Finding Rover Privacy Policy

Effective on: July 20, 2013

Last updated on: July 20, 2013

INTRODUCTION

1.1 ABOUT FINDING ROVER
Finding Rover offers a pet facial recognition technology to help identify lost pets using mobile devices. Finding Rover also provides safety, health, and educational information for pet owners along with products, information and special offers from Finding Rover and our selected business partners.

1.2 PURPOSE OF POLICY
Finding Rover is committed to respecting the privacy rights of its customers, visitors, and other users of our services. We created this Website Privacy Policy (“Privacy Policy”) to give you confidence as you visit and use the Site, and to demonstrate our commitment to fair information practices and the protection of privacy. This Privacy Policy is only applicable to the Site, and not to any other websites that you may be able to access from the Site, each of which may have data collection and use practices and policies that differ materially from this policy.

All Finding Rover products and services are governed by this Privacy Policy. By using or accessing any Finding Rover service you expressly consent to the collection, processing, use and disclosure of your personal information and data. Please do not use any Finding Rover service if you disagree with this Privacy Policy.

1.3 NOTICE CONCERNING CHILDREN
We do not direct any of our content at, nor do we knowingly collect personal information from, children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If we learn or have reason to suspect that a Site user is under the age of 13, we will promptly delete any personal information in that user’s account.

INFORMATION AND DATA COLLECTION PRACTICES

2.1 BASIC DATA COLLECTTON
Finding Rover collects personally identifiable information (“Personal Information”) that is specifically and voluntarily provided by visitors. Finding Rover is most likely collect personally Personal Information about you in the following instances:

(a) INFORMATION YOU PROVIDE. Finding Rover will collect and store any Personal Information you enter on our mobile applications (“mobile app”), website or provide to us in some other manner. We may collect your information when you register for our services, request information from us, or otherwise submit personal data, in any manner, for the purpose of using or accessing Finding Rover services. Other situations where you may make, or be requested to provide, personal data include, but is not limited to, responding to surveys, assessments, questionnaires, if you ask Finding Rover to resolve a dispute, or if you request information about products and services offered by Finding Rover.

(b) CATEGORIES OF PERSONAL INFORMATION. Personal Information includes, but is not limited to, (a) contact information such as your full name, mailing address, phone number, and e-mail address; (b) financial information, including billing address, social security number, banking information, and credit card information; and (c) profile information, such as interests, marital status, gender, age, household income level, and other identifiers that permit the physical or online contacting of a specific individual.

(c) LOCATION SERVICES. To the extent Finding Rover makes location enabled services available, Finding Rover may collect location information and share it with its partners and contractors for the purpose of providing location-specific services.

(d) INFORMATION FROM OUTSIDE SOURCES. Other entities may collect Personal Information from or about you and provide it to Finding Rover. For example, veterinary clinics, animal shelters, pet stores, retailers, and other entities, may with your approval create a temporary registration for your pet with Finding Rover.

(e) INFORMATION ABOUT OTHERS. Finding Rover will also collect and store Personal Information about other people that you provide to us. For example, if you list someone other than yourself as a point of contact, we will collect and store that information. We will also collect information about your pet, such as name, age, weight, mix, sex, breed, and microchip number.

2.2 WHAT ADDITIONAL INFORMATION DOES FINDING ROVER COLLECT
(a) COOKIES AND LOG FILES. Our website and mobile apps will automatically collect information from or about your computer or mobile device when you visit, such as your browser type, the website you came from (known as the referring URL), the time and date of your access, your Internet Protocol (“IP”) address, hardware, device identification, and software.

Finding Rover also collects information through cookies and other technologies to help Finding Rover store your interactions. If you have shared Personal Information, such as an e-mail address or username, we will include a portion of this information in a cookie so that Finding Rover can recognize you and remember your selections when you return to our website. Please note that your web browser can be set to allow you to control whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent.

Finding Rover uses standard Internet technology, such as Internet tags (also known as web beacons, action tags, or GIFs) in combination with cookies at our website and on our mobile apps and may deploy these tags through an advertising company. These tags are placed on both online advertisements that bring members to our website and on different pages within our website. Finding Rover uses this technology to measure members’ responses to our advertising campaigns (including how many times a page is opened and which information is consulted).

