Privacy Policy

This privacy policy applies to all the products, services and websites offered by POWR Inc., except where otherwise noted. We refer to those products, services and websites collectively as the “services” in this policy. Some services have supplementary privacy statements that explain in more detail our specific privacy practices in relation to them. Unless otherwise noted, our services are provided by POWR Inc.

Questions? For questions regarding our privacy policy or practices, contact POWR at info@powr.io.

Plugin Creators & Plugin Respondents

POWR is used by plugin creators (people who create POWR plugins) and plugin respondents (people who respond or interact with those plugins).

PRIVACY FOR PLUGIN CREATORS

What information does POWR collect?

When you use POWR, we collect information relating to you and your use of our services from a variety of sources. These are listed below. The sections afterward describe what we do with this information.

Information we collect directly from you
• Registration information. You need a POWR account before you can create plugins on POWR. When you register for an account, we collect your username, password and email address. If you choose to register by using a third party account (such as your Google or Facebook account), please see "Information from third parties" below.
• Billing information. If you make a payment to POWR, we require you to provide your billing details, such as a name, address, email address and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date or a bank account number). If you provide a billing address, we will regard that as the location of the account holder.
• Account settings. You can set various preferences and personal details on pages like your account settings page.
• Plugin data. We store your plugin data. This includes plugin settings (eg colors, fonts, backgrounds) as well as content (eg form questions in a Survey, or work history in a Resume).
• Other data you intentionally share. We may collect your personal information or data if you submit it to us in other contexts. For example, if you submit a feature request, provide us with a testimonial, or participate in a POWR contest.

Information we collect about you from other sources
• Usage data. We collect usage data about you whenever you interact with our services. This may include which webpages you visit, what you click on, when you performed those actions, and so on. Additionally, like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses.
• Device data. We collect data from the device and application you use to access our services, such as your IP address and browser type. We may also infer your geographic location based on your IP address.
• Referral data. If you arrive at a POWR website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
• Information from third parties. We may collect your personal information or data from third parties if you give permission to those third parties to share your information with us.
• Information from page tags. We use third party tracking services that employ cookies and page tags (also known as web beacons) to collect aggregated and anonymized data about visitors to our websites. This data includes usage and user statistics.

How does POWR use the information we collect?

We treat your plugin data as information that is private to you. Unless you decide to share your plugin questions and/or responses with the public, we do not use your plugin data for our own purposes, except in the limited circumstances described in this privacy policy or unless we have your express consent. We do not sell your plugin data to third parties.

Generally, we use the information we collect from you in connection with providing our services to you and, on your behalf, to your plugin respondents. For example, specific ways we use this information are listed below. (See the next section of this privacy policy to see who we share your information with.)

• To provide you with our services.
  • This includes providing you with customer support, which requires us to access your information to assist you (such as with plugin design and creation or technical troubleshooting).
  • Certain features of our services use the content of your plugin data and your account information in additional ways. Feature descriptions will clearly identify where this is the case. You can avoid the use of your plugin data in this way by simply choosing not to use such features.
  • If you choose to link your POWR account to a third party account (such as your Google or Facebook account), we may use the information you allow us to collect from those third parties to provide you with additional features, services, and personalized content.
• To manage our services. We internally use your information, including certain plugin data, for the following limited purposes:
  • To monitor and improve our services and features. We internally perform statistical and other analysis on information we collect (including usage data, device data, referral data, and information from page tags) to analyze and measure user behavior and trends, to understand how people use our services, and to monitor, troubleshoot and improve our services.
  • To assist the enforcement of our Terms of Use.
  • To prevent potentially illegal activities.
  • To screen for undesirable or abusive activity. For example, we have automated systems that screen content for phishing activities, spam, and fraud.
• To create new services, features or content (public data and metadata only). We may use public plugin data and anonymized plugin metadata (that is, data about the characteristics of a plugin but not its non-public content), to create and provide new services, features or content. For example, we may look at statistics like response rates, question and answer word counts, and the average features of a plugin and publish interesting observations about these for informational or marketing purposes. When we do this, neither individual plugin creators nor plugin respondents will be identified or identifiable unless we have obtained their permission.
• To facilitate account creation and the logon process. If you choose to link your POWR account to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate the account creation and login process.
• To contact you about your service or account. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, a welcome email when you first register). You can't opt out of these communications since they are required to provide our services to you.
• To contact you for marketing purposes (if you opt in). We will only do this if you have given us your express permission to contact you for this purpose. For example, during the account registration process we will ask for your permission to use your information to contact you for promotional purposes. You may opt out of these communications at any time by clicking on the "unsubscribe" link in them, or changing the relevant setting on your My Account page.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

