- To improve the Electronic Platforms by solving technical problems, to calculate overall usage statistics, for internal marketing and promotional purposes, and for service development and content improvement.
- To maintain the security and integrity of the Electronic Platforms and our IT systems. • For any other purpose with your consent.
We may also use your information to contact you about our own and third parties goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. If you wish to stop receiving certain emails please click the “unsubscribe” link at the bottom of the email. For more information, see Section 8 below.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.]
We will retain your Personal Information for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purposes(s) remains valid during such time. When Personal Information is no longer needed or legally required, it will be permanently deleted or de-identified so that it can no longer be associated with a specific individual.
- Disclosure of Your Information.
We may disclose aggregated, non-personally identifiable information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:
- To our parent companies, subsidiaries, and affiliates.
- To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users is among the assets transferred.
- To fulfill the purpose for which you provide it.
- As set forth in any separate agreement between you and us.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your Personal Information:
- To comply with any court order, law, or legal process, including to respond to any government, law enforcement, or regulatory request.
- To enforce or apply our terms of use located at https://possibilitycompany.com/terms-of-service/ (“Terms of Service”), other agreements, and any other documents included or referenced therein (all of which are incorporated into and made a part of this Privacy Policy by this reference).
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, other users, service providers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
- Choices About How We Use and Disclosure Your Information.
We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Tracking Technologies and Advertising. We do not track your online activity but track cookies related to your use of the Electronic Platform to improve the service delivered. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of our Electronic Platforms may then be inaccessible or not function properly.
- Disclosure of Your Information for Third Party Advertising. We do not disclose your Personal Information with unaffiliated or non-agent third parties for promotional purposes.
- Promotional Offers from us. If you do not wish to have your contact information used by us to promote our own or third parties’ products or services, you can opt-out by logging into an Electronic Platform and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes. If we have sent you a promotional email, you may update your preferences to unsubscribe.
In the future, only approved and vetted advertisers, can utilize our Electronic Platform and they will never be provided with Personal Identifiable Information. However, we do not control third parties’ collection or use of your information to serve interest-based advertising. These third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website, available here: http://optout.networkadvertising.org/?c=1#!/
- Accessing and Correcting Your Information.
You can review and change your Personal Information by logging into the Electronic Platforms and visiting your account profile page.
You may also send us an email at account@possibilitycompany.com to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.]
If you delete your User Contributions from our Electronic Platforms, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Electronic Platforms users.
- Your California Privacy Rights.
This section is required under California law. California residents are entitled to information about our practices regarding the sale of Personal Information. [We do not sell your Personal Information. If at any time we begin selling Personal Information, we will update this Privacy Policy.]
California Civil Code Section § 1798.83 permits users of our Electronic Platforms that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@possibilitycompany.com.
- Data Security.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Electronic Platforms, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. In addition, we urge you to be careful about giving out information in public areas of the Electronic Platforms like message boards. The information you share in public areas may be viewed by any user of the Electronic Platforms.
Unfortunately, the transmission of information via the Internet is not completely secure and can potentially be intercepted or incorrectly routed. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Electronic Platforms. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on any Electronic Platform. Please consider this before submitting any information to us or through the Electronic Platforms.
- Social Media.
Any information, communications, or material of any type or nature that you submit to us through a third party website including, but not limited to, any of our Electronic Platforms or accounts contained on a social media platform or website such as Facebook, Instagram, LinkedIn, or Twitter, whether by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at your own risk and without any expectation of privacy. By visiting any of our social media accounts, you are representing and warranting to us that you have reviewed the applicable social media platform’s or website’s privacy policy and terms of use and that you will abide by all such provisions contained therein. We cannot control the actions of the providers or the other users of any social media platform and we are therefore not responsible for any content or Submissions contained on such platforms. We do not guarantee the privacy and safety of these areas. We encourage you to be wary of providing any of your personal information in such public forums. The information you submit can be collected and used by people you do not know. Again, your use of these features and your Submissions are fully at your own risk.
- Monitoring and Enforcement.
We have implemented various measures to monitor compliance with and enforce the elements in this Privacy Policy, however, we expressly disclaim the obligation to monitor such compliance. If you have a privacy related inquiry, complaint or dispute, please contact us at the postal address, telephone number, or e-mail listed in Section Error! Reference source not found.
4819-1406-1311 v.1