PAWS Energy Privacy Policy

PAWS – PRIVACY POLICY

PersonifiSolutions, Inc. respects your privacy. PersonifiSolutions, Inc. and its affiliates (“Global Straticom” or “PAWS” or the “Company”) offer Personnel Authentication for Worksites services to Operators and Work Site Personnel “WSP” through the use of www.globalstraticom.com/paws-app/ (the “Website”) and/or PAWS’s mobile applications (the “Application”) (collectively referred to as the “Services”). When you use our services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information.

This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, and delete your information. This Privacy Policy covers:

  • User Accounts & Accessing the Services
  • Information that is being collected
  • Why PAWS collects data
  • Sharing your information
  • Visibility
  • Integration with other third party services
  • Controlling your personal information
  • How PAWS retains data we collect
  • How does PAWS use aggregated information?
  • Information security
  • Compliance & cooperation with regulators
  • Changes to this Privacy Policy

This Privacy Policy is incorporated as part of the PAWS Terms of Use (the “Terms of Use” or the “Terms”). Your use of the Services is subject to the Terms of Use, Copyright Policy and this Privacy Policy and indicates your consent to them.

To use our Services, you must be 16 years of age or older. If you are under 16, you may not download or use the Services.

In this Privacy Policy, the term “personal information” means information which you provide to us which personally identifies you, such as your photo, name, email address, physical address, phone number, certifications, your location and, in certain circumstances, billing information or other data which can be reasonably linked to such information by PAWS.

There are no privacy settings as all of the required information in the PAWS app and website and the personal information we may collect is determined by your agreements with the Operator to use PAWS Services as part of your relationship with the Operator.

 

Privacy Concerns Reports

If you have any questions about this Privacy Policy, or if you believe that your privacy has been compromised in the course of using the Services, please contact the Operator directly and the Operator Administrator will work with PAWS to resolve the issue.

User Accounts & Accessing the Services

Please note that when you install the Application on your mobile device, PAWS will set up an account associated with that mobile device (the “Account” or “PAWS Account”). After installation, PAWS will collect and use your information, including meta-data (as described below), in accordance with this Privacy Policy. This use will include linking your information with your Account.

PAWS requires you to set an account with your first and last name, email address and picture on the PAWS website https://globalstraticom.com/paws-app/ for you to use the Services. PAWS will not be able to link all of your information with your Operator’s account until you complete your profile including uploading a picture. If you do so:

  • PAWS will link all of your information with your Account using your email address as your unique identifier. This includes information received from all mobile devices running the Application on which you have chosen to sign in;
  • With the exception described in the bullet below and as explained in the section “Visibility” below, your Account and information associated with your Account will be visible only to PAWS and the Operator who designated you as am authorized WSP; and
  • When using the Application, your location, the time, date and account information will be visible by PAWS and the Operator.
  • PAWS may also establish and require from time to time additional or different means of identification and authentication for logging in and accessing the Services or for accessing certain features or designated sections of the Services.
  • Your login details are your responsibility. You are fully accountable for any use or misuse of your Account and personal details as a result of conveying your login details to someone else. You must maintain your login details in absolute confidentiality and avoid disclosing them to others.

Information that is being collected

We want you to understand the types of information we collect as you use our services

PAWS collects information to provide better services to all its users. The information PAWS collects, and how that information is used, depends on how the Operator and you choose to use our services.

Information you create or provide to us:

  • Account Information: information required when setting up an account such as your name, email address, photo, etc. Bear in mind that false, incorrect, or outdated information may impair PAWS’s ability to provide you with the Services and to contact you when necessary. PAWS will explicitly indicate the fields for mandatory completion. If you do not enter the requisite data in these fields, you may not be able to set up an account (and therefore will not be able to use our Services); and/or
  • Information that you choose to share with PAWS: information that you choose to share with PAWS, including a name, email address, address, phone number, photo, training certifications and any billing information added to your Account.
  • Communication which you choose to conduct through the PAWS Services: We may also collect information when you exchange communication with your Operator concerning PAWS, for example, if you submit a request, contact a support team, or report a violation to.

