EIP Concepts CA, Inc's Presto-Changeo (POCO) provides software development services, e-commerce & marketing consulting services and develops software to help merchants sell better or more efficiently online through various platforms, such as Wix. POCO has adopted this Privacy Policy Agreement to guide you through the collection, use, retention, and disclosure of Personally Identifiable Information (“Personal Data”, as further described below) that you may provide while using our apps and services in connection with these platforms (collectively referred to as “Services”). All POCO websites & apps are located on presto-changeo.com and its’ subdomains. We encourage you to read this Privacy Policy Agreement in order to understand how we collect and process Personal Data in the course of providing the Services and your interaction with the Services.

By using the Services, you consent to the collection, use, retention, and disclosure of your Personal Data for processing as described in, and subject to the limitations set out in, this Privacy Policy Agreement.

Note to Residents of the European Union: In order to comply with the requirements of the European General Data Protection Regulation (GDPR) for our European users, this Privacy Policy Agreement outlines the legal basis on which we process your Personal Data and provides other information required by the GDPR.

We never sell personal data and we carry out all processing operations in strict compliance with the EU General Data Protection Regulation (“GDPR”) (specifically but not limited to Article 6(1)(b) to (f) and Article 28) as well as the Privacy Act (together the “Applicable Law”), where EIP Concepts CA, Inc is incorporated.

PRIVACY POLICY AGREEMENT SUMMARY

TYPES OF DATA COLLECTED

Our website, software or apps may collect three types of Personal Data:

The data that we might collect about a website visitor.

The data that we might collect about our software/apps user (merchant).

The data that we might collect about merchant’s customers through APIs if you use our software/apps.

MERCHANT’S DATA

Merchant’s store data. We collect merchant’s email, name, store name, store domain, store country on app install.

App usage data. We collect pages visited, buttons clicked, device type, browser type and version, operating system, screen resolution, language, country.

Cookies. We use cookies to store app data. Information we store in cookies does not contain any personally identifiable information or your store related data.

Communication. Your email and name may be used to send communications from us to you. You can always unsubscribe using a special link in an email.

Advertisers. We use a number of trusted advertising platforms. These service providers are carefully selected and meet high data protection and security standards as described below.

MERCHANT’S STORE CUSTOMERS DATA

We DO NOT collect, process or store your customers’ personal data, including email, name, location, IP address, physical address, bank/card, details, history of orders, etc. none of our apps require this information in order to function properly

and most effectively.

PERSONAL DATA

Personal Data is any information that would identify a person directly, or indirectly in combination with data from other sources. For example, a full name, home or work address, phone number, national identification number (SSN, SIN, etc.), email

address, banking details, IP address, biometric data, usage data, or any information that may individually identify a person.

POCO may collect Personal Data including without limitation your name, phone number, email address, IP address, and device identifiers and/or geolocation information, in the course of its Services, and may use or disclose that Personal Data as

described with this Privacy Policy Agreement.

POCO may collect and use aggregated, anonymous information to provide data about the Services to advertisers, potential business partners, and other unaffiliated entities. As this information does not identify a person and is therefore not Personal

Data, POCO’s use of such aggregated, anonymized and/or de-identified data is not subject to this Privacy Policy Agreement.

CONSENT & COLLECTION OF PERSONAL DATA

If you use an POCO website or software developed by POCO your consent is implied to collect and use your Personal Data to facilitate that use which can be initiated by you only. Examples of instances in which Personal Data may be collected

by POCO are, but are not limited to:

When you install a POCO App,

When you access and navigate an POCO website, or engage in communication and/or business transactions with POCO services,

If you knowingly submit Personal Data through an POCO website for the purpose of registering for a service, a contest, or authentication.

During these instances, we may collect data such as, but not restricted to: areas of the services or POCO website you visit, content you view, your IP address, data downloaded or submitted by you, the individuals or entities with whom you communicate.

In the event POCO requests Personal Data for scenarios independent of the above, such as marketing-related questions via questionnaires, surveys, and profile data, it will include a specific consent request. The consent request will include a

clear purpose and goal for the collection of Personal Data, along with a means of withdrawing consent. In these scenarios, we may ask for data such as, but not limited to: your contact information (name, telephone numbers, email address, mailing

address), date of birth, product and/or cosmetic concerns, which brands and products you use, user authentication and security information (e.g. username and password).

