Last updated December 20, 2022
Following “Website” and our Pivo-related applications (“Services”) are part of 3i Inc.
- pivo.ai (including circle.pivo.ai)
- pivo. app (including tour.pivo.app, developer.pivo.app, meet.pivo.app)
- Pivo Play
- Pivo Cast
- Pivo Present
- Pivo Live
- Pivo Tour
- Pivo Studio
3i collects personal information that you provide directly, information about how you use our Services and information from third party sources. 3i uses this information to provide you with Services, understand the way you use our Services so we can improve your experience and to develop the most relevant Services for you.
What Information Do We Collect About You?
We collect information from and about you in connection with your use of the Services. Some of this information may be considered “Personal Information” or “Personal Data” (as defined under applicable laws) which is information that identifies you or your device or is reasonably associated with you.
We also collect, use, and disclose aggregated or de-identified information that does not reasonably identify you or your device, and is not considered Personal Information.
Information You Provide
- Registration Information: When you create an account or profile with us, register for certain Services, complete an application form, participate in promotions, or respond to market research surveys that we sponsor, or place an order for any of our products or Services, we may ask for information such as your name, gender, email address, telephone number, billing address, or other postal address. This will include your date of birth and payment method(s) if you subscribe the Premium Tracking Plan or purchase any paid function of our Services.
- Information You Post on our Services: We may collect information when you post comments or other content to our Services, which may include your username or screenname, comments, likes, interests, status, pictures, and references to your online presence.
Information Collected Automatically
- Device information: We may collect information about you, your use of our Services, your interaction with us including our advertisement, the information about the network, network device, or computer you may use to access to our Services, or other devices (such as Pivo Pod, Pivo Wireless Microphone, etc.) that you may use with Pivo. The information includes:
- Your activity on our Services, including, but not limited to, the filter or function you used, your search history, the content you watched, and your recording activity on our Services.
- Your interaction with us such as email, push message, and other message through online messaging channels.
- Your interaction with our customer service such as the date, time and reason you contact us, transcripts of your conversation with us, and if applicable, your phone number and recordings of your call.
- Your hardware model, device hardware information (Pod information such as Pod name, firmware version), and other unique device identifiers, serial number, current software version, IP address, Application version, OS, OS version, cookies, subscription information, and settings of the devices you use to access the Services.
- The information we automatically collect may also include geolocation information, such as (a) information that identifies the precise location of your mobile device and (b) your IP address, which may be used to estimate your approximate location.
- Viewing Information: Information about statistics on page views, referring sources (such as referral URLs), browser and standard web server log information.
- Information From Our Partners: We may also collect information about you from other sources, including Apple, Facebook, Google, Kakao, Naver, TikTok and public databases.
- Publicly or Commercially Available Information We sometimes gather publicly or commercially available information, including information from social networks, and combine it with other information about your needs, interests, and preferences.
You may choose not to provide us with certain types of information, such as information requested as part of creating an account or profile. In some cases, this may limit your ability to use some Services.
How Do We Use Your Information and Why?
We may use the information we collect as disclosed and described here:
We may use information to provide you with the Services. We may use your information to create, manage, and authenticate your account with us and provide you with customer support and account updates. We may use your information to complete the transactions you request and perform our contractual obligations with you or to ensure that our Services function properly.
We may use information for marketing purposes. We may use your information to send promotional messages and newsletters such as via email, text messaging, or push notifications. These might be our own offers or products or third-party offers or products we think you might find interesting. To learn about your choices for these communications, read the Your Rights and Choices section of this Policy.
We may use information to improve our products and Services. We use your information to analyze our products and services to help us better understand our customers in order to offer best experiences to you. This may also include conducting internal research and development of our Services.
We may use information to maintain the safety and security of our Services. We use your information to protect the rights, property, or safety of 3i Group, business partners, or customers and others and to comply with our legal obligations, including to detect, investigate, and prevent fraud and other illegal activities and to enforce our agreements.
We may use information as otherwise permitted by law. We may use your information to resolve disputes, enforce our agreements, and as otherwise required by law.
Who Do We Share Your Information With and Why?
We may share information within the 3i family of companies. We may disclose your information internally within our business, but only to those who need it to further provide Services or to help with your requests.
We may share your information in connection with a corporate transaction. We may disclose or transfer your information as part of, or during negotiations for, any purchase, sale, lease, merger, or any other type of acquisition, disposal, or financing involving our brands.
We may share information with third parties who perform Services on our behalf. We may share your information with carefully selected companies that provide services for or on behalf of us with professional advice, business support, or perform services on our behalf, including web hosting, information technology, payment processing, direct mail and email distribution, and promotion administration, and analytics services. These Service Providers are allowed to use your information to help us provide our Services and not for any other purpose.
