Privacy Policy

Last Updated: September 20, 2021

Welcome to Peer! We believe you should always know what data we collect from you and how we use it, and that you should have meaningful control over both. We want to empower you to make the best decisions about the information that you share with us and the world. And we are committed to protecting your privacy in all aspects of our business. This privacy policy (“Policy”) explains (1) what information we collect from you, (2) how we use that information, and (3) what rights you may have with respect to the information we collect. By using any of our Websites or services, applications, or products (collectively, our “Services”), you agree to be bound by this Policy. If you do not wish to be bound by this Policy, you will not be allowed to use our Services.

Please read this document carefully because this Policy, along with our Terms and Conditions, incorporated by reference, describe the legally binding agreement between you (referred to hereinafter as, “you,” “your”, “User,” “Guest”, or “Visitor”) and us. Our Privacy Policy may be updated from time to time, and we will notify you of any material changes by posting the new Privacy Policy to our Website at www.peerclub.com (“Website”). Your continued use of the Website thereafter shall constitute your acceptance of the updated terms. We encourage you to review the most up-to-date version of the Policy from time-to-time on the Website. We will notify you of any material changes to the Policy through the Website, or through other communication. In the event you choose not to accept the updated terms, you agree to cease use of all the Website.

By accessing the Website, you agree (i) to comply with this Policy, and (ii) that your visit and use of the Website, and any dispute directly arising out of your use or misuse, shall be governed by this Policy.

Nothing in this Policy shall be deemed to confer any third-party rights or benefits. Our partners, affiliates, vendors, and/or third-party websites may have additional privacy policy terms, restrictions, limitations and data collection and protection practices that you should review separately and independently from this Policy. We are not liable for the data collection, storage and usage practices of any third-party affiliate, vendor, licensor or the like.

  1. Data Definitions.

    1. Personal Information. In order to better provide you with our Services, we may collect personally identifiable information that can be used to contact or identify you, and information on your use of our Services that may be connected with you or your household (“Personal Information”). Personal Information that we collect may include, but is not limited to, your name, email address, payment information, and location. Personal Information may also include information you supply to us concerning your User Content, preferences and interests expressed in the course of using our Services, as well as the content which you have viewed through the Services. Your use of the Services to record your preferences, identify content relevant to you, and otherwise personalize your activity in relation to the Services is intended for your benefit; however, we want to make you aware as described below how we use your Personal Information. You may also be required to provide certain Personal Information to us when you elect to use certain products or services available through the Services. These may include: (a) registering for an account on our Website; (b) purchasing products or paying for certain services; (c) signing up for special offers from us or selected third parties; (d) sending us messages; (e) submitting your credit card or other payment information when ordering and purchasing products and services on our Website. We will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us, and to improve our Services. We also may gather additional personal or non-personal information in the future in order to provide you with our Services.
    2. Navigational Information. When you visit the Website, our may servers automatically record information that your browser sends whenever you visit a website. This information may include, but is not limited to, your computer’s Internet Protocol address, browser type, the web page you were visiting before you came to our Website, access times and information you search for on our Website (“Navigational Information”). Navigational Information is used for the operation of our Services, to maintain quality of our services, and to provide general statistics regarding use of the Website.
    3. Cookies. Likemanywebsites,wemayalsouse“cookies”tocollect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We may use “persistent cookies” to save your username and password for future logins to the Website; and we may use “session ID cookies” to enable certain features of the Website, to better understand how you interact with the Website and to monitor aggregate usage and web traffic routing on the Website. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the Website you visit. If you do not accept cookies, however, you may not be able to use all portions of the Website or all functionality of our services.
    4. INFORMATION ABOUT MINORS/CHILDREN. WE NEVER COLLECT, SELL, SHARE, OR STORE DATA OR PERSONAL INFORMATION FROM MINORS OR CHILDREN UNDER THE AGE OF 13 OR UNDER THE AGE OF 18, UNLESS WE HAVE A PARENTAL OR LEGAL GUARDIAN’S CONSENT. THE ONLY INFORMATION WE COLLECT, STORE AND USE TO PROVIDE THE SERVICES IS THE PERSONAL INFORMATION OF THE ACCOUNT CREATOR, WHO MUST BE ABOVE THE AGE OF 18. INDIVIDUALS BELOW THE AGE OF 18 (“MINORS”) SHALL NOT BE ALLOWED TO CREATE AN ACCOUNT ON THE WEBSITE WITHOUT THE EXPRESS PERMISSION OF A LEGAL GUARDIAN OR PARENT. IF YOU BECOME AWARE THAT WE HAVE COLLECTED PERSONAL INFORMATION FROM A MINOR WITHOUT PARENTAL OR LEGAL GUARDIAN CONSENT, PLEASE LET US KNOW BY CONTACTING US AT SUPPORT@PEER.INC, SO WE CAN TAKE APPROPRIATE ACTION. TO PREVENT INADVERTENT DISCLOSURE OF PERSONAL INFORMATION WHILE USING THE OUR SERVICES OR WEBSITE, ASSIST IN EFFECTIVE USE OF INFORMATION, AND ENSURE APPROPRIATE USE OF THE WEBSITE, WE STRONGLY ENCOURAGE THE PARENT OR GUARDIAN OF ANY MINOR TO ACTIVELY GUIDE ANY INTERACTIONS WITH AND/OR USE OF THE WEBSITE.

