Privacy Policy of Pando Holdings, LLC

Effective: January 1, 2018

1. Some Definitions Pando Holdings respects your privacy. Within this Privacy Policy (the “Privacy Policy”) the following terms shall have the definitions specified.
“Pando Holdings,” “Pando,” or “we” (and related pronouns) means Pando Holdings, LLC, and its subsidiaries and affiliates that own and operate websites and Internet services on its behalf.
“Customer” and “you” (and related pronouns) means you as a user of the Pando websites and services as described below.
“Personally Identifiable Information” or “PII” means to information that identifies a specific person, such as the person’s name, address, social security number, financial account number, and telephone number.
“Non-Personally Identifiable Information” or “non-PII” means information that is demographic, aggregated, or does not otherwise identify a specific person, such as a person’s gender, ZIP code, or other information when that information is not used with Personally Identifiable Information.

2. Scope of this Privacy Policy This Privacy Policy explains how we will use information you provide when you use certain websites, mobile applications, and other interactive features that link to this Privacy Policy, including, but not limited to the website, pandolink. com; all mobile applications that link to this Privacy Policy such as Facebook, Instagram, Twitter, and such applications like those listed, and any software or services provided by Pando, including those services made available through its alarm security services.
If any Pando Web Services contains a link to a third party website, those websites are not operated by Pando and have their own privacy policies you should read before using that site.

3. Information We Collect Pando routinely logs Non-PII that is automatically generated when any user visits or uses the Pando Web Services (including both the Pando Sites and Pando Apps), as a by-product of the user’s activities (“Web Log Data”). This information includes, but is not limited to, Internet protocol (“IP”) and HTTP header information that is automatically passed between a user’s device and the Pando Web Services, such as the device’s IP address, the browser being used at the time, the operating system being used at the time, the UDID of the device (if the device being used to access the Pando Web Services is a mobile device), and the URL of the webpage or other location within the Pando Web Services being requested. This information may also include details relating to the activities users perform within the Pando Web Services, such as what links they click on, in what order they access specific web pages within the Pando Web Services, and search queries they perform on the Pando Web Services.
Pando asks its Customers to provide certain information when subscribing to Pando Web Services, and may ask you to provide additional information when you use certain Pando Web Services for the first time, such as your first and last name, email addresses, mailing address, telephone number, and gender. In addition, Pando also collects information about your use of the Pando Web Services as a registered user. For example, when you log-in to our use your account of the Pando Web Services by flagging or rating news articles, movies, television shows or other content, posting blog entries or comments, sharing URLs, and content and data feeds from non-Pando social networks or services that you choose. This table summarizes the different types of information that we may collect from you when you register for the Pando Web Services and use the Pando Web Services as a registered user. Your Registration Data and Activity Data, and any other generally available demographic data about you we gather from other sources are referred to collectively as “Your Data”. Your Data does not include information third parties may independently gather from you from using other websites, by use of cookies, or otherwise.
Referral Service
If you choose to use our referral service to tell a friend about the Pando Web Services, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the Pando Website. We store this information and may use it for the sole purpose of sending this email offers to our and tracking the success of our referral program.
User Access and Choice
You may review and update your PII by emailing us at marketing@Pandolink. com and verifying your identity. If you’d like us to help you remove any of your PII that we have previously collected through the Pando Websites, please contact us. We will respond to your request within 30 days. In some cases, we may not be able to remove your PII, in which case we will let you know if we are unable to do so and why.
We will retain Your Data for as long as your account is active or as needed to provide you with the Pando Web Services, or as otherwise necessary to help us improve our products and services, comply with our legal obligations, resolve disputes, and enforce our agreements with you.
Tracking Technologies and Pando’s Data Collection
Pando, and its marketing partners and service providers, may use technologies such as cookies, beacons, tags, and scripts to collect information as further described in this Privacy Policy. A cookie is a small file stored on a user’s computer. Among other things, cookies enable Pando Web Services to store Preferences Data, as described in this Privacy Policy. For example, cookies enable our website to remember information about your browser such preferred zip code, and IP address. Cookies can also hold information like an anonymous but unique string of numbers and letters Pando may use to help it collect Activity Data, as further described in this Privacy Policy.
The Pando Web Services may use different types of cookies, like HTTP cookies (sometimes referred to as “browser cookies”), Flash cookies (sometimes referred to as “Flash LSOs”), and HTML5 local storage (sometimes referred to as “LS” or “LS cookies”). For more information on controlling HTTP cookies and these cookies, please see Section 8, below.