We may share information with our business partners. Partners may include marketing, advertisement measurement, or other partners such as those working with us on co-branded Services or events and digital distribution partners where we make our Services available. Our partners use the information we give them as described in their privacy policies. This may, depending on the Partner services you use, include:
- Facilitating partner pre-paid promotions or collection of payment for our Services;
- Suggesting content and features available in our Service to you in the Partner’s user interface. These suggestions are part of our Services for you and may include customized and personalized recommendations for certain content;
- Sharing information from or about you with online and/or offline marketplace in order to analyze and improve your purchasing experiences.
We may share your information with sponsors and other partners for contests, giveaways, sweepstakes and promotions. We may use information you provide to verify your entry into and eligibility to participate in contests, sweepstakes, giveaways, or promotions and to inform you if you have won. If your entry information will be used for any other purposes, we will disclose that in the applicable rules governing that sweepstake, contest, giveaway, or promotion.
We may share information to provide advertising based on your interests. For more information, please see “Your Choices, Rights, and Controls” section of this Policy.
We may share information when required by the law or to protect ourselves. For example, we will share information when it is necessary for us to comply with applicable law or legal process, to respond to legal claims, or to protect our rights or the property or personal safety of our users, employees, or the public.
We may share your information for reasons not described in this policy. We will tell you before we do this.
Your Rights and Choices
You have certain choices about how we use your information. We would like to make sure you are fully aware if all of your rights and choices. Every user is entitled to the following:
- The right to access: You have the right to request 3i Inc. for 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 3i Inc. correct any information you believe is inaccurate. You also have the right to request 3i Inc. to complete information you believe is incomplete.
- The right to erasure: You have the right to request that 3i Inc. erase your personal data, if your Personal Data is no longer required for the purposes of which it was collected or if you withdraw consent. You can email to firstname.lastname@example.org for further request.
- The right to restrict processing: You have the right to request that 3i Inc. restrict the processing of your personal data, if you think that the data is incorrect or against the law.
- The right to data portability: You have the right to request that 3i Inc. transfer the data that we have collected to another organization, or directly to you.
- Opt out of receiving our marketing emails: To stop receiving our promotional emails, please contact to email@example.com. Even if you opt out of getting marketing emails, we will still be permitted to send you transactional messages.
Additional Information if You Are Located in California
- California Consumer Privacy Act and California Privacy Rights Act: If you are a California resident, you have specific privacy rights governed by the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).
- Right to Know: You have the right to request a report showing the Personal Information collected, shared, and sold about you in the past 12 months.
- Right to Opt-Out of Sale of Your Personal Information: You have the right to opt-out of the sale of your Personal Information to third parties.
- Right to Deletion: You have the right to request that we delete any Personal Information collected from you.
- Right to Non-Discrimination: We shall not discriminate against you based on your exercise of any of the above rights.
We may require additional information to verify your identity or to verify that your authorized agent has the authority to make the request on your behalf before responding to a CCPA and CPRA rights request. We will respond to your request within 45 days if possible and required under the law.
Personal Information Disclosed for a Business Purpose to Third Parties
Some of Personal Information may be disclosed to the following categories of third parties:
- The 3i family of companies;
- In connection with a corporate transaction (e.g. any purchase, sale, lease, merger, acquisition, disposal, or financing involving our brands);
- Our service providers;
- Business partners;
- Sponsors and other partners for contests and promotions;
- To law enforcement or others if required by law.
The disclosures to third parties listed above may be for any of the following business purposes
- To provide you with our Services;
- For marketing purposes;
- To provide you with ads or information we think may be of interest to you;
- To improve our products and Services;
- To maintain the safety and security of our Services; or
- As otherwise permitted by law.
Information about the Sale of Personal Information
Because of the broad definition of “sale” under CCPA, some information that we share with third parties may constitute the “sale” of your information. For instance, some of our Services share identifiers, such as cookies and the advertising identifier associated with your mobile or internet-connected device with our advertising partners, and those partners use and share those identifiers to show advertisements.
Where we do this or otherwise “sells” your information, we will give you the opportunity to opt out by clicking the “DO NOT SELL MY PERSONAL INFORMATION” on the homepage of the relevant website, mobile and online application, or other service. Please note that, when you use these tools on our properties, you will need to renew your choices if you clear your cookies or use a new browser or device.
The following types of information may be “sold”:
- Names and Aliases;
- Email Address;
- IP Address;
- Unique Identifier;
- Information about transactions or content choices made on or in connection with our Services;
- Customer preferences and attributes, such as likes, interests, social media statuses and updates, pictures, and references to your online presence;
- Information collected through cookies and web beacons; or
- Device attributes.
3i does not engage in any “sales” of Personal Information of users that it has actual knowledge are minors under the age of sixteen (16).
Do Not Track: Our websites and apps are not designed to respond to “do not track” requests from browsers.
