WE ARE POOSHLO. This Privacy Policy (“Policy”) describes how POOSHLO (“Company”, “Pooshlo”, “we”, “us”, or “our”) collect, use, and share in connection with the Pooshlo website at https://pooshlo.com/ (the “Site”) and our mobile application (the “Application”), as described in our Terms of Service (collectively, the “Services”). 

By accessing or using our Services you acknowledge that you read, understood and accept this Privacy Policy and consent to the collection, use and disclosure of your personal information as detailed herein. If you do not agree with any part of this Privacy Policy, you should immediately discontinue your use of the Services.

About the Services. As indicated in the Terms of Use, Pooshlo is a technology platform that connects brands and/or agencies with influencers. Through the Services, brands or agencies may create marketing campaigns with an allocated budget and assign specific tasks to influencers, such as liking, commenting, reposting, or engaging in other interactions on third-party platforms.

Influencers may participate in such campaigns and receive monetary compensation for each completed action. Pooshlo acts solely as a technological intermediary that facilitates and orchestrates interactions within the platform and does not act as an employer, agent, or representative of any user.

The Services are intended for mixed use, including business-to-business (B2B) and business-to-consumer (B2C) interactions.

Collection of your Personal Information

1.  Information You Provide Us.

1.  “Personal Data” means data that allows someone to identify you individually, including, for example, your name, email address, as well as any other non-public information about you that is associated with or linked to any of the foregoing. 
2.  “Anonymous Data” means data, including aggregated and de-identified data, that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons.

We collect Personal Data and Anonymous Data as described below. We may Personal Data such as your blockchain address, which may become associated with Personal Data when you use our Service. We may also collect Personal Data at other points in our Service where you voluntarily provide it or where we state that Personal Data is being collected. We may also collect Anonymous Data. 

The following sections describe the types of information we may collect from users of the Services (“Users”), including both influencers and brands or agencies. All such information is treated as Personal Data or Anonymous Data as defined above.
1. Data collected from Influencers. We may collect Personal Data and other information from influencers using the Services, which may include but is not limited to:
• Identification information (such as name, email, etc.)
• Information about your social media accounts
• Social media accounts linked to the platform
• Audience metrics (for example, age ranges, interests, or type of audience)
• Type of content published
• History of collaborations with brands
• Work preferences (such as brands or tasks accepted or declined)
• Information obtained through third-party APIs (for example, Meta platforms)

1.  We may collect Personal Data and other information form brands and agencies using the Services, which may include, but is not limited to:
•   Identification and contact information
•   Commercial information about the brand
•   Type of products or services offered
•   Target audience information
•   Information about campaigns created on Pooshlo
•   Budgets assigned and usage within the platform
•   Behavior and usage data within the Services

Personal Data also includes photos and/or videos that you upload to our Site or Application. Please note that we might store them in our systems including the metadata that may be associated with your photos and (or) videos by default (including, for example, geotags). We can access your photos and videos only after you grant us permission to access your camera or your devices’ photo library. You provide such  permission through the request that it appears on your mobile device (it may differ depending on your device operating system). You may revoke permission to access your camera or photo library through the settings on your mobile device, 

B. Information We Get From Third Parties. We may get Personal and/or Anonymous Data information about you from other sources such as third-party wallet providers giving us your blockchain address and other information you choose to share with those wallet providers. We may add this to information we get from this Site and through our Service.

C. Social Media Connections and Third Parties APIs. If you choose to connect your account with third-party platforms, such as social media networks, we may collect information from those platforms in accordance with the permissions you grant and the applicable third-party policies. Such information may include account data, metrics, and other information made available through third-party APIs. We process this information solely for the purposes described in this Privacy Policy and subject to the limitations imposed by such third parties

D. Information Automatically Collected. We may automatically collect information about your computer hardware and software as you navigate through and interact with our Service. We may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
1. To provide our Service and make it more useful to you, we (or a third-party service provider) collect information from you, including, but not limited to, your browser type, operating system, Internet Protocol (“IP”) address, mobile device ID, blockchain address, wallet type, and date/time stamps.
2. As is true of most websites and applications, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamps, and clickstream data. We use this information to analyze trends, administer the Service, track users’ movements around the Service, and better tailor our Services to our users’ needs. For example, some of the information may be collected so that when you visit the Service, it will recognize you and the information can be used to personalize your experience.
3. Like many online services, we use cookies to collect information. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to analyze how users interact with our Service, make improvements to our product quality, and provide users with a more personalized experience.
4. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags allow us to analyze how users find our Service, make the Service more useful to you, and tailor your experience with us to meet your particular interests and needs.
5. How We Respond to Do Not Track Signals: Our systems do not currently recognize “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our site.
6. In addition to the tracking technologies we place like Cookies and Pixel Tags, other companies may set their own cookies or similar tools when you visit our Service. This includes third-party analytics services (“Analytics Services”) that we engage to help analyze how users use the Service. The information generated by the Cookies or other technologies about your use of our Service (the “Analytics Information”) is transmitted to the Analytics Services. The Analytics Services use Analytics Information to compile reports on user activity, which we may receive on an individual or aggregate basis. We use the information we get from Analytics Services to improve our Service. The Analytics Services may also transfer information to third parties where required to do so by law, or where such third parties process Analytics Information on their behalf. Each Analytics Services’ ability to use and share Analytics Information is restricted by such Analytics Services’ terms of use and privacy policy. By using our Service, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above.
• Device information: Information about your mobile device and internet connection, including your IP address, the device’s unique device identifier, operating system, and mobile network information.
• Usage details: Details of your use of Services, including frequency of use, areas and features of the application that you access and engagement with particular features. This information is used for in-app event analytics and, upon your consent, for marketing purposes.
1. (If you have provided your consent) IDFA or Android Advertising ID, whichever is applicable to your device. If you want to disable the collection of IDFA and/or Android Advertising ID by Pooshlo, please follow the instructions below.
1. If you use an iOS device:
2. Details about your in-app purchases. This data is used to provide you with the Services and for our in-app analytics.
Such automatically collected data helps us operate our Services and improve it to deliver better service, including but not limited to enabling us to estimate our audience size, and understand how you use our Services and what you like and dislike the most.
We encourage you to review the privacy statements of websites you choose to link to from us so that you can understand how those websites collect, use and share your information. We are not responsible for the privacy statements or other content on websites outside of our Site or Application.