If at any point you wish to withdraw consent to Personal Data collection, please contact the POCO via the Contact Us area at the bottom of this Privacy Policy Agreement. Please note that certain Services may only be able to be offered or provided to you

if you disclose the Personal Data necessary to facilitate those Services, and therefore POCO  may not be able to provide you with certain Services in the event that you choose not to disclose that Personal Data.

AGE OF CONSENT

The Services offered by POCO are directed towards and designed for the use of persons above the age of majority in your province, state, or country. Persons under the age of majority are not permitted to use the Services on their own, and POCO 

will not approve applications of, or establish, or maintain accounts or memberships for, any persons below their respective region’s age of majority.

POCO does not solicit or knowingly collect Personal Data from persons below the age of majority of their region. If we discover we have received Personal Data of a person below the age of majority, we will delete such information from our systems.

Additionally, if a parent or legal guardian believes that Personal Data regarding a minor in their care has been provided to POCO , they may request the minor’s information be corrected or deleted by contacting the POCO via the Contact

Us area at the bottom of this Privacy Policy Agreement.

ANONYMOUS DATA

When you interact with an POCO Service, similar to most other websites, apps, and online services, certain anonymous technical information about your visit is automatically logged and collected by POCO. This may include information about the

type of browser you use, operating system, the date and time you access the Service, the links you accessed while using the Service, and the internet address of the website, if any, which linked directly to the POCO Service. This information

is used for system administration purposes such as diagnosing problems with POCO’s Services, servers, and websites, compiling aggregated and statistical information, and to improve the operation and content of POCO’s websites and Services.

It is not personally identifiable and is not considered Personal Data and subject to this Privacy Policy Agreement.

PERSONAL DATA USAGE

POCO may use collected Personal Data for such purposes as:

Helping to establish and verify the identity of users, and to keep user accounts secure,

Opening, maintaining, administering and servicing users’ accounts or memberships,

Providing Services and support to users,

Improving POCO’s websites, including tailoring its websites to users’ preferences,

Providing users with product or Service updates, promotional notices, and offers, and other information about POCO and its affiliates,

Corresponding with you, and responding to your questions, inquiries, comments, and instructions,

Maintaining the security and integrity of POCO systems, and,

Complying with applicable laws.

Once collected, POCO will store and process your Personal Data in secure locations. Personal Data will only be retained by POCO for the length of time required to fulfill the purpose or complete the service for which it was collected, or as

may be required by law. Beyond that point, Personal Data in the possession or control of POCO will be anonymized or securely destroyed.

LEGAL BASIS FOR PROCESSING

Data protection law in the European Union requires a “lawful basis” for collecting and retaining Personal Data from citizens or residents of the European Economic Area. POCO collects and processes your Personal Data for a variety of purposes outlined

in this Privacy Policy Agreement. In certain cases, separate consent to this processing is not required, including:

For the performance of a contract: To perform our contractual obligations to you, including app installation, contacting you in relation to the provision of the Services, where POCO needs to provide your Personal Data to our service providers

to provide the Services, or to aggregate and centralize data for the performance of the Services.

To meet legal obligations: To comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation.

For legitimate interests: To operate POCO’s business and provide the Services, other than in performing our contractual obligations to you, except where overridden by the interests or fundamental rights and freedoms that require protection

of Personal Data. For example, the following areas include processing permitted due to legitimate interests:

Communication. To communicate with you regarding the Services, including to provide you important notices regarding changes to POCO’s Terms of Use, and also to address your requests, inquiries, and complaints. POCO may send

strictly necessary communications, including emails, even if you have opted out of receiving other POCO emails or communications. These types of communications do not require consent. POCO also processes your Personal Data

for our legitimate interests when you communicate with us, including when you sign up for promotional materials and POCO has not asked you for your consent in that regard.

Respond to Your Requests. To respond to your requests for technical support, online services, product information or to any other communication you initiate. This includes accessing your account to address technical support requests.

Promotional Messages. POCO processes your non-sensitive Personal Data to provide you with promotional messages, including when you communicate with POCO or sign up for promotional materials, when you participate in special activities,

offers, or programs, when we aggregate and centralize data, and when we share Personal Data with our service providers and vendors.

