TERMS

Privacy Policy

Last updated on April 15, 2020

Thank you for using Pico. Pico collects information you provide when you sign up to access content from websites (“Communities”), on which our software (“Pico Plugin”) is integrated. Through the Pico Plugin you can manage your access to Communities’ articles and other content, subscribe for additional content and services, and complete purchases from and donations to Communities. Communities may also use the information provided by you through the Pico Plugin to advise you of new content, goods, or services in which they believe you may be interested.

This Privacy Statement (“Privacy Statement”) explains how Pico Networks, Inc. (“Pico”, “we", “us", “our") collects, uses, and shares your personal information, and the choices that are available to you. Our Privacy Statement applies to all who use our website, trypico.com (the “Site”), the Pico Plugin that is integrated within our Communities’ websites, and any online services, applications, and tools that we own or control, regardless of how you access or use them (collectively, the “Services”). This Privacy Statement is incorporated in our Terms of Use, which also apply when you use our Services. Capitalized terms used in this Privacy Policy that are not defined herein shall bear the meanings set forth in the Terms of Use.Your use of the Services is subject to this Privacy Statement. Please read this Privacy Statement carefully. We may change this Privacy Statement at any time. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Statement was last revised. Any changes to this Privacy Statement will become effective when we post the revised Privacy Statement on the Site.

1. How We Collect Your Information

1.1

When you visit and interact with our Services, we may collect certain information about you, including personal information. “Personal Information”means information that specifically identifies you or, when combined with other information we have, can be used to identify you, such as your name, email address, physical address, phone number, age, gender, reading history, purchase history, and payment information. Pico does not collect any Personal Information from you through the Services unless you voluntarily choose to provide us with such information. In some cases, if you choose not to provide us with the requested Personal Information, you may not be able to use some or all of our Services.

1.2

We may automatically collect certain information about you and store it in our log files when you use and interact with our Services or our Communities’ websites, such as data collected from Cookies (defined below) and other automated technology. This information may include details about the content you purchase or the emails we send that you open, forward, or click through to our Services, Internet Protocol (IP) address, Internet Service Provider (ISP), date and time stamps, sites visited before and after interacting with our Services, page views, page navigation, links that are clicked, ad blocker status, and certain device data (such as operating system type, device type or model, location, browser type and version, member language, and other system settings).

1.3

Pico collects Personal Information about you through the Services when you:

(a)

register or login to a Community via your Pico account;

(b)

purchase content through your Pico Account;

(c)

open or respond to our email offers;

(d)

contact customer service or otherwise make use of our customer support tools;

(e)

connect or link our Services to third-party social media services; or

(f)

when you otherwise voluntarily provide us with your Personal Information.

1.4

When You Log In Through Your Social Media Account. In order to view certain content made available by our Communities across the web, you must sign up and login to the Services. If you sign up using your Google Plus or Facebook credentials, you are asking these third-party services to share your authentication information with Pico, and you are authorizing us to collect and use the information they send us in accordance with our Privacy Statement. This information includes your username, access credentials, and certain other information that may be available on or through your Google Plus or Facebook account, such as your name, email address, gender, date of birth, general location, friends’ names, profile pictures, a list of Facebook “likes”, and a link to your profile. For the privacy practices of Google and Facebook, please refer to their privacy policies here and here, respectively.

1.5

When You Make Purchases or Donations. When you use Pico to purchase any products, services, or content, or to make a Donation, we ask you to provide certain financial information that we need in order to complete your order. Financial information includes payment card data (e.g., credit card number, expiration date, and CVV) or, if you opt for payment via a third party payment provider whose services are made available on the Pico Plugin, the necessary information those third party payment providers require for processing the transaction. We do not store any payment card information. All payment card information is stored by our trusted third-party payment processors.

1.6

Personal Information Collected by Automated Means. As with most online services, we gather certain Personal Information about your interaction with our Services and store it in our log files. We may also use “Cookies”, web beacons/pixel tags, and other similar technology to collect Personal Information about you when you visit our Site or otherwise interact with our Services or emails. Additionally, we may use Cookies and other similar technology to collect Personal Information about you when you visit our Communities' websites, even if you do not interact with our Services. “Cookies” are small bits of data cached or stored on your computer based on Internet activity. These technologies help us track and understand how individuals use and interact with our Services as well as the websites and content of our Communities offer you customized content or recommendations based on your specific interests; and otherwise manage our Services. Your access to our Services should not be affected if you do not accept Cookies served by third parties.