Cookies or internet tags may also be used within certain e-mail communications or in conjunction with such communications sent by us or our business partners for the purpose of tracking whether a promotion was viewed by the e-mail recipient or someone the e-mail was referred to.

USE AND SHARING OF INFORMATION

3.1 WHAT DOES FINDING ROVER DO WITH COLLECTED INFORMATION?
(a) USES OF INFORMATION. Finding Rover will use the Personal Information and other information we collect to enroll you or renew your membership in Finding Rover programs and services, fulfill your requests for information, products or services, provide you with product support and answer your questions, manage and provide you with access to your account and our website, analyze use of Finding Rover programs and services, develop new products and services, and customize our products, services and other information we make available, periodically communicate with you about your account and/or about special offers related to the Finding Rover programs and services, and/or enforce the terms and conditions of Finding Rover mobile apps and our website.

(b) DISCLOSURES OF INFORMATION. Finding Rover will not sell or rent any Personal Information (including e-mail address) we collect. We may share your information with Finding Rover service providers in order to deliver or advertise the services, products, and information offered by Finding Rover. Finding Rover is not liable for the acts or omissions of these third parties.

These service providers include, but are not necessarily limited to:

Pet facial recognition identification and recovery service that contacts members of lost pets during the facial recognition identification and recovery process,
The animal shelters, veterinary clinics, and animal welfare organizations that provide care until the lost pet is returned to its owners, and other providers who help us deliver (or provide the technical support for) our services,
Finding Rover programs and services, including membership, customer communications, call centers, mobile apps and the website.
In addition, we may share your Personal Information with carefully selected business partners so we may communicate with you about special offers related to Finding Rover programs or contests that may be of interest to you. These business partners will only be authorized to use your Personal Information for marketing purposes related to pet products, safety and health, and contests. These companies may include subsidiaries, affiliates, marketing partners, market research companies, advertisers, and data aggregators.

(c) OTHER DISCLOSURES: Finding Rover will disclose your information as required by law and when Finding Rover believes that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on us. Also, we will disclose your information in connection with a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation or asset sale, or in the unlikely event of bankruptcy.

MEMBER CHOICES & RIGHTS

4.1 E-MAIL OFFERS
You as a member have a choice about the receipt of special e-mail offers. Once you register for Finding Rover programs and services, you will be presented at that time with the option to opt-out of receiving promotional emails. Please note that regardless of the choices you make about the receipt of special e-mail offers, we will continue to provide you with service-related e-mail announcements. We also will continue to send you information about special offers and other information relating to Finding Rover by postal mail. This is an essential component of Finding Rover and a condition of your membership.

4.2 OPT-OUT POLICY
You may opt-out of the disclosure of Personal Information to third parties, including information that may be used for their direct marketing purposes. You may opt-out at any time by submitting a request in writing to Finding Rover at the following address: Attn: John Polimeno, PO Box 705, Byron CA 94514.

4.3 ACCESSING AND UPDATING YOUR INFORMATION
Finding Rover provides several options for reviewing, removing, correcting, updating or otherwise modifying information you have previously provided. For example, you may update your personal information through your online account, or by contacting us using the information in the Contact Us section of this Privacy Policy below.

SECURITY AND COMPLIANCE

We maintain reasonable and appropriate technical, administrative and physical safeguards to protect Personal Information from loss, misuse, or alteration. Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) to protect out rights or property; or (c) enforce our Terms of Use.

WEBSITE AREAS BEYOND FINDING ROVER’S CONTROL

6.1 PUBLIC FORUMS
The Site may include interactive forums such as message boards and chat rooms. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your Personal Information.

6.2 PRIVACY PRACTICES OF OTHER SITES AND ENTITIES:
Please note that the Finding Rover mobile apps and website may contain information about and links to other sites that are not owned or controlled by Finding Rover. If you click on a link provided on our Mobile app or Web site, you will be directed to a Web site that operates under a different Privacy Policy. Finding Rover is not responsible for the privacy practices of other sites or entities. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information.

