Last modified: May, 2022

In this Privacy Policy (“Policy”), we describe how Sagoon, Inc. (“Sagoon”) collects, retains, uses, and discloses information that we obtain about visitors to our websites (the “Sites”), users of our mobile application (“App”), and the services available through our App and Sites including, but not limited to, Earning Rewards, and Gifting (collectively, the “Services”).

By visiting the Sites, using or downloading the App, or using any of our Services, you agree that you have read and understand that your personal information will be handled as described in this Policy. Your use of our Sites, App, Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The Sagoon Terms of Service are incorporated by reference into this Policy.

Overview

We think transparency is important. In this overview, we summarize the personal information we collect and how we use it in California, which is further explained in our Policy below. Keep in mind that the actual personal information we collect and how we use it varies depending upon the nature of our relationship and interactions with you. Also, in some cases (such as where required by law), we ask for your consent or give you certain choices prior to collecting or using certain personal information.

Categories of Personal Information Collected. Generally, we may collect the following categories of personal information:

Information We Collect About You

When you use our Services, we collect information about you directly from you and from third parties, and automatically through your use of our Sites and App. While the information we collect varies depending upon the circumstances and the Services you use, in this section we explain in general the personal information we collect.

Information We Collect Directly. We may collect the following personal information directly from you:

• Account information: The actual information we collect from you depends on how you use and interact with our Services. To create an account, you must provide a valid phone number. We also may collect additional information from you, including but not limited to, your name, password, date of birth and email address. We may also ask you to provide us with some additional information that will be publicly visible on our Sites and App, such as a profile picture, tagline message. In addition:
• Phonebook and contacts: If you grant us permission within the App, Sagoon may access your contacts from your contact list or phone book, in order to help you connect with your family, invite your family, share stories, send and receive gifts to your contacts. Please note that we only use your contacts details in order to connect or facilitate your connections with users you know on the Services and to enable you to invite others to join. You can also invite your family to join Sagoon by providing us with their contact information directly.
• Camera and photos: Many of our Services require us to collect images and other information from your device’s camera and photos. For example, you won’t be able to share stories or upload profile photos from your camera unless we can access your camera or photos. However, we only use and process your photos in order to enable you to share them or manage your content within the Services.
• Your connections: To help you organize how you socialize with others, we may create a favorites list of your contacts for you, and you may create, join, or be added to groups which are associated with your account information. You can invite your family to join Sagoon by providing us with their contact information or by allowing Sagoon to access your contacts from your mobile device or third-party sites to select family to invite.
• Customer support: When you contact our customer support or communicate with us in any other way, we will collect the information you provide.
• Other information: We also may collect information that your mobile device provides to us in connection with your use of the Services, such as your browser type, type of mobile device, browser language, IP address, mobile carrier, phone number, unique device identifier, advertising identifier and requested and referring URLs.

Information We Collect From Third Parties. We may collect personal information about you from third parties that we work with such as third-party providers of services to us (e.g., fraud detection, identity verification and security), advertising networks, analytics providers and marketing partners, social media platforms, as well as from public records and our affiliated companies. We work with these third-party providers to help us operate, provide, improve, understand, customize, support, and market our Services.

Information We Collect Automatically. We automatically collect information about your use of our Sites and App through various technologies. To the extent permitted by applicable law, we combine this information with other information we collect about you from other entities, including your personal information.

• Usage and log information: We collect information about your activity through our Services. For example, we may collect information about how you interact with our Services, such as what types of Stories you post or share; how you communicate with other users, such the time and date of your interactions, the number of stories you share with your family, which family you share stories with the most, and your interactions with stories (such as when you open a story or capture a screenshot); and how you earn and spend Rewards, how frequently you shop using your rewards, and how frequently you send gifts to your family or receive gifts from your family. We also collect log information when you use our Site and App, such as details about how you’ve used our Services; device information, such as your web browser type and language; access times; pages viewed; IP address; identifiers associated with cookies or other technologies that may uniquely identify your device or browser; and pages you visited before or after navigating to our Site.
• Content information: We collect content you create while using our Services, such as stories and information about the content you create or share, such as if the viewer has viewed the story, reacted on it, posted comments, shared it, or reported it.
• Device information: We collect information from and about the devices you use. For example, we collect information about your hardware and software, such as the hardware model, operating system version, device memory, advertising identifiers, unique application identifiers, apps installed, unique device identifiers, browser type, language, battery level, and time zone; information from device sensors, such as accelerometers, gyroscopes, compasses, microphones, and whether you have headphones connected; and information about your wireless and mobile network connections, such as mobile phone number, service provider, IP address, and signal strength.
• Location Information: When you use our Services, we may collect information about your location. With your permission, we may also collect information about your precise location using methods that include GPS, wireless networks, cell towers, Wi-Fi access points, and other sensors, such as gyroscopes, accelerometers, and compasses.
• Commercial information: We may collect information related to how many Rewards you earn and how you spend. We may also collect information on which categories of products you mostly shop, frequency of shopping for products, frequency of sending gifts, etc.
• Cookies and other technologies: We may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers to collect information about your activity, browser, and device. Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our Services. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information.