E. Payment information.
Payments made through the Services are processed by third party payment services providers. Pooshlo does not collect, store, or process full credit card or debit card information. Payment information is provided directly to the applicable third-party payment provider and is subject to that provider´s privacy policy and security practices, which we are not responsible for. 

Use of your Personal Information
We may collect and use your personal information to operate its Site or Application and deliver the Services you have requested. We may use your Personal Data as follows, but not limited to:

1.  Creating, managing and execution campaigns.
2.  Operating and maintaining the Services;
3.  Assigning tasks and facilitating interactions between brands, agencies and influencers
4.  Analyzing compatibility between brands and influencers;
5.  Communicating with users regarding service-related matters, updates or support;
6.  Improving, optimizing and developing new features of the Servies;
7.  Complying with legal obligations and enforcing Terms of Services/Use
8.  For legal, protection, and safety purposes.
9.  Complying with laws.
10. Responding to lawful requests and legal processes.

protection of  rights and property of the company, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use
1. Sharing information with those who need it to do work for us.

We may also create aggregated or anonymized data from personal information for analytics and business purposes.

Infrastructure, Third-Party Service Providers and International Data Transfers
We rely on third-party service providers to operate, host, process, analyze, and support the Services. These third-party providers may process personal information on our behalf and include, without limitation, providers of cloud hosting, data storage, analytics, artificial intelligence, communications, and other technical infrastructure services.

Such service providers may include, but are not limited to:
1. Amazon Web Services (AWS)
2. Google Cloud
3. Apple
4. Microsoft Azure
5. OpenAI
6. Similar technology partners.

These third-party providers may process or store personal information in multiple jurisdictions, including jurisdictions outside of your country of residence. As a result, your personal information may be subject to international data transfers. Where required by applicable law, we rely on appropriate contractual safeguards and other lawful mechanisms to protect such transfers.

While we take reasonable steps to select service providers that apply appropriate data protection and security standards, each third-party provider processes personal information in accordance with its own privacy policies and internal practices, subject to applicable contractual arrangements.

Use of Cookies & Similar Technologies 
We use a variety of technologies to help us to deliver customized visitor experiences. We use Google analytics to collect information about your interaction with our website. We may use a technology called “cookies”, for example, to count the number of unique visitors to a web page and to develop other statistics about the use of the website.
A cookie is a text file that is placed on your hard disk by a web page server when it visits a website. They allow the site to “remember” your computer, but not specifically who is using it, and improve your user experience. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize our pages, a cookie helps us to recall your specific information on subsequent visits. This simplifies the process of recording your Personal Data. When you return to the same website, the information you previously provided can be retrieved, so you can easily use the features that you customized.

Security of your Personal Information
We care about the security of your information and use physical, administrative, and technological safeguards to preserve the integrity and security of information collected through our Service. However, no security system is impenetrable, and we cannot guarantee the security of our systems. In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.
You are responsible for the security of your digital wallet, and we urge you to take steps to ensure it is and remains secure. If you discover an issue related to your wallet, please contact your wallet provider.

Data Retention of your Personal Data
We may retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In general, We retain Personal Data for as long as your account remain active and as need to provide the Services. 

Following the cancellation or termination of your account, we may retain certain Personal Data for a reasonable period of time for legal, operational, security or compliance purposes. After such period, Personal Data will be deleted or anonymized in accordance with applicable laws and our internal data and retention policies. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Children’s Privacy
We do not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parents or guardian for permission to use this website.

Opt-Out & Unsubscribe
We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.
You can typically remove and reject cookies from our Site with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Site works for you.

Changes to this Privacy Policy
We will occasionally update this privacy policy to reflect company and customer feedback, at our sole decision. We encourage you to periodically review this privacy policy to be informed of how we are protecting your information. If we make any changes, we will change the Last Updated date above.

POOSHLO Contact Information
If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us by contacting: hello@pooshlo.com