1.7

The table below explains the cookies we use and why:

Purpose

Created when the member successfully logs in to a Community using Pico

A cryptographic hash of the original cookie

2. How We Use Your Information

2.1

We use the Personal Information we collect for various purposes, including to:

(a)

operate, maintain, and improve the Services and overall customer experience;

(b)

establish an online Pico account for you at your request through which you may access content from various Communities;

(c)

process online purchases or Donations and keep you informed about your Pico Account;

(d)

provide customer service (for example, answering your questions or responding to a request);

(e)

communicate and provide additional information that may be of interest to you about Pico and our Communities;

(f)

identify your preferences so can we can notify you of new or additional content, services, and promotions that might be of interest to you;

(g)

validate your ability to access certain content or use certain services, including access of content from various Communities;

(h)

send you reminders, updates, support, administrative messages, service-related announcements, marketing messages, and requested information;

(i)

perform analytics and conduct customer research;

(j)

allow you to interact with certain third-party content service providers (for example, to enable you to link to, or view content from, third-party sites within our Site, or view our content on a third-party site);

(k)

administer special offers from us or through our third-party Communities;

(l)

enhance other information we have about you to help us better understand you and determine your interests; or

(m)

manage our everyday business needs, such as administration of the Services, fulfillment, analytics, fraud prevention, and enforcement of our corporate reporting obligations and Terms of Use, or to comply with applicable law.

We also use information regarding the pieces of content you view and purchase on an anonymized basis together with certain Personal Information from your connected Google Plus and/or Facebook account such as your age and gender to enhance the Services and your customer experience.

2.2

We may use information collected as described in this Privacy Statement with your consent or as otherwise required or permitted by law.

2.3

We also use the Personal Information we collect to fulfill contracts with our Communities, including allowing Communities to track those who access or sub-scribe to its content; help confirm receipt of and response to our emails; and provide more effective customer service.

3. How We Share Your Information

3.1

Personal Information. We may share your Personal Information as required or permitted by law as follows:

(a)

with any of our affiliates, who may only use your Personal Information for the purposes described in this Privacy Statement;

(b)

with our vendors who provide services for us on our behalf, such as processing and fulfilling payment orders for Services or Donations, data storage, assistance with direct marketing and distribution of emails and other communications, fraud prevention services, and to accomplish the other purposes for collection described above;

(c)

in the event we or any of our affiliates file for bankruptcy, or where there is a transfer of ownership (or assets) in connection with proposed or consummated corporate reorganizations of Pico or any of our affiliates, such as mergers, acquisitions, or sales of business units;

(d)

to comply with legal orders and lawful government requests;

(e)

to combat fraud or criminal activity, and to protect our rights or those of our affiliates, members, and business partners, or as part of legal proceedings affecting Pico;

(f)

in response to a subpoena, court order, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate; or

(g)

with your consent.

3.2

Communities. We may share your Personal Information with our third-party Communities:

(a)

to give you access to content from our Communities;

(b)

to allow Communities to offer products and services;

(c)

to facilitate a direct relationship with you, including in connection with any services we administer on behalf of a Community;

(d)

to the extent you have purchased or redeemed content or other services offered by a Community or participated in an offer, rewards, contest or other activity sponsored or offered through Pico on behalf of that Community; or

(e)

to enable electronic communications with you as part of purchase, a sponsored reward, offer, contest, program, or other activity in which you have elected to participate.

3.3

We may also disclose Personal Information on an anonymized basis with Communities for their own research and analysis.

4. Communities’ Websites; Other Third-Party Websites and Services

4.1

Third-Party Websites and Services. The Pico Services are primarily accessible and available via the independent, third-party websites of our Communities, who provide you with content that you can purchase through your Pico Account. Additionally, our Services may contain links to, or have features that are hosted by, other third-party websites or services that are not owned or controlled by us. For example, we give you the opportunity to connect, link, or share our Services (and the content you access) via certain social media websites. We also make it possible for you to pay for our Services directly with certain third-party payment processing providers.

4.2

What this Privacy Statement Covers. This Privacy Statement only addresses the collection, use, and disclosure of information by Pico through your interaction with our Services. This Privacy Statement does not address the policies or practices of any third parties, including our Communities, or any third-party websites or features that are linked to or available from our Services.

4.3

Third-Party Terms. We have no control over or responsibility for the privacy practices and content of our Communities, linked services or features, or any other third-party services. If you provide any information to our Communities, or any other third parties (e.g., social media services, payment processor providers), different rules regarding the collection and use of your Personal Information by such third parties may apply. As such, we strongly recommend that you review our Communities’ privacy policies and any other third-party’s privacy policies before providing information to them. You should contact these entities directly if you have any questions about their privacy practices.

