Privacy Policy

Peblla, Inc. and its affiliates (“Peblla” “we,” “our,” and/or “us”) value the privacy of individuals who use our application, websites, and related services (collectively, our “Services” or “Platform”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose information from users of our Services (“Users”) through providing access to rewards programs. This Privacy Policy applies to our customers “Customers”, businesses selling products through our Platform (“Merchants”). By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

If you are a California resident, please also review our California Resident Privacy Notice for more information about the types of personal information we collect and disclose, as well as how to exercise your rights under California law.

Information We Collect

We may collect a variety of information from or about you or your devices from various sources, as described below.

If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.

A. Information You Provide to Us.

B. Information We Collect When You Use Our Services.

C. Information We Receive from Other Sources.

How We Use the Information We Collect

We use the information we collect:

To provide, maintain, improve, and enhance our Services;

To personalize your experience on our Services such as by providing tailored content and recommendations;

To understand and analyze how you use our Services and develop new products, services, features, and functionality;

To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;

For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;

To generate anonymized or aggregate data containing only de-identified, non-personal information that we may use for any lawful purpose;

To send you text messages and confirmation notifications;

To facilitate and keep track of rewards transactions and payments;

To find and prevent fraud and abuse, and respond to trust and safety issues that may arise;

For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and

For other purposes for which we provide specific notice at the time the information is collected.

How We Disclose the Information We Collect

We do not disclose information we collect from or about you except as described below or otherwise disclosed to you at the time of the collection.

Affiliates.
We may disclose any information we receive to our affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers.
We may disclose any information we receive to vendors and service providers retained in connection with the provision of our Services.

User Content.
Our Services allow Users to find, enjoy, and share content. When you share content on our Platform your name, username, and other profile information will always be viewable and searchable by other users. The content you post to the Services will be displayed on the Services and viewable by other users by default. Although this content is public by default, below in the “Your Choices” section of this Privacy Policy, we describe the controls that you can use, along with other relevant settings associated with your account, to limit the sharing of certain information. We are not responsible for the other Users’ use of available information, so you should carefully consider whether and what to post or how you identify yourself on the Services.

As Required By Law and Similar Disclosures.
We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

Merger, Sale, or Other Asset Transfers.
We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Consent.
We may also disclose your information with your permission.

Your Choices

Sharing Preferences.
Certain information may always be publicly available to others, and other information is made publicly available to others by default.
To change whether certain information is publicly viewable, you can remove your content or contact [email protected].

Location Information.
You can prevent your device from sharing precise location information at any time through your device’s operating system settings.

Marketing Communications.
You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Do Not Track.
There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

If you choose not to provide us with information we request, some features of our Services may not work as intended.

Data Retention

We take measures to delete your information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided by law, and any relevant statute of limitations.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected].

If you are a California resident under the age of 18 and you wish to remove content that you publicly posted, you may submit a request by contacting us at [email protected].

Removing the public content does not ensure complete or comprehensive removal of the content or information.

Your California Privacy Rights

If you reside in California and have provided your personal information to us, you may request information once per calendar year about our disclosures of certain categories of personal information to third parties for their direct marketing purposes. Such requests must be submitted to us in writing at the following [email protected].

International Visitors

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

Update Your Information

You can update your account and profile information or close your account through your profile settings.

Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

Contact Information

COMPANY is responsible for processing your information. If you have any questions, comments, or concerns about our processing activities, please email us at [email protected].

Last Updated: [October 25, 2023]


PEBLLA, INC. Notice to California Residents of Financial Incentive

We offer financial incentives to consumers who sign up for our loyalty program, subscribe to our newsletters and updates, or otherwise consent to our collection, retention, or sale of personal information. The financial incentive offered is a discount on the price of Products and Services, based on continued patronage of our Services, or affiliation with an affiliate with which we partner. The categories of personal information that are implicated by the financial incentive or price or service difference include identifiers such as name, email addresses, phone number, commercial information and internet activity like purchasing, consuming, and browsing histories.

The amount of financial incentive is calculated based on a reasonable and good-faith estimate of the value derived from developing new products and services with the assistance of consumer information, which forms the basis for offering such financial incentives.

You may enroll in or withdraw from our financial incentive program at any time by updating your preferences on-line or contact [email protected].


