Pallo Privacy Policy

ThisPrivacy Policy governs the manner in which BMG Technologies Inc. (dba Pallo)and its affiliates (collectively, “Pallo,” “we,” “our,” or“us”) collect, use, maintain and disclose information collected fromusers (a “user,” as well as “you,” “your” and similar terms) through ourwebsite www.pallo.com, our mobileapplication, as well as any other online services that we operate and that linkto this Privacy Policy (collectively, the “Online Resources”).

Byusing the website or any of the Online Resources, you signify your acceptanceof this Privacy Policy. If you do not agree to this Privacy Policy, please donot use the Online Resources.

What Information Do We Collect and How Do We Collect It?

Pallo strives to be fair and open about the way we collect information about you and what we intend to do with the information.

If you choose to use any of our Online Resources, we may collect all or any of the following information:

Personal Information. “Personal Information” or “PII” is information and documentation that you provide to us that can be used to identify you, members of your family, other dependents or your business. We respect your privacy and we recognize the importance of protecting Personal Information collected about you. We collect Personal Information from you that you voluntarily provide to us or permit us to obtain when you contact or interact with us, to request or utilize our services (including, without limitation, in connection with preparing and filing your tax returns) and, more generally, in connection with other activities, services, features or resources we make available through the Online Resources, or otherwise, from time to time. In addition, we may receive Personal Information about you, your family members and dependents and/or your business from other persons, entities and government agencies that share such information with us.

Core to Pallo’s business is supporting its users. This is not limited to helping you with your tax and accounting work, either personally or as part of your business. In order to provide you with our services, Pallo may collect any or all of the following information (without limitation) either directly from you or from other sources with your consent. This is not limited to:

Contact information (e.g., name, address, phone number, e-mail address, IP address)
Tax identification number (e.g., Social Security number (SSN), individual tax identification number (ITIN), employer identification number (EIN))
Other government identification numbers (e.g., driver’s license number)
Credit scores
Date of birth
Financial account information (e.g., account number, routing number)
Employment or other professional information
Demographic information
Geo-location information
Vehicle Information
Location Names that may or may not be named by you that may allow for easier start and end point identification
Work Hours
Health insurance and healthcare expense information
Information regarding household employees
Information regarding income, gains, deductions, expenses, losses and credits
Information regarding investments (e.g., identifying numbers, tax basis, holding period)
Other tax return information
Spending patterns
Account amounts, including changes and trends in such amounts

We may also collect certain biometric information, such photos, facial scans, or fingerprints, in order to secure your account. Our collection and use of such biometric information is governed by our Terms of Service.

Finally, Personal Information also includes financial account information, such as bank account or credit card information, that you may voluntarily provide to us if you are purchasing one of our products or services, including a subscription service. Providing such information to us is governed by our Terms of Service. We do not maintain or store any such financial account information; instead, when you provide that information to purchase one of our products or services, the payment information is processed through a third-party provider. We only use providers that we understand adhere to appropriate industry standards (such as Payment Card Industry Data Security Standards, or PCI-DSS).

Aggregate Information. “Aggregate Information” is information that cannot be used to identify you, such as the type of browser and computer or mobile device you are using, technical information about your means of connecting to our Online Resources (e.g., the operating system and the Internet or mobile service providers utilized), information about other websites you have recently visited, your site activity, and the time and date of your visit, and other similar information. Aggregate Information may be collected when you visit or interact with our Online Resources, independent of any information you voluntarily enter.

Tracking Technologies.

a) Cookies. A cookie is a datafile placed on a device (such as your computer or smartphone) when it is used to visit our Online Resources. Cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some but not all instances can be blocked in the future by selecting certain settings. Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard. Please be aware that if you disable or remove cookies on your device, some parts of our Online Resources might not function properly, and that when you revisit our Online Resources your ability to limit cookies is subject to your browser settings and limitations.
b) Web Beacons. A web beacons is apiece of code embedded in our Online Resources that collects information about engagement on our Online Resources or emails.
External links from our Online Resources may have their own tracking technologies which they may include in their privacy policy.

What Do We Do with the Information We Collect?

Personal Information. We use Personal Information only as permitted or required by law, for the purposes of providing our services and products to you (which services and products may be provided by us or by a service provider acting for us) or communicating with you, both about the services we are providing you and to market other services to you. We will not use your Personal Information for any other reason, except to the extent that you consent for us to do so, and in any event only as provided pursuant to this Privacy Policy. We limit access to Personal Information only to those individuals whose responsibility it is to address the user’s specific request. We may use third party processor to process any financial account information you provide to us, although some features allow for you to process financial account information directly without the use of third-party providers. When any such financial account information is accessed or processed by third parties, third parties only access or process your information to provide the services you have requested.
We may also analyze your Personal Information for analytical purposes, to improve our algorithms in order to improve the services we provide you, to develop new products and services, and to market additional services that may be relevant to you. Section 7216 of the U.S. Internal Revenue Code of 1986, as amended, and the U.S. Treasury regulations and other administrative guidance promulgated thereunder, requires that we obtain your consent to the disclosure and use of Personal Information that you provide to us in connection with the preparation and filing of your tax returns. We will not disclose such Personal Information for any purpose other than preparing, assisting in preparing or obtaining or providing services in connection with the preparation of your tax returns unless you authorize us to do so (except when expressly required or authorized by law or pursuant to court order).