Information we collect as you use our services

We collect information about your activity in the Services, which we use to provide you with the Services of PAWS, including features which are meant to personalize your experience. The activity information we collect may include:

  • Detailed location information. Location information is collected for example in the form of GPS signals (combined with a time-stamp) and other information sent by your mobile device on which the Application is installed and activated. This location information is saved to your account. The types of location data we collect depends in part on your device and account settings.

Meta-data (information about your device, browser and app use):

  • Once you install the Application, PAWS collects information about the use of the Services and information from the device you have PAWS installed on. For example:
  • PAWS may collect and record how often you use the app and for how long, your device type, unique identifiers, operating system type & version, battery usage, information that you viewed on our Services, the fact that you used the Services, and the geographic location of the device that you are using to log in and use PAWS on.
  • We also collect information about the interaction of your devices with our Services, including, crash reports, system activity, and the date, time, and referrer URL of your request.

Information we collect about you from our partners

Why PAWS collects data

PAWS may use information collected from or provided by you for the following purposes:

Provide our services

We use your information to deliver our services. For example:

  • Use your location information; and
  • To share your submissions with the Operator associated with your account of the Services.

Maintain & improve our services

  • We also use your information to ensure our services are working as intended, such as tracking outages or troubleshooting issues reported to us. And we use your information to improve the service or to develop new features or services.

Measure performance

  • We use data for analytics and measurement to understand how our services are used. For example, we analyze data about your usage of the Services to do things like optimize product design. We may also use data to measure the usability and effectiveness of PAWS’s own marketing efforts on third party sites or platforms.

Communicate with you

  • We may also use your information to send you updates, notices, announcements, and additional information related to the Services;
  • We may also use your information to conduct surveys and questionnaires; And if you contact your Operator concerning PAWS we may keep a record of your request in order to help solve any issues you might be facing.
  • Subject to your prior indication of consent (to the extent required under applicable law), we may also use the email address that you provided to send you promotional and/or marketing materials. At any time, you may choose not to receive such materials by clicking on the “Unsubscribe” link in the email messages that we may send to you. In any case, PAWS will not share your contact details with any advertiser, unless explicitly permitted or required by law.

To protect PAWS, our users, the public and for Legal reasons

We may also use and process your information and content, using different technologies to the following purposes:

  • To enforce the Terms of Use or Privacy Policy;
  • To contact you when PAWS believes it to be necessary;
  • To comply with any applicable law and assist law enforcement agencies under any applicable law, when PAWS has a good faith belief that PAWS’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;
  • To detect abuse and illegal activity; to detect and prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services. However, PAWS denies any duty to perform such tasks;
  • To handle breakdowns and malfunctions;
  • To take any action in any case of dispute, or legal proceeding of any kind between you and the Services, or between you and other users or third parties with respect to, or in relation with the Services;
  • For purposes provided under this Privacy Policy and Terms of Use;
  • To help improve the safety and reliability of our Services. This includes detecting, preventing, and responding to security risks, and technical issues that could harm PAWS, our users, or the public;
  • To create aggregated and/or anonymous data (where such data does not enable the identification of a specific user). See “How does PAWS use aggregated information”, below;

We’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy.

Sharing your information

Personal information that you share

The Services are based on relationships between Operators and End Users or Work Site Personnel (WSP).

In particular, users will share personal information such as name, email address, address, phone number, photo, training certifications, their location information and other files. This information will be shared directly to the Services and the Operator.

You can decide whether or not to upload content to the Services. However, any content that you choose to share and submit for posting is neither private nor confidential and you should expect that it may be made public and known to others according to the terms of your agreement with the Operator. Information you choose to upload will linked with your account and other information including personal information you attached. You should be aware of how the Operator intends to use your information.

We, at PAWS, take great measures to provide you with the best experience you can have while using the Services. However, PAWS has no control over the conduct of any Operator and disclaims all liability in this regard. Users are advised to carefully and thoroughly consider whether or not to make available any information.

Participating in any Operator’s activities as a result, directly or indirectly, from using PAWS, is entirely at your own risk. PAWS is not a party to any agreement entered into between the users in any circumstances. The user has the sole and ultimate responsibility regarding compliance with all laws, regulations or any other duty. We do not accept any liability for any loss, damage, cost or expense that you may suffer or incur as a result of or in connection with your participation in any activity or event initiated, held or conducted by a user or a third party, Operator nor in connection to any agreement between the users or third parties, Operators, including any activity or event related in any way, directly or indirectly, the Services or the use thereof.

