PRIVACY POLICY

Privacy & Cookie Policy
Pink Iguana Skunkworks LLC (“Pink Iguana”, “we”, “us” or “our”) is committed to respecting and protecting the accuracy, confidentiality and security of your personal information, and wants you to feel secure when visiting our website (the “Website”), downloading and using our mobile device applications (the “Mobile Apps”), and using our services (the “Services”). This Privacy Policy sets out our policies concerning the collection, use, disclosure and protection of personal information we receive from individuals using the Website, the Mobile Apps or the Services.“Personal information” means all information about an identifiable individual.Unless otherwise agreed to in writing by Pink Iguana, by using the Website, the Mobile Apps or the Services, you will be deemed to have consented to the terms and conditions set forth in this Privacy Policy, including (without limitation), the collection, use and disclosure of your personal information by Pink Iguana.

IF YOU ARE NOT IN AGREEMENT WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, DO NOT SUBMIT ANY OF YOUR PERSONAL INFORMATION, USE THE WEBSITE, OR DOWNLOAD THE MOBILE APPS.

Scope of Privacy Policy
This Privacy Policy outlines the minimum standards for Pink Iguana’s treatment of personal information. Where applicable laws contain additional requirements, Pink Iguana will ensure compliance with those laws. Should there be, in any specific case, an inconsistency between this Privacy Policy and applicable local privacy laws, this Privacy Policy will be interpreted in that case to give effect to and comply with the local privacy laws.Pink Iguana may update this Privacy Policy from time to time. We will notify you about material changes by placing a prominent notice on the Website and the Mobile Apps. However, it is your responsibility to review the most current version. If this Privacy Policy is updated, your continued use of this Website, the Mobile Apps or the Services and any subsequent submission of personal information by you will be deemed your conclusive acceptance of the most recent version of this Privacy Policy.

Accountability
Pink Iguana is responsible for personal information under its control, and will take all reasonable steps to handle such personal information fairly and to ensure compliance with applicable laws in relation to the collection, use, disclosure and protection of personal information.Please note that if you are a corporate customer or any other type of organization, you are responsible for the legal collection and use of personal information of individuals within your organization, in accordance with the principles set out in your privacy policy and the applicable laws in the countries in which you operate. Pink Iguana is not responsible for your privacy practices and policies.

Purposes for Collecting Personal Information
Through the Services, the Website and the Mobile Apps, Pink Iguana collects, uses and discloses to certain third parties personal information for the following primary purposes:to develop, manage and deliver our products and the Services to our customers;to contact our customers, either directly or through one of our resellers, to offer them the option to renew the Services;to contact our customers directly about products and services that may be of interest;to ensure high standards of service to customers;to contact customers with product and service updates, upgrades and enhancements;to meet regulatory requirements; andto verify a customer’s identity.The paragraphs below provide further information about what types of personal information we collect and how we use and disclose it for the Website and the Mobile Apps.The Website and Use of Cookies”Cookies” are small text files containing small amounts of information which are downloaded to your device when you visit a website, so that the website can remember some information about your browsing activity on the website, either for the duration of your visit or for repeat visits. The cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie.

Cookies are useful because they allow a website to recognize a users device. They do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your user experience. In general, cookies make the interaction between you and the website faster and easier. They cannot be used to run programs or deliver viruses to your device. In general, cookies do not identify you personally.The following describes the types of cookies that Pink Iguana currently uses or may in the future use on our Website:

Session Cookies
These are temporary cookies that expire when you close your browser. A session cookie assigns a randomly-generated, unique identification number to your device when you access the Website. Assigning your device a number facilitates the proper functioning of the features of our Website by permitting us to maintain a persistent “state” for your session, including information relating to orders that you may place. We also use session cookies to collect anonymous information (i.e., information that does not identify you personally) about the ways users use the Website, such as which pages they visit, which links they use, and how long they stay on each page. We analyze this information (known as “click-stream information”) to better understand our user’s interests and needs and to improve the content and functionality of the Website.

Persistent Cookies
Unlike a session cookie, a “persistent cookie” does not expire when you close your browser. It stays on your device until the expiration date set in the cookie (for example, at the end of a calendar month) or until you delete it. Persistent cookies can be used to “tag” your device so that the next time you visit (or someone using your device visits), our server will recognize you, not by name, but by the “tag” on your device. This will enable us to provide you with a personalized experience even if we do not know who you are. It will also allow us to collect more accurate information about the ways people use the Website, for example, how people use the Website on their first visit and how often they return. Using persistent cookies permits us to provide you with a more personalized experience and, in some cases, may save you the trouble of re-entering information already in our database.

