This Privacy Policy describes Intersections, LLC’s d/b/a Pango (“Pango”, “we”, “us”, or “our”) privacy practices as it relates to the Robo Shield website located at https://www.roboshield.com/ (the “Website”), its Robo Shield mobile app software (the “App”), and related services and content (collectively, the “Services”).
See the Contact Us section below for more information about Pango and contact details.
When and How We Collect Personal Information
What Information Do We Collect About You?
How Do We Use Your Information?
How We Disclose Your Information
Cookies and Other Tracking Technologies
Mobile Privacy
Your Rights
U.S. State Specific Disclosure
EEA/UK Disclosure
Security
Data Retention
Technology Licensing
Children’s Privacy
Privacy Policy Updates
Contact Us
When and How We Collect Personal Information
We may collect personal information that you provide when you:
Visit our Website;
Use our App;
Use our Services;
Contact us;
Sign up for email newsletters; and
Provide us with user content, ideas, information, user reviews, comments, feedback or other submissions.
What Information Do We Collect About You?
This section describes the various types of personal data (aka ‘personal information’) we collect from and about you. This information is not collected in all situations, but only in specific product-specific situations.
Information You Provide to Us
Account Information. Our Services require you to create an account before you can access it. As part of registering for an account, we may collect information such as your name, username,and password.
Billing and Payment Information. In order to purchase a service, you may need to provide us with details such as billing name, billing contact details (street addresses, email addresses), and payment instrument details.
Communications and Submissions. You may choose to provide us with information when you communicate with us (e.g. via email, phone, or chat for support or to inquire about our services), including when you fill out an online form, respond to surveys, provide feedback, post comments to our website, participate in promotions, or submit information through our services.
Information collected when you use our Services
Usage information. We collect information about how you interact with the Service, including when you visit and use our websites or app, and when and for how long you use our Service. We may use cookies and/or other technologies to collect this information. See below for more information.
Device information. We collect information from and about the device you use to access the Service, including about the browsers and Pango apps you use to access our Services. For example, we may collect device or mobile advertising identifiers, browser types, device types and settings, operating system versions, mobile, wireless, and other network information (such as internet service provider name, carrier name and signal strength), and application version numbers. We may use cookies and other technologies to collect this information. See below for more information.
Your Telephone Number. We collect your phone number for the technical provision of our Services to you.
Transcripts and Recordings of Voicemail. If you enable our call assistant services, we may create and store transcripts of voicemails in order to provide you with our services and to improve our ability to identify unsolicited commercial calls or scam offers (aka ‘spam’).
Call Recordings and Transcripts. We record and transcribe the conversation between an unknown caller (ie. a caller with a phone number not in your phone contact list) and the virtual call assistant and store the recordings, and if applicable transcripts of the recordings.
Phone Contacts. We may access the phone numbers in your phone’s contact list to ensure that those numbers are not blocked. We do not capture the names or other contact information associated with the number, and store the information as a cryptographic hash rather than as a plain text number. This information is exclusively used to provide our Services, and is not disclosed to third parties.
Unknown Caller Numbers and Associated Caller-ID Information. We collect the calling phone number and associated caller-ID text information associated with unknown callers into your device.
SMS Text Messages of Unknown Senders. We filter out all messages from unknown senders that are not in your phone contact list. For all other messages from initiators that are not in your contact list, we de-identify, disassociate, and collect the initiating phone numbers or caller-ID information from SMS text messages. These captured SMS texts are not connected to your personal information when we collect and store them. We do not capture images or videos sent in SMS or MMS messages.
Information Provided to Us by Third Parties
If you are invited to use the Services, the person who invited you may submit your personal data, such as your email address or other contact information.
Third Party Partners or Services. In order to facilitate the Services, we may receive information from third parties such as known spam numbers.
Third Party Accounts. Our Service may allow you to register an account using a third party account (such as a Google or Microsoft account). If you do so, that third party may send us some information about you that they have. You may be able to control what information they send us via your privacy settings for that third party account.
Threat Information. We receive information from reputable members of the security industry who provide information to help us to provide, develop, test, and improve our Services (for example, lists of malicious URLs, spam blacklists, phone number blacklists, and sample malware). Some of this information may contain personal data on an incidental basis.
How Do We Use Your Information?
