Privacy Policy

 

IMPORTANT NOTICE:  Pomo One Marketing, Inc. (“Pomo One”) is a wholly-owned instrumentality and economic development arm of the Habematolel Pomo of Upper Lake, a federally recognized Indian tribe, located on sovereign land of the Habematolel Pomo of Upper Lake. For purposes of this privacy policy, any reference to “our”, “we” or “us” will mean Pomo One.

We would like to take this opportunity to thank you for using our website and/or smart phone App.  We appreciate that you may be concerned about privacy.  For this reason, we have developed the following Privacy Policy.  If you have questions regarding our Privacy Policy, please direct such questions to CustomerService@LendWallet.com.

 

HOW WE PROTECT PERSONAL INFORMATION

We maintain administrative, technical and physical safeguards in an effort to protect against unauthorized disclosure, use, alteration or destruction of any personal information you may provide to us through our website and/or our smart phone App.

 

COLLECTION, USE AND SHARING OF PERSONAL INFORMATION

Information Collected

We collect and use your personal information in various ways.  Specifically, we collect the following:

Information you give us.  The information we collect includes information that you submit to us, including your name, postal address, telephone number, e-mail address, date of birth, social security number or other government identification number, demographics, financial information and personal preferences.  You may submit this information in a variety of ways, including without limitation when you submit your information using one of our application forms, when you use a website owned or operated by Pomo One, or when you use our smart phone App.

Information from other sources.  We may collect your information from other sources, , and may combine it with information that you give us.

Information that we automatically collect.  We collect certain information when you visit our website and use our smart phone App.  This information tells us such things as how many people visit our site and which features of our website and/or smart phone App users find useful.  This information assists us with maintaining and designing a user-friendly website and smart phone App.

We collect this information through “browser cookies” (as described below), by tracking web beacons (typically, small transparent graphic images), session tokens, and other mechanisms.  To assist with technical problems, we may also collect local web confirmation information, including browser type, operating system, and various other settings.

In addition, our servers automatically collect limited information about your computer when you visit our website and about your phone when you use our smart phone App.  This information may include the IP address assigned to your computer, smart phone or internet connection, the IP address of the website, if any, that referred you to our website, and geolocation information associated with your computer or smart phone.  This information is typically used for security purposes; however, our technical staff may also use this information to assist customers with technical problems, and the information may also be used to better provide you with services.
If you decide to sign up with us, we will collect information that will help enhance your experiences using our website and/or smart phone App.

 

Browser Cookies

We use browser cookies to enhance your online experience.  Browser cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites.  We utilize browser cookies to tell us, for example, whether you’ve visited our website before or if you’re a new visitor.

Browser cookies may enhance your online experience by saving your preferences while you are visiting a particular site.  If you wish to stop receiving browser cookies from us, please contact us so that we may suggest ways for you to disable existing browser cookies.  Please note that disabling browser cookies may prevent you from taking full advantage of all of our website features.  If you disable browser cookies on your Internet browser, you also may stop some collection and use of data when you visit our web sites.

 

Use of Personal Information

In addition to the uses explained above, we may also use your personal information in one or more of the following ways:

  • Determine which, if any, of our affiliates may be able to provide you with the desired services.
  • Monitor, evaluate or improve our services, systems and marketing strategies.
  • Customize or personalize your experience with our services.
  • Customize or personalize online advertising to bring you information about products and services of our affiliated entities, partners or others that may interest you, including co-branded offers.
  • Develop or inform you of new products and services offered by our affiliates and partners.
  • Respond to legal process and emergencies, and protect our rights and those of our customers.

We may also anonymize or aggregate information for market analysis and reporting purposes.

 

Information We Share

We do not share information that identifies you personally other than as follows:

Affiliates.  We may share personal and non-personal information with affiliated entities for approved business purposes.

Service Providers.  We may share personal information with third parties who perform services on our behalf.

Other Third Parties with Your Consent.  We may share information with other third parties with your consent.  For example, you may agree to our sharing your information with other third parties to hear about their products or services.  Use of the information you agree to share will be subject to the privacy policies of the third parties who receive your information.

Disclosures to Third Party Application and Service Providers.  You may choose to use services and products offered by third parties through our Services.  You may also choose to give personal information directly to third parties when using our Services.  In each case, personal information you give a third party will be subject to that third party’s terms, conditions and policies, and not those of Pomo One.  We recommend that you review all third party privacy policies and terms of service before providing your information to a third party or using the third party’s service.

Internal Business Purposes.  We may access, monitor, use or disclose your personal information to initiate, render, bill and collect for services.

De-Identified Information.  We may share information that has been de-identified or aggregated in such a way that it does not directly identify you.  We may share this de-identified or aggregated information with a variety of third parties for purposes such as conducting market analysis and reporting.

 

CONFIDENTIALITY; EXCEPTIONS

We do not knowingly reveal any personal information that you provide except as provided in this Privacy Policy, when requested to do so by a governmental agency having jurisdiction, by a court of competent jurisdiction or other operation of law, or when we believe that disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity or to otherwise protect our rights and the rights of our agents and customers.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets, or in the event of an insolvency, bankruptcy or receivership.  Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use the personal information you have provided through this website in a manner that is consistent with this Privacy Policy.

