Pivo Privacy Policy


Last updated February 10, 2023

Dear Visitor:

Following “Website” and our Pivo-related applications (“Services”) are part of 3i Inc. and its affiliates:

Websites:

  • pivo.ai (including circle.pivo.ai)
  • pivo.app (including tour.pivo.app, developer.pivo.app, and meet.pivo.app)
  • pivo.kr

Apps:

  • Pivo+
  • Pivo Play
  • Pivo Cast
  • Pivo Present
  • Pivo Live
  • Pivo Tour
  • Pivo Studio

This Privacy Policy describes how 3i Inc. and its affiliates (collectively “3i”, “we”, “our”, or “us”) collect, use, share and disclose information collected from or about you when you use our Services and how you can manage and control your information.
We collect various information from and about you, including information that you directly provide when you use our Services, information about how you use our Services and information from third-party sources. We use your information to deliver, analyze, maintain and support our Services. We also use your information to enhance our understanding of the way you use our Services and to develop the most relevant Services for you.

What Information Do We Collect About You?

We collect information from and about you in connection with your use of our Services. Some of this information may be considered “Personal Information” or “Personal Data” (as defined under applicable laws) which is any information that identifies you or your device or is reasonably associated with you.
We also collect, use, share and disclose aggregated or de-identified information that does not reasonably identify you or your device and is not considered personal information.

Information You Provide

  • Registration Information: When you create an account or profile with us, register for certain Services, complete an application form, participate in promotions, respond to market research surveys that we sponsor, or place an order for any of our products or Services, we may ask for your information including your name, sex,[JS1] [YS2] age, email address, telephone number, billing address, or other postal address. We may also collect your information such as your date of birth and payment methods when you subscribe to the [Premium Tracking Plan] or purchase any paid function of our Services.
  • Information You Post on our Services: We may collect information when you post comments or other content to our Services, which may include your username or screenname, comments, likes, interests, status, pictures, and references to your online presence.

Information Collected Automatically

  • Device information: We may collect information from and about you, including your use and activity in our Services, your interaction with us, information about your network data, network device, or computer you may use to access our Services, and other devices (such as Pivo Pod, Pivo Wireless Microphone, etc.) that you may use with Pivo. The information includes:
    • Your activity in our Services, including, but not limited to, the filter or function you used, your search history, the content you watched, and your recording activity in our Services.
    • Your interaction with us such as email, push message, and other messages through online messaging channels.
    • Your interaction with our customer services such as date, time, and reason you contact us, transcripts of your conversation with us, and if applicable, your phone number and call recordings.
    • Your device hardware model, device hardware information (Pod information such as Pod name, firmware version), and other unique device identifiers, serial number, current software version, IP address, Application version, OS, OS version, cookies, subscription information, and settings of the devices you use to access the Services.
    • Your location information, such as (a) information that identifies the precise location of your mobile device and (b) your IP address, which may be used to estimate your approximate location.
  • Viewing Information: We may collect information about statistics on page views, referring sources (such as referral URLs), browser, and standard web server log information.
  • Information From Third-Parties: We may also collect information about you from third parties, including government entities, public databases, payment partners such as card networks and payment processors, and third-party applications that you choose to use such as Apple, Facebook, Google, Kakao, Naver, TikTok or other social networking sites.

Publicly or Commercially Available Information

We may also collect publicly or commercially available information about you, including information from social networks, and combine it with other information about your needs, interests, and preferences.

Your Options

You may choose to limit information you provide when our Services request it. If you choose not to provide information that is required for our Services to function, this may limit your ability to use some Services.

How Do We Use Your Information and Why?

We may use the information we collect as described here:

We may use information to provide our Services. We may use your information to create, manage, and authenticate your account with us and provide you with customer support and account updates. We may use your information to complete the transactions you request, to perform our contractual obligations with you, or to ensure that our Services function properly.

We may use information for marketing purposes. We may use your information to market our Services, no mobile information will be shared with third parties or affiliates for marketing purposes. This may include sending emails, text messages, push notifications, or other communications marketing or advertising our products, services, features, offers, promotions, news, and events. This also may include ads for our products or services, and/or a third-party’s products or services that are personalized based on information we collect from and about you. See the section titled “Your Rights and Choices” for information on your choices regarding how we may use your information for marketing purposes.

We may use information to improve our products and Services. We may use your information to analyze our products and services to enhance our understanding of you for providing you with the most relevant Services. This may also include using information for testing, research, analysis, and development of our Services.

We may use information to maintain the safety and security of our Services. We may use your information to protect our rights, privacy, property, or safety, and/or that of our affiliates, partners, you, or others and to comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements.

We may use information as otherwise permitted by law. We may use your information to resolve disputes, enforce our agreements, and as otherwise required or permitted by law.

Who Do We Share Your Information With and Why?

