Last Updated: January 31, 2024

Welcome to our Privacy Policy for The Pouch (“Policy”). This document outlines the practices adopted by Jump Marketing and Technology Services, headquartered at 2250 Mario de Boni Street, apt 3, Caxias do Sul, Rio Grande do Sul, Brazil, registered in the National Register of Legal Entities (CNPJ): 19.260.147/0001-49, and its affiliates (collectively referred to as “The Pouch” or simply “Pouch,” “we,” or “our”) regarding the collection, use, and disclosure of information related to users of the website https://thepouch.io/ (“Site”) and/or our mobile application (“App”), if available, as well as any other associated platforms and related connections, such as Discord, Twitter, or any other social or communication medium, covering both online and offline interactions (referred to collectively as “Services”).

This Privacy Policy has been crafted to help you understand how we collect, use, process, and share your personal information and to assist you in comprehending and exercising your privacy rights within the scope of applicable laws.

1. SCOPE

This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively referred to as “Services.”

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information you provide, information we automatically obtain when you use our Services, and information from other sources, such as third-party services and organizations, as described below.

1. Information Provided by You Directly

We may collect the following personal information provided by you.

• Your Communications with Us. We may collect personal information, such as email address, phone number, or postal address when you request information about our Services, register for our newsletter or loyalty program, seek customer or technical support, apply for a job, or otherwise communicate with us.
• Sweepstakes or Contests. We may collect personal information provided by you for sweepstakes or contests that we offer. In some jurisdictions, we may be required to publicly share information about sweepstakes and contest winners.
• Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when participating in conferences, trade shows, and other events.
• Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
• Job Applications. We may post job opportunities on our Services. If you respond to one of these postings by submitting your application, resume, and/or cover letter, we collect and use your information to evaluate your qualifications.

1. Information Collected Automatically

We may collect personal information automatically when you use our Services:

• Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet Protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information about your use of our Services, such as pages you visit before, during, and after using our Services, information about the links you click on, types of content you interact with, frequency and duration of your activities, and other information about how you use our Services.
• Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties providing content, advertising, or other features on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to collect information automatically through the use of our Services.
• Cookies. Cookies are small text files placed on device browsers that store preferences and enhance user experience.
• Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user visited a specific web page or clicked on a specific ad. We may also include web beacons in emails to understand if messages have been opened or forwarded.

Our uses of these Technologies fall into the following general categories:

• Operationally Necessary. This includes Technologies that enable access to our Services, applications, and tools that are necessary to identify irregular site behaviors, prevent fraudulent activities, enhance security, or allow you to make use of our functionality;
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytical practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related. We may use Technologies that enable us to offer enhanced features when accessing or using our Services. This may include identifying you when you log into our Services or tracking your preferences, interests, or previously viewed items;
• Advertising or Targeting-Related. We may use first or third-party Technologies to provide content, including ads relevant to your interests, on our Services or on third-party websites.

Refer to “Your Choices and Privacy Rights” below to understand your choices regarding these Technologies.

• Analytics. We may use third-party Technologies and other tools to process analytical information on our Services. Some of our analytics partners include:
• Google Analytics. For more information, visit the Google Analytics Privacy Policy.
• LinkedIn Analytics. For more information, visit the LinkedIn Analytics Privacy Policy.
• Social Media Platforms. Our Services may contain social media buttons, such as Discord, Twitter, Instagram, Facebook, and LinkedIn (which may include widgets like the “share” button or other interactive mini-programs). These features may collect your IP address, the page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing them.

1. Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social network, we may collect information about you from this third-party application that you made available through your privacy settings.

3. HOW WE USE YOUR INFORMATION

We use your information for various business purposes, including providing our Services, for administrative purposes, and to market our products and services, as described below.

1. Providing Our Services

We use your information to fulfill our contract with you and provide our Services, such as:

• Managing your information;
• Providing access to specific areas, features, and functionalities of our Services;
• Responding to customer or technical support requests;
• Communicating with you about your account, activities on our Services, and policy changes;
• Processing applications if you apply for a job we posted on our Services; and
• Enabling you to sign up for events.

1. Administrative Purposes

We use your information for various administrative purposes, such as:

• Pursuing our legitimate interests, such as direct marketing, research and development (including market research), network and information security, and fraud prevention;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activities, and prosecuting those responsible for such activities;
• Measuring interest and engagement in our Services;
•  

 Short-term, transient use, such as contextual customization of ads;

• Improving, updating, or enhancing our Services;
• Developing new products and services;
• Ensuring internal quality control and security;
• Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
• Debugging to identify and fix errors in our Services;
• Compliance-related audit of interactions, transactions, and other compliance activities; 
• Fulfilling our agreements and policies; and
• Complying with our legal obligations.

1. Marketing and Advertising of Our Products and Services

We may use personal information to tailor and provide content and ads to you. We may provide you with these materials as allowed by applicable law.

Some ways we market to you include email campaigns, advertising to specific audiences.

If you have questions about our marketing practices, you can contact us anytime as outlined in “Contact Us” below.

1. Other Purposes

We also use your information for other purposes requested by you or as allowed by applicable law.

• Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
• De-Identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, information about the device from which you access our Services, or other analyses that we create.
• Sharing Content with Friends or Colleagues. Our Services may offer various tools and features. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Share only with us the contact information of individuals with whom you have a relationship (e.g., family member, friend, neighbor, or colleague).

4. HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for various business purposes, including providing our Services, protecting ourselves or others, or in the event of a major business transaction, such as a merger, sale, or asset transfer, as described below.

1. Disclosures to Provide Our Services

The categories of third parties with whom we may share your information are described below.

