PRIVACY POLICY

This Privacy Policy describes the privacy practices of Pray, Inc. (“we”, “us”, or “our”), and how we handle personal information that we collect through our websites and mobile applications, and any other website or service that we own or control and that links to this Privacy Policy (collectively, the “Service” or “Services”).

The information we collect may belong to representatives of faith-based organizations that use our Services (“FBO Users”), FBO Users’ congregants and current and prospective subscribers of their content, consumers who use our platform, and individuals who visit our website or otherwise interact with our Services.

To the extent we provide you notice on our Services of different or additional privacy policies or practices (e.g., at the point of our collection), those additional terms shall govern our data collection and use.

Personal Information We Collect

The information that you provide to us depends on how you interact with the Services and may include:

• Contact information, such as your first and last name, email and mailing addresses, and phone number.
• Account information, such as the username and password you use to access our Services,  other information you add or upload to your account profile, and your social network authentication information.
• Contact book information. If you give us permission to sync your