  2. Information We Collect.

    1. When you visit our Website, including peerclub.com, we may collect your IP address, internet service provider description, information about the type of device use you to access our Website, and browser information. We may also deposit and collect information from cookies. We use this information to help diagnose problems with and secure our servers, to administer the proper functioning and legitimate use of our Website, and to improve the nature and marketing of the Services. Your IP address is also used to gather broad demographic information that does not personally identify you.
    2. When you request more information about the Services, we collect your email address, name, and any other information you voluntarily provide to us so that we can respond to your request and/or provide you with additional information.
    3. When you set up an account with us, you may need to provide us with information such as your name, username, password, email address, phone number, location, gender, age, profile pictures, and credit card information (“Account Information”). The information required to create an account may vary depending on the country, region, or type of user. We use the information you provide to us upon creating an account to identify and administer your account. We use this information to fulfill any orders or payments, and communicate with you about offers, promotions, discounts, and updates, if any. You have the right to opt-out of communications from us, but you cannot opt out of communications that we send you regarding your account.
    4. When you pay for Services or products, we collect your name, address, telephone number, email address, credit card number, credit card billing address, credit card expiration date, and credit card verification value (ccv) code (your "Payment Information"). This Payment Information is necessary for us to use to process and fulfill your payments. We do not save your credit card information. For credit card payments, we use third party payment gateways (“Third Party Payment Gateways”), such as Stripe to process any applicable Fees and/or payments. By using the Services, you hereby agree to the terms of use and privacy policy of the then-current Third-Party Payment Gateway. We are not liable for any issues arising from or related to your breach of any Third-Party Payment Gateway’s policies. We may, from time-to-time, change our Third-Party Payment Gateway, and will provide you with written notice of such change. All information collected through our Third-Party Payment Gateway, such as credit card information, names, and addresses, may be accessible to us but will not be used, sold, or stored by us. We are not liable for any data breach or security incident, or compromised personal information that is caused, directly or indirectly, by the Third-Party Payment Gateway. You are responsible for any data or personal information that you directly provide to any ThirdParty Payment Gateway.

  3. How We Use Your Information. We use your personal information to help create your account, communicate with you, process any transactions with us, and provide you with our Services. We never sell your Personal Information. Further, we use Personal Information collected via the Services for a variety of business purposes as described below:

    1. To facilitate account creation and logon process;
    2. To send you marketing and promotional communications about our Services (you can opt-out of this at any time);
    3. To send administrative information and notices to you regarding your account;
    4. To fulfill and manage orders, returns, refunds, features, and other purchases or requests made by you;
    5. To administer promotions, offers, codes or discounts, if applicable;
    6. To request feedback and to contact you about your use of the Services;
    7. To protect our Website from fraud monitoring and prevention;
    8. To enforce our terms, conditions and policies;
    9. To respond to legal requests, subpoenas, court orders and to prevent harm;
    10. To manage user accounts;
    11. To deliver services to the user;
    12. To respond to user inquiries/offer support to users;
    13. To respond to any data privacy or legal requests.

      14. We also may use your data for internal business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include Personal Information. We will not use identifiable Personal Information in any other manner without your consent. We may post user testimonials and comments on our Website or social media upon written notice to you, which may contain Personal Information. You have the right to request removal of such testimonial, images, likeness, and/or comment(s) upon receiving our written notice.

  4. Who Your Data Will Be Shared With. We may share and disclose your data with the following third parties, vendors, contractors and affiliates solely for the purposes of providing and improving the Services.

    1. Advertising, Direct Marketing, and Lead Generation;
    2. Affiliate Marketing Programs;
    3. Communicate and Chat with Users;
    4. Data Backup and Security;
    5. Functionality and Infrastructure Optimization such as Amazon Web Service;
    6. Invoice and Billing such as Stripe;
    7. Web and Mobile Analytics;
    8. Website Hosting such as Amazon Web Services.