We use the information we collect for various purposes described below. For visitors from the European Economic Area (EEA) or U.K., please also note our lawful basis for each processing activity in the EEA/UK Disclosure section below;
To combine information you provide us, such as your identification of calls and/or SMS as spam or not spam, with other information we receive from third parties to improve the services we provide to you and other users by allowing us to better identify and publicly expose spam and new spam tactics
To provide, maintain, troubleshoot, and support our services. We use your information for this purpose on the basis that it is required to fulfill our contractual obligations to you and ensure proper functioning of our services.
For billing and payment purposes. We use your information in order to perform billing administration activities and process payments, which are required to fulfill our contractual obligations.
To communicate with users and prospective users. We use your information to communicate with you, including by responding to your requests, and sending you information and updates about our services. We may do this in order to fulfill our contract with you, because you consented to the communication, or because we have a legitimate interest in providing you with information about our services.
To improve our services. We want to offer you the best services and user experiences we can, so we have a legitimate interest in continually improving and optimizing our services. To do so, we use your information to understand how users interact with our services. Examples: we analyze certain usage, device, and diagnostic information to understand aggregated usage trends and user engagement with our services (and, for example, invest in technical infrastructure to better serve regions with increasing user demand); we may use device and threat information to conduct spam, threat, and other scientific research to improve our threat detection capabilities; we review customer feedback to understand what we could be doing better.
To develop new services. We have a legitimate interest in using your information to plan for and develop new services. For example, we may use customer feedback to understand what new services users may want.
To market and advertise our services. We may use your information to provide, measure, personalize, and enhance our advertising and marketing based on our legitimate interest in offering you services that may be of interest.
To prevent harm or liability. We may use information for security purposes (such as to investigate security issues or to monitor and prevent fraud) and to prevent abuse. We may do this to comply with our legal obligations, to protect an individual’s vital interests, or because we have a legitimate interest in preventing harm or liability to Pango and our users. For example, we may use account, usage, and device information to determine if an entity is engaging in abusive or unauthorized activity in connection with our services.
For legal compliance. We may use your information as required by applicable law, legal process, or regulation. We may also be compelled by a contract or court to provide certain information necessary to our business partners in order to fulfill the terms of a business agreement. To learn about our practices regarding sharing your information with third parties for legal compliance purposes, see Section 4 below. We also use your information to enforce our legal rights and resolve disputes.
How We Disclose Your Information
We may disclose your information in the following circumstances:
With your consent.
With service providers. We use third-party service providers to help us provide our Services. For example, we have service providers help us with payment processing, email automation, website and app diagnostics, and analytics. Some of these providers may process your personal information. To protect your information, we require third parties to sign confidentiality and data processing agreements and review their security practices, we also only disclose the information about you that is necessary for them to perform their services.
With affiliates. We may disclose your information with our affiliates, as well as its subsidiaries, and other affiliated companies (collectively, the “Pango Group Companies”).
To enforce our rights and prevent fraud and abuse. We may disclose your information to enforce and administer our agreements with customers and users, and to respond to claims asserted against Pango. We may also disclose your information in order to protect against fraud and abuse against Pango, our affiliates, users and others.
In connection with a business transaction. If ownership or control of all or part of our services, assets, or business changes or an investment entity conducting due diligence in connection with an acquisition or investment, we may transfer certain information to the new owner.
Where legally required. We may disclose your information as required to do so by applicable law, to comply with our legal obligations, to comply with legal process, and to respond to valid law enforcement requests relating to a criminal investigation or alleged or suspected illegal activity that may expose Pango, you, or any of our other users to legal liability. If we disclose your information for these purposes, we limit the information disclosed to what is legally necessary, and challenge information requests that we believe are unlawful, overbroad, or otherwise invalid.
Cookies and Other Tracking Technologies
Like many companies, we use cookies, pixels, web beacons, SDKs, and other tracking technologies to collect information about your browsing activities, your interactions with websites and apps, and to serve tailored ads. There are a number of ways to opt out of having your online activity and device data collected through these services, which we summarize below:
Your Choices With Our Use of Cookies
You have the ability to manage your cookie preferences in your web browser settings, including deleting cookies and blocking cookies from being set on those browsers or devices. Visit the “help” section of your browser to understand what controls it gives you over cookies. Note that deleting or blocking certain cookies could adversely impact the proper operation of our services.
