Penlo operates a service that allows you to share your location with other users in your family or friends, which we make available through our apps (the "Service"). This Privacy Policy explains our practices regarding the collection, use, disclosure, transfer, storage, and protection of personal information that is collected through our Service, as well as your choices regarding the collection and use of information. Our Service is available in many countries, which may have different standards and requirements in respect of the information we provide in the Privacy Policy and how we use personal information.
Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in the part of this Privacy Policy that is relevant to you.
Registration and Profile Information. When you create an account, we may collect your personal information such as your username, first and last name, email address, mobile phone number. We may collect a photo, if you or a Friend member associate a photo with your account. If you want to add a family member’s name to your account, we collect the family member’s name, email address, and mobile phone number. We may also collect billing information when you sign up for Premium service.
Data collected through use of the Service. After you set up your account, we may ask for other profile and demographic information, such as personal emergency instructions and information, and nickname. You may also customize your map by labeling locations, such as “work” and “home,” to make it easy to spot your favorite places and to provide alerts when family members leave and arrive.
Geolocation. We collect your location information through your IP address, WiFi, Bluetooth, and GPS coordinates (e.g., latitude/longitude) available through your mobile device. We may also gather information about your location using other technologies and sensors which may provide us with information about nearby devices, WiFi access points and networks, and nearby cell towers. If you enable the mobile app to use your Bluetooth signal, we may be able to determine location based on nearby Bluetooth-enabled devices, which helps us to improve location accuracy, identify other Penlo users and devices that have been in proximity to each other, and improve location updates for all devices in the Penlo network. Depending on your device settings, we collect location information in the background, even when you are not actively using the app. We collect and maintain location data to provide you the features and functionality of the Service.
Driving Event Data. We collect, and may use a third party partner to collect, sensory and motion data from your smartphone or mobile device, including information from the gyroscope, accelerometer, compass and Bluetooth, in order to calculate and detect driving events such as speeding, hard braking, crash detection and other events. Your mobile device provider may refer to this information as “Motion and Fitness” data (description may vary according to device and platform). We may also share this information with third party partners for marketing, research, analytics and other purposes. If you want to opt-out of the collection of your sensory and motion, please adjust your settings in your mobile device to limit the app’s access to your sensory and motion data. Please see “Your Choices About Your Information” below to learn more.
Messages and User Content. We collect information when you message other members of your Friend through use of the service. We may also retain any messages you send to us.
We use this information to operate, maintain, and provide to you the features and functionality of the Service and to communicate directly with you, such as to send you alerts on the movements of your Friend, crime alerts in your neighborhood, etc.
Social Media. When you interact with our site through various social media, such as when you Like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Penlo’s website or Service.
Identity verification. In limited circumstances, we may use identity verification services provided by a third-party provider Berbix to verify your age and/or to obtain verifiable parental consent for your child to use the Service. When identity verification is required, we will ask you to upload an image of your valid government-issued ID along with a selfie image. Our identify verification provider will use a combination of machine learning tools and optical scans to authenticate your identity document, and may use facial recognition technology to produce a unique biometric identifier based on facial geometry that can be used to compare your selfie to the image on the identity document you provided to determine the likelihood that the images are a "match." Penlo does not receive the biometric identifier generated from the images. It is generated and held by our identity verification provider until the biometric identifier is no longer needed for the purposes described in this paragraph, which will occur no later than 60 days after your last verification interaction with us. For identity verification and security purposes, Penlo may have access to the information extracted from the identity scan of the ID document (such as a name and partial driver’s license number) as well as the results of the identity verification process. We may use this process and associated information to verify your identity, authenticate your identity documents, confirm appropriate parental consent, and protect against fraud and misrepresentation. We do not use, disclose or retain your biometric information for any other commercial purpose. Our third-party provider processes this information on our behalf strictly in accordance with our contractual agreements. Please note this service may not be available in all jurisdictions.
Information from third-party services. We collect information from third party services that you connect to your Penlo account. For example, if you link your Penlo account to a voice assistant platform to enable interaction with our service through voice commands, such as through the Penlo Google Action (“Action”) available on Google Assistant-enabled devices, we will collect the queries and commands applicable to Penlo that you make through the Action or other voice assistant platforms.
Information we collect automatically through the use of technology. When you visit our website, use our mobile app, read our emails or otherwise engage with us, we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you. We use these tracking technologies to collect usage and device information, such as:
We may collect analytics data, or use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
We use this information to (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide custom, personalized content and information, including targeted content and advertising; (iii) track your location and movements; (iv) identify and contact you across multiple devices; (v) provide and monitor the effectiveness of our Service and our marketing campaigns; (vi) monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns; (vii) diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs; and (viii) detect or prevent fraud or other harmful activities; (xi) automatically update our mobile application on your system and related devices; and (x) otherwise plan for and enhance our Service.
If you prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. These browser settings that block cookies may have no effect on non-cookie technologies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time.
We and our third party partners may also use information collected through tracking technologies for advertising purposes. Please see “Third Party Tracking and Online Advertising” below to learn more.