Strictly Necessary Cookies
These cookies are essential for the running of our Website. Without these cookies, parts of our Website would not function. They enable you to move around the Website and use its features, such as accessing secure areas. These cookies do not track where you have been on the Internet and do not gather information about you that could be used for marketing purposes.

Performance Cookies
These cookies are used to monitor the performance of our Website, for example, to determine the number of page views and the number of unique users the Website has. Web analytics services may be designed and operated by third parties on Pink Iguana’s behalf. The information provided by these cookies allows us to analyze patterns of user behavior, and we use that information to enhance user experience or identify areas of the Website which may require maintenance. These cookies do not collect information that identifies a visitor. All information collected through these cookies is aggregated and therefore anonymous.

Functional Cookies
These cookies allow the Website to remember choices you make (such as your preferences, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. The information these cookies collect may be anonymized, and they cannot track your browsing activity on other websites.

Targeting or Advertising Cookies
These cookies, which may be placed on your device by us or our trusted third party service providers, remember that you have visited a website and use that information to provide you with advertising which is tailored to your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Although this type of cookies can track your activity around the Internet, they cannot identify you personally. Without these cookies, online advertising you encounter will be less relevant to you and your interests.

Web Beacons
When you visit our Website, your device may receive one or more “web beacons” in order to assist us with delivering cookies, to collect anonymous information about the use of the Website by our users, and to deliver customized or targeted content to you on the Website and through our partners. Web beacons (also referred to as “tracking pixels,” “1×1 gifs,” “single-pixel gifs,” “pixel tags,” or “action tags”) are graphic images, usually no larger than a 1×1 pixel, placed at various locations on the Website. They also help us identify browser types, search terms that bring users to our Website, and the domain names of websites that refer traffic to us. We also utilize web beacons to provide us with more information on any emails we send out. In particular, a web beacon in an email communication will send us information to let us know that you have received, opened, or acted upon an e-mail you have chosen to receive from us.

JavaScript Tags/Pixels
These are used by us to collect anonymous information about the use of the Website by our users, and to deliver customized or targeted content to you on the Website and through our partners. We may use JavaScript tags to anonymously track how visitors interact with our Website, including where they came from and the manner in which they use our Website.By using our website, you agree that we can place these types of cookies on your device.Some people find the idea of a website storing information on their device intrusive. If you would prefer to opt out of cookies, it is possible to manage them by changing the cookie settings on your device, in your browser settings.

Existing cookies that have already been set can be deleted from your hard drive. You can also block some or all cookies. However, you should be aware that you might lose some features and functionality of our Website if you do so. If you need assistance with your cookie settings, consult the help menu within your Internet browser. Pink Iguana’s Website may contain links to third party sites, and we recommend and encourage you to read the privacy policies posted on those third party sites.

Pink Iguana is not responsible for the privacy policies or practices of any third party.The Mobile AppsFor Pink Iguana’s consumer customers (i.e., individuals who purchase our products for their own personal use), our Mobile Apps may collect personal information such as your name, email address, street address, phone number, device make and model, serial number, and device IMEI (International Mobile Equipment Identity) number. In addition, if you choose to agree to Pink Iguana’s geolocation service, Pink Iguana will also collect geolocation data from your device which can be done through IP, wifi or GPS.Pink Iguana will use this personal information for product registration and installation purposes, as well as for customer. If you have agreed to Pink Iguana’s geolocation service, Pink Iguana may use your geolocation data to map your device location.For Pink Iguana’s non-consumer customers (i.e., businesses, schools, government and other organizations), our Mobile Apps generally do not collect personal information. Rather, they facilitate the collection of information by our customers and utilize information already collected through the use of the Services. These Mobile Apps generally serve as management agents and self-service portals, facilitate the download of non-app software, and perform administrative functions. Pink Iguana will try to collect personal information directly from the individual concerned unless authorized by that individual to collect it from a third party or as otherwise permitted by law.If personal information is collected for any other purposes than described above (unless the purpose for collecting personal information is obvious and you provide your personal information for that purposes, or unless otherwise permitted or required by laws), Pink Iguana will communicate the purpose of collecting the personal information to you at the time of collection, either orally or in writing, as well as its use and how it may be disclosed.If personal information is gathered in writing, the purpose of its collection will be communicated through printed materials, the Website or email. If personal information is gathered orally, Pink Iguana will provide an oral explanation of the purpose for the collection and use.

