Privacy Policy

Last modified: July 25, 2018

Introduction

Panda Planner Inc. (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website https://positiveroutines.com (our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information we collect:

• On this Website.
• In e-mail, text and other electronic messages between you and this Website.

 

It does not apply to information collected by:

• us offline or through any other means, including on any other website operated by Company or any third party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from the Website.

 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Use by Children

Our Website is not intended for children under 13 years of age. No one under age 13 (or, for residents of the European Union, age 16) (together “Underage Users”) may provide any personal information to the Website. We do not knowingly collect personal information from Underage Users. If you are an Underage User, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from an Underage User without verification of parental consent, we will delete that information. If you believe we might have any information from or about an Underage User, please contact us at [email protected].

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, such as name, postal address, e-mail address or telephone number, and IP address, as well as information about your internet connection, the equipment you use to access our Website and usage details.  

 

Information You Provide to Us. The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further services. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including e-mail addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.

 

Usage Details, IP Addresses And Cookies, Cookies and Other Technologies. As you navigate through and interact with our Website, we may automatically collect certain information about your equipment, browsing actions and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system and browser type.

 

The information we collect automatically is statistical data. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.

 

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
• Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

 

We may tie information gathered automatically to information that you provide directly to us.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide though it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

 

With your consent, we may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers and other third parties we use to support our business.  When we disclose personal information for this consent, we disclose the minimum amount of personal information necessary to allow the contractor, service provider, or other third party to provide services to us.  
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Panda Planner Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Panda Planner Inc. about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you give us an e-mail address to use the “e-mail a friend” feature of our Website, we will transmit the contents of that e-mail and your e-mail address to the recipients.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

 

We may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Panda Planner Inc., our customers or others.

 

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Promotional Offers from the Company.  We only use your e-mail address to promote our own or third parties’ products or services with your consent. 
• We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

 

Legal Bases for Processing Your Information

We rely on the following legal grounds to process your personal information:

• Performance of a contract – If you choose to make a purchase through the Website, we need to collect and use your personal information to perform our agreement with you.  
• Consent – We may use or disclose some of your personal information as described in this Privacy Policy subject to your consent.
• Legitimate interests – We may use your personal information for our legitimate interests to improve our products and service, including the Website. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use technical information as described in this Privacy Policy and use personal information for our marketing purposes.

Transfer and Processing of Data

For users within the United States, we process data in data centers located in the United States.  We have adopted reasonable physical, technical, and organizational safeguards against accidental, unauthorized, or unlawful destruction, loss, alteration, disclosure, access, use, or processing of user data in our possession.  We comply with state and federal laws governing the protection of personal information.

For users within the European Union, we transfer data from the European Union to data centers located in the United States for processing.  The European Commission has determined that the law of the United States does not provide a level of protection adequate to satisfy the requirements of Regulation 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and free movement of such data, known as the General Data Protection Regulation (“GDPR”).  As to users residing in the EU, however, we extend the rights provided for by the GDPR including the imposition of required safeguards with respect to accidental, unauthorized or unlawful destruction, loss, alteration, disclosure, access, use or processing of data.

If you are a resident of the EU, you have the right to:

• request an accounting of all personal information that we possess that pertains to you in an electronically portable format (e.g., electronic copies of information attached to an email).

• request that we change any personal information that pertains to you.

• request that we delete any personal information that pertains to you.

• fully or partially withdraw your consent to the collection, processing, and/or transfer of your personal information.   

To request an accounting of your personal information, a change to your personal information, deletion of your personal information, or to withdraw your consent to the collection, processing, and/or transfer of your personal information, contact [LINK]. Once we have received notification that you withdraw your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further processing which override your interests, rights and freedoms or for the establishment, exercise or defense of legal claims.

You also have a right to lodge a complaint with a national Data Protection Authority.  Each European Union member nation has established its own Data Protection Authority; you can find out about the Data Protection Authority in your country here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

Data Retention and Deletion

We will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected and processed, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements.

In some circumstances, we may anonymize your personal information so that it can no longer be associated with you, in which case it is no longer personal information.

It is our policy to retain personal information for [number] months once such personal information is no longer necessary to deliver the Site and to delete such personal information thereafter.  This means that, if you close your account with us, we will delete personal information associated with your account after [number] months. Regarding other types of information we collect as described in this policy, it is our policy to retain such personal information for number] months and to delete such personal information thereafter.

Data Security

We have implemented commercially reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at [email protected].

 

Our representative in the EU for personal data purposes is Mrs. Catherine Muyl of Foley Hoag, you can contact our representative at the following address 53 Rue du Faubourg Saint-Honoré, 75008 Paris, France.