We may share information inside of 3i. We may share your information internally within our business, including our subsidiaries and affiliates, to help us provide our Services or to help us process your request.

We may share your information in connection with a corporate transaction. We may share your information in connection with, or during negotiations of, any merger, sales of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

We may share information with third parties who perform Services on our behalf. We carefully select companies – service providers – who operate on our behalf to perform Services we outsource to them, such as marketing, research, compliance, audits, processing payments, communications, IT development, maintenance, hosting and support, and customer service operation. We may share your information with service providers to help us provide our Services.

We may share information with our business partners. Partners may include marketing, advertising, or other partners such as those working with us on co-branded Services or events and digital distribution partners where we make our Services available. We may share your information with our partners. Our partners may use your information as described in their privacy policies and procedures. This may, depending on the partner services you use, include:

  • Facilitating partner pre-paid promotions or collection of payment for our Services;
  • Suggesting contents and features available in our Services to you in the partner’s user interface. These suggestions are part of our Services for you and may include customized and personalized recommendations for certain contents;
  • Sharing information from or about you with online and/or offline marketplaces to analyze and improve your purchasing experiences.

We may share your information with sponsors and other partners for contests, giveaways, sweepstakes, and promotions. We may use your information to verify your entry into and eligibility to participate in contests, sweepstakes, giveaways, or promotions and to inform you if you have won. If your entry information will be used for any other purposes, we will disclose that in the applicable rules governing that sweepstake, contest, giveaway, or promotion.

We may share information to provide advertising based on your interests. See the section titled “Your Rights and Choices” for information on your choices regarding our sharing of your information for advertising purposes.

We may share information when required by law or to protect ourselves. For example, we may share your information when it is necessary for us to comply with applicable laws and rules or legal obligations, to respond to legal claims, or to protect against harm to the rights, property, or safety of 3i, our users, or the public.

We may share your information for reasons not described in this policy. We may share your information for any reasons not described in this Privacy Policy, as long as it is appropriate to carry out legitimate business activities allowed by law. In that event, we will provide prior notification.

Your Rights and Choices

You have certain choices about how we use your information. We would like to make sure you are fully aware of all of your rights and choices. Every user is entitled to the following:

  • The right to access: You have the right to access, update or delete information we have on you. You have the right to request us a copy of your personal information.
  • The right to rectification: You have the right to request us to correct any incomplete or inaccurate information we have about you.
  • The right to erasure: You have the right to request us to delete or remove your personal information. You can email us at support@pivo.ai for further requests.
  • The right to restrict processing: You have the right to request us to restrict the processing of your personal information. You have the right to object to the processing of your personal information on grounds relating to your particular situation if we process your personal information based on our legitimate interest. You have the right to object to the processing of your personal information for direct marketing purposes at any time.
  • The right to data portability: You have the right to request us to transmit your personal information, which you have provided to us in a structured, commonly used, and machine-readable format, directly to you, or to a third-party you have chosen.
  • The right to withdraw your consent: You have the right to withdraw your consent to use your information. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of our Services.
  • Opt out of receiving our marketing emails: If you would like to opt-out of receiving our promotional messages, please contact us at support@pivo.ai. You will not be able to opt-out of messages that are considered necessary for our Services.
  • Control cookies and tracking tools: To learn how we—and our partners—use cookies and other tracking tools, please visit the 3i Cookie Policy at here.

International Transfer

Please be aware that your personal information we collect and process may be transferred and maintained outside your home country, where that information will be processed may have lower standards of data protection than in your home country. We may transfer personal information to another country in order to provide our Services. When we do transfer personal information to other countries, we ensure appropriate safeguards are in place with appropriate security measures. The transfer of such information will be in compliance with local legislation for the cross-border transfer of data, where applicable. Any international transfer of personal information will be in accordance with this Privacy Policy and in compliance with applicable laws.

Additional Information if You Are Located in California

  • Your Rights under California Consumer Privacy Act If you are a California resident, you have certain rights under the California Consumer Privacy Act of 2018 (“CCPA”).
  • Right to Know: You have the right to request us to disclose information to you about our collection, use and disclosure of your personal information over the past twelve (12) months. Once we receive and confirm your request, we will disclose to you the following:
    • 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
    • If we sold or disclosed your personal information for a business purpose, we will disclose to you:
      • Sales, identifying the personal information categories that each category of recipient purchased
      • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained
  • Right to Opt-Out of Sale of Your Personal Information: You have the right to opt-out of the “sale” or “sharing” of your personal information. “Sale” means the disclosure of personal information to a third party in exchange for money or other value. “Sharing” means the disclosure of personal information to a third party for targeted marketing.
  • Right to Deletion: You have the right to request that we delete any personal information we maintain about you.
  • Right to Non-Discrimination: We shall not discriminate against you for exercising any of your CCPA rights.

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us by emailing us at support@pivo.ai.