 

THIRD PARTY COMMUNICATIONS

By providing us with your e-mail address you are authorizing us to share this information with our affiliated entities, and further authorizing our affiliated entities to communicate with you via that e-mail address. We may also share your phone number with our affiliated entities.

You should notify our affiliated entities directly of your desire to opt out from receiving emails.  In addition, please let us know if at any time you would like us to discontinue providing your e-mail address and/or telephone number to our affiliated entities by contacting us consistent with the Contact Us section below.  Please note that if we are unable to provide your e-mail address and/or telephone number to our affiliated entities, we and our affiliated entities may not be able to provide you with services.

 

INFORMATION CHOICES AND CHANGES

You may register a do-not-contact request by calling Pomo One or sending an email to CustomerService@LendWallet.com.  If you register a do-not-contact request, we still may contact you for non-promotional purposes.

You may be required to enable notifications on your smart phone to permit you to take full advantage of the features in our smart phone App.  If you disable notifications from our smart phone App, you will lose the ability to receive subsequent notifications via the App platform. However, you may opt back in to these notifications at a later date, if you so choose.

 

ADVERTISEMENTS

You may see advertisements on a web sites or web sites offered or operated by us. These advertisements may be selected and delivered by third parties, such as ad networks, advertising agencies, advertisers, list management providers and other lead generators. These third parties may collect information about you and your online activities, either on the web site or on other websites, through browser cookies, web beacons, and other technologies in an effort to understand your interests and deliver to you advertisements that are tailored to your interests. Please remember that we do not have access to, or control over, the information these third parties may collect. The information practices of these third parties are not covered by this privacy policy.

 

CHILDREN USING THE INTERNET

This website, our smart phone App and the services we provide are not intended for children under the age of 18.  For that reason, we strongly encourage parents to supervise their children when visiting our website or using our smart phone App.

We do not knowingly collect personal information from children under the age of 15.  If you believe we have collected personal information from children under the age of 15, please notify us immediately so that we may take steps to eliminate such information.

 

A WARNING ABOUT E-MAIL THAT WE SEND; A WARNING ABOUT “PHISHING”

We do not and will not at any time request any personal information via e-mail, nor will we include a link to an account login page in any e-mail.  If you receive an e-mail requesting any personal information, including without limitation your social security number, your credit card or bank information, PLEASE DO NOT RESPOND BY PROVIDING ANY OF THE INFORMATION REQUESTED.  We never request any of this information from you, even if you elect to sign up with our website.  If you receive an e-mail requesting any of this information, it is likely that you have received an attempted theft of your identity commonly called “phishing.”  Likewise, if you receive an e-mail urging you to login to your account and providing you with a link to the login page, it is also likely that you have received a “phishing” e-mail.  In either case, you should bring the e-mail to our attention by forwarding the e-mail to CustomerService@LendWallet.com

For more information about “phishing,” you should visit the Federal Trade Commission’s website at www.ftc.gov.

 

EFFECTIVE DATE OF THE PRIVACY POLICY; CHANGES

This Privacy Policy is effective April 2017.

We reserve the right to alter or amend this Privacy Policy at any time and without prior notice to you in order to reflect changes in our online information practices.  In an effort to ensure that you receive notice of any changes to the Privacy Policy, we may include a notice on our website or smart phone app.  Alternatively, we may send a notice to the e-mail address you provide to us; however, if you do not provide us with an e-mail address, we will not be able to provide you with such notice.

We also recommend that you check back with this web page or app periodically so that you may be kept informed regarding any changes to the Privacy Policy.  You should also visit our Terms of Use in addition to this Privacy Policy.

 

THIRD PARTY LINKS

Our website may contain links to third party websites that are not subject to this Privacy Policy.  If you visit these websites, we encourage you to read their privacy policies before providing them with any personal information.

 

FEDERAL AND STATE LAW

Pomo One’s collection, access, use, disclosure and safeguarding of your personal information is subject to U.S. federal law.

You may have privacy rights under applicable state law in addition to those outlined in this privacy policy.

Pomo One shares personal information between Pomo One affiliated entities and marketing agents for marketing purposes. We do not share your personal information with unaffiliated third parties for their own independent marketing purposes without your consent. California residents may request the categories of personal information Pomo One shared with its affiliated entities during the previous calendar year, if any. To make your request, send an email to CustomerService@LendWallet.com. Written requests may be sent to the Privacy-Legal Department, Pomo One, 635 East Hwy 20 “M” Upper Lake CA, 95485. Pomo One will respond to these requests within 30 days. Requests that come to Pomo One by other means may result in a delayed response.

 

CONTACT US

If you choose to e-mail us through the “Contact Us” link on this website, you will be asked to provide information such as your name and e-mail address so that one of our employees can respond to your questions and comments.  Alternatively, you may e-mail us at CustomerService@LendWallet.com, or you may submit your questions or comments via U.S. mail, by mailing them to:

Privacy – Legal Department
Pomo One
635 East Highway 20 “M”
Upper Lake, CA 95485

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