  5. Communications. In connection with your use of the Services, you agree that we may send you service announcements, administrative messages, notifications, offers, promotions, affiliate information and other important information. You may opt out of some of those communications by clicking the “unsubscribe” button on the bottom of all emails sent from us to you, or by altering your communication preferences by logging into your account. However, there are certain material transactional or data privacy emails you may not opt out of. Additionally, you agree that all agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing. Peer is always public facing which means stories are immediately viewable and searchable by anyone around the world. We give you non-public ways to communicate on Peer too, through protected OTR Direct Messages. You can also use Peer under a pseudonym if you prefer not to use your name.

  6. How We Protect Your Data.

    1. In all of our Services, we have security measures in place to protect the loss, misuse, and alteration of the information under our control. When you place orders or access your account information, we use a secure server. The secure server layer (SSL) encrypts all information you input before it is sent to us. All of the user data we collect is similarly protected against unauthorized access. That being said, no measures are guaranteed to be 100% secure. You should take steps to protect against unauthorized access to your device and account, including to (1) choose a robust password that nobody else knows or can easily guess and (2) keep your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
    2. We may store your data on servers provided by third party hosting vendors with whom we have contracted. To facilitate operations, we may transfer and access Personal Information from around the world, including to servers located inside or outside the United States. By providing information to us, you consent to the transfer and storage of Personal Information in these locations

    3. We use the following technical safeguards to keep your data safe and secure:

      1. Unique password requirements and limited employee access;
      2. Destruction, deletion or de-identification of data;/li>
      3. Industry standard security protocols;
      4. Industry standard security protocols;
      5. Employee training on how to handle sensitive data, breach notice and procedures;
      6. Secure Technology (SSL), server authentication and data encryption and use of firewall to host data;
      7. Designated security coordinator or team on our team;
      8. Sub-processors and third-parties are bound to same security practice obligations;
      9. Backups;
      10. Periodic audits.

  7. When We May Disclose Data

    Most importantly, We do not sell, share, license, or otherwise share your Personal Information or any personally identifiable information with any entity or person, except as expressly described in this Policy or when we have a legal basis to do so, for instance with your prior written consent or a court order. We may disclose your Personal Information in the following circumstances and as otherwise permitted by applicable law:

    1. Disclosure to Authorized Persons. If you use the Services on behalf of another person or organization, we may provide your Personal Information to that authorizing person/organization. We have no control over the use of your Personal Information by the authorizing person/organization, and that use is not subject to this Policy. If you do not wish your Personal Information to be disclosed to the person/ organization on whose behalf you use the Services, you may not use the Services.
    2. Vendors, Consultants and Third-Party Service Providers. We may share Your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples third-party services we may engage include, but is not limted to, payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your data with third parties for their promotional or commercial purposes. We have contracts in place with our data processors that ensure they safeguard your data. This means that they cannot do anything with your data unless we have instructed them to do it or if they have a legal basis. They will not share your Personal Information with any organization apart from us. They will hold it securely and retain it for the period we instruct or required by law. However, we are not responsible for the privacy practices other content and/or services operated by third parties that are linked to or integrated with our Service or for the privacy practices of any third party. Our provision of such third-party links, content and/or services does not constitute our endorsement of these third parties, their content, their owners, or their practices. Once you leave the Website via such a link, access a third party application, or click on a third party offer, you should check the applicable privacy policy of the third party or advertiser website to determine, among other things, how they will handle any Personal Information they collect from you.
    3. Disclosure in Business Transfers. We may be involved in the sale or transfer of some or all of our business. As part of that sale or transfer, we may disclose your Personal Information to any actual or potential acquiring organization, but we will require the actual or potential acquiring organization to agree to protect the privacy of your Personal Information in a manner that is consistent with this Policy or a similar policy. We are not liable for the actual or potential acquiring organization’s use and disclosure of your Personal Information.
    4. Law Enforcement and Legal Obligations. We may disclose your Personal Information to a government institution that has asserted its lawful authority to obtain the information. We may also disclose your Personal Information if we have reasonable grounds to believe the Personal Information could be useful in the investigation of unlawful activity. We may also disclose your Personal Information to comply with a subpoena, judgment, or warrant or an order made by a court, person, or body with jurisdiction to compel the production of information, or to comply with court rules regarding the production of records and information. We have no control over, or liability for, those persons’ use and disclosure of your Personal Information, and their use and disclosure is not subject to this Policy.
    5. Disclosure of Aggregated and De-Identified Information. We may provide and sell aggregate statistics about our customers, sales, traffic patterns, and related website and product information to third parties, but these statistics will include no personally identifying information. All information used will be de-identified or anonymized upon aggregation. For example, we will not tell our business partners that you bought a particular service, but we may tell those business partners how many customers in demographic groups bought that certain service or feature, and your Personal Information may be used to place you in that demographic group without identifying you.
    6. To the extent permitted or required by applicable law, you can opt-out of having your information shared with a third party that is not our agent, by contacting us at support@peer.inc. However, please note that opting-out of information sharing or collection may affect your ability to use the Services.