Aggregate Information. We use Aggregate Information for a variety of purposes, such as to understand how our users as a group use the Online Resources, to improve the Online Resources, to personalize user experience, and to process transactions. We also use Aggregate Information to track numbers of visitors to our site and numbers of visitors to various sections of our site for the purpose of determining trends and user needs. Aggregate information is analyzed and used as input to help us improve our site. No personally identifiable information is available or used in this process.

We use Tracking Technologies for the following purposes:

when it is operationally necessary for us to provide you with access to our Online Resources. This also includes tracking behavior in order to protect against irregular, fraudulent, or possibly illegal behavior on our Online Resources.
to assess the performance of how you use our Online Resources
to enhance the functionality of our Online Resources. This includes but is not limited to identifying you when you sign into our Online Resources and keeping track of your preferences, interests, financial behavior or past items viewed
to target our advertising to you using Tracking Technologies that we or our third-party partners place on our Site or other websites

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When Do We Provide Information to Third Parties?

Service Providers. We may use third party service providers to perform certain services on our behalf on the Online Resources, such as hosting the Online Resources, tracking the Online Resources’ activities and analytics, and performing other administrative services. We also use third party processor to process any financial account information you provide to us if you purchase our services for the purposes of fulfilling the transactions you have requested, and to assist us in analyzing your personal information so we can improve our services and market services that may be relevant to you. We may provide these service providers with access to user information, including Personal Information, solely to the extent necessary to carry out the services they are performing. These third-party service providers are not authorized to retain, share, store or use the Personal Information for any purposes other than to provide the services they have been hired to provide.
In some circumstances, you may provide your information to Pallo through our partners and affiliates. Please note that you are subject to any applicable terms of use that our partners and affiliates may employ, and that your personal information is also subject to the terms of their applicable privacy policies. Pallo makes no representations regarding partner terms and policies, and takes no responsibility for their terms. If you have any questions or concerns regarding the terms of use or privacy policies of our partners and affiliates, please contact them directly.
We may use your Financial Information to generate offers for financial products and services from our marketing partners that may be of interest to you. It is always your choice whether or not to apply for an offered product or service and we will never submit an application for a financial product or service on your behalf without your express consent. If you choose to pursue any of the offers that the Services present to you, you may be asked if you would like the Services to pass on your PII and relevant Financial Information to the third-party marketing partner as a convenience. For example, if the Services generate an offer from a third-party loan provider for you, the Services may give you the option of moving forward with that offer within the App, and if you agree to do so, the Services will pass your PII and relevant Financial Information to that third-party loan provider to speed up the process of your application.
Pallo uses Plaid Inc. (“Plaid”) to gather your data from financial institutions. By using our Online Resources, you grant Pallo and Plaid the right, power, and authority to act on your behalf to access and transmit your personal and financial information from your relevant financial institution. You agree to your personal and financial information being transferred, stored, and processed by Plaid in accordance with the Plaid end user privacy policy, available at https://plaid.com/legal/#end-user-privacy-policy.

Pallo utilizes Google for its maps platform as well as its analytics to collect and use cookies and identifiers for mobile devices pursuant to your use of our Online Resources. This enables processing of data with Google subject to Google’s privacy policy https://policies.google.com/privacy or any other URL Google may provide from time to time. Pallo does not control Google’s collection or use of any such information and you agree to your personal information being transferred, stored, and processed by Google.

Taxing Authorities. We may be required to disclose certain Personal Information and Aggregate Information to the U.S. Internal Revenue Service and state, local and other taxing authorities in order to file and/or process your tax returns.
Analytics. We use analytics services to help us understand how users use our Online Resources, so that we may improve and market our services.

Without limiting the above, we may access, use, preserve, transfer and disclose your Personal Information to third parties: (i) to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process if in our good faith opinion such is required or permitted by law; (ii) to protect and/or defend the policies applicable to the Online Resources, including investigation of potential violations thereof; (iii) to protect the safety, rights, property or security of the Online Resources or any third party; and/or (iv) to detect, prevent or otherwise address fraud, security or technical issues.

We reserve the right to disclose and transfer all user information: (a) to a subsequent owner, co-owner or operator of the Online Resources or applicable database; or (b) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.

Do You Retain and Delete My Data?