When PAWS shares your information

PAWS does not sell, rent or lease your personal information to third parties.

PAWS will not share your personal information with others, without your permission, except for the following purposes and to the extent necessary in PAWS’s good-faith discretion:

  • As necessary for the facilitation and operation of the Services. For example, logging the date and time associated with your account and your location;
  • If PAWS reasonably believes that you have breached the Terms of Use or is investigating potential breach of the Terms of Use, or believes that you abused your rights to use the Services, or performed any act or omission that PAWS reasonably believes to be violating any applicable law, rules, or regulations. PAWS may share your information in these cases, with law enforcement agencies and other competent authorities and with any third party as may be required to handle any result of your wrongdoing. However, PAWS has no obligation to investigate a user;
  • If PAWS is required, or reasonably believes that it is required by law to share or disclose your information;
  • In any case of dispute, or legal proceeding of any kind between you and PAWS, or between you and other users with respect to, or in relation with the Services;
  • In any case where PAWS reasonably believes that sharing information is necessary to protect against harm to the rights, property or safety of PAWS, our users, or the public as required or permitted by law, including to prevent imminent physical damage or damage to property;
  • To detect, prevent, or otherwise address fraud, security, or technical issues;
  • If PAWS organizes the operation of the Services within a different framework, or through another legal structure or entity, or if PAWS is acquired by, or merged into or with another entity, or if PAWS enters bankruptcy, provided however, that those entities agree to be bound by the provisions of this Privacy Policy, with respective changes taken into consideration;
  • To collect, store, hold and manage your personal information through cloud based or hosting services or a third party or a party affiliated or connected to PAWS, as reasonable for business purposes, located in the U.S.A.;
  • PAWS may also share personal information with companies or organizations connected or affiliated with PAWS, such as subsidiaries, sister-companies and parent companies;
  • Personal information may also be shared with PAWS’s trusted partners and service providers to process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures. For example, we use service providers to help us with customer services.

 

Visibility

Please note that all of your account information and some other information will be visible to Operators. Note that your account will be included along with any information you submit. It will therefore be visible to Operators.

Integration with other third-party services

PAWS may offer you the option to link PAWS to third party services that may be useful to you (like, Spotify). Where PAWS detects an integration may be available (either because a third party service attempts to link to PAWS, or PAWS detects an installed service on the device which has an integration option, or you request a particular integration), PAWS will ask for confirmation to connect the accounts. If you choose to connect the accounts, PAWS will ask for your permission to share data with the third party service. You should only agree to connect accounts if you are comfortable with the third party service receiving the data set out at the time of connecting the accounts and PAWS is not responsible for the third party service’s use of data. You can disconnect PAWS and the third party service at any time and PAWS will cease sharing data with that service from the point of disconnection onwards

Controlling your personal information

You can always review and update certain information by visiting your Account settings (such as your phone, email and more).

You can log on to the PAWS website to view and change your photograph by going to https://globalstraticom.com/paws-app/ and click on “Sign In” .

If you find that the information associated with your Account is not accurate, complete or updated, then you should make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may impair the ability to provide you with Services.

Deleting your information

Your personal account information can only be deleted at the direction of the Operator.

How PAWS retains data we collect

Some data can be deleted whenever the Operator likes, some data is deleted automatically, and some data we retain for longer periods of time when necessary. This section describes why we hold onto different types of data for different periods of time.

  • Information retained until you remove it – such as your photo, email address, phone number and other personal information. We’ll keep this data in your PAWS Account until the Operator choose to remove it and/or update it.
  • Data that expires after a specific period of time – in some cases, you don’t need to actively delete your information as we set retention timeframes based on the reason for the data’s collection. We may also take steps to anonymize certain data within set time periods.
  • Information retained by PAWS after your Account is deleted – we may keep some anonymous data at PAWS’s discretion if it’s useful for helping us understand how users interact with our features and how we can improve our services. For example, metadata, longitude, latitude, and other information not personally identifying an end user.
  • Information retained for extended time periods for limited purposes – sometimes business and legal requirements oblige us to retain certain information, for specific purposes, for an extended period. For example, when PAWS processes a payment for you, we’ll retain this data for longer periods of time as required for tax or accounting purposes.

