This Privacy Policy (“Privacy Policy”) explains how Paonaa Inc. (“Paonaa,” “us,” “our,” and “we”), collects, uses, discloses, and shares information when you interact with us. This Privacy Policy applies to all users of Paonaa’s mobile device applications, Paonaa’s website as published at www.paonaa.com , Paonaa’s browser extension, and any other sites or applications that are branded “Paonaa” and link to or reference this Privacy Policy (collectively, the “Services”).
Please read this Privacy Policy carefully. This Privacy Policy replaces and supersedes the last version of this Privacy Policy for all users (including users who registered before January 3, 2023). If you do not agree to the terms in this Privacy Policy, please do not register, subscribe, create an account, or otherwise interact with the Services. By signing up for, using, or continuing to use the Services, you consent to the practices described in this policy.
1. Collection of Information
1.1 Sources of Collection
We collect, process, and use information about you when you:
- Register for our Services
- Interact with our Services
- Install and/or access our Services through our application(s), including our mobile application and browser extension
- Connect to our Services through third parties, including social media accounts, email accounts, and Merchants (described in Section 3 below)
- Contact us for support
- Enter a sweepstakes, contest, or promotion, or respond to a survey or poll
We collect certain information when you submit or provide it to us directly. When you have installed our mobile application or browser extension or when you interact with our Services online, we also automatically collect information about you and your use of the Services through the use of log processes, cookies, location-identifying technologies, and other tracking technologies. Certain information is collected about you from third parties, including when you connect through a third-party service or business partner site or when information is shared by merchants with whom you’ve also interacted.
1.2 Types of Information We May Collect
The types of information we collect about you may include personal information of the following types:
- Identifiers that you provide us directly, such as your first and last name, address, email address, and/or phone number
- Identifiers collected through your use of the Services, such as unique online or device identifiers, IP address, device or session IDs and information regarding your system configuration (operating system and version), network, and connected hardware (e.g., computer or mobile device and carrier) and software applications (e.g., other applications installed on your mobile device)
- Customer Record Information, such as payment account name, payment account number, payment card expiration date and billing address
- Classification Characteristics, such as your gender, age, household income, marital status, or your inclusion in any other classification, only to the extent you provide this information to us as demographic information in a survey response that is identifiable to you
- Commercial Information about you, such as records of products, product types, merchants, merchant types, goods or services purchased, obtained, or considered by you, including products, merchants and coupons you searched for, viewed or clicked, items added to cart and abandoned, shopping trips initiated, merchant sites visited from our Services, transaction history related to our Services, purchase confirmation data, accrued cashback
- Internet and other Network Activity, such as your browsing and search history and your interactions with our sites and Services, including:
- Products, coupons, offers, or merchants you search, click, favorite, and/or view, including clicks you make on the merchant sites you visit within our mobile app;
- URL’s of the pages you visit, including those tracked by our browser extensions and mobile application;
- Date and time stamps associated with such browsing, searches, and clicks;
- Click stream data, meaning the page by page clicks that you make as you navigate through our Services, including the web page visited before you came to our website;
- Locale preferences for your use of the Services Sensory-related information, such as audio recordings of your voice to the extent you call our member services representatives, as permitted under applicable law.
- Member account credentials, including username and password
- Inferences drawn about you and your likely preferences, characteristics, behavior, and attitudes from any information we collect about you, except “sensitive” information.
2. Use of Information We Collect
We use information we collect about you for the following business and commercial purposes:
To Provide Our Services and Manage Your Account, including to:
- Process your registration with our Services, including verifying whether your email address is active and valid and enrolling you into our programs
- Manage your account and interaction preferences, including tracking your favorite stores, preferred merchants and your transaction history
- Deliver you rewards or payments and identify opportunities for rewards and/or offers
- Send you technical notices, updates, security alerts and administrative messages
- Provide you member services and support regarding your account and reply to your questions, comments, and requests
2.1 To Personalize and Improve Our Services
We may use information we collect about you to create a profile of your preferences to personalize and tailor Services content so that it is more likely to be of interest to you. For example, we may use your most frequently visited Merchant stores or shopping history to display offers for similar stores in relevant parts of the Services or to present special offers that may interest you via our Services, including in-store.
