Last Update April 10, 2022
This Policy explains how we collect, use, protect, and disclose personally identifiable information and data (“Personal Information”) when you use the Palo website at https://palonow.com (“Site”, “Website”, “Web”) and associated mobile and other applications and services, any online purchase you make at our Site or any of our services (collectively, the “Services”).
This Policy also explains your choices for managing your Personal Information preferences, including your rights under the California Consumer Privacy Act (“CCPA”).
This Policy is subject to the Terms and Conditions which govern any Services. By accessing or using the Site or Services, you consent to and agree to be bound by this Policy and, depending on the Services, the relevant Terms and Conditions. If you are a resident of California, additional provisions may apply to you as set forth in Appendix A below.
Collecting Your Information
The Site is operated by Talentnook, Inc., dba Palo, which is the controller for all Personal Information collected through the Site and Services. This Policy applies only to the Site and Services.
Managing Your Information Preferences
You can request to review, correct, update, change, or delete the Personal Information you provided to us by sending email to firstname.lastname@example.org. We will respond to your requests within the time period specified by applicable law, or if no time period is specified, we will use reasonable efforts to respond within thirty (30) days of receipt of the request, subject to any limitations in applicable law.
For the avoidance of doubt, while we believe that the CCPA is not applicable to us at this time, we enable our users, to the extent possible and according to our discretionary judgment, to request to exercise some of the rights laid down in the CCPA. Please note that we reserve exclusive discretion as to whether to grant such requests. For further details please review Appendix A below. If you wish to opt-out of receiving email marketing communications, you can click the unsubscribe mechanism at the bottom of the email.
Information We Collect
1. Personal Information We Collect Directly From You
We may collect Personal Information that you choose to provide us, such as when you register for our Services, including name, address, phone number, email address, birthdate, school name, grade level, and a username and password for your account (collectively, “Registration Information”). When you sign up for our Services, you provide us consent to send marketing emails to you. If you wish to opt out/revoke consent, please send an email to email@example.com.
We may also collect Personal Information when you use, or make an online purchase via any of our Services. We collect information regarding your transactions at our Services (“Transaction Information”) which we may use for marketing and promotions, and to develop and improve our products and services.
From time to time, our Site may request Personal Information from you via surveys. Participation in these surveys is completely voluntary. Survey Personal Information will be collected and used for purposes of monitoring or improving the use, features, and performance of the Site and our other products and services.
2. Information We Collect Automatically
Geolocation: If you have provided permission through your mobile device to allow us to collect location information through the App, we may obtain your physical location information in terms of latitude and longitude from technologies like GPS, Wi-Fi, or cell tower proximity. You are able to withdraw your permission for us to acquire such physical location information from your mobile device through your mobile device settings, although we do not control this process. If you have questions about how to disable your mobile device’s location services, we recommend you contact your mobile device service provider or the mobile device manufacturer.
3. How We Use Your Information
We use your Personal Information for the following business purposes:
- To provide our Site and Services to you, including the ones you request at any of our services, to optimize and fulfill your online orders through our Site, to communicate with you about your use of our Site and Services, to respond to your inquiries, to process job applications, to fulfill your orders, and for other customer service purposes.
- To tailor the content and information that we may send or display to you, to offer location customization, personalized help and instructions, and to otherwise personalize your experiences while using our Site or Services.
- To notify you about marketing and promotional opportunities. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our Site and Services on third-party websites.
- To conduct promotions and giveaways.
- To better understand how users access and use our Site and Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.
4. How We Share Your Information
We may share your Personal Information as follows:
- Affiliates. We may disclose the Personal Information we collect from you to our affiliates; however, if we do so, their use and disclosure of your Personal information will be maintained by them in accordance with this Policy.
- Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, or if we are in negotiations with respect to any such transaction, we may transfer the Personal Information we have collected from you to the other company or legal entity.
- In Response to Legal Process. We also may disclose the Personal Information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena.
- To Protect Us and Others. We also may disclose the Personal Information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of any applicable Terms and Conditions for Services provided through this Site or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and De-Identified Information. We may share aggregate or de-identified Personal Information about users with third parties and publicly for marketing, advertising, research, or similar purposes.
Except as noted in this Section, we do not disclose Personal Information to third parties, including for their direct marketing purposes, without your consent, except as explained in this Policy.
