Privacy policy

Effective Date: November 14, 2017

Last modified: May 25, 2018

Our Privacy Policy has recently received an update to comply with the EU’s new General Data Protection Regulation (GDPR). More information about the GDPR can be accessed here. Nothing about the way we collect and handle your data has changed, we’ve just added even more clarity about our processes. If you have any questions, feel free to email us at [email protected].

At Paloma Works PBC (“Paloma®”), your privacy is incredibly important to us. This Privacy Policy describes what Personal Data (as we describe further below) we collect about you, our legal basis for processing the Personal Data, how the Personal Data will be used and shared, how the Personal Data will be stored, and your rights in relation to the collection of your Personal Data when you visit, use, or interact with our business and website, GetPaloma.com, including any and all versions of GetPaloma.com optimized for viewing on a wireless or tablet device (the “Website”), all email newsletters published or distributed by Paloma, and all other interactive features, services, and communications provided by Paloma® (including our main service through the Facebook Messenger API), however accessed and/or used, that are operated by us, made available by us, or produced and maintained by us (the “Services”).

We internally collect Personal Data in connection with our Services. We do this to personalize, provide, and improve our Services, to allow you to set up a user account, to enable you to build Conversations, to contact you, to fulfill your requests for certain products and services, and to analyze how you use the Services, but we’ll talk more about all of that below.

This Privacy Policy also covers how your Personal Data is handled by our third-party data processors. Through your use of our Services, you may find links to other websites or mobile applications, but this Privacy Policy won’t apply to any of those linked applications or websites unless they are also our data processors, which we will describe clearly in this Privacy Policy. We are not responsible in any manner for the privacy practices of those websites or mobile applications.

This Privacy Policy also specifically incorporates by reference our Terms of Service. Any capitalized words or phrases we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Service.

Who are we and how can you contact us?

We are, as stated above, Paloma®. We collect and process your Personal Data, as well as manage our third-party service providers that additionally process your Personal Data.

The best way to contact us is through our dedicated customer service email, [email protected].

You can also reach us as follows:

Paloma Works PBC
126 Graham Ave, 1B
Brooklyn, NY 11206

Who do we collect Personal Data from?

We collect Personal Data from our users, who are those individuals and businesses that sign up to use our Services. For our users, we act as data controllers, making decisions about the purposes for which we process Personal Data.

We also collect Personal Data on behalf of our users and for their customers or clients (collectively, “User Customer”). For User Customers, we act as data processors, because we don’t make decisions about which Personal Data we collect, but we do collect the Personal Data at the direction of our users. “You” will mostly refer to our own users in this Privacy Policy, but in certain provisions, we’ll refer specifically to User Customers.

What Personal Data do we collect from you and why?

Through your visitation to, use of, and interaction with Paloma®, you may be asked for certain types of Personal Data. You will be asked to register to use our Services and when you do so, we will ask you for certain Personal Data. This section will only cover the Personal Data that we receive specifically from you.

Personal Data collected when you register with us: When you register to use the Services, we will collect the following Personal Data from you: name, business name ( if applicable), email address, time zone, and a list of Facebook pages you own. You may also be asked to provide Facebook or other third party account credentials to us (such as the third party services you use to communicate with your customers and/or clients) (we’ll call this “Third Party Account Information”). By providing the information we request at registration, including the Third Party Account Information, you’ll help us to better serve you, and to provide a more personalized user experience for your use of our Services. We process all registration information manually and you will never be asked to sign up for anything outside of the registration information that we specifically ask you for when you sign a contract with us to use our Services.

Personal Data collected from User Customers: We collect Personal data from User Customers under the direction of our users. If you are a User Customer who engages in a Conversation through our Services, we may collect information such as your name, gender, time zone, and any profile picture or avatar you have associated with your Facebook account. We’ll also collect and process the information that you provide to us through Conversations (such as responses to questions and search queries) and we’ll then provide that information to our users for their business purposes. We never sell or rent such information to anyone.

Personal Data collected for billing: As a user of our Services, you will be asked to provide us with billing and payment information. However, such billing information will be provided on a one-to-one basis and only if you sign a separate contract with us for our Services. We do not collect or store billing information through any web portals, just like our registration Services.

Personal Data collected when we’re communicating: As a user of our Services, we may communicate with you about your account with us. These communications specifically won’t be marketing communications, but will rather be informational items, such as updates to our policies or other privacy-related matters (in other words, you won’t be able to opt-out of these important messages). You may also be asked questions about how to improve Paloma®, or you may, at some point, communicate with our representatives because of questions that you have. In that case, we’ll receive your contact information and the contents of those communications. We consider this information Personal Data. We collect this information so that we can help with anything you need and to continue improving our Services in the future.

What Personal Data do we collect about you that we get from other sources and why?

Geo-location data: We may collect information about your location depending on the permissions you have set on your device or browser. We solely and exclusively use this information to provide you with our Services, including to update your time zone for accuracy. You can enable or disable location Services when you use our Services at any time, through your device or browser settings.