4. Use of Information Pando uses Web Log Data, Preferences Data, and Your Data, including both PII and Non-PII in both aggregated and individual forms, to provide the Pando Web Services and support them. We may process and use this data for purposes consistent with this Privacy Policy including, but not limited to:
Customize, measure, and improve the Pando Web Services, and the content and advertising provided through them;
Enforce our Web Services Terms of Service and detect fraud and other illegal activities;
Bill and collect applicable fees or charges;
Let you know about new products or services from Pando or other companies we work with as well as promotional offers, based on your preference settings;
Let you know about changes to the Pando Web Services, the Web Services Terms of Service, this Privacy Policy, and other terms that apply to our services; and
Update any other tools or information we provide in connection with Pando Web Services.
We may use Web Log Data, Preferences Data, and Your Data in these forms for our internal business purposes, such as determining how much traffic certain portions of the Pando Web Services receive, for license reporting and assessment of service levels, to better understand how the Pando Web Services are used, to gauge traffic patterns, to determine what types of content and services are most popular with users of the Pando Web Services, to determine which search queries on certain Pando Web Service are the most popular, or track the path of our customers. Pando may also use Web Log Data, Preferences Data, and Your Data to customize the Pando Web Services and make them more relevant to you. Pando may use your Registration Data to verify you are the person authorized to use the Pando Web Services and to manage your account.

5. Sharing of Information
Pando does not share your PII with any third party, except as required by law.

6. Online Tracking Policy
Some of the third-party service providers that Pando uses to deliver services, content, and advertising on the Pando Web Services may collect information from those services, as disclosed in this Privacy Policy. This information may include PII or may be used to contact you online. As stated in this Privacy Policy, in the sections 7 and 8 below, we and our service providers may also use cookies to deliver relevant advertising to you when you visit other websites, including advertising based on the products and services you viewed on the Pando Web Services.

7. Advertisements purchased by Pando
Pando, or third parties acting at Pando’s request, may deliver advertisements to you through the Pando Web Services and other websites, depending on whether you are a registered user or not, as described in more detail below.
We, or our advertising providers, automatically deliver ads to all users on the Pando Web Services, whether the users are registered or not, based on non-PII including: (i) the IP address associated with your device for purposes of determining your approximate geographic location; (ii) the type of web page being displayed, e. g. news or sports page; or (iii) the content on the page shown, e. g. a sports article or movie review. Because this advertising activity automatically applies to all users and it is contextual, this type of advertising delivery cannot be customized or controlled by individual users.
We may also use one or more advertising networks and/or other audience segmenting technology providers to help select and deliver: advertisements purchased by Pando on the Pando Web Services and other websites, other content on the Pando Web Services, and Pando-purchased advertisements on other websites. These providers help us deliver advertisements or content tailored to interests you have shown by the way you interact with the Pando Web Services, and other websites and web-based content containing their technology, such as opening an HTML-formatted email that contains their web beacon. This is intended to provide you with an opportunity to look at advertising that may be of interest to you. These providers may collect and use data subject to their own privacy policies, not Pando’s Web Services Privacy Policy. If you do not want the benefits of the data collected by these providers, you may opt-out here:
Ad Choices for Registered Users
If you are a registered user, Pando, or service providers acting at Pando’s request, may use Your Data, regardless of where we gathered such information, to determine what type of ad to display to you on the Pando Web Services and other websites. For example, Pando may use portions of Your Data that it gathered on Facebook and Pandolink. com, to determine which ad to show you when you visit that site. In addition, some of the graphical display, text, and other ads sold or purchased by Pando on the Pando Web Services and other websites are customized for you based on the ZIP code or other geographic data of your Pando Web Services, information about your current subscription, or use of Pando products and services. If you do not want this information to be used to serve you targeted ads, you may opt out by emailing marketing@Pandolink. com. Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.

8. Advertising Networks and Advertising Sold By Content Providers
The advertising networks and/or content providers that deliver ads on the Pando Web Services may use technologies such as HTTP cookies, Flash cookies, and HTML5 local storage to uniquely distinguish your web browser and keep track of information relating to serving ads on your web browser, such as the type of ads shown and the web pages on which the ads appeared. In addition, the third parties that provide Web Log services for Pando may use cookies to distinguish your web browser and to keep track of the websites your web browser visits on the service provider’s network of websites. Cookie management tools provided by your browser may not affect Flash cookies. To learn how to manage privacy and storage settings for HTML5 local storage, you may refer to the end user documentation for your browser.
Some of these companies may combine information they collect in connection with the Pando Web Services with other information they have independently collected relating to your web browser’s activities across their network of websites. These companies collect and use this information (which may include PII or information that can be used to contact you online) under their own privacy policies. More information about these companies, their privacy policies, and the opt-outs they offer can be found here.