How We Use Your Information

While the purposes for which we may process personal information will vary depending upon the circumstances, in general we use, disclose and process personal information for the following business and commercial purposes:

• Providing our Services: to provide and operate our Services; provide troubleshooting and technical support, to fulfill your orders and requests, and to protect and secure our Services.
• Communicating with you: to communicate with you about your use of our Services, to respond to your inquiries, to administer surveys and questionnaires, such as for market research or member satisfaction purposes; and for other customer service purposes.
• Personalizing content and experiences: to tailor the content and information that we may send or display to you, to offer location customization, and to otherwise personalize your experiences while using the Services.
• Marketing and advertising: to send you newsletters, offers or other information we think may interest you; to contact you about our Services or information we think may interest you; and to administer promotions and contests. To assist us in advertising on third-party websites, mobile apps, and other online services, and to evaluate the success of our adverting campaigns through third-party channels (including our online targeted advertising and offline promotional campaigns). Where required by applicable law, we will obtain your consent to use your personal information for marketing and related purposes. You may unsubscribe from our mailing lists at any time by using the “unsubscribe” feature in any marketing emails you receive from us.
• Analyzing and improving the Services and our business: to better understand how users access and use the Site and our Services, as well as other products and offerings, both on an aggregated and individualized basis, to administer, monitor, and improve our Services, for our internal purposes, and for other research and analytical purposes. For example, we may evaluate which features of our Sites and App are more (or least) used by users.
• Complying with legal obligations: to comply with legal obligations, as part of our general business operations, and for other business administration purposes.
• Protection of rights: where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Service or this Policy.
• In support of our general business operations: relating to audits and assessments of our business operations, security controls, financial controls, records and information management program, and otherwise relating to the administration of our general business, accounting, record keeping and legal functions.
• Securing and protecting assets and rights: to protect our business operations, secure our network and information technology, assets and services; to prevent and detect fraud, unauthorized activities, access and other misconduct; where we believe necessary to investigate, prevent or take action regarding suspected violations of our Terms and other agreements, as well as fraud, illegal activities and other situations involving potential threats to the rights or safety of any person or third party; and as necessary to defend our legal interests and rights.

Aggregate, De-identified or Anonymous Data. We also create and use aggregate, anonymous and de-identified data to assess, improve and develop our business, products and the Services, and for similar research and analytics purposes. This information is not generally subject to the restrictions in this Policy, provided it does not identify and could not be used to identify a particular individual.

How We Share Your Information

We may share your information, including personal information as follows:

• Service Providers. We disclose the information we collect from you to service providers, contractors or agents who perform functions on our behalf. These service providers include IT hosting service, fraud prevention, and customer support providers.
• Affiliates. We disclose the information we collect from you to our affiliates or subsidiaries.
• Sagoon Platform Users. We disclose your username and any information that you post to our Sites and App, including, reviews, comments, and texts to all users of the Sites and App.
• Third Parties. We disclose the information we collect from you to third parties such as marketing companies to assist us with marketing products to you, app developers, publishers, and Google and Apple Maps.
• Third-party Applications. We disclose your posted content (e.g. texts, images, videos) to third-party applications where necessary to operate the Services.

We also disclose information in the following circumstances:

• Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company. As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
• In Response to Legal Process. We disclose your information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We disclose your information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Service or this Policy, or as evidence in litigation.
• Aggregate and De-Identified Information. We share aggregate, anonymized, or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

Our Use of Cookies and Other Tracking Mechanisms

We and our third-party providers use cookies, clear GIFs/pixel tags, JavaScript, local storage, log files, and other mechanisms to automatically collect and record information about your browsing activities and use of the Sites and other Services. We may combine this “usage data” with other personal information we collect about you. We use this usage data to understand how our Services are used, track bugs and errors, provide and improve our Services, verify account credentials, allow logins, track sessions, prevent fraud, and protect our Services, as well as for targeted marketing and advertising, to personalize content and for analytics purposes.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process or to allow us to track your activities while using our Site. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Some of the Services may not work properly if you disable cookies.

Pixel tags. Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use pixel tags (also referred to as web beacons, web bugs or clear GIFs), in connection with our Services to, among other things, help us manage ads and content, and compile statistics about usage of our Services. We may also use pixel tags in HTML emails to our customers, to help us track

Third-Party Analytics. We use automated devices and applications, such as Google Analytics, to evaluate usage of our Sites, and to the extent permitted, our Apps. We also may use other analytic means to evaluate our Sites and Apps. We use these tools to help us improve our Sites’ and Apps’ performance and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the Third-Party Ad Network section.