How does PAWS use aggregated information?

PAWS may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes (including advertising).

PAWS may also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services’ providers, partners and any other third party. For example, metadata information that we receive from your mobile device to determine how often the average application is used.

Cookies

PAWS may use cookies and similar technologies on the Services. Cookies are packets of information sent by the Website’s servers to your web browser and then sent back by the browser each time it accesses the Website’s servers.

PAWS may use cookies for various purposes, such as to save you the need to re-enter your username and password each time you log in, to facilitate the use of the Website, to collect statistical information, to verify information, and to customize the Website to your personal preferences and for information security purposes.

Some of the cookies may expire when the session ends and you exit your browser. Other cookies are saved on your computer’s hard drive. If you wish to block the Website’s cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Website, or certain features thereof.

Information Security

PAWS considers information security to be a top priority. PAWS services are built with strong security features that continuously protect your information. PAWS and its Third Party Services providers implement systems, applications and procedures to secure your personal information, to minimize the risk of theft, damage, loss of information, or unauthorized access or use of information. For example, we review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems. In addition, we restrict access to personal information to PAWS employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

The insights we gain from maintaining our services help us detect and automatically block security threats from ever reaching you.

However, these measures are unable to provide absolute assurance. Therefore, although PAWS takes great efforts to protect your personal information, PAWS cannot guarantee and you cannot reasonably expect that PAWS’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

Compliance & cooperation with regulators

We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it.

Data transfers

We store data on servers located in the USA and your information is processed on servers located the country where you live.

When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly.

European requirements

If the European Union (EU) data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to request access to, update, remove, delete, and restrict the processing of your information.

We process your information for the purposes described in this policy, based on the following legal grounds:

With your consent

We ask for your agreement to process your information for specific purposes and you have the right to withdraw your consent at any time. You can manage your settings at any time, including your in-app Privacy Settings (if applicable).

When we’re pursuing legitimate interests

We process your information for our legitimate interests and those of third parties (such as partners including advertisers, in order to report use statistics) while applying appropriate safeguards that protect your privacy. This means that we process your information for things like:

  • Providing, maintaining, and improving our services to meet the needs of our users
  • Developing new services and features that are useful for our users
  • Understanding how people use our services (including how they interact with our ads) to ensure and improve the performance of our services
  • Customizing our services to provide you with a better user experience
  • Marketing to inform users about our services
  • Providing advertising to make our services freely available for users
  • Detecting, preventing, or otherwise addressing fraud, abuse, security, or technical issues with our services
  • Protecting against harm to the rights, property or safety of Waze, our users, or the public as required or permitted by law
  • Performing research that improves our services for our users and benefits the public
  • Fulfilling obligations to our partners like developers and rights holders
  • Enforcing legal claims, including investigation of potential violations of applicable Terms of Service

When we’re providing a service

We process your data to provide a service you’ve asked for under a contract (including our terms of use).

When we’re complying with legal obligations

We’ll process your data when we have a legal obligation to do so, for example, if we’re responding to legal process.

If you have any questions about Data Protection, please contact the Operator directly and the Operator Administrator will work with PAWS to answer your questions.

Changes to this Privacy Policy

PAWS may from time to time change the terms of this Privacy Policy. Substantial changes will take effect 30 days after PAWS has posted a:

  • System message to users notifying them of changes to the Privacy Policy; and
  • Notification on the Website’s homepage or any other relevant web pages, explaining the changes to the Privacy Policy alongside a comparison of the “old” and “new” versions of the Privacy Policy.

Other changes will take effect 7 days after their initial posting on the Website. However, if PAWS amends this Privacy Policy to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required.

You agree to be bound by any of the changes made in the terms of this Privacy Policy. Continuing to use the Services will indicate your acceptance of the amended terms. If you do not agree with any of the amended terms, you must avoid any further use of the Services.

Last modified: 03 January 2019

 

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