Surveys. To send you surveys in connection with our Services, unless commercial in nature. In those cases, a survey request may be sent to you if you have given POCO your consent to receive marketing from us.

Compliance with Law and Public Safety. To assist in the investigation of suspected illegal or wrongful activity, including sharing information with other entities for fraud, loss, and crime prevention purposes. To protect and defend POCO’s

rights and property, or the rights or safety of third parties.

Improvement and Development. To develop, provide, enhance, and improve POCO Services and your experience, including to enable you to use the full range of our Services. For internal purposes related to certain research, analytics,

innovation, testing, monitoring, customer communication, risk management, and administrative purposes.

Enforcing Terms and Notice. To enforce POCO’s Terms of Use or this Privacy Policy Agreement, or agreements with third parties.

Merger or Acquisition (Note that certain country/region-specific disclosures may also apply, depending upon the jurisdiction in which you reside). To support a contemplated reorganization or an actual reorganization of POCO’s business,

in connection with a financing, a sale, or other transaction involving the disposal of all or part of our business or assets, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction.

CONSENT AS A BASIS FOR PROCESSING

In some cases, POCO will ask for your consent to process your Personal Data. You may indicate your consent in a number of ways, including, as may be presented by POCO and permitted by law, ticking a box (or equivalent action) to indicate your consent when providing us with your Personal Data through our Services or a form, or registering or installing our software. Note that certain country/region-specific rules regarding consent may also apply, depending upon the jurisdiction in which you reside.

DATA SECURITY

POCO maintains reasonable physical, technical, and administrative security measures to minimize the risk of unauthorized loss, theft, copying, misuse, access, disclosure, alteration, or destruction of your Personal Data.

If transactions are offered as part of an POCO Service, transaction information is transmitted to and from POCO in encrypted form using industry-standard Secure Socket Layer (SSL) connections to help protect such information, including Personal Data transmitted in the course of these transactions, from interception.

POCO also restricts access to your Personal Information to only those persons who have a legitimate business need or legal requirement to view it in connection with the Services. You, as a Personal Data owner, may also authorize any persons you may choose to have access to your Personal Data.

Although POCO does utilize security measures appropriate to the level of risk, no method of data transfer or storage on the internet is 100% secure and security risks cannot be eliminated entirely. As such, POCO cannot guarantee perfect security, integrity, or confidentiality of Personal Data.

POCO maintains a security incident response protocol to be put in place in the event that the security of your Personal Data in the possession or control of POCO is compromised. In the event of a data breach or security incident involving the Services, POCO will apply this protocol to enable POCO to effectively and efficiently respond to, and contain the breach or incident. POCO may also seek to notify you in such event. If notification is appropriate or required, POCO may notify you by email, messaging to your device, or other reasonable means.

DISCLOSURE OF PERSONAL DATA

POCO does not provide Personal Data to unaffiliated third parties for their use in marketing directly to you. We may use unaffiliated companies or trusted third party service providers, to help maintain and operate our Services for reasons related to our business operations and to better serve you, and those companies may receive your Personal Data for that purpose. When POCO shares Personal Data with third-party services that support our delivery of the Services, we require that they use your Personal Data only for the purposes we’ve authorized and that they protect your Personal Data to at least the same standards used by POCO . We DO NOT disclose or collect Personal Data which potentially can be collected by us & is specific to merchant’s store and transactions in connection therewith.

POCO may disclose Personal Data about you in connection with legal requirements, such as in response to an authorized subpoena, governmental request or investigation, or as otherwise permitted by applicable law (including, without limitation,

to prevent fraud or abuse, or to protect POCO’s legal rights, property, or the safety of POCO, its employees, users or others).

Finally, as POCO’s business develops, it may sell or buy corporate assets, and in such transactions, Personal Data may be one of the transferred business assets. If POCO, its internet businesses, or substantially all of its shares or assets,

is acquired or an acquisition is contemplated, Personal Data may be one of the assets assessed or transferred in connection with that transaction.

If you believe your Personal Data has been disclosed other than as described in this Privacy Policy Agreement, please contact POCO Contact Us area at the bottom of this Privacy Policy Agreement.