  8. Processing Grounds. We will only use your Personal Information outside the scope of this Policy if we have your consent or if we have a lawful basis for doing so. Lawful bases for processing include contractual necessity, and our “legitimate interests” or the legitimate interest of others, as further described below. You have the right to request that your Personal Information not be processed by us. However, this may impair the quality of and our ability to deliver our Services.

    1. Contractual Necessity. We process some Personal Information because we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Information will result in your inability to use some or all portions of the Services that require such data.
    2. Legitimate Interest. We may process Personal Information when we believe doing so furthers our legitimate interest. Our legitimate interests may include operation and improvement of the Services; marketing the Services; provision of customer support; protection from fraud or security threats; completion of corporate transactions; and compliance with legal obligations.
    3. Consent. In some cases, we process Personal Information based on the consent you expressly grant to us at the time we collect such data. When we process Personal Information based on your consent, it will be expressly indicated to you at the point and time of collection. To withdraw your consent, please email us at support@peer.inc.
    4. Other Processing Grounds. From time to time we may also need to process Personal Information to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

  9. Data Retention

    We keep the data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected, to perform our contractual and legal obligations, and for any applicable statute of limitations periods for the purposes of bringing and defending claims. We may also indefinitely retain aggregate, anonymized and/or de-identified data. When we have no ongoing legitimate business need to process the data, we will either delete, de-identify it or anonymize it. If this is not possible (for example, because your data has been stored in backup archives), then we will securely store the data and isolate it from any further processing until deletion is possible. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

  10. Breach Notification

    In the event of an actual data breach or the unauthorized access or disclosure of any sensitive or personal data, we will notify you in writing as soon as possible outlining the following information:

    1. What happened (date of breach is possible, or estimated date of incident, or the date range within which the breached occurred);
    2. What information was involved (list the type of Personal Information);
    3. What we are doing to help resolve or mitigate the issue (and if there was any delay in providing this notice due to law enforcement investigation);
    4. What you can do to help us;
    5. How you can get more information or contact us;
    6. Information about what we have done to protect individuals whose information has been breached;
    7. Advice on steps that the person whose information has been breached may take to protect himself or herself; and
    8. Information about the steps we have taken to cure the breach and the estimated timeframe for such cure.

  11. Your Data Rights

    1. You have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of Your Personal Information, (ii) to request rectification or erasure; (iii) to restrict the processing of Your Personal Information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the sharing of Your Personal Information. To make such a request, please contact Us at [EMAIL]. We will consider and act upon any request in accordance with applicable data protection laws.
    2. If you are resident in the European Economic Area and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html .
    3. If you would like to opt-out of or unsubscribe from receiving direct marketing communications, you can do so by changing the notification settings in your account, or you can also use the unsubscribe link contained in the message you have received. However, you cannot opt out of receiving transactional emails related to your account with us or Services, unless you delete your account. Where we process your data on the basis of our or a third party's legitimate interest, you may object to such processing at any time by contacting us. Our affiliates and partners are solely responsible for their own marketing emails and other communications directed to you. We cannot unsubscribe you from any partners’ communications.
    4. You have the right to control your settings to limit the data we collect from you and how we use it, and to control things like account security, marketing preferences, apps that can access your account, and address book contacts you’ve uploaded to Peer. You can also always download the information you have shared on Peer.
    5. In addition to information you share with us, we use your posts, content you’ve read, Liked, or Forwards, and other information to determine what topics you’re interested in, your age, the languages you speak, and other signals to show you more relevant content. We give you transparency into that information, and you have the right to modify or correct it at any time.
    6. If you would at any time like to review or change the information in your account or terminate your account, you can:
      1. Log into your account settings and update your user account; or
      2. Contact us using the contact information provided.

  12. Your Responsibilities and Consents

    By visiting or using the Services, you agree to be bound by this Privacy Policy. This is the entire and exclusive Privacy Policy and it supersedes any earlier version. By using the Services, you expressly consent to the following:
    1. The collection, use, disclosure and processing of your data in the manner described in this Privacy Policy, including our procedures relating to cookies, IP addresses, log files and the like;
    2. Our servers are based in the United States, so all data will be primarily processed by Us in the United States. You consent to the transfer and processing of your data in the United States, in the country you are located in, or the EEA/EU by us and by our partners and affiliates;
    3. You consent and agree that we may transfer your data to data processors located in countries which do not have data protection laws that provide the same level of protection that exists in countries in the European Economic Area. Your consent is voluntary, and you may revoke your consent by opting out at any time, as described above. Please note that if you opt-out, we may no longer be able to provide you with our Services; and
    4. You consent to us sharing your information with relevant persons working for service providers and third-party affiliates who assist us to provide our Service as described herein.