“Shine the Light” and “Eraser” Laws: Residents of the State of California may request a list of all third parties to which we have disclosed certain information during the preceding year for those third parties’ direct marketing purposes.
If you are a California resident under the age of eighteen (18), and a registered user of the website where this policy is posted, you may request removal of content or information you have publicly posted. Please be aware that such a request does not ensure complete removal from the Internet of the content or information you posted, and there may be circumstances in which the law does not require or allow removal.
Additional Information if You Are Located in EEA, the UK or Switzerland
If you are located in the European Economic Area (the “EEA”), in the United Kingdom (the UK), or in Switzerland, you may have certain rights under applicable data protection laws:
- The right to request access to, and a copy of, the information we hold about you, including details as to how we process this information.
- The right to object to, or restrict, our processing of your information.
- The right to request that your information be erased from further use.
- The right to correct, amend, or update information you have given us (in some instances, where you have an account with us, you can also do this by logging in and updating your information).
- The right of portability, which allows you to request that we share your information with others.
- The right to withdraw any consent to processing you have provided us.
Please note that 3i does not engage in any automated decision-making about you.
International Transfers: Information that is collected from the EEA, the UK or Switzerland may be transferred to countries outside of the EEA, the UK or Switzerland, as applicable, that may not provide levels of protection for your Personal Information equivalent the protection provided by the laws of the European Union, the UK or Switzerland, including the United States. For the purposes of such cross-border data transfers, and to protect your information, we executed Standard Contractual Clauses with all such Controllers and Processors located outside the EEA, the UK or Switzerland and, where necessary, implemented further measures to ensure the Personal Information is subject to equivalent protection.
We will retain your Personal Information as long as it is needed for our business purposes and in accordance with applicable law. In determining this, we will be considerate of the amount, nature and sensitivity of the Personal Information, the potential risk of harm to the Personal Information, and whether our purposes can be achieved through other means.
Legal Basis for Processing: We will only collect, store, or otherwise process Personal Information collected from you in the EEA or the UK in the following situations:
- When we have your consent to do so. You can withdraw your consent at any time.
- When we need to use your Personal Information to perform our responsibilities under our contract with you.
- When we or a third party have a legitimate interest in processing your Personal Information. For example, we may process your Personal Information to communicate with you about our Services, to provide, secure, and improve our Services, and, in certain circumstances, to deliver advertising to you. You have the right to object to our processing of your Personal Information that is based on our legitimate interests.
- When we are required by law to process the Personal Information.
If you would like to exercise your rights under the GDPR (or similar laws in the UK or Switzerland), you may contact the Controller and our Data Protection Officer at firstname.lastname@example.org.
How Do We Protect Your Information?
We are committed to protecting your information. We have adopted commercially reasonable technical, administrative, and physical security procedures to help protect your information from loss, misuse, unauthorized access, and alteration. However, please note that although we take reasonable steps to protect your information, no website, internet transmission, computer system, or wireless connection is completely secure.
Cookies and Similar Technologies
Cookies are small files that store information on your computer. They enable the entity that put the cookie on your computer to recognize you across different websites, services, and browsing sessions. Cookies serve many useful purposes.
- Cookies can remember your sign-in credentials, so you don’t have to enter those credentials each time you sign-in to the Services.
- Cookies help us and third parties understand which parts of our Services are the most popular because they help us to see which pages and features visitors are accessing and how much time they’re spending on the pages. Studying this information helps us to adapt the Services and provide you with a better experience.
- Cookies help us and third parties to provide you with relevant content and advertising by collecting information about your use of our Services and other websites and apps.
When you use a web browser to access the Services, you can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser is different, so check the help menu of your browser to learn how to change your cookie preferences. Your device operating system may contain additional cookie controls. Note that some Services are designed to work using cookies, so disabling cookies may affect your ability to use those Services or certain parts of them.
Other Local Storage
We, along with certain third parties, may use other kinds of local storage technologies, such as Local Shared Objects (also referred to as Flash cookies) and HTML5 local storage, in connection with our Services. These technologies are similar to the cookies discussed above. They’re stored on your devices and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your devices from standard cookies, so you might not be able to control them using standard browser tools and settings.
We, along with certain third parties, may use IP-based Geolocation technology, which retrieves geolocation information of a device, such as country, city, state, province, local currency, latitude and longitude, etc., by using a client’s IP address. This technology is similar to the cookies discussed above. However, this technology may make use of different parts of your devices from standard cookies, so you might not be able to control them using standard browser tools and settings.
You can contact us to update your preferences, correct your information, submit a request, or ask us questions by email at email@example.com.
You can also contact us at:
1F ~ 4F, 23 Yeoksamro-25gil, Gangnam-gu, Seoul 06224 Republic of Korea