9. Communicating with You
Pando may use your Registration Data to send you a confirmation email verifying the ownership of the email addresses provided in your Registration Data and to send you service-related communications about the Pando Web Services. Pando may send you promotional or commercial email relating to each Pando Web Services for which you have activated your account. You can opt-out from receiving such promotional or commercial email by following the instructions contained in the emails.

10. Security
Pando uses industry standard approaches to securely store, control access to, and make appropriate use of Your Data, and we require our contractors and other providers to do so as well. However, no security measure is completely effective and Pando cannot guarantee the complete security of Your Data. If you don’t want Pando to know any particular information about you, you should not register to use the Pando Web Services or include it in anything that you submit to Pando.
Pando also takes additional steps to increase the security and reliability of customer communications. We do not read your outgoing or incoming email, file attachments, video mail, private chat, or instant messages. However, we (along with our third-party providers) use software and hardware tools to help prevent and block “spam” emails, viruses, spyware, and other harmful or unwanted communications and programs from being sent and received. These tools may automatically scan your emails, video mails, instant messages, file attachments, and other files and communications in order to help us protect you and the Web Services against these harmful or unwanted communications and programs.
We follow generally-accepted standards to protect the information submitted to us, both during transmission and after we receive it. Please remember that no method of transmission of any information over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee data security absolutely or unconditionally. If you have any questions about security on the Pando Web Services, you can contact us.
As an additional security precaution, neither Pando nor any of our authorized service providers will ever ask you for your Pando Web Services password in any email, over the telephone, or in an online support forum or chat. Do not give your Pando Web Services password to anyone in an email, over the telephone, or in an online support from any source.

11. Disclosure of Information
Pando holds customer privacy in the highest regard and we make every reasonable effort to protect your privacy as described in this Privacy Policy. Nevertheless, we may be required by law to disclose PII or other information about you or other users of Pando Web Services. Such disclosure may be made with or without your consent, and with or without notice to you, in compliance with the terms of a subpoena, court order, search warrant, or other valid legal process. We may also disclose information about you or users of Pando Web Services when we believe in good faith the disclosure of information is necessary to prevent financial loss, address suspected illegal activity, protect our or your rights or property, or prevent imminent physical harm. In addition, Pando may disclose your PII or other information if Pando enters into a sale of its business or assets (see Section 14, below).

12. Our Sites are Not Intended for Children
Through the Pando Web Services, Pando does not knowingly collect PII from anyone under the age of 13. Children should always seek permission from a parent or legal guardian before sending any information about themselves (such as their names, email addresses, and telephone numbers) over the Internet including in any email.

13. Your California Privacy Rights
California law permits its residents to request and receive information about a business’ disclosure of certain categories of PII to other companies for their use for direct marketing. If you are a California resident and a user of any of the Pando Web Services, you can request a copy of this information from Pando by sending email to marketing@Pandolink. com or by letter to Pando Holdings, LLC, Attn: Marketing Department, 450 N. 1500 W. Orem, UT 84057. You should include your name and email address with email requests, and your name and postal address with in mail requests.

14. Change of Pandos Ownership
If Pando enters into a merger, acquisition, or the sale of substantially all its assets, Your Data (including your PII and non-PII associated with the Pando Web Services) will likely be part of the assets transferred. If you are a Customer or subscriber, we will notify you of any such transaction that transfers Your Data.

15. Privacy Policy Changes
Pando reserves the right to change this Privacy Policy from time to time. If we make material changes to it, and you are a Customer or subscriber, we will make a copy of the updated Privacy Policy available to you before it takes effect. We may notify you by email, direct mail, or any other reasonable method we may select. You understand and agree that if you use the Pando Web Services after the effective date of the updated Privacy Policy, Pando will consider your use as acceptance of the updated Privacy Policy.

16. EU and Other International Users and Subscribers
Our computer systems are based in the United States, and your PII will be processed by us in USA. Applicable data protection and privacy regulations may be different outside of USA. If you create an online account to use the Pando Sites as a visitor from outside the United States, you will have agreed to the terms of the Privacy Policy and our Web Services Terms of Service and you will have consented to the transfer to and processing of all such information in the United States, which many not offer an equivalent level of protection of other countries, such as the European Union or certain other countries.

17. How to Contact Customer Support
Your questions regarding this Privacy Policy may be sent to us by email to marketing@Pandolink. com. You may also write to us at Pando Holdings, LLC, Attn: Marketing Department, 450 N 1500 W Orem, UT 84057. You should include your name and email address with email requests, and your name and postal address with in mail requests.

You can find customer support and help information at https://pandolink.com. Some online support areas and tools may ask you to provide information to Pando to help us address your questions or problems.

We may also make software tools available to help configure your device’s or network’s settings, or collect information from your device or network to help us provide support to you. If you choose to provide this information to Pando, or use these tools, we will use the information only for customer support purposes.