5. Retention of Personal Information
We retain Personal Information about you for the time necessary to accomplish the purpose for which such information was collected, usually for the duration of any contractual relationship or as long as you use or are registered for any of the Services and for any period thereafter as legally required or permitted by applicable law. Our retention policies respect applicable statute of limitation periods and legal requirements.
You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies), but such disabling will impair use of the Site and Services.
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Services. There are two types of cookies: session and persistent cookies.
- Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
- Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. Visitors to our Site who disable cookies will not be able to browse certain areas of the Site or use the Services.
We maintain physical, technical, and administrative safeguards to protect the security of information transmitted to us through this Site or Services. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk. You are also responsible for maintaining the security of any password or user login credentials you are provided in connection with the Site or the Services, including your user login credentials for your account. You should use robust passwords that are not easily guessed. We are not responsible for any unauthorized use of your user login credentials, but you should notify us immediately if you are aware or suspect unauthorized use of your account.
8. Links to Other Websites
9. Children’s Privacy
NOTE TO PARENTS
Our Services are available for users of all ages, including those under 13 (“Children” or “Child”) with a legal parent/guardian consent. Please discuss this Policy with your Children so that they will better understand how to use the Services and the information they may be asked to provide when using the Services. Palo is committed to compliance with the Children’s Online Privacy Protection Act (“COPPA”). We encourage parents to take an active role in protecting their Children’s privacy and online experience at all times. Parents can learn more about how to protect children’s privacy online here.
Collection and Use of Children’s Personal Information
Palo may collect and store persistent identifiers (e.g., cookies, IP addresses, etc.) from Children without parental consent for the purpose of supporting the internal operations of the Service or as otherwise permitted under COPPA.
If a Service is directed to Children under COPPA, we may ask users to verify their date of birth before collecting any Personal Information from them. Those users that indicate they are Children are either blocked from the activity or taken through a parental consent process.
When you are accessing our Services via a third party such as an educational institution or another service provider that is using our Services, we may obtain parental consent and verify the user’s date of birth via that third party.
Palo may collect and store the following types of Personal Information about a Child when submitted by a Child with prior parental consent or by the parent or guardian of the Child: first and/or last name, email address, parent’s or guardian’s name, and parent’s or guardian’s email address. Palo may also collect the Child’s mailing address and/or telephone number when necessary to respond to an inquiry or fulfill a transaction, such as sending the winner of a contest or sweepstakes the awarded prize. Palo may also collect demographic information about a Child such as the Child’s date of birth, gender, and other preferences, and combine such information with the Child’s Personal Information.
While interacting with Palo, the student will share their behavioral responses to curriculum questions. This information will be used to evaluate Social Emotional level of student. Palo may also analyze such information to develop pattern detection and intervention algorithms to inform contracting parties i.e. school or the parent about such patterns.
When registering an account, we may collect a username and password from registrants for the purpose of saving that user’s activities. Once collected, we may also use the information for our internal marketing and demographic studies so that we can improve the products and services we provide our visitors in order to better meet their needs, or as otherwise described in this Policy. Please note that we use aggregated (i.e., non-personal) information for analytics purposes.
Additionally, we are prohibited by COPPA from conditioning a Child’s participation in an activity on the Child’s disclosure of more Personal Information than is reasonably necessary to participate in the activity. This means that if we don’t need a specific piece of information to allow the Child to participate in the activity, we will not ask for it, even with parental consent.
A parent who has already given Palo a permission to collect and use his or her Child’s Personal Information can, at any time, do the following: (1) review, correct, or delete the Child’s Personal Information; and/or (2) discontinue further collection or use of the Child’s Personal Information. To do so, please refer to the confirmation email provided to you when you gave consent or contact us at firstname.lastname@example.org. Please be sure to include your Child’s name and email address, your name and email address, and the name of the site on which your Child is registered.
10. Processing in the United States
Please be aware that, depending on your location, your Personal Information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we store all Personal Information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the Site or Services, you agree that the collection, use, transfer, and disclosure of your Personal Information and communications will be governed by the applicable laws in the United States.