Usage Data: We may also collect information about the use of our Services, such as Conversations you have created using the Services, as noted above, and general data about your interactions with our Services. We collect this data to help us troubleshoot any problems that may arise for you and other users, as well as to help us understand usage trends and information.

Personal Data from cookies: We use technological tools such as cookies, beacons, scripts, and tags. Cookies are small files stored on your computer or mobile device which collect information about your web behavior (we’ll call this “Automatic Data”). These cookies do not access information which is stored on your device. We collect IP address, device identification, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. If you click on a link to a third party website or service, a third party may also transmit cookies to you. Again, this Privacy Policy does not cover the use of cookies by any third parties, and we aren’t responsible for their privacy policies and practices. Please be aware that cookies placed by third parties may continue to track your activities online even after you have left our Services, and those third parties may not honor “Do Not Track” requests you have set using your browser or device. We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services.

What can I do about cookies in general? Most Internet browsers accept cookies automatically, although, you are able to change your browser settings and control cookies, including whether or not you accept them, and to remove them. Unfortunately, if you set your browser so that it refuses cookies, you may not be able to use the Services. You can visit http://www.whatarecookies.com for further information. Your browser may also 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 wish such operators to track certain aspects of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time.

What is our legal basis for processing your Personal Data?

We respect data minimization principles, which means we only collect the minimal amount of Personal Data required for legitimate business purposes, including providing the Paloma® Services to you.

In other words, we need the Personal Data that we do to effectively run our business and we don’t collect more than is necessary. The Personal Data you provide to us voluntarily (such as through registration, use, and communication with us) is up to you. That said, we may still process automatic Personal Data, such as that received through cookies, regardless of how you interact with our Services.

We also, though, want to ensure that you feel we’re always treating your voluntary Personal Data - in other words, that data that we ask you for - just the way that you’d expect. Because of that, before you use or access any of our Services, you’ll be directed to this Privacy Policy. You should take the time to read and review it carefully, and then feel free to reach out to us with any questions. We’ll ask you to check a box indicating that you’ve read this Privacy Policy in full and that you agree to the processing of your Personal Data as we’ve described here.

If you don’t understand this Privacy Policy or you’re not sure about anything we’ve described here, please reach out to us so that we can help. If you’re still unsure, it’s best not to use any of our Services until we can answer all of your questions.

Additionally, if we collect or process your Personal Data in any way not indicated by this Privacy Policy in the future, we will seek your explicit prior consent. To be clear, consent will be sought if we wish to provide you with direct marketing communications, if we transfer your data to third parties not indicated here, or if we otherwise significantly amend or change this Privacy Policy.

Will your Personal Data ever be shared and if so, how and with whom?

At Paloma®, we never rent or sell your Personal Data to anyone in a form that can identify you. We do, however, use third party service providers (those “data processors” we mentioned earlier) to help us operate Paloma®, including our web host and payment processors. We also share general business information - i.e. non-Personal Data - with partners and potential partners.

Third-Party Service Providers: The third party service providers that we use help run the business, so your data will pass through them, but we don’t provide your Personal Data (or any personally identifying information) for intentional access ( for marketing list purposes, for example) to anyone. For the third parties that we utilize who also process your Personal Data, we have appropriate security and contractual measures (like encryption and data processing agreements) to ensure that your Personal Data always gets treated in compliance with the policies laid out here, as well as applicable law.

Other Disclosures: In certain cases, we may have to disclose your Personal Data to third parties outside those above. We limit that disclosure to the following circumstances:

  • To satisfy any local, state, or Federal laws or regulations;
  • To respond to requests, such discovery, criminal, civil, or administrative process, subpoenas, court orders, or writs from law enforcement or other governmental or legal bodies;
  • To bring legal action against a user who has violated the law or violated our Terms of Use;
  • In the case of any business transfer, sale, or transfer of assets of Paloma® (we’ll notify you if this happens);
  • To generally cooperate with any lawful investigation about our users; or
  • If we suspect any fraudulent activity on Paloma®.

Your Consent:Otherwise, if we get your explicit, unambiguous, and prior consent to share your Personal Data with anyone, we’ll do so.

What about marketing?

We may send you marketing communications, such as newsletters and brochures, but only after we obtain your explicit consent. In other words, we’re never going to automatically add you to a mailing list or other marketing communication list - we’ll specifically ask you to opt-in to the communications you want to receive.

If you do consent to receive marketing communications through your affirmative opt-in, you’ll be receiving things like newsletters, targeted campaigns, and offerings of new products, services, promotions, or recommendations from us and our affiliates and subsidiaries.

Even if you do want to get marketing messages from us, you’ll be able to revoke your consent at any time. You can do so by:

  • Clicking on the “unsubscribe” link contained in each marketing email sent to you,
  • Sending an email to [email protected]
  • We’ll take you off our marketing list as soon as we can and you won’t hear from us again.

How do we store and protect your Personal Data?