Industry Advertising Choices: For information on how to opt out of personalized or interest-based advertising, you can visit the following pages:
For more information on each Pango product website’s use of cookies, visit the privacy or cookie-specific notices here.
Mobile Privacy
The App uses software code provided by our business partners (software development kits or SDKs) that let our software interact with the services those partners provide. Sometimes these interactions will involve that business partner collecting some information from the device on which the software is run.
To view our app privacy disclosure:
On iOS:
Open the App Store. Go to the Binance.US app page. Scroll to the App Privacy section. Click See Details.
On Android:
Open Google Play. Browse or use the search bar to find the Binance.US app. Click on the app. Under Data safety, you’ll find a summary of the app’s data safety practices. For more detail, tap See details.
To opt out of tracking:
On iOS:
When you download and open a new app, you’ll get a notification that asks if you want to let the app track your activity across other companies’ apps and websites. You’ll also see information about what the app would track. You can tap Ask App not to Track to block that activity or Allow.
For apps that you’ve already downloaded and may have tracking permissions set up for, you can opt out of tracking if you go to Settings, tap an app, and then tap to turn off Allow Tracking. Alternatively, you may go to Settings > Privacy > Tracking. There you will see a list of apps that have requested permission to track your activity. You can tap to turn tracking on or off for each app.
On Android:
Go to the Settings app and navigate to Privacy > Ads. Tap Delete advertising ID, then tap it again on the next page to confirm. This will prevent any app on your phone from accessing it in the future.
Your Rights
Depending on your country of residence, you may have certain legal rights in relation to your personal data that we maintain. Subject to exceptions and limitations provided by applicable law, these may include the right to:
Access the personal information we maintain about you.
Delete the personal information we maintain about you.
Correct inaccurate personal information we maintain about you
Restrict the processing of your personal data;
Data portability;
Lodge a complaint with a data protection authority;
Object to or restrict our use or processing of your personal data;
Withdraw any consent you previously gave to the processing of your data (such as opting out to marketing communications);
Opt out of certain uses of your personal information, notably:
Email marketing – unsubscribe to our email list by clicking the unsubscribe link at the bottom of marketing emails.
SMS marketing – if applicable, you can opt out at any time by replying STOP.
Push notifications – opt out of notifications on your mobile device
Tailored advertising using third party cookies – refer to the Section 5 above to learn how to opt out of tailored ads.
Tailored advertising on your mobile device – refer to the ‘Mobile Privacy’ section below to learn how to opt out.
request that we provide you with the categories of personal data we collect, disclose or sell about you; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal data; and the categories of third parties with whom we share personal data. This information may also be provided in this Privacy Policy.
You can exercise these rights by contacting us at [email protected]. You may also be able to exercise some of these rights by using the settings and tools provided in our Services. For example, you may be able to update your user account details via the relevant account settings screen of our Apps. You may also be able to opt out from receiving marketing communications from us by clicking an “opt out” or “unsubscribe” link in such communications.
Some mobile and web browsers transmit “do-not-track” or “opt-out preference” signals. We currently do not take action in response to these signals. Otherwise, if you wish to exercise any of these rights, you may contact us using the details in the “Contact Us” section below. As permitted by law, we may ask you to verify your identity before taking further action on your request. You may also be permitted to designate an authorized agent to submit certain requests on your behalf. If you do so, you must give the authorized agent written permission to make such requests, or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
U.S. State-Specific Disclosure
Some U.S. states have enacted comprehensive privacy laws. The California Consumer Privacy Act, as amended by the California Privacy Rights Act or “CPRA” (collectively, the “CCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”) create additional privacy obligations for businesses and provide Californians and Virginians with additional privacy rights.
Additional Privacy Rights:
In addition to the rights granted above, if you are a California or Virginia resident, you have the right to:
Opt out of the “sale” or “share” of your personal information for targeted advertising. Some tracking technologies placed on our website and our App may be considered a ‘sale’ under Virginia and California law or ‘share’ under California law. You may opt out of such cookies as detailed in ‘Cookies And Other Tracking Technologies’ section (above).
Sensitive personal information.
Californians have the right to limit the use of their sensitive personal information.
Virginians have the right to opt in to the use of their sensitive personal information.