We may also use information we collect about you to identify usage trends and perform statistical analyses to improve our Services, websites, applications, marketing efforts, and the products and services of our Merchants we recommend or offer, in order to provide a better service to you in the future.
2.2 To Provide You Marketing Information
Subject to your consent where required, Paonaa may use information we collect about you to provide you more personalized offers, special offers, discounts, and/or more relevant offers from our participating merchants via email and other direct communications, and through digital advertising. Subject to your consent where required, we may use your information to directly send you email newsletters, rewards offers, discounts, promotion codes, events and general information about the Services. You can manage these direct marketing communications as provided in Section 4 (Your Choices) below. We may also use your information to advertise to you online, including targeting advertising to you on other websites. You can withdraw your consent of use of your personal information for targeted online advertising as provided in Section 4 (Your Choices) and Section 5 (Your Rights).
2.3 To Protect You, Others, and our Business
We may use collected information to assess risk and to investigate and limit fraud, spam, and other malicious online activities in our Services, and to improve our security measures. We may also use collected information to assert our legal rights or to defend our legal rights against third parties.
2.4 To Comply With Applicable Laws
We may use information we collect about you to enable us to comply with applicable laws, rules, regulations, and judicial authorities in each geographical region in which we operate.
2.4 To Administer Contests, Sweepstakes, Surveys, Polls, and Promotions
From time to time, Paonaa may invite you to enter various contests, sweepstakes, surveys, polls, and promotions. If you choose to participate in a contest or promotion, your personal information may be used to administer the contest, such as to determine your eligibility for the contest or to award a prize. If you choose to participate in a survey or poll, the feedback you submit will be aggregated and deidentified to provide us insight on business and shopping trends. We maintain this information in a deidentified manner and do not attempt to re-identify it.
2.4 To Administer Referral Programs
We offer features that allow you to inform another individual about our Services. If you choose to use our referral features, we will ask for your referral’s email address to send them an electronic communication inviting them to join our Services. We will store this information for the sole purpose of sending this email and tracking the success of our referral program. If you choose to participate in our referral programs, you represent and warrant that you have a personal relationship with your referral and that you are authorized to share their information with Paonaa for the purpose of Paonaa sending a communication to invite them to join the Services. If you believe that one of your contacts has provided us with your personal information through our referral service and you would like to request that it be removed from our database, please contact us through our Member Services page.
3. Disclosure of Information
We may disclose the below-specified categories of information for our business or commercial purposes, including the following:
3.1 Disclosure to Our Service Providers
We may disclose all categories of your collected personal information as necessary with our third-party service providers (which may include Company affiliates) who perform various business operations, solely for our benefit or on our behalf, under our instructions and in compliance with appropriate contractual, technical and organizational security measures to protect your data from unauthorized use, retention, or disclosure. For example, we may partner with other companies to provide you member support services, authentication services, prevent fraud on our Services, process payments, administer our promotions, referral programs, sweepstakes, and surveys, perform analytics, maintain the accuracy of our databases, deliver direct marketing and communications, limit delivery of repetitive or unnecessary marketing or communications, fulfill your product purchases, place and fulfill your takeout orders, and administer your rewards or payments.