PEBLLA, INC. California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA.

Personal Information Collection, Disclosure, and Sale

For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, or sold in the preceding twelve months since this notice was last updated. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

Category We Collect We Disclose We Sell

Identifiers
Name, email address, address

Yes Yes No

Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)
Name, address, telephone number

Yes Yes No

Characteristics of Protected Classifications under California or Federal Law
Examples:
Race or color, ancestry or national origin, religion or creed, age (over 40), mental or physical disability, sex (including gender and pregnancy, childbirth, breastfeeding or related medical conditions), sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military and veteran status.

No No No

Commercial Information
products or services purchased histories

Yes Yes No

Biometric Information
Examples:
Physiological, biological, or behavioral characteristics, including DNA, that can be used, singly or in combination with each other or with other identifying data, to establish individual identity, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.

No No No

Internet or Other Electronic Network Activity Information
Examples:
Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.

No No No

Geolocation Data
Example: Precise physical location.

Yes Yes No

Sensory Information
Examples:
Audio, electronic, visual, thermal, olfactory, or similar information.

No No No

Professional or Employment-Related Information
Examples:
Job application or resume information, past and current job history, and job performance information.

No No No

Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)
Examples:
Records that are directly related to a student maintained by an educational agency or institution or by a party acting for the agency or institution.

No No No

Inferences Drawn from Personal Information
Examples:
Consumer profiles reflecting a consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

No No No

How We Use Your Personal Information

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:

Providing Services:
Providing our services.

Communicating:
Communicating with you, providing you with updates and other information relating to our services and products, providing information that you request, responding to comments and questions, and otherwise providing customer support.

Social Network Support:
Updating your status on social networks, sending messages on your behalf to your social networks, and providing other features and services to you.

Connecting Third Party Services:
Facilitating the connection of third-party services or applications, such as social networks.

Marketing:
Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.

Personalization:
Personalizing your experience on our services, such as presenting tailored content.

Sending Messages:
Sending you text messages or push notifications.

Facilitating Payments:
Facilitating and maintaining records of transactions and payments.

Deidentification and Aggregation:
Deidentifying and aggregating information collected through our services and using it for lawful purposes.

Job Applications:
Processing your job application.

Safety Issues:
Responding to trust and safety issues that may arise.

Compliance:
For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

Auditing Interactions:
Auditing related to your interaction with our services and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with other standards.

Fraud and Incident Prevention:
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

Debugging:
Debugging to identify and repair errors that impair existing intended functionality.

Transient Use:
Short-term, transient use.

Contracting Vendors:
Contracting with vendors and service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytics services, or providing similar services on behalf of the business or service provider.

Improving Our Services:
Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.

Enabling Transactions:
Otherwise enabling or effecting, directly or indirectly, a commercial transaction.

Notified Purpose:
For other purposes for which we provide specific notice at the time the information is collected.

Collection of Personal Information

In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:

You/Your Devices: You or your devices directly.

Users: Users of our services.

Affiliates.

Advertising Networks.

ISPs: Internet service providers.

Analytics Providers.

OS/Platform Provider: Operating systems and platforms.

Social Networks.

Partners: Business affiliates/partners.

Public: Publicly accessible sources.

Disclosure of Personal Information

In the preceding twelve months since this notice was last updated, we disclosed Personal Information to the following categories of third parties:

Vendors: Vendors and service providers.

Personal Information we share: Name, phone number, e-mail address.

Your California Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you during the past twelve months.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you. Click here to request deletion of your Personal Information.

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please authenticate your account by logging into your account.

Right to Opt Out. We do not sell your Personal Information.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations. You may opt in to certain financial incentive programs we may offer related to the collection, retention, or sale of your Personal Information. Please see our Notice of Financial Incentive.

Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light” law (Civil Code § 1798.83), unless we have your permission.

Submit Requests. To exercise your rights under the CCPA, please send an email to [email protected] or visit our website.

Authorizing an Agent. If you are acting as an authorized agent to make a request to know, delete, or opt out on behalf of a California resident, please attach a written authorization signed by the resident.

Do Not Track

There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

Contact Information

If you have any questions, comments, or concerns about this notice or our processing activities please email us at [email protected].

Last Reviewed and Updated: [October 26, 2023]