5. Your Choices

5.1

Accounts and Connections to Social Media. If you registered with the Services through your social media account, or connected, linked, or shared your use of our Services via your social media profile, you can manage the permissions granted to such third party social media services by accessing your member settings under your account. You can also remove Pico’s access to your social media account or otherwise control what information these third-party social media services share with us at any time by accessing the privacy settings in your social media account. Restricting Pico’s access to your Google or Facebook account may result in your being unable to access some or all of Pico’s Services.

5.2

Commercial Emails. You may choose to opt-out of receiving commercial emails from us by following the instructions contained in any of the commercial e-mails. Please note that even if you unsubscribe from commercial email messages, we may still email you non-commercial (transactional) emails related to your account and your transactions via the Services. Also, please allow us 10 business days from when the request was received to complete the removal. If you wish to opt-out of receiving offers directly from our third-party Communities, you can follow the instructions in the emails that they send you.

5.3

EU Members. If you are a member based in the EU, we only send you commercial emails when we have obtained your explicit prior opt-in consent, except where we have obtained your e-mail address in the course of a sale or negotiations for a sale of a product or service and where the commercial emails are only marketing similar products or services.

5.4

Cookies and Tracking. You can disable Cookies at any time by adjusting your browser settings. Browsers are different, so refer to instructions related to your browser to learn about cookie-related and other privacy and security settings that may be available. Please be aware, however, that if you turn off Cookies, you may not be able to take full advantage of all of our Services’ features.

5.5

Do Not Track. Currently, we do not alter our data collection and use practices in response to Do Not Track signals.

5.6

Accessing your Personal Information. Subject to applicable law, you have the right to obtain request access to and receive information about the Personal Information we keep about you, receive copies of the Personal Information we keep about you, correct inaccuracies with your Personal Information, object to the processing of your Personal Information, and have your Personal Information blocked, anonymized or deleted, as appropriate. The right to access Personal Information may be limited by local law requirements. To exercise your rights, please contact us as set forth below.

6. How We Protect Your Information

The security of your Personal Information is very important to us. We maintain commercially reasonable security safeguards that are designed to protect the Personal Information we collect against unauthorized use, disclosure, alteration or destruction.

Notwithstanding the steps we have taken to protect your Personal Information, no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to protect your information, Pico cannot guarantee or warrant that your Personal Information is under absolute security with the existing security technology. If you have any questions about the security of our Services, you can contact us at [email protected].

We store Personal Information only for as long as it is necessary for the fulfillment of the purpose for which the Personal Information was collected, unless otherwise authorized by applicable law. We take measures to destroy or permanently anonymize personal information if required by law, or if the personal information is no longer required for the purpose for which we collected it.

7. Children's Privacy

Pico does not intend that any portion of its Services will be accessed or used by children under the age of thirteen, and such use is prohibited. Our Services are designed and intended for adults. By using the Services, you represent that you are at least 18 years old and understand that you must be at least 18 years old in order to create an account and purchase paid content or other products, features, or services advertised through the Services.

If we obtain actual knowledge that an account is associated with a registered member who is not at least 18 years old, we will promptly delete information associated with that account. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed Personal Information to us, please contact us at [email protected]. A parent or guardian of a child under the age of 13 may review and request deletion of such child’s Personal Information and prohibit the use of such information.

8. International Members

If you live outside the United States (including the European Economic Area and Switzerland), and you use the Services or provide us with Personal Information directly via the Services, your information will be handled in accordance with this Privacy Statement. Your Personal Information will be collected and stored in the United States, and subject to the laws of the United States. By using the Services or giving us your Personal Information, you are directly transferring your Personal Information to us in the United States. Please note that the data protection and privacy laws of the United States may not be as protective as the laws in your country. The laws of the United States will govern the processing of your Personal Information, including any obligations of security and third-party information sharing.

If you would like to learn what Personal Information Pico has collected about you, receive a copy of such Personal Information, or would like to request that Pico restrict use of or delete your Personal Information, please contact us at [email protected].

9. California Privacy Rights

Under California Civil Code section 1798.83, California residents who have an established business relationship with us are entitled to ask us for a notice describing the types of personal customer information we have shared with third parties for those parties’ direct marketing purposes during the preceding calendar year. That notice will identify the categories of information shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you are a California resident and would like to request a copy of this notice, please submit a written request to [email protected].

10. Contact Us

If you have any questions or comments about our privacy practices or this Privacy Statement, please contact us at [email protected].