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. In some circumstances, we may anonymize your Personal Information so that it can no longer be associated with you, in which case it is no longer Personal Information. We will retain, destroy, or dispose of your data in accordance with our data retention policy, consistent with applicable law.

Will You Contact me by Phone or Email?

We may send you certain communications relating to use of our Online Resources, such as administrative and service announcements, via email, phone, or text (including SMS).

We may also market our services through the use of email, phone or text. This may include inviting you to participate in a referral or marketing program.

You may opt out of email communications at any time. We will not contact you via phone or text unless you explicitly consent to such communications. You may opt out of email, phone, and text communications at any time, including by contacting us at support@pallo.com.

How Do I Change My Information and Communications Preferences?

You are responsible for maintaining the accuracy of the information you submit to us. You may provide updates and changes by contacting us at support@pallo.com. If so, we will make good faith efforts to make requested changes in our then-active databases as soon as reasonably practicable.

What if I am Using Pallo on Behalf of a Business?

If you are using Pallo on behalf of a business, you are responsible to obtain all appropriate consents and authorizations to collect and enter Personal Information through the Online Resources. Pallo is not responsible for any failure to obtain such consents and authorizations, and by using the Online Resources in this way, you are representing that you have all lawful and appropriate bases to obtain and provide the Personal Information of other parties.

What Should Parents Know About Children?

We do not knowingly collect any Personal Information from individuals younger than the age of eighteen (18). We will delete any Personal Information collected that we later determine to be from a user younger than the age of eighteen (18). If you are a parent or guardian of a child under the age of eighteen (18) and believe he or she has disclosed Personal Information to us, please contact us at support@pallo.com.

What About Security?

Pallo is deeply committed to the integrity and security of your and your Personal Information. Pallo uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of Personal Information. However, we cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use Personal Information for improper purposes. You acknowledge that you provide Personal Information at your own risk.

Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to the owner’s or operator’s privacy policy. We’re not responsible for the content, privacy, or security practices and policies of any Third-party Service. To protect your information, we recommend that you carefully review the privacy policies of all Third-party Services that you access.

Please note that your PII may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide your PII to us, we may transfer your PII to the United States and process it there.

What if I am a California Resident?

Although Pallo does business in California, as of the date of this Privacy Policy we are not subject to the California Consumer Privacy Act (CCPA).

Nevertheless, if you are a California resident, please be advised that we do not sell your information (as the word “sale” or “sell” is defined under the CCPA). Further, we will honor the following rights, subject to reasonable limitations consistent with our lawful and legitimate business needs and interests:

Your request for access to Personal Information that we possess that pertains to you;

Your request that we delete any Personal Information that pertains to you.

To request access to your Personal Information or deletion of your Personal Information, please contact support@pallo.com. Once we have received your request, we will respond to you promptly to confirm your request and to advise you of the actions we will take in response to your request.

We do not honor “do not track” signals.

We authorize the collection of personally identifiable information from our users for third party use through advertising technologies.

What if I am in the UK, the European Union, or Switzerland?

Pallo does not have an establishment in the UK, the European Union or Switzerland; it monitors data subjects in those jurisdictions; and it does not market its Services in those jurisdictions. Pallo is thus not subject to the General Data Protection Regulation (GDPR) or any other data protection law in these jurisdictions.

Nevertheless, individuals from these jurisdictions should be aware that any data provided to us is transmitted to and processed in data centers located in the United States

Although we are not subject to these (or any non-U.S.) data protection laws, if you are a resident in these jurisdictions, we will honor the following rights, subject to reasonable limitations consistent with our lawful and legitimate business needs and interests:

Your request for an accounting of all Personal Information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).
Your request that we correct or update any Personal Information that pertains to you;

Your request that we delete any Personal Information that pertains to you; and
Your full or partial withdrawal of your consent to the collection, processing, and/or transfer of your Personal Information.

To request an accounting of your Personal Information, a correction or update to your Personal Information, deletion of your Personal Information, or to withdraw your consent to the collection, processing, and/or transfer of your Personal Information, please contact support@pallo.com. Once we have received notification that you withdraw your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

Will This Policy Change?

We reserve the right to change this Privacy Policy at any time without notice to you. Any changes will be effective immediately upon the posting of the revised Privacy Policy. Your continued use of the Online Resources following the posting of revisions to this Privacy Policy will be deemed your acceptance of such revisions. We encourage users to frequently check the email account that they use in connection with the Online Resources, as well as this Privacy Policy, to stay informed about any changes to this Privacy Policy. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically. The date at the bottom of this Privacy Policy will be updated for each revision.

Miscellaneous

This Privacy Policy will be governed by and construed in accordance with the laws of the State of New York, USA, without regard to conflicts of law principles. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

Questions or Concerns

You may direct any questions or concerns regarding the use or disclosure of your information, or any other matter related to this Privacy Policy, to support@pallo.com.

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Last Updated: August 2022