Consent
As indicated at the top of this Privacy Policy, unless otherwise agreed to in writing by Pink Iguana, by using the Website, the Mobile Apps or the services, you will be deemed to have consented to the terms and conditions set forth in this Privacy Policy, including (without limitation), the collection, use and disclosure of your personal information by Pink Iguana.

IF YOU ARE NOT IN AGREEMENT WITH THE TERMS AND CONDITIONS OF THIS PRIVACY POLICY, DO NOT SUBMIT ANY OF YOUR PERSONAL INFORMATION, USE THE WEBSITE OR DOWNLOAD THE MOBILE APPS.

As a general principle, Pink Iguana will obtain your consent before collecting, using or disclosing your personal information for any purpose other than as identified in this Privacy Policy. Pink Iguana will make an exception only where legal, medical or security reasons make it impossible or impractical to obtain consent, as discussed further below. We will make reasonable efforts to ensure you understand how your personal information may be used or disclosed. If Pink Iguana plans to use previously-collected personal information for a new use that is incompatible with the original purpose, you will be informed of the new purpose, and we will obtain consent from you prior to this new use.

The form of consent can vary, depending on the sensitivity of the information and the circumstances. Consent may be express or implied depending on the nature of the personal information or the use. At times, consent for one use can fairly be implied to include consent for other included or related uses. When determining the appropriate form of consent, Pink Iguana will be guided by what a reasonable person would consider fair and appropriate in the circumstances.

Your consent may be provided to Pink Iguana orally, in writing or electronically, either personally or through an authorized individual. Consent can be implied when you are informed that information will be used for certain purposes and you submit the information with this knowledge, or consent can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the individual voluntarily provides personal information for that purpose.

Pink Iguana may collect, use or disclose personal information without your knowledge or consent in the following limited circumstances:

* When the collection, use or disclosure of personal information is permitted or required by law (including subpoenas, search warrants, court orders and government orders)
* In an emergency that threatens an individual’s life, health or personal security;
* When the personal information is available from a public source (e.g. a telephone directory);
* When we require legal advice from a lawyer;
* For the purposes of collecting a debt;
* In connection with criminal justice, taxation or regulatory activities;
* To protect ourselves from fraud or to protect the rights and property of Pink Iguana;
* To investigate an anticipated breach of an agreement or a contravention of law; or
* In the event of a reorganization, merger or sale of Pink Iguana.
Subject to certain exceptions (e.g. where the personal information is necessary to provide Services, or the withdrawal of consent would frustrate the performance of a legal obligation), you may withdraw or refuse to provide your consent to Pink Iguana, or request that your personal information be removed from our databases and records, by giving reasonable notice. All communications with respect to the withdrawal of consent should be made in writing and addressed to Pink Iguana’s Privacy Officer.

If you refuse or withdraw consent, or request that your personal information be removed from our databases and records, Pink Iguana will make you aware of the likely consequences of this action. In some cases, it may prevent Pink Iguana from providing you with the Services.

Limited Collection
Pink Iguana will restrict its collection of personal information to that information which is necessary and relevant for the legitimate purposes identified. Pink Iguana will not collect excessive personal information, and will limit the purposes of collection to what a reasonable person would consider fair and appropriate in the circumstances.

Pink Iguana will collect personal information only by fair and lawful means, will be transparent, up front and open with you, and will communicate in a manner that is clear and reasonably understood.

Limited Use, Disclosure and Retention
Pink Iguana will use and disclose personal information only as described in this Privacy Policy, or for the purposes for which it was collected, or as agreed by you, or without your consent for the limited circumstances listed above in the section titled “Consent”. We will not use or disclose personal information for any additional purpose that is incompatible with the original purpose unless we obtain consent to do so. We will not sell your personal information to other parties.

Pink Iguana may share personal information with our employees, contractors, consultants, service providers, business partners and other parties who require such information to assist us with providing you with the Services. By providing personal information to Pink Iguana, you will be deemed to have consented to the disclosure of your personal information to such parties.
The use, collection and disclosure of personal information may involve Pink Iguana transferring personal information across borders. If this occurs, we will comply with all applicable trans-border data flow privacy laws.

Pink Iguana will retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required for legal or business purposes. After this time, any personal information you have provided to us will be destroyed, deleted or made anonymous. If you have an account with Pink Iguana, any personal information will be destroyed, deleted or made anonymous once your account has been inactive for two years.