User-Generated Content

We invite you to post content on our Sites and App, including your comments, pictures, and any other information that you would like to be available on our Sites or App. If you post content to our Sites or App, all of the information that you post will be available to all visitors to our Sites. If you post your own content on our Sites or App, your posting may be accessed and shared by others and Sagoon cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy. However, please note that when you share new content, you can choose to share with everyone, only with your connections, or only with a subset of your connections, and you can also choose to block other users.

Third-Party Links

Our Sites and App may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

Security of My Personal Information & Sensitive Personal Information

We have implemented safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.

You should take steps to protect against unauthorized access to your login ID, password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Choices Regarding Your Personal Information

• You can modify, edit or remove most of your basic account information directly in the App.
• You can delete posted content such as texts, images, videos, comments that you have posted or shared privately and publicly directly in the App.
• You can control your communication with other users and whether you want to share posted content and who can view, you may delete others users’ posted content, and you may block other users from viewing your posted content or contacting you. You can also report content related to abuse and fraud that you have received from other users.
• You can revoke your permissions by changing the settings in the App or on your device if your device offers those options. If you choose to do so, certain services may lose full functionality.

Additionally, we may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. If you opt-out of receiving promotional emails, we may still send you emails about your account or any Services you have requested or received from us.

Retention Period

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or permitted by law. We may retain personal information for longer where required by our regulatory obligations, professional indemnity obligations or where we believe it is necessary to establish, defend or protect our legal rights and interests or those of others.

Children Under 13

Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems. Contact Us

If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at legal@sagoon.com or write to us at:

If in U.S.:
Sagoon Inc.,
1980 Teasel Ct.,
Woodbridge, VA 22192

If in India:
Privacy Officer/Grievance Officer
Sagoon India Private Limited,
Vatika Mindscapes, Tower B,
8th Floor, Sector 27 (D),
Faridabad-121003

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Sites and App. If we make any material changes to how we use your personal information, we will endeavor to provide you advanced notice, such as by emailing you or displaying a prominent notice to you within the App or on our Site.

Additional Information for California Residents

In this section, we provide additional information to California residents about how we handle their personal information, as required under California privacy laws including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.

A. Categories of Personal Information Under the CCPA

While our collection, use and disclosure of personal information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed personal information about consumers in the prior 12 months (from the Effective Date above).

Categories and Sources of Personal Information Collected. The table below identifies, generally, the categories of personal information (as defined by the CCPA), we have collected about consumers. For more information about the business or commercial purposes for which we collect and use personal information, please see the “How We Use Your Information” section above.

*See the Overview section above for further details regarding the categories of personal information we collect

Do We “Sell” Personal Information? Under the CCPA, a “sale” includes disclosing or making available personal information to a third party in exchange for monetary compensation or other benefits or value. While we do not disclose personal information to third parties in exchange for monetary compensation, we may disclose or make available certain categories of personal information to third parties in order to receive certain benefits or services, such as when we make browsing information available to third-party ad companies (through third-party tags on our Site and Apps) in order to improve and measure our ad campaigns and reach users with more relevant ads and content. As defined by the CCPA, we may “sell” Usage Data and Identifiers to advertising networks, social media platforms, and data analytics providers.

Sources of Personal Information. As further described in the “Information We Collect About You” section above, we may collect personal information from the following sources:

• directly from the individual
• advertising networks
• data analytics providers
• social media platforms
• internet service providers
• operating systems and platforms
• government entities
• data brokers
• business customer/client

B. California Residents’ Rights

CCPA Rights. In general, California residents have the following rights with respect to their personal information:

Do-not-sell (opt-out): to opt-out of our sale of their personal information. While we may “sell” personal information as defined by the CCPA, we do not sell personal information about California consumers who we know are younger than 16 years old.

• Right of deletion: to request deletion of their personal information that we have collected about them and to have such personal information deleted (without charge), subject to certain exceptions.
• Right to know: with respect to the personal information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
  • categories of personal information collected;
  • categories of sources of personal information;
  • categories of personal information about them we have disclosed for a business purpose or sold;
  • categories of third parties to whom we have sold or disclosed for a business purpose their personal information;
  • the business or commercial purposes for collecting or selling personal information; and
  • a copy of the specific pieces of personal information we have collected about them.
• Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting CCPA Requests. California residents may submit CCPA requests to opt out of sales, requests to know (access) and requests to delete their personal information through one of the following methods:

• Online by emailing legal@sagoon.com,
• Contact us through the App, or
• Write to us at:
  Sagoon Inc. ,1980 Teasel Ct.
  Woodbridge, VA 22192

When you submit a request to know or a request to delete, we will take steps to verify your request by matching the verified user’s account phone number provided by you with the phone number we have in our records. You must provide your user account phone number to verify your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

For more information about our privacy practices, you may contact us as set forth in the “Contact Us” section above.