We operate several marketplaces, including Pairdrop, that allow merchants to list items and users to find and purchase items, often at a discount from retail prices. We collect and use purchaser and merchant information, including for payment methods and shipping address, to support these experiences. We also use information to find items that we think will be of interest to buyers and to find the right price for each item.
1. Information We Collect & Use - Some of the information we collect is provided by you, some is collected automatically (typically from devices) and some may be collected from other sources.
A. Information You Provide – When you use the Services you often provide information to us, such as when you create an account or a store, make or fulfill a purchase, leave a review, or request customer support. Examples of the information you may provide are:
◦ Email Address
◦ Payment Method or Financial Account Information
◦ Shipping Address
◦ Phone Number
◦ Social network account credentials
B. Information We Collect Automatically – When you use the Services, such as when you visit our sites, and install or use our apps, we automatically collect information about how you use the Services and the devices you use to access the Services. Examples of the information we collect automatically are:
◦ IP Address
◦ Location information - we and our service providers may automatically collect general location information from your computer or mobile device. We will ask your permission before collecting your precise GPS location information.
◦ Social network account and profile data (when you use social login)
◦ Unique Device Identifiers, including MAC Address, Ad IDs, and device attributes, such as operating system and browser type
◦ Usage Data, such as: web log data, referring and exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used our Services, the frequency of your use of our Services, error logs, and other similar information
C. Analytics, Advertising & Technical Data
Analytics – We use Google Analytics or other providers to understand better how individuals and their devices interact with the Services. Learn more about How Google uses data when you visit a partner site or app.
Ads for Products and Services. We may use services, like Facebook, to serve tailored ads to you about the LARGEGO, INC services, our companies or products we are developing. We may also support or allow the delivery of advertising for the products and services of other companies. We allow ad networks and other participants in the online advertising sector (“Advertisers”) to use and access their own Cookies on your computer or other device(s) you use to access our Services. They may also access and use unique device identifiers, such as IDFA. For example:
◦ We may deliver a file to you through the Services (known as a "web beacon") from an ad network. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network's servers, these companies can view, edit, or set their own cookies, just as if you had requested a web page from their site.
Third-Party Content, Links, or Plug-Ins.
◦ The Services may have links to third-party websites or apps, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.
D. Other Sources – We may gather information, including demographic and statistical information from third parties, such as business partners, marketers, researchers, analysts. We may attribute this information to you based on your assignment to certain statistical groups. We may use this information to supplement the other information that we collect in order to derive your possible interests and to provide more relevant experiences for you within the Services and improve our products, analytics, and advertising.
2. How We Use Information & Lawful Bases
In general, we collect, use and store (“process”) your information to provide the Services, to fix and improve the Services, to develop new services, and to market our companies and their products and services. Some specific examples of how we use information are:
◦ Collect payment
◦ Communicate with you - using email, sms, push notifications or platform messaging (like Whatsapp) - about your account or activity or to market product listings, features, or events.
◦ Test changes in the Services and develop new features
◦ Analyze use of the Services and personalize content, including ads and prices
◦ Fix problems you may have with the Services or a particular purchase, including answering support questions and resolving disputes
◦ Prevent, detect, investigate and respond to fraud, unauthorized access/use of the Services, breaches of terms and policies, or other wrongful behavior
◦ Comply with any procedures, laws, and regulations which apply to us, including those that set retention periods
Lawful Bases – for purposes of European data protection law, we normally process personal data where:
◦ we need to perform the contract we are about to enter into or have entered into with you, such as when we process a payment
◦ it is in our legitimate interests (or those of a third party) and your data protection interests and fundamental rights and freedoms do not override those interests, such as when we secure the Services, engage in fraud prevention, and direct marketing
◦ we need to comply with a legal or regulatory obligation
◦ we have your consent to do so. We do not generally rely on consent as a lawful basis for processing your personal data, but you have the right to withdraw consent to marketing at any time by contacting us
3. Location of Data Processing – United States and elsewhere
Information that we collect and use is normally processed outside of Europe. By using the Services you:
4. Retention of Personal Data/Information
We keep your information for the time period required to complete the purposes for which it is processed or satisfy legal retention requirements. The length of time for which we retain information depends on the purposes for which we collected and use it or the requirements of applicable laws.
5. Information Sharing
Agents/Service Providers. We employ other companies and people to perform tasks on our behalf and need to share information with them so they can perform tasks and services. For example, we may use a payment processing company to receive and process your payment when you make a purchase using the Services or we may use a cloud services provider to store data.
Merchants & Users. Information about merchants and users (purchasers) is shared in certain contexts. For example, merchant store information is made available to users and user reviews of a store are made available to merchants and other users. Also, when users complete a purchase using the Services, we normally share information needed to fulfill the purchase, such as shipping address and phone number, with the seller (usually a merchant) and its service provider(s), such as a shipping company. Information shared with sellers and their service providers is subject to their own policies.
Advertisers: We allow advertisers, including merchants ("Advertisers"), to choose the types of users who will see their advertisements or promotional offers based on demographic information about our users. We might allow Advertisers to display their ads to users with similar usage patterns or similar geographic locations. For example, if you are located in Austin, TX we may show you ads or offers for businesses in Austin, TX. If an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach.
With Other Users:
◦ Any information you may disclose on the Services, in blogs, on message boards, in chat rooms, or on other public areas on the Services or other third-party websites or apps that the Services may link to, becomes public information accessible to other users and visitors. Please exercise caution when disclosing personal information in these public areas.
