Pronto, Inc. DBA Infilla (“we,” “us,” or “our”) wants you to be familiar with how we collect, use, and disclose information.  This Privacy Policy describes our practices in connection with information that we collect through:

• Website(s) operated by us from which you are accessing this Privacy Policy;

• Software application(s) made available by us for use on or through computers and mobile devices;

• Email messages that we send to you that link to this Privacy Policy.

Collectively, we refer to the website(s), app(s), and emails as the “Services.”

1. Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.  We collect Personal Information through or in connection with the Services, such as:

• Name

• Company name

• Postal address

• Telephone number

• Email address 

• IP address (we may also derive your approximate location from your IP address)

• Payment information

Collection of Personal Information 

We collect Personal Information through the Services, such as when you apply for a permit. We may also receive your Personal Information from other sources, such as local government records.

We need to collect Personal Information in order to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services.  If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for the following purposes: 

• Providing the functionality of the Services and fulfilling your requests. 

• To provide the Services’ functionality to you, such as logging in via mobile passcode.

• To complete pay fees to the jurisdictions we work with.

• To respond to your inquiries and fulfill your requests.

• To send administrative information to you, such as changes to our terms, conditions, and policies.

• Accomplishing our business purposes. 

• To analyze use of the Services.

• We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information.  We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

• For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements; 

• For fraud prevention and security monitoring purposes, including to detect and prevent cyberattacks or attempts to commit identity theft; 

• For developing new products and services;

• For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures; 

For identifying usage trends, for example, understanding which parts of our Services are of most interest to users; 

• For determining the effectiveness of our promotional campaigns; and 

• For operating and expanding our legitimate business activities.

Disclosure:

We disclose Personal Information to:

• Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.

• Contractors and Subcontractors. We may share information we receive with contractors and subcontractors that you invite to access our Services.

• Local government. We may share information we receive with city planning and permitting officials and authorities on your behalf in connection with your use of the Services.

• Marketing. We do not rent, sell, or share personal information about you with nonaffiliated companies for their direct marketing purposes, unless we have your permission.

• Analytics Partners. We use analytics services such as PostHog to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources.

• As Required by Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

• Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

Consent. We may also disclose your information with your permission.

2. Information Collected Automatically

We and our service providers may collect information automatically in a variety of ways, including:

• Your browser or device. Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type and version. We use this information to ensure that the Services function properly.

• Your use of our app(s). When you use our application, we and our service providers may track and collect usage data, such as the date and time the app on your device accesses our servers and what information and files have been downloaded to the app based on your device number. We use this information to understand how the app is used and improve it.

• Cookies. Cookies are pieces of information stored directly on your computer. Cookies allow us to collect such information as browser type, time spent on the Services, pages visited, language preferences, and traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting particular cookies from a particular website. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.

• Pixel tags and other similar technologies.

  • Pixel tags.  We may use pixel tags (also known as web beacons and clear GIFs) to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about use of the Services and response rates. 

  • Analytics.  We use analytics services, such as PostHog, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  These services may also collect information regarding the use of other websites, apps, and online services.

Uses and Disclosures of Information Collected Automatically 

If we are required to treat such information collected automatically as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information, as detailed in this Privacy Policy.  In some instances, we may combine information collected automatically with Personal Information. If we do, we will treat the combined information as Personal Information so long as it is combined

3. Security

We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

4. Third-Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating a website or service to which the Services link. The inclusion of a link on the Services does not imply our endorsement of the linked site or service.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Twitter, Instagram, YouTube, Pinterest, LinkedIn, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our apps or social media pages.

Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.

5. CCPA Privacy Rights (California Residents)

‍Under the CCPA, among other rights, California consumers have the right to:

• Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.

• Request that a business delete any personal data about the consumer that a business has collected.

• Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please notify us in accordance with the “Contact Us” section below.

6. GDPR Data Protection Rights (EU/UK Residents)

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

• The right to access – You have the right to request copies of your personal data. We may charge you a small fee for this service.

• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.

• The right to erasure – You have the right to request that we erase your personal data, under certain conditions.

• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.

• The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.

• The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

7. Use of the Services by Minors

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.

8. Jurisdiction

Our Services are hosted in the United States (“U.S.”) and intended for visitors located within the U.S. If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your information outside of those regions to the U.S. for storage and processing. We may transfer information from the European Economic Area, Switzerland, or the United Kingdom to the U.S. and other third countries based on standard contractual clauses approved in the applicable jurisdiction, or otherwise in accordance with applicable data protection laws. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services. By providing any information, including information, on or to our Site, you consent to such transfer, storage, and processing.

9. Sensitive Information

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., Social Security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) on or through the Services or otherwise to us.

10. Third-Party Payment Service

The Services may provide functionality allowing you to make payments using a third-party payment service with which you have created your own account. When you use such a service to make a payment to us, your Personal Information will be collected by such a third party and not by us and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any such third party’s collection, use, or disclosure of your Personal Information.

11. Contact Us

If you have any questions about this Privacy Policy, please contact us at privacy@infilla.com.