TRANSFER OF YOUR PERSONAL DATA TO OTHER COUNTRIES

The Personal Data POCO  processes, and associated Services and systems, may be housed on servers in various locations where POCO maintains servers or facilities, including the United States, Canada, Australia, and the EU. Please be aware that Personal Data we collect may be processed and stored in one or more of these locations. The data protection and privacy laws in these locations may offer a different level of protection than in your country/region, however, as noted earlier in

this Privacy Policy Agreement, POCO  takes steps, including through contracts, intended to ensure that the Personal Data it collects continues to be protected wherever it is located in a manner consistent with the standards of protection required under applicable law.

Where Personal Data is transferred from the European Economic Area to a country that has not received an adequacy decision by the European Commission, POCO relies on appropriate safeguards, such as for example the European Commission-approved Standard Contractual Clauses and EU-U.S. Privacy Shield Frameworks, to transfer the Personal Data. By using our Services and submitting your Personal Data, you agree to the transfer, storage, and/or processing of your Personal Data in the locations contemplated above. Where and as required, we will seek your explicit consent as outlined in this Privacy Policy Agreement.

COOKIES

The POCO website, or the third party companies used to host, operate, or maintain these websites, may place a “cookie” on your computer in order to allow you to use these websites and to personalize your experience.

A “cookie” is a small piece of data or an alphanumeric identifier, that can be sent by a web server to your computer or device, which then may be stored by your browser on your computer or device. Cookies allow POCO to recognize your computer or device while you are on our websites and help customize your online experience and make it more convenient for you. Cookies are also useful in allowing more efficient log-in for users, tracking activity histories, and preserving information between browsing sessions. The information collected from cookies may also be used to improve website functionality.

The advertisers and/or other content providers that may appear on POCO websites may also use cookies that are not sent by POCO. Such ads or content may contain cookies that help track and target the interests of users of our websites in order to present “personalized” advertisements or other messages that the user might find interesting. POCO is not responsible for any such cookies.

Most web browsers have features that can notify you when you receive a cookie or prevent cookies from being sent. If you disable cookies, however, you may not be able to use certain functions of POCO websites or apps.

RIGHTS WITH RESPECT TO PERSONAL DATA

POCO is committed to ensuring you retain full access to and control of your Personal Data. To that end, we endeavor to respect your right to be informed regarding the collection, use, and disclosure of Personal Data, and your right of correction and access to it, via this Privacy Policy Agreement.

If you would like to access, correct, remove, request a copy of, withdraw consent to the collection of your Personal Data, or are looking for any additional information on how your Personal Data may be collected, used or disclosed by POCO, please contact POCO via the Contact Us area at the bottom of this Privacy Policy Agreement. Subject to certain exceptions and limitations that may be prescribed by applicable law, you will be provided with reasonable access to your Personal Data, and will

be entitled to have it amended or corrected as appropriate.

In certain circumstances, you may have the right to have your Personal Data, or certain components of your Personal Data, erased by POCO, to have your Personal Data moved, copy or transmitted from POCO’s systems to other systems, or to object to or restrict certain processing of your Personal Data by POCO. In the event that you wish to inquire about, or seek to exercise any of these rights (as they may be applicable), please contact POCO’s Privacy Officer.

LINKS TO 3RD PARTIES

POCO Services may contain links to other websites, apps, or services, including those of advertisers or third party content providers who offer downloads as part of a POCO  Service. POCO is not responsible for the privacy practices or the content of other websites, apps, or services. We encourage you to read the privacy policies published by such third parties before divulging your Personal Data to them.

PRIVACY POLICY AGREEMENT CHANGES & UPDATES

POCO reserves the right to modify or supplement this Privacy Policy Agreement in its discretion, at any time. If a material change to the terms of this Privacy Policy Agreement is made, it will take place immediately.

The collection, use, and disclosure of your Personal Data by POCO will be governed by the version of this Privacy Policy Agreement in effect at that time. Your continued use of POCO’s websites and/or Services subsequent to any changes to this Privacy The policy will indicate your consent to the collection, use, and disclosure of your Personal Data in accordance with the amended Privacy Policy Agreement.

CONTACT US

If you have any questions or comments regarding this Privacy Policy Agreement or any aspects of POCO Services, please contact us at wi[email protected]

Subject to applicable law, if you are a citizen or resident of the European Economic Area, you also have the right to (i) object to POCO’s use of your Personal Data and (ii) lodge a complaint with your local data protection authority.