◦ Certain user profile information, including your name, photo, location, purchase history, items on your wishlist, reviews you have written (including any photos you upload with such reviews), and the list of people you follow or that follow you, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Please remember that any content you upload to your public user profile, along with any personal information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) becomes publicly available, and can be collected and used by anyone. Your user name may also be displayed to other users if and when you send messages or comments or upload images or videos through the Services and other users can contact you through messages and comments. Additionally, if you sign into the Services through a third party social networking site or service, such as Facebook, your list of "friends" from that site or service may be automatically imported to the Services, and such "friends," if they are also registered users of the Services, may be able to access certain non-public information you have entered in your Services user profile. Again, we do not control the policies and practices of any other third party site or service.
Business Transfers: We may choose to buy or sell assets and may share or transfer user information (including personal information) in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, user information could be one of the assets transferred to or acquired by a third party.
Consent. We may share your information in other ways if you have asked us to do so or have given consent.
Accounts are protected by a password for your privacy and security. If you access your account via a third party site or service, such as Facebook, you may have additional or different sign-on protections via that third party site or service. We recommend that you choose an appropriate password, safeguard your password and limit access to the devices on which you access your account.
We use reasonable organizational and technical measures intended to protect the privacy of your account and personal information we use or store, but the Internet and our Services are not 100% secure. We cannot guarantee complete privacy or security for the information that you provide or that we collect.
7. Choices & Rights
Access, Review, Correct - Through your account "Settings," you are able to access, edit or delete information you've provided to us, including:
◦ name and password
◦ email address
◦ physical address
◦ phone number
◦ billing information
◦ user profile information, including images and videos you have uploaded to the Services
The information you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at [email protected]
Marketing Communication Opt-out - To opt-out of marketing communications you can use any of the following methods.
◦ Electronic Promotional Offers. If you do not want to receive emails from us regarding special promotions or offers, you may (1) follow the unsubscribe options at the bottom of each email; or (2) contact us at [email protected] and provide your email address along with the name of the newsletter from which you would like to unsubscribe.
◦ Mobile Promotional Offers: When you provide us with your mobile number for marketing purposes, we may send you certain marketing alerts via text message. Standard data and message rates will apply. If you no longer wish to receive mobile alerts from us, you can follow the instructions provided in those messages or otherwise reply STOP to any alert we send.
◦ Push Notifications: When you use the App, you may receive push notifications. If you prefer not to receive push notifications, you may adjust your settings on your mobile device to control whether you want to receive these alerts.
◦ Settings - You can opt out of certain communications from us by changing your preferences under the "Settings" option of the applicable service.
Location Information - If you do not want us to see or access your device location, you can turn off location sharing on your device, change your device privacy settings, or decline to share location on your browser.
Cookies, Analytics & Ads
◦ You may be able to opt-out of certain web beacon tracking and other Cookie activity by adjusting the settings on your browser, including Do Not Track settings.
◦ To opt-out of Google Analytics you can install the Google Analytics Opt-out Browser Add-on
◦ To exercise choices for tailored advertising, please visit the following sites. If you opt-out, you may still receive advertising content, but it will not be tailored to you.
◦ Network Advertising Initiative (NAI) - You may use the NAI opt out tool here, which will allow you to opt out of seeing personalized ads from NAI member companies.
◦ Digital Advertising Alliance (DAA) - You may opt out of receiving personalized ads from certain companies that perform ad targeting services, using the DAA website here.
◦ European Interactive Advertising Digital Alliance (EDAA) – You can learn more about online advertising and opt out at the Your Online Choices website.
◦ For your mobile devices, please read your operating system’s instructions for complete instructions.
◦ iOS 7 or Higher: Go to your Settings > Select Privacy > Select Advertising > Enable the “Limit Ad Tracking” setting
◦ For Android devices with OS 2.2 or higher and Google Play Services version 4.0 or higher: Open your Google Settings app > Ads > Enable “Opt out of interest-based advertising”
Deactivate Account - You may request deactivation of your account by emailing us at [email protected]
Rights - If our processing of your personal data is covered by European data protection law, you typically have certain rights, including:
◦ You can access and review information associated with your account at any time through the “Settings” page or tab. You also can request the following information: how we collect and use your information and why; the categories of personal data involved; the categories of recipients of your personal data; how we received your personal data; and how long we use or store your personal data or the manner in which we determine relevant retention periods.
◦ You also have a right to correct your personal data. In certain situations, you can ask that we stop using your information or erase it or export it. You may also have a right to object to additional processing of your personal data.
◦ Where we rely on your consent to process your personal data, you have the right to not give your consent or (if you have provided consent) to withdraw consent at any time. Withdrawing consent will not affect the lawfulness of processing prior to the withdrawal. At any time, you can request that we stop using your information for direct marketing purposes.
◦ You have a right to raise questions or complaints with us as described below or with your local data protection authority at any time.
8. Children’s Privacy
We do not knowingly collect or solicit “personal information” (as defined by the U.S. Children’s Online Privacy Protection Act) from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information. If you believe that a child under 13 may have provided us personal information, please contact us at [email protected]
For residents of the EU and Switzerland, where processing of personal data is based on consent, we will not knowingly engage in that processing for users under the age of consent established by applicable member or data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.
If you are 13 or older, but have not reached your country’s age of majority (i.e. able to enter a contract), you should use the Services with permission from your parent(s) or guardian(s).
9. Do Not Track & California Shine the Light
Do Not Track Policy - Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not want your online activities tracked over time and across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.
California Residents - If you are a California resident, you may ask for a list of third parties that have received your information for direct marketing purposes during the previous calendar year. This list also contains the types of information shared. To make such a request, contact us at [email protected]
◦ LARGEGO, INC Inc., PO BOX 1902, Burlingame, CA 94011