We may require additional information to verify your identity or to verify that your authorized agent has the authority to make a request on your behalf before responding to your CCPA rights request. We use good faith efforts to respond to a verifiable request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing.

Categories of Personal Information Collected We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. The following is a list of categories of personal information which we may collect or may have been collected from California residents in the past 12 months. The categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected but reflects our good faith belief that to the best of our knowledge that some of that information from the applicable category may have been collected.

Categories of Personal Information Collected

Category Examples Collected
A. Identifiers A name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account username, screen name, password, Social Security number, driver’s license number, passport number, or other similar identifiers. YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. YES
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). YES
D. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. NO
F. Internet or other similar network activity. Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement, including user generated content. YES
G. Geolocation data. Physical location or movements. YES
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. YES
I. Professional or employment-related information. Current or past job history or performance evaluations. NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO

Under the CCPA, personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the CCPA's scope, such as:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”), the Gramm-Leach-Bliley Act (“GLBA”) or California Financial Information Privacy Act (“FIPA”), and the Driver's Privacy Protection Act of 1994

Source of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you: for example, from forms, subscriptions, or purchase orders you complete on our Services.
  • Indirectly from you: for example, from observing your activities in our Services.
  • Automatically from you: for example, through cookies we set on your device.
  • From third parties: for example, from marketing and advertising companies, social networking companies, and service providers.
  • From publicly available sources: for example, online database searches.

Use of Personal Information

As described in more detail in the section titled “How Do We Use Your Information and Why?” of our Privacy Policy, we may use or disclose personal information we collect for the following business purposes or commercial purposes:

  • To provide our Services
  • For marketing purposes
  • To provide you with ads or information that may be of interest to you
  • To improve our products and services
  • To maintain the safety and security of our Services
  • To carry out our legal obligations
  • For testing, research, analysis, and development of our product and services
  • As described to you when collecting your personal information or as otherwise set forth in the CCPAAs described to you when collecting your personal information or as otherwise set forth in the CCPA
  • For internal administrative and auditing
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations

Disclosure of Personal Information

As described in more detail in the section titled “Who Do We Share Your Information With and Why?” of our Privacy Policy, we may use or disclose your personal information to a third party for the above purposes. We may share your personal information with the following categories of third parties:

  • Our affiliates and subsidiaries
  • Service providers
  • Business partners
  • Payment processors
  • Sponsors and other partners for contests and promotions
  • In connection with corporate transactions
  • Third parties to whom you or your agent authorize us to disclose your personal information in connection with products or services we provide to you
  • Law enforcement or others if required by law

From the chart of the above sub-section titled “Categories of Personal Information Collected”, we may use or disclose and may have used or disclosed in the past twelve (12) months the following categories of personal information for the above purposes:

  • Category A: Identifiers
  • Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Category C: Protected classification characteristics under California or federal law
  • Category D: Commercial information
  • Category F: Internet or other similar network activity
  • Category G: Geolocation data
  • Category H: Sensory data

When we disclose personal information for a business purpose or a commercial purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

Sales of Personal Information

The CCPA broadly defines the term "sale" or “sell” to mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that we may have received some kind of benefit in return for sharing personal information and it does not necessarily mean we received any money in exchange.

As defined by the CCPA, we may “sell” or “share” identifiers, customer records, commercial information, internet or other similar network activity, geolocation data, and sensory data to or with our affiliates and subsidiaries, service providers, business partners, payment processors, sponsors, and other partners for contests and promotions, other companies in connection with corporate transactions, and third parties to whom you or your agent authorize us to disclose your personal information in connection with products or services we provide you.

As required by the CCPA, we provide a link on our website, mobile and online application, titled “DO NOT SELL MY PERSONAL INFORMATION” , to a web page where you can opt-out of the ‘sale’ of your personal information. California residents may exercise your right to opt-out there by clicking the “DO NOT SELL MY PERSONAL INFORMATION” button.

Personal Information of Minors Under 16 Years of Age

We do not knowingly collect, maintain, disclose, or otherwise process personal information from minors under the age of sixteen (16) through our Services.

We do not sell your personal information if we actually know you are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either you if you are between 13 and 16 years of age, or the parent or guardian if you are less than 13 years of age. If you opt-in to the sale of personal information, you may opt-out of future sales at any time. To exercise the right to opt-out, you or your authorized representative may submit a request to us by contacting us.

Do Not Track

Our websites and apps are not designed to respond to “Do Not Track” requests from browsers.

“Shine the Light” and “Online Eraser” Laws

Under the California Civil Code §1798.83 (California’s “Shine the Light” law), California residents may request us once a year, free of charge, information about sharing their personal information in the preceding calendar year with third parties for those third parties direct marketing purposes.
If you would like to request more information under the California’s Shine the Light law, you can contact us using the contact information provided below.