CHANGES TO THIS PRIVACY POLICY

We reserve the right, at any time, to add to, change, update, or modify this Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site. It is your responsibility to review this Privacy Policy from time to time to ensure that you continue to agree with all of its terms. You can determine whether the Privacy Policy has changed by reviewing the effective date posted at the top. Your continued use of Finding Rover services will signify your acceptance of any changes to this Privacy Policy.

CONTACT US

For inquiries or complaints about this Policy, please contact Finding Rover through the following address: Attn: John Polimeno, PO Box 705, Byron CA 94514. This Privacy Policy is governed by the laws of the State of California, USA.

FINDING ROVER SAFE HARBOR POLICY

To learn more about our privacy practices, see our general Privacy Policy.

Finding Rover complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the European Union member countries and Switzerland. Finding Rover has certified that it adheres to the Safe Harbor Privacy Principles (“Principles”) of notice, choice, onward transfer, security, data integrity, access, and enforcement. Moreover, Finding Rover fully commits to follow the Safe Harbor Principles and the 15 related FAQs that make up the U.S.-EU and U.S.-Swiss Safe Harbor Frameworks with respect to all personal data received from any individual or entity in the EU, the EEA or Switzerland. To learn more about the Safe Harbor program, and to view Finding Rover’s certification, please visit http://export.gov/safeharbor/.

This Safe Harbor Policy (“Policy”) outlines our general practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information.

SCOPE

This Policy applies to all personal information received by Finding Rover in the United States, whether in electronic, paper or verbal format, from the European Economic Area (“EEA”) and from Switzerland, in any format, including electronic, paper or verbal.

DEFINITIONS

“Personal Information” or “Information” means information that (1) is trans­ferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosoph­ical beliefs, trade union membership or that concerns an individual’s health.

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, Finding Rover or to which Finding Rover discloses personal information for use on Finding Rover’s behalf.

“Finding Rover” means Finding Rover Inc., its predecessors, successors, subsidiaries, divisions and groups in the United States.

PRINCIPLES

Notice

Finding Rover shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which Finding Rover discloses or may disclose that Information. Finding Rover shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Per­sonal Information to Finding Rover, or as soon as practicable thereafter, and in any event before Finding Rover uses or discloses the Information for a pur­pose other than for which it was originally collected.

Choice

Finding Rover will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was origi­nally collected or subsequently authorized by the individual. For Sensitive Personal Information, Finding Rover will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the informa­tion for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Finding Rover shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

Onward Transfers

Prior to disclosing Personal Information to a third party, Finding Rover shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Finding Rover shall ensure that any third party for which Per­sonal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Prin­ciples and agree in writing to provide an adequate level of privacy protection.

Data Security

Finding Rover shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Finding Rover has put in place appropriate physical, electronic and manage­rial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Finding Rover cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity

Finding Rover shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Finding Rover shall take reasonable steps to ensure that Personal Information is accurate, com­plete, current and reliable for its intended use.

Access

Finding Rover shall allow an individual access to their Personal Information and al­low the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated.

Enforcement

Finding Rover uses a self-assessment approach to assure compliance with this privacy policy and periodically verifies that the policy is accurate, compre­hensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Princi­ples. We encourage interested persons to raise any concerns using the con­tact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Informa­tion in accordance with the Principles. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using the American Arbitration Association (“AAA”) for mediation and then if necessary, to binding arbitration for final resolution. Information about AAA services can be found at its website: www.adr.org.

AMENDMENTST

This privacy policy may be amended from time to time consistent with the re­quirements of the Safe Harbor. We will post any revised policy on this website.

INFORMATION SUBJECT TO OTHER POLICIES

The Finding Rover is committed to following the Principles for all Personal Infor­mation within the scope of the Safe Harbor Agreement. However, certain information is subject to policies of Finding Rover that may differ in some respects from the general policies set forth in this privacy policy.

CONTACT INFORMATION

Questions, comments or complaints regarding the Finding Rover’s Safe Harbor Poli­cy or data collection and processing practices can be mailed or emailed to:

Finding Rover
Attn: John Polimeno
PO Box 705
Byron CA 94514

Effective date: July 1, 2013