• Collaborations and Influencers. We may share your information with other collaborators, influencers, and charities to promote The Pouch collections and its partners.
• Service Providers. We may share your personal information with our third-party service providers who use this information to assist us in providing our Services. This includes, but is not limited to, service providers who provide us with IT support, hosting, payment processing, customer service, and related services.
• Affiliates. We may share your personal information with our affiliates.
• APIs/SDKs. We may use third-party Application Programming Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as outlined in “Contact Us” below.

1. Disclosures to Protect Us or Protect Others

We may access, preserve, and disclose any information we store associated with you to external parties if we believe, in good faith, that doing so is necessary or appropriate to: comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; protect yours, ours, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist in an investigation or prosecution of suspected or actual illegal activity.

1. Disclosure in Case of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, administration, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such transaction, as permitted by law and/or contract.

5. YOUR CHOICES AND PRIVACY RIGHTS

Your Privacy Choices. The privacy choices you may have regarding your personal information are determined by applicable law and are described below.

• Email and Phone Communications. If you receive unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out and stop receiving future emails. Please note that you will continue to receive transaction-related emails about products or services you have requested. We may also send you certain non-promotional communications about us and our Services, and you may not be able to opt out of these communications (e.g., communications about our Services or updates to our Terms or this Privacy Policy).

We process requests to be placed on “do not mail,” “do not call,” and “do not contact” lists as required by applicable law.

• “Do Not Track.” “Do Not Track” (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Interest-Based Advertising. You can stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as allowed by your browser or device. However, if you adjust your preferences, our Services may not function properly. Please note that cookie opt-outs are not effective in mobile applications. However, you can opt-out of receiving personalized ads in some mobile applications by following instructions for Android, iOS, and other mobile platforms.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. Note that you must opt-out separately on each browser and on each device.

Your Privacy Rights. Under applicable law, you may have the right to:

• Access Personal Information about you, including: (i) confirm whether we are processing your personal information; (ii) obtain access or a copy of your personal information in a structured, commonly used, and machine-readable format; and (iii) receive an electronic copy of personal information you provided to us, or request that we send such information to another company in a structured, commonly used, and machine-readable format (the “right to data portability”);
• Request Correction of your personal information when it is inaccurate or incomplete. In

 some cases, we may provide self-service tools that enable you to update your personal information;

• Request Deletion of your personal information;
• Request Restriction or Object to our processing of your personal information; and
• Withdraw your Consent to our processing of your personal information.

If you wish to exercise any of these rights, please contact us as outlined in “Contact Us” below. We will process such requests in accordance with applicable laws.

6. SECURITY OF YOUR INFORMATION

We take measures to ensure your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We take appropriate steps to require that your personal information remains protected, and we require our third-party service providers and partners to have appropriate security measures in place as well. To the fullest extent permitted by applicable law, we accept no liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues related to your use of our Services. If we learn of a security breach, we may attempt to notify you electronically by sending an email to you or posting a notice on our Services.

7. INTERNATIONAL DATA TRANSFERS

We may transfer personal information we collect about you to third countries for processing and storage. If those countries do not offer the same level of data protection as the country in which you reside, we will take steps to ensure that your personal information receives adequate protection as required by applicable laws. This may include, for example, entering into specific contracts approved by the European Commission that require the protection of personal information transferred from the EU to countries outside the EU, or using other legal safeguards, such as the EU-U.S. Privacy Shield.

8. RETENTION PERIOD

We retain your personal information for the time necessary to fulfill the purposes for which it was collected unless otherwise required by applicable law. To determine the appropriate retention period for your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means and the applicable legal requirements.

9. MINIMUM AGE

Our Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under the age of 13. If we learn that we have collected or received personal information from a child under the age of 13 without verified parental consent, we will take steps to delete that information. If you believe we may have information from or about a child under the age of 13, please contact us as outlined in “Contact Us” below.

10. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time to reflect the collection, use, processing, disclosure, or management of personal information. We will post the date of the last revision of the Privacy Policy at the top of this page. If we make substantial changes to this Privacy Policy that affect your rights, we will provide prominent notice and obtain your consent, as required.

11. CONTACT US

If you have any questions or concerns about this Privacy Policy, your personal information, or our privacy practices, please contact us:

Jump Serviços de Marketing e Tecnologia.

Address: Rua Mario de Boni 2250, apt 3, Caxias do Sul, Rio Grande do Sul, Brazil.

Email: contact@thepouch.io

12. IMPORTANT DEFINITIONS
13. Processing. “Processing” means any operation or set of operations performed on personal information or sets of personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or provision, alignment or combination, restriction, erasure, or destruction.
14. De-identified Information. “De-identified Information” is information that has been altered in a way that does not allow or facilitate the identification of a specific individual. We may create De-identified Information from personal information by excluding information (such as the name) that would make the personal information identifiable to you or associated with you.
15. Aggregated Information. “Aggregated Information” is information that has been combined in a way that is not intended to allow or facilitate the identification of a specific individual.
16. Cookies. Cookies are small text files stored on your device that contain a unique string of characters and can be used to help identify, remember, and track your browser or device. Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your device for a specific period or until you delete them, while session cookies expire as soon as you close your browser.
17. Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is code embedded in our Services that collects information about engagement in our Services. The use of a pixel tag allows us to record, for example, that a user visited a specific web page or clicked on a specific ad. We may also include web beacons in emails to understand if messages were opened, acted upon, or forwarded.
18. Technologies. “Technologies” include cookies, pixel tags, local storage, and other similar technologies.
19. Application Programming Interface or API. An API is a set of rules that allows one software to request services or functionalities from another software.
20. Software Development Kit or SDK. An SDK is a collection of software development tools and code libraries used to create applications for a specific platform.
21. Interest-Based Advertising. Advertising targeted to you based on your browsing activities or use of apps or websites over time and across various sites, apps, or devices.

Jump Serviços de Marketing e Tecnologia.