With whom do we share or disclose your information?

We don't sell your plugin data!

When might we disclose your plugin data to third parties? Only for a limited number of reasons. Mostly commonly, we share your information with our service providers who help us to provide our services to you. We contractually bind these service providers to keep your information confidential and to use it only for the purpose of providing their services to us. For example, we use payment processors who help us to process credit card transactions. By using our services, you authorize POWR to sub-contract in this manner on your behalf.

Rare circumstances include when we need to share information if required by law, or in a corporate restructuring or acquisition context (see below for more details).

We recognize that you have entrusted us with safeguarding the privacy of your information. Because that trust is very important to us, the only time we will disclose or share your personal information or plugin data with a third party is when we have done one of three things, in accordance with applicable law: (a) given you notice, such as in this privacy policy; (b) obtained your express consent, such as through an opt-in checkbox; or (c) anonymized the information so that individuals cannot be identified by it. Where required by law, we will obtain your express consent prior to disclosing or sharing any personal information.

We may disclose:

• Your information to our service providers. We use service providers who help us to provide you with our services. We give relevant persons working for some of these providers access to your information, but only to the extent necessary for them to perform their services for us. We also implement reasonable contractual and technical protections to ensure the confidentiality of your personal information and data is maintained, used only for the provision of their services to us, and handled in accordance with this privacy policy. Examples of service providers include payment processors, email service providers, and web traffic analytics tools.
• Your account details to your billing contact. If your details (as the account holder) are different to the billing contact listed for your account, we may disclose your identity and account details to the billing contact upon their request (we also will usually attempt to notify you of such requests). By using our services and agreeing to this privacy policy, you consent to this disclosure.
• Aggregated information to third parties to improve or promote our services. No individuals can be identified or linked to any part of the information we share with third parties to improve or promote our services.
• The presence of a cookie to advertise our services. We may ask advertisers to display ads promoting our services on other websites. We may ask them to deliver those ads based on the presence of a cookie but in doing so will not share any other information with the advertiser. Our advertising network partners may use cookies and page tags or web beacons to collect certain non-personal information about your activities on this and other websites to provide you with targeted advertising based upon your interests.
• Your information if required or permitted by law. We may disclose your information as required or permitted by law, or when we believe that disclosure is necessary to protect our rights, and/or to comply with a judicial proceeding, court order, subpoena, or other legal process served on us.
• Your information if there's a change in business ownership or structure. If ownership of all or substantially all of our business changes, or we undertake a corporate reorganization (including a merger or consolidation) or any other action or transfer between POWR entities, you expressly consent to POWR transferring your information to the new owner or successor entity so that we can continue providing our services. If required, POWR will notify the applicable data protection agency in each jurisdiction of such a transfer in accordance with the notification procedures under applicable data protection laws.
• Information you expressly consent to be shared. For example, we may expressly request your permission to provide your contact details to third parties for various purposes, including to allow those third parties to contact you for marketing purposes. (You may later revoke your permission, but if you wish to stop receiving communications from a third party to which we provided your information with your permission, you will need to contact that third party directly.)