Under the California Business and Professions Code §22581 (California’s “Online Eraser” law), California residents under the age of eighteen (18) who are registered users of online sites, services, or applications where this policy is posted may request and obtain removal of content or information you have publicly posted. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
If you would like to request more information under the California’s Online Eraser law, you can contact us using the contact information provided below.

California Consumer Privacy Notice for California Employee and Job Applicants

Additional Information if You Are Located in the EEA, the UK or Switzerland

If you are located in the European Economic Area (“EEA”), in the United Kingdom (“UK”), or in Switzerland, you may have certain rights under the EU General Data Protection Regulation (“GDPR”) and applicable national legislation:

  • The right to request access to, and a copy of, information we hold about you, including details as to how we process this information.
  • The right to object to, or restrict, our processing of your information.
  • The right to request that your information be erased from further use.
  • The right to correct, amend, or update information you have given us.
  • The right of portability, which allows you to request that we share your information with others.
  • The right to withdraw any consent to processing you have provided us.
  • The right not to be subject to a decision based solely on automated processing including profiling, under certain conditions.

In addition, you have the right to enforce your rights in court. You may also have the right to lodge a complaint against us to a Data Protection Authority.

International Transfers: Information that is collected from the EEA, the UK, or Switzerland may be transferred to countries outside of the EEA, the UK, or Switzerland, as applicable, that may not provide levels of protection for your personal information equivalent to the protection provided by the laws of the European Union, the UK or Switzerland, including the United States. When we transfer your personal information outside the EEA, we generally use EU-approved Standard Contractual Clauses to ensure your personal information is adequately protected. We may also transfer to recipients with binding corporate rules or international frameworks intended to enable secure data sharing.

Retention of Personal Information: We retain your personal information only for as long as necessary for the purpose for which it was collected or in accordance with applicable law.

Legal Basis for Processing: We will only collect, store, or otherwise process personal information collected from you in the EEA or the UK in the following situations:

  • When we have your consent to do so. You can withdraw your consent at any time.
  • When we need to use your personal information to fulfill a contract with you.
  • When we or a third party have legitimate interests in processing your personal information. For example, we may process your personal information to communicate with you about our Services, to provide, secure, and improve our Services, and, in certain circumstances, to deliver advertising to you. You have the right to object to our processing of your personal information that is based on our legitimate interests.
  • When we are required by law to process personal information.

If you would like to exercise your rights under the GDPR (or similar laws in the UK or Switzerland), you may contact us at dpo@3i.ai.

How Do We Protect Your Information?

We are committed to protecting your information. We have adopted commercially reasonable technical, administrative, and physical security measures designed to provide protection for your information against loss, misuse, unauthorized access, and alteration. The security of your information is important to us, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security.

Cookies and Similar Technologies

We and our third parties that provide content, advertising, or other functionality in our Services, use cookies and other tracking technologies such as beacons, tags, and scripts to collect and track information and to improve and analyze our Services.

Cookies

Cookies are small files placed on your device. They enable the entity that put the cookie on your device to recognize you across different websites, services, and browsing sessions. Cookies serve many useful purposes.

  • Cookies can remember your sign-in credentials, so you don’t have to enter those credentials each time you sign-in to our Services.
  • Cookies help us and third parties understand which parts of our Services are the most popular because they help us see which pages and features visitors are accessing and how much time they spend on the pages. Studying this information helps us to improve our Services.
  • Cookies help us and third parties to provide you with relevant content and advertising by collecting information about your activity in our Services, other websites and apps.

When you use a web browser to access our Services, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check your browser’s help menu to learn how to change your cookie preferences. Your device operating system may contain additional cookie controls. Please note that some of our Services are designed to work using cookies, so disabling cookies may affect your ability to use those Services.

Other Local Storage

We and our third parties may use other kinds of local storage technologies, such as local stored objects (also referred to as Flash Cookies) and HTML5 local storage, in connection with our Services. These technologies are similar to the cookies described above. They are stored on your devices and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your devices from standard cookies, so you might not be able to control them using standard browser tools and settings.

GeoIP Location

We and our third parties may use technologies called geoIP that communicate information about the country you are located. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed a particular content or a particular email message, and determine the time and date on which you viewed the beacon and the IP address of your device. We and our third parties use beacons for a variety of purposes, including to analyze your activity in our Services and, along with cookies, to provide content and ads that are more relevant to you.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you if any changes to this Privacy Policy are material and, where required by applicable laws, we will obtain your consent. Notice may be made by email, a prominent notice on our websites, applications or Services, or other means of complying with applicable laws.

Contact Us

You may contact us if you have general questions regarding our Privacy Policy, your personal information, or exercising your rights:

  • By email: questions@pivo.ai
  • By writing us: 3i, Inc., 23 Yeoksamro-25gil, Gangnam-gu, Seoul 06224, Republic of Korea