3.2 Disclosure to Our Business Partners
We work with various types of third-party business partners to offer you our Cashback shopping Services. We may disclose the following types of information with the following types of Business Partners:
- Merchants: When you click on a link to a merchant site presented on our Services to start your Cashback shopping, you evidence your intent to interact with that business through our Services, and thereby are directing us to disclose certain information about you (including the link you clicked in our Services and a unique ID assigned to track that your shopping originated from our Services) to an affiliate network to properly account for your purchases with a merchant. For a small number of merchants that do not utilize an affiliate network, this information is provided directly to the merchant. The Merchant will collect Internet and Network Activity information about your use of our Services in relation to the merchant site, products, or offers. Our Merchants collect this information to track the shopping trip, but some of them may also use this information to measure performance, contribute it to their own user profiles and/or combine it with information they collect elsewhere, which they may make available for use by their other business clients. In such cases, via the instructions in Section 5, below, we offer our consumers with the ability to withdraw their consent which would signal these Merchants to not collect or use your information from our Services except as necessary to validate and provide your Cashback.
- Referral Marketing Partners: In order to expand your options to sign up for our Services and start your Cashback shopping from third-party sites where you learn about our Services, we contract with certain referral marketing business partners to enable that functionality, which may require that we disclose certain data about you to them. For example, if you are referred to our Services from a business partner’s websites, we may provide that partner with information about your sign up to validate the referral and activate your Services account access from the partner’s site. In addition, we may disclose information about whether you have made a purchase with us recently and whether you have installed our mobile app or browser extension so that the partner can personalize their email and site content to you. We provide you with the opportunity to withdraw your consent from our disclosure of your information to these referral marketing business partners via the instructions in Section 5, below.
- Financial Partners: For the purposes of providing you additional redemption options for your Cashback, we may disclose your collected information, including Identifiers, to financial business partners. If you select bKash or Nagad for receiving your Cashback, you are directing us to disclose your personal information, as necessary, to the relevant financial partner to facilitate that transaction. We may also disclose personal information about you to our financial partners in order to facilitate their marketing purposes and in some instances for the financial partner to directly send marketing to you. You may withdraw your consent of this disclosure for partner marketing via the instructions in Section 5, below.
3.3 Disclosure to Digital Advertising Providers
To provide us with targeted advertising and marketing services, we partner with certain third parties that automatically collect Internet and Network Activity information about your use of the Services, such as your browsing history, IP address, pages viewed, and links clicked, so that they can use this information to serve you ads for our Services on other sites you visit. Some of these third parties may also use this collected information to draw inferences about you for their own purposes or separately collect personal information about your online activities over time and across different websites (in addition to our Services) to help predict your preferences and to display (and enable other third parties to display) ads to you that are more likely to be of interest to you. You have the right to withdraw your consent of our sharing of your information with certain third parties for the purposes of cross-context behavioral or targeted advertising. To exercise this right, you can withdraw your consent via the instructions in Section 5, below. Note that this Privacy Policy covers only our use of data and does not include further use of data by third parties.
3.4 Disclosure for Legal Purposes
We may disclose the information we collect, including personal information, to the extent permitted by applicable law, (i) in response to subpoenas or other legal processes or if, in our good faith opinion such disclosure is required or permitted by law without a specific disclosure; (ii) at the request of governmental authorities conducting an investigation; (iii) to enforce our terms and conditions or other policies applicable to our Services; and (iv) to protect the rights, property, life, health, security and safety of Paonaa or any third party.
4. Your Choices
4.1 Updating Account Information
We encourage you to maintain the accuracy of the information you submit to us. You may provide account updates by logging into your Service account and updating your information in the settings.
4.2 Communications Preferences
- Email Marketing: We may send you periodic electronic communications and direct mailings when you sign up for an account. If you consented to receiving promotional email communications, you can withdraw your consent of receiving promotional communications from us at any time by following the instructions provided in those communications to unsubscribe or stop them, modifying the settings of your account, or contacting us through the Services. Please note that even if you withdraw your consent of receiving promotional communications, we may continue to send you non-promotional emails and other types of communications, as permitted by law, such as service emails relating to our ongoing business relationship. Service emails contain service-related announcements that affect your account, such as product order confirmations, reward or payment updates, and responses to your comments and feedback submitted to us.
- Mobile Application Notifications: When using our mobile application, your preferences for receiving push notifications and other mobile alerts can be configured in the settings of your mobile device.