What are your rights to your information?

You can:

• Update your account details. You can update your registration and other account information on your My Account page. Information is updated immediately.
• Download/backup your plugin data. We provide the ability to export, share and publish some plugin data in a variety of formats. This allows you to create your own backups or conduct offline data analysis.
• Delete your plugin data. Deleting plugin data in the ways described on this page may not permanently delete plugin data immediately. As long as you maintain an account with us, we may retain your deleted data in case you delete something by accident and need to restore it. To the extent permitted by law, we will permanently delete your data if you request to cancel your account.
• Cancel your account. To cancel and delete your account, please contact customer support. Deleting your account will cause all the plugin data in the account to be permanently deleted, as permitted by law, and will disable your access to any other services that require a POWR account. We will respond to any such request, and any appropriate request to access, correct, update or delete your personal information within the time period specified by law (if applicable) or without excessive delay. We will promptly fulfill requests to delete personal data unless the request is not technically feasible or such data is required to be retained by law (in which case we will block access to such data, if required by law).

For how long do we retain your data? We generally retain your data for as long as you have an account with us, or to comply with our legal obligations, resolve disputes, or enforce our agreements. Data that is deleted from our servers may remain as residual copies on offsite backup media for up to approximately 12 months afterward.

Security, cookies and other important information

Changes to this privacy policy. We may modify this privacy policy at any time, but if we do so, we will notify you by publishing the changes on this website. If we determine the changes are material, we will provide you with additional, prominent notice as is appropriate under the circumstances, such as via email.

For any changes to this privacy policy for which you are required to provide prior consent, we will provide you with reasonable notice of such changes before they become effective and provide you with the opportunity to consent to those changes. If you do not cancel your subscription and continue to use our services beyond the advance-notice period, you will be considered as having expressly consented to the changes in our privacy policy. If you disagree with the terms of this privacy policy or any updated privacy policy, you may close your account at any time.

• Security. We are committed to handling your personal information and data with integrity and care. However, regardless of the security protections and precautions we undertake, there is always a risk that your personal data may be viewed and used by unauthorized third parties as a result of collecting and transmitting your data through the internet.
• Cookies. We use cookies on our websites. Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period of time, depending on what we use it for. By using our websites and agreeing to this privacy policy, you expressly consent to the use of cookies as described in this policy. We use cookies for several reasons:
• To make our site easier to use. When you sign into your account, we may store your username in a cookie to make it quicker for you to sign in whenever you return to POWR.
• For security reasons. We use cookies to authenticate your identity, such as confirming whether you are currently logged into POWR.
• To provide you with personalized content. We may store user preferences, such as your default language, in cookies to personalize the content you see.
• To improve our services. We use cookies to measure your usage of our websites and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services and optimize the content we display to users.
• Blogs and Forums. Our website offers publicly accessible blogs and community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. We’re not responsible for any personal information you choose to submit in these areas of our site. To request removal of your personal information from our blog or community forum, contact us at support@powr.io. In some cases, we may not be able to fulfill your request and we will let you know why.
• Online Tracking. We currently do not process or comply with any web browser's "do not track" signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit our websites or use our services (unless otherwise stated in a service-specific privacy statement).
• Safety of Minors and COPPA. Our services are not intended for and may not be used by minors. "Minors" are individuals under the age of majority in their place of residence (or under 13 in the United States). POWR does not knowingly collect personal data from minors or allow them to register. If it comes to our attention that we have collected personal data from a minor, we may delete this information without notice. If you have reason to believe that this has occurred, please contact us at support@powr.io.
• Third Parties POWR may allow third-party companies to collect certain information when you visit our web site or in our emails/communications. These companies may utilize cookies, pixels or other technologies to collect and use non-personally identifiable information (e.g., hashed data, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over). Our partners may link the personal information we share with them to the cookie stored on your browser or device, and they may collect information such as your IP address, browser or operating system type and version, and demographic or inferred-interest information. Our partners use this information to recognize you across different channels and platforms over time for advertising, analytics, attribution, and reporting purposes. To learn more about behavioral advertising practices or to opt-out of this type of advertising, you can visit the websites of the Digital Advertising Alliance at www.aboutads.info, the Networking Advertising Initiative at www.networkadvertising.org/choices/, the Digitial Advertising Alliance at http://youradchoices.com, and the European Interactive Digital Advertising Alliance at http://www.youronlinechoices.eu .
• English version controls. In the event of any ambiguity or conflict between translations, the English version is authoritative.

Consents

By signing up for an account, clicking "I Agree" or any other button indicating your acceptance of this privacy policy, you expressly consent to the following:

1. You consent to the collection, use, disclosure and processing of your personal data in the manner described in this privacy policy, including our procedures relating to cookies, IP addresses and log files.
2. Our servers are based in the United States, so your personal data will be primarily processed by us in the United States.
3. You consent to us sharing your personal data with relevant persons working for service providers who assist us to provide our services.
4. If you have enabled cookies on your web browser, you consent to our use of cookies as described in this privacy policy.

Additional information for European Union users

• "Personal data". For users located in the EU, references to "personal information" in this policy are equivalent to what is commonly referred to as "personal data" in the EU.
• About IP addresses. Our servers record the incoming IP addresses of visitors to our websites (whether or not the visitor has a POWR account) and store the IP addresses in log files. We use these log files for purposes such as system administration and maintenance, record keeping, tracking referring web sites, inferring your location, and security purposes (e.g. controlling abuse, spam and DDOS attacks). We also store IP addresses along with certain actions you take on our system. IP addresses are only linked to plugin responses if a plugin creator has configured a plugin to collect IP addresses. By agreeing to this privacy policy, you expressly consent to POWR using your IP address for the foregoing purposes. If you wish to opt out from the foregoing consent to use your IP address, you must cancel your account (if you have one) or not respond to a plugin if requested to do so.
• Data controller. POWR Inc., is the data controller for registration, billing and other account information that we collect from users in the EU. However, the data controller for plugin data is the plugin creator. The plugin creator determines how their plugin data are used and disclosed. POWR Inc. only processes such plugin data in accordance with the instructions and permissions (including those given under this privacy policy) selected by the plugin creator when they create and administer their plugin.
• Your responsibilities. Your responsibilities. By using our services, you agree to comply with applicable data protection requirements when collecting and using your plugin data, such as requirements to inform respondents about the specific uses and disclosures of their data, including (but not limited to) cookies. You are responsible for protecting user personal information you receive or process and complying with all relevant legal requirements when you use our services. This includes applicable data protection and privacy laws that govern the ways in which you can use a user’s information. Such laws may require that you post, and comply with, your own privacy policy, which must be accessible to the respondents you interact with and compatible with this policy and POWR’s Terms of Use. For more information on the General Data Protection Regulation, see more resources at https://gdpr-info.eu and http://gdprandyou.ie.

Additional information for California Residents

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that POWR Inc discloses certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that POWR Inc delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing support@powr.io, calling us at +1 415-619-2830, or sending a letter to us at POWR Inc, 44 Tehama Street, San Francisco 94105.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Categories of information that may have been collected in the previous 12 months:

Category	Examples
Identifiers	A real name, alias, postal address, email address, unique personal identifier, online identifier, Internet Protocol address, email address, phone number, or other similar identifiers.
Commercial information	Records of products or services purchased through POWR and POWR's products.
Usage	Information on the User's interaction with POWR's products.
Geolocation data	General physical location, based on Internet Protocol address.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Additional information for Japanese users

You agree that you are responsible for notifying the respondents of plugins that you create using our services about how POWR may use the respondents’ plugin responses and personal data as described in this privacy policy and obtaining prior consent from respondents to disclose their personal data to POWR.