Accuracy
Pink Iguana will make reasonable efforts to ensure that the personal information collected and used by us is accurate, complete and up-to-date to meet the purposes for which it is collected and used. Pink Iguana does not routinely update personal information unless it is necessary to meet the purposes for which it is collected. Pink Iguana therefore relies on you to keep your personal information accurate and current.

You may request correction to your personal information in order to ensure its accuracy and completeness. Any request to correct personal information must be made in writing to Pink Iguana’s Privacy Officer and must provide sufficient detail to identify the personal information and the correction being sought.

If your personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any third party to whom we disclosed the personal information in the previous year. If the correction is not made, we will note your correction request in the relevant records.

Safeguarding Personal Information
Pink Iguana will make reasonable security arrangements and use appropriate technical and organizational measures to protect all personal information under our control (regardless of the format in which it is held) against unauthorized access, loss, theft, collection, use, disclosure, duplication, modification, disposal or similar risks, by both individuals outside of Pink Iguana as well as within. The types of security safeguards that we use vary, depending on the nature and sensitivity of the personal information, the harm that might result from its improper use or loss, and how it is stored (e.g. in paper or electronically). Pink Iguana’s security safeguards include locked filing cabinets, physically secured offices where personal information is held, limited employee access, the use of IDs, passwords, restricted servers, firewalls and encryption for electronic files, as well as contractual requirements for service providers to provide comparable security measures.

Pink Iguana will use appropriate security measures when disposing of and destroying personal information, such as shredding documents and deleting electronically stored information, in order to prevent unauthorized access.

Pink Iguana trains all staff who handle personal information on the importance of and procedure for maintaining confidentiality. All employees, contractors, consultants and service providers of Pink Iguana who are provided access to personal information on behalf of Pink Iguana are required to be familiar with and comply with the provisions of this Privacy Policy and applicable laws.

Pink Iguana will continually monitor compliance with this policy and will investigate any suspected breaches swiftly and effectively. If a breach is found to have occurred, Pink Iguana will comply with all applicable data breach laws, including notifying relevant individuals and regulatory bodies where required. Pink Iguana and its employees will respond promptly and in accordance with applicable laws to any notices or demands issued by a regulatory body in any relevant jurisdiction.

Pink Iguana will also continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Openness
This Privacy Policy is available to the public on our Website, so that information about our policies and practices relating to the management of information is readily available to everyone.

Requests for Access
You have the right to access your personal information, subject to limited exceptions under applicable laws such as solicitor-client privilege, disclosure that would reveal personal information about another person, legal obligations and proprietary rights. Pink Iguana’s Privacy Officer will assist you with your request. This includes:

* Identification of and access to any or all of your personal information under Pink Iguana’s custody or control.

* An explanation of how that personal information is or has been collected, used or disclosed by Pink Iguana.

* The names of any individuals and organizations to which your personal information has been disclosed by Pink Iguana

All requests should be made in writing (by mail, fax or email), provide sufficient detail to identify the information being sought, and be directed to Pink Iguana’s Privacy Officer. Pink Iguana’s Privacy Officer may require further information defining the request more succinctly.

We will respond to written requests within thirty (30) days of receiving such request. We will either make the requested information available within that time period, or provide written notice of an extension where additional time is required to fulfill the request. If Pink Iguana cannot fulfill your request in full or in part, you will be provided with a response in writing that documents the reason for refusal and the recourse available to you.

A minimal fee may be charged for providing access to personal information, where permitted under applicable law. Where a fee applies, we will inform you of the cost and request further directions from you on whether or not we should proceed with your request.

Complaint Procedure
Complaints, concerns or inquiries about Pink Iguana’s privacy policies and practices, including compliance with this Privacy Policy, should be made in writing to:

Privacy Officer
Pink Iguana Skunkworks LLC
717 North Union Street, Suite 78
Wilmington, Delaware 19805-3031
United States of America
Tel: 206 446 8463
Email: terry@pinkiguanadigitalmuses.com
Specific details about the inquiry or complaint must be provided. All complaints will be investigated and will be responded to in accordance with the section above as well as applicable laws. If the Pink Iguana Privacy Officer is unable to address your concerns, the issue may be escalated to the office of the CEO or to the regulatory authority for your jurisdiction.

Effective Date and Updates
Pink Iguana’s Privacy Policy was initially published effective December 31, 2014