Personal Data Storage: We only store your Personal Data as long as it is necessary for providing you with the Services or until you stop using our Services and request deletion of your data. We may also store your Personal Data for any applicable legal record-keeping, including after the closure of your account for legitimate business purposes (e.g., maintaining our accountancy records, enforcing our Terms of Use, or otherwise maintaining the safety and security of our Paloma® for a time period permitted by applicable law).

Personal Data Protection: We employ organizational and technical security measures to protect your Personal Data, such as limiting access to your Personal Data, secured networks, and encryption.

We also use secure physical and digital systems to store your Personal Data. We ensure that your Personal Data is protected against unauthorized access, disclosure, or destruction by utilizing practices that are consistent with standards in the industry to protect your privacy.

Please note, however, that no system involving the transmission of information via the Internet or the electronic storage of data is completely secure, no matter what reasonable security measures are taken. Although we take the protection and storage of your Personal Data very seriously, and we take all reasonable steps to protect your Personal Data, we cannot be responsible for data breaches that occur outside of our reasonable control. We will, however, follow all applicable laws in the event a data breach occurs, including taking reasonable measures to mitigate any harm, as well as notifying you of such breaches as soon as possible, but in no event, later than two weeks time.

What are your rights in relation to your Personal Data?

By using Paloma, you can exercise the following rights:

  • REFUSING TO PROVIDE YOUR PERSONAL DATA: The voluntary Personal Data you provide to us is an integral part of your use of Paloma®. You can choose to forego the provision of that data, but you will be restricted from using our Services.
  • WITHDRAWING CONSENT: You can withdraw your consent to the processing of your Personal Data at any time by sending an email to [email protected] However, please be advised, as above, that you may be restricted from using the Paloma® Services. We may request identity verification to ensure we are interacting with the correct data subject. User Customers must contact the businesses they began conversations with for any withdrawal of consent, modification, or deletion of Personal Data.
  • ACCESSING, OBTAINING, MODIFYING, AND DELETING YOUR PERSONAL DATA: Through your use of our Services, you can access and amend your own data at any time. To obtain, modify, amend, or delete your personal information, you can contact us directly at [email protected] will seek to respond to your request within a reasonable time.
  • SUBMITTING A COMPLAINT: If you would like to submit a complaint to us about the way in which your Personal Data is handled, please contact us by using any of the contact details located in this Privacy Policy. After you submit such a complaint, we will contact you within three (3) business days confirming that we have received your complaint. Afterwards, we will investigate your complaint and provide you with our response within a reasonable timeframe but in no event later than two (2) weeks.
  • LAUNCHING A COMPLAINT WITH A DATA PROTECTION AUTHORITY: If you are a resident of the European Union and you are not satisfied with the outcome of your complaint submitted to us, you have the right to lodge a complaint with your local data protection authority.

How exactly can you launch a complaint, if you’re unhappy with the way in which we collect or process your Personal Data?

As noted elsewhere in this Privacy Policy, you can reach out to us anytime you are unhappy with the processing of your Personal Data. You can also undertake the following:

.S. Residents: If you’re located in the United States, the collection of your Personal Data, is subject to investigation and enforcement by the Federal Trade Commission (“FTC”). We’re committed to resolving any complaints about the handling of your Personal Data as quickly and efficiently as we can, but if you’re not happy, you can lodge a complaint with the FTC.

California Privacy Rights: California Civil Code Section § 1798.83 permits users of Creatively, LLC that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].

E.U. Residents: If you are a resident of the European Union and you are not satisfied with the outcome of your complaint as you submitted it to us, you have the right to lodge a complaint with your local data protection authority.

What happens if we modify or revise this Privacy Policy?

We do reserve the right to modify, revise, or otherwise amend this Privacy Policy at any time and in any manner, but if we make any significant changes or otherwise change the way that we process your Personal Data, we’ll let you know and seek your consent through the contact methods that are accessible for you, including through email and through a posting on GetPaloma.com. We’ll also change the date this Privacy Policy was last modified at the top of this document.

If we can’t communicate with you for any reason, you are still responsible for being aware of the changes to the Privacy Policy, as we’ll post notices in as many places as possible. Continuing to use Paloma® after the change indicates your continuing assent to our privacy practices.

Unless we specifically obtain your consent, any changes to the Privacy Policy will only impact the Personal Data collected on or after the date of the change.

What about the international transfer of Personal Data?

We are based in the United States. In other words, your Personal Data gets sent to the United States whenever you use our Services. The risks of transferring data outside of your jurisdiction to the United States includes the possibility of data breaches and loss, but we maintain industry standards to protect your Personal Data as much as possible.

Do we collect any Personal Data from minors?

We do not allow use of Paloma® or any of our Services by users under the age of 18 (eighteen). As such, we don’t collect, store, or otherwise use any Personal Data from any minors under 18 (eighteen). If you are a parent or guardian, and you learn that your children have provided us with Personal Data, please contact us immediately. If we become aware that we have collected Personal Data from children without verification of parental consent, we will immediately take steps to remove that information from our servers.

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