You can exercise these rights by contacting us at [email protected].
Service Provider/Procesor Designation:
Under the CCPA, we operate as a Business.
Under the VCDPA, we operate as a Controller.
The above information includes the categories of personal information Pango collects, processes and shares with service providers and other businesses. If you would like to exercise your rights to receive the specific pieces of information, or other rights indicated above applicable to you, please refer to the ‘Contact Us’ section below.
Pango does not ‘sell’ personal information for our own monetary benefit. However, as the CCPA defines ‘sell’ broadly, some of the advertising services that support our website, marketing efforts, and mobile applications use third party advertising services that may be deemed a ‘sale’ under California Law. Please see the list of cookies or cookie notices listed above, or app-specific advertising services listed above to indicate your continued preferences to receive such personalized ads.
EEA/UK Disclosure
Additional Right for EEA Residents:
In addition to the rights granted above, if you are an EEA resident, the General Data Protection Regulation (“GDPR”) grants you the right to lodge a complaint against us with your local data protection authority. You can find your data protection authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
Legal Basis:
Under the GDPR, we may only process personal data where we have a sufficient legal basis.
Processing Activity
Legal Basis under GDPR
Placement of tracking technologies on our Website and App
Consent
Collecting, processing, and sharing your child’s Personal Data
Consent*
Collecting and processing your personal data to maintain and fulfill the Services
Contract
Processing your personal data to improve our Services
Legitimate Interest
Processing your personal data to communicate with you.
Legitimate Interest
Controller/Processor Designation:
We are a Controller under the GDPR.
Cross-Border Data Transfers:
We may transfer to, and store the data we collect about you, in countries other than the country in which the data was originally collected, including the United States, Canada or other destinations outside the EEA and the UK. Those countries may not have equivalent data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and applicable supplemental product privacy policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA.
If you are located in the EEA, we will only transfer your Personal Data if:
The country to which the Personal Data will be transferred has been granted a European Commission adequacy decision; or
We have put in place appropriate safeguards in respect of the transfer, for example we have entered into standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by an EU supervisory authority.
Security
Pango employs a range of administrative, organizational, technical, and physical safeguards designed to protect your data against unauthorized access, loss, or modification. Access to your Account Information and Services Information is restricted to our employees who require such access to perform their job functions. While our controls are strong, no data security measures can guarantee 100% protection.
Data Retention
Pango generally retains your personal information for as long as is needed to provide the Services to you, or for as long as you have an account or subscription with us, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements.. We may also retain personal information if required by law, or for our legitimate interests, such as abuse detection and prevention, and defending ourselves from legal claims. Residual copies of personal data may be stored in backup systems for a limited period as a security measure to protect against data loss.
. Technology Licensing
Pango occasionally licenses its technology to third party partners who may integrate it with applications developed and offered by those partners. Our partners, and not Pango, are responsible for those applications and for determining what data is collected by those applications and how it is processed. Please contact the relevant partner and refer to their Privacy Policy to learn more about how those applications process your personal data.
Children’s Privacy
Our services are not intended for and may not be used by minors. In this context, minors are individuals under the age of 16 except for our identity and credit monitoring services, which are restricted to those under the age of 18. Pango does not knowingly collect personal data from minors or allow them to use our services. If we discover that we have collected personal data from a minor, we may delete such data without notice. Please note that the legal terms under which we make certain services available may require users to be older than 16 years of age.
Privacy Policy Updates
Pango may update this Privacy Policy from time to time in accordance with this section for reasons such as changes in laws, industry standards, and business practices. Pango will post updates to this page and update the “Last updated” date above. If we make updates that materially alter your privacy rights, we will also provide you with advance notice, such as via email or through the services. If you disagree with such an update to this policy, you may cancel your services account. If you do not cancel your account before the date the update becomes effective, your continued use of our services will be subject to the updated Privacy Policy.
Contact Us
We expect this Privacy Policy to evolve over time and welcome feedback from our users about our privacy practices. If you would like to exercise your rights, have any questions or complaints about our privacy practices, you can contact us using the following details:
For visitors from the UK or EEA, the GDPR gives you additional rights to contact our Data Protection Officer (DPO). The Pango has appointed Bird & Bird DPO Services SRL as a DPO for Pango and its services, and may be reached:
