PRIVACY AGREEMENT

Pally, (“Penpal Group Ltd” or“Company” or “we” or “us”) is committed to protecting and respecting your privacy. This Privacy Policy sets forth how personal information is collected and used through our Service, the Site, and the App (see definitions in our Terms of Service, incorporated herein by reference). Please read the following to understand our practices regarding personal information and how they affect you as you use our Service. This statement discloses our current privacy policies; if we make material changes to these policies, we will notify you via email. What Information is Collected? Pally and our Providers may collect the following personal information (“Personal Information”) from you in providing our Service and Programs: Contact Information such as name, email address, mailing address, phone number; Unique Identifiers such as user name, account number, password; Preferences such as product wish lists, order history, marketing preferences; Demographic information such as age, education, gender, interests and zip code; When you download and use our Services, we automatically collect information on the type of device you use, operating system version, and the device identifier. how does Pally protect your information? The security of your personal information is important to us. Pally uses encryption to protect your most sensitive Personal Information. Pally will never disclose this most sensitive information to others, except as necessary to deliver our Service and any Programs for which you enroll, or as required by law (see discussion below). In addition, Pally uses Secure Socket Layer (SSL) technology to protect the transmission of sensitive Personal Information through the Site and the App. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of even your most sensitive Personal Information. what does Pally do with your information? Subject to the limitations on disclosure of your most sensitive Personal Information discussed above, Pally may use and disclose your Personal Information (including your name, email address, mailing address, phone number, and information regarding your usage of our Service). To deliver to you any administrative notices, alerts and communications relevant to your use of the Service. For market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity. To third-party contractors or Providers to help with our operations and delivery of the Service. For example, we may give third-parties access to databases of user information, so that they can perform their services for us, including performing system maintenance, displaying personalized content, performing list analysis or management, or sending mailings for us from our advertisers. These third-parties are all subject to confidentiality agreements that restrict their use and disclosure of information they obtain through their relationship with Pally. To enforce our Terms of Service. To analyze usage of the Site and App and to improve the Service. We also may disclose your Personal Information to others whenever we obtain your consent (for example, through on option provided on our Site or App). In addition, we may, from time to time, offer promotions with various businesses, websites, mobile applications or third-parties, which may include opportunities for you to earn credit within your Pally account. Each such promotion will be subject to and governed by our Terms of Service, this Privacy Policy and any applicable rules or terms we may post online, include within e-mail or other communications or otherwise make available to you. To the extent you elect to participate in any such promotion or otherwise make any purchase subject to a promotion, we may share personal information such as your name, e-mail address, and other related information with the applicable third-party for the limited purpose of allowing the parties the make the promotion available and track participation within such promotion. We may also disclose your Personal Information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. If Pally is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information. changes to your personal information If your Personal Information changes, or if you no longer desire to use our Service, you may correct or update your Personal Information by making the change on your account page in the Site or the App or by emailing Customer Support at info@pally.co. CHANGES TO THIS POLICY We may change this Privacy Policy at any time, but we will give notice of any material change (or any notices that we are required to give you) on our Site and/or in email messages prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy policies and how they may affect you.


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