11. How to Contact Us?
Although we do not sell consumers’ Personal Information (“Covered Information”), out of abundance of caution and according to Nevada law, any Nevada consumer who wants to opt out of the sale of Personal Information may submit a request by contacting us at email@example.com. Please note that we will take reasonable steps to verify your identity and the authenticity of the request.
Appendix A – Your Rights Under the California Consumer Privacy Act
If you are a California resident who has provided Personal Information to Palo, or a California resident that reasonably believes that Palo collects or stores their Personal Information, you may exercise your rights under the CCPA and submit your requests by emailing to firstname.lastname@example.org
NOTE: we do not sell your Personal Information as that term is defined in the CCPA or under Nevada Law (Section Chapter 603A of the Nevada Revised Statutes).
As California resident, you have the right to request Palo to:
- Disclose if we have collected Personal Information on you;
- Disclose the categories of Personal Information that we have collected on you (if any), and the business or commercial purpose for collecting or selling personal information, the categories of sources of such Personal Information, the categories of third parties to whom such personal information is disclosed (if any);
- Disclose the specific pieces of Personal Information that we have collected on you (if any); and
- Delete the Personal Information we have collected on you.
In order to submit a request, we will need to verify your identity. If you have an account with us that is password-protected, we may verify your identity through our existing authentication practices for your account.
If you do not have an account with us, and your request concerns “categories” of Personal Information collected, we can request from you two data points of Personal Information to verify your identity. If you do not have an account with us, and your request concerns specific Personal Information, we can request from you at least three data points of Personal Information as well as a signed declaration with penalty of perjury to verify your identity.
Please note that following your verified request, we will send you your Personal Information from the following email address: email@example.com (Any response to your request, including any Personal Information may be sent as an encrypted file).
Please note that once you have submitted a request, we will send you a receipt, acknowledging your request, within 10 days. If, for some reason, you do not receive such a receipt within 10 days of your submitted request, please send us an email to firstname.lastname@example.org as an error may have occurred.
We will process and respond to your request within 45 days after it is received (in some cases, as is allowed under the CCPA, this process may be extended by an additional 45-90 days).
Please note, that regarding requests under subsections (a), (b), and (c) above, you may only make two requests in a 12-month period, and the information provided need only cover the 12-month period prior to your request.
The CCPA allows California consumers to use “authorized agents” to submit requests to Palo on their behalf. If you have elected to use an authorized agent, or if you are an authorized agent who would like to submit requests on behalf of a consumer, the following minimum procedures will be required prior to acceptance of any requests by an authorized agent on behalf of a California consumer allowed under CCPA.
For the safety and security of the consumer’s information, for certain requests submitted to Palo by an authorized agent, we will require a direct form of communication, preferably a valid email address, with the consumer, to fulfill the request. We may also request several pieces of identifying information to verify the identity of the authorized agent.
We hereby inform you that you have a right not to receive discriminatory treatment by Palo for the exercise of the privacy rights conferred by the CCPA. If you exercise any of your rights under the CCPA we may not deny you goods or services for that reason, or subject you to different prices than those paid by other consumers, unless provided otherwise under the CCPA, Federal, or State law.
Notice of Information We Collect
Pursuant to California Civil Section 1798.100(b), this serves as notice of the categories of Personal Information that we collect through the Site and Services and the commercial purposes for which the information was collected. Please note that all of the categories of Personal Information we collect about you (as detailed below) come from the following categories of sources:
- You, including through your use of our services
- Automatically collected from you
- Our affiliate companies
- Third parties
Notice of Disclosures of Personal Information to Categories of Third Parties for a Business Purpose
In the preceding 12 months, we disclosed certain data from the categories of Personal Information listed above to the following categories of third parties to whom the personal information was disclosed for a business purpose: affiliates, service providers, third parties (according to the categories noted above).
We disclose the above categories of Personal Information to service providers to fulfill certain business purposes, such as:
- Maintaining and servicing your account;
- Providing you customer service;
- Processing transactions and providing your products and services;
- Processing applications and payments;
- Processing and evaluating job applications;
- Verifying the identity of users;
- Detecting and preventing fraud;
- Providing promotional programs;
- Providing marketing and advertising services;
- Providing analytics services; and
- Undertaking internal research to improve and develop our products and services.
Please note that when we disclose Personal Information for a business purpose to a third party, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.