- Data Collection and Sharing PreferencesYou may in some cases have the option to decline to provide us with certain information; however, your choice may impact your use of certain features or services for which that information is a necessary component.
- Mobile App/Browser ExtensionYou can prospectively stop all collection of information by our mobile application and/or browser extension by uninstalling our mobile application and/or browser extension. Because the browser extension and mobile application permit data about your online behavior on that device or browser to be collected when installed, even without interaction, they must be uninstalled to withdraw your consent to this data collection. In some instances, you can withdraw your consent of certain data collection by updating your mobile device settings.
5. Your Privacy Rights
You have certain rights in relation to your personal information under applicable laws, subject to certain exceptions.
5.1 Right to Know and Access
You have the right to request to know the personal information specific to you that we collected, used, disclosed for a business purpose, and sold or shared for the purposes of cross-context or targeted advertising, including the purposes of use, categories of sources from which we acquired your information and the categories of third parties to whom we disclosed your information. You also have the right to request to access (receive a copy of) the specific pieces of personal information we have collected about you (note that we will not provide any sensitive personal information we may hold in response to this type of request).
5.2 Right to Correct
You have the right to request that Paonaa to correct any inaccurate or incomplete personal information we have collected from you or maintain about you, subject to certain exceptions. You have the ability to correct information provided by you in your account settings located at https://www.paonaa.com/account once you log in to your account.
5.3 Right to Withdraw Your Consent of the Sale or Sharing of Your Personal Information/Personal Data
As described in Section 3 of this Privacy Policy, we may make certain disclosures of information to our merchant partners, third parties or affiliates in order to provide you rewards and benefits and for our targeted marketing purposes. If you would like to withdraw your consent of having your personal information used or disclosed in this way, please contact us through our Member Help page. Please note that to the extent you withdraw your consent of certain disclosures we may be unable to offer you some of our services which require such disclosures. If you have further questions, you can contact us from the Contact Us section.
5.4 How To Exercise Rights to Know, Access, and Correct
To assert your privacy rights please contact us through our Member Help page. If we cannot verify your identity from the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.
5.5 Agents
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. For any agent making a request on your behalf, we may require you to prove that you authorized this agent to submit a request on your behalf, and we may require you to independently verify your identity or log in to your account to provide the access code.
6. Other Notices
6.1 Notice Regarding Information of Minors
This site and any related services are intended for adults 18 years of age or over as applicable by law, and we do not knowingly collect or sell or share personal information of consumers under 16 years of age without affirmative authorization or without verifiable consent from a parent for those under age 13.
6.2 Retention of Data
We may retain information about you for as long as it is necessary to fulfill the purposes described in Section 2. Some of your information may be retained in our systems in order to comply with our obligations under applicable law, collect fees owed, resolve disputes, enforce our legal rights, undertake any investigations necessitated by the foregoing, or otherwise use internally in a lawful manner that is reasonably aligned with your reasonable expectations or compatible with the context in which the information was provided.
6.3 Information Security
We have implemented technical and organizational measures to provide a level of security appropriate to the risk to the personal information that we process. These measures are aimed at preserving the ongoing integrity and protecting the confidentiality of personal information. We evaluate these measures on a regular basis to confirm that they continue to maintain and apply an appropriate level of security.
7. Changes to This Privacy Policy
This Privacy Policy is current as of the effective date set forth below. We reserve the right to change this Privacy Policy from time to time consistent with applicable privacy laws and principles and our practices in relation to personal information. If we make changes to this Privacy Policy, we will notify you by revising the date on this Privacy Policy. In the event of a material change, we will provide you with additional notice (such as adding a statement to the homepages of our Services or sending you an email notification).
8. Contact Us
Paonaa is responsible for all personal information under our control. Our Privacy Manager is accountable for Paonaa’s compliance with the principles described here. If you have any questions, concerns or complaints regarding the privacy practices of our organization or would like information on our use of service providers located, please feel free to contact us at the following:
Email: [email protected]
Updated: 11 November 2023