Our partners and service providers may also store your personal information outside your jurisdiction of residence. Accordingly, your personal information will be accessible to law enforcement and/or regulatory authorities according to the applicable laws of such jurisdictions.
De-Identified Information: We may also share your information with third parties in a form that does not reasonably identify you directly. These third parties may use the de-identified information for any purpose.You may, of course, decline to submit any personal information through the Service, in which case Penlo may not be able to provide its Services to you.
Modifying Your Account Information and Settings: You may modify your account information, update or amend your personal information, or change your password at any time by logging in to your account. If you have any questions about reviewing or modifying your account information, you can contact us directly at [email protected].
Close Your Account or Delete Personal Information: We retain your information for as long as your account is active or as reasonably necessary to maintain the Service, meet legal and accounting obligations, and for the other purposes described in this Privacy Policy. If you wish to close your account, and/or request to delete your personal information, please contact us at [email protected]. When account information is deleted or de-identified, certain residual information may remain within our archive records, such as for customer and technical support, billing and tax purposes.
Emails and Notifications: You can control your receipt of email and text alerts by visiting “Settings” and “Alert Options” within the mobile app. You can also stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of Service-related emails (e.g., account verification, parental consent notification, order confirmations, change or updates to features of the Service, technical and security notices). You may also unsubscribe from receiving SMS text messages by replying “STOP” to the number sending the message. We make every effort to promptly process all unsubscribe requests.
Location and Movement Data Collection and Sharing: As described in Section 2, we collect precise location data and driving event and movement data (such as accelerometer data, magnetometer data, gyro data, etc.) from your device to provide the Penlo Services, and may share your personal information, including location and movement data, with other Penlo users in your Family or other Friend you belong to, and with third parties for crash detection, research, analytics, attribution and tailored advertising purposes. You have many options to control this data collection and sharing activity through the App Settings:
Third Party Tracking and Online Advertising: We may share information about your use of our Services over time, including location information, with third party ad networks, social media companies and other third parties so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites, apps or services, or on other devices or advertising channels. We may also display targeted advertising to you through social media platforms, such as Facebook, Twitter, Google+ and others. These third party ad partners collect and use information such as click stream information, timestamp, hashed email address, device ID or AdID, your use of third party applications and/or precise geolocation data and other information, and may combine this information with information they collect directly through tracking technologies or that they receive other partners, both online and offline, so that they may recognize you across other browsers or devices you use, including computers, mobile devices and Smart TVs. These third parties use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
Penlo takes special precaution to protect the privacy of our younger users. Penlo does not knowingly collect personal information from children under the age of 13 (a “child”) without verifiable consent of a parent or guardian and the Service is intended to be used by children under 13 only with significant parental involvement and approval.
If Penlo learns that we have inadvertently collected personal information of a child without parental consent, we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has a registered account with our Service without your consent, please alert us immediately by emailing [email protected] so that we may delete that child’s personal information from our systems.
By enabling your child to create a user account and permitting your child to use the Service, you expressly agree to the practices described in this Children's Privacy Policy and you consent to the collection, use, and disclosure of your child's personal information as described herein.
Personal information we collect. We take special precautions to collect only as much information as is reasonably necessary for the child to use the Service. As further described in our Privacy Policy above, we collect various types of personal information from all users of the Service. For example, we collect profile information (username, email address and mobile phone number) when a user creates an account and other types of personal information the user may provide during the course of using the Service, such as a nickname, favorite location, and emergency contact information. We collect information about a user’s device (e.g., IP address, device type/model/manufacture / operating system, and a unique ID that allows us to identify the browser, mobile device or account, such as a UDID, IDFA, Google AdID or similar) as well as certain usage information about the use of the Service (for example, whether the user opens emails) and we collect analytics data. We collect geolocation data through the device IP address, WiFi, Bluetooth and GPS coordinates available through the user’s mobile device and through technologies and sensors that may be nearby. We also collect driving event data through sensory and motion data sensors in the user’s mobile device (e.g., data from a smartphone’s gyroscope, accelerometer, compass and Bluetooth) in order to calculate and detect driving events such as hard braking, speeding and crash detection. Please review the section of our Privacy Policy called “How We Collect and Use Information” to learn more.
Information sharing. Penlo may share or disclose a child’s personal information our third party vendors, service providers and business partners as described in our full privacy policy, including, for example, with third parties as needed to analyze and detect driving behavior data, perform analytics or otherwise , support the features and functionality of our Service such as crash detection. However, we do not share or sell personal information collected from the accounts of children under 13 for marketing or advertising purposes, nor permit our third party partners to collect and use such information for advertising purposes. Please review the section of our Privacy Policy called “Sharing of Your Information” to learn more about how we share information with our vendors, service providers and others.
Sharing information with other Penlo users. The child’s profile information and location will be shared with other members of the Family and any other Friend the child joins. Please note that if your child joins any other Friends, the child will be able to share his or her location with other members of that Friend and may exchange messages with those Friend members. You are responsible for monitoring your child’s account and location-sharing activity through the Service and for blocking or permitting location sharing features.
We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.
If you have any questions about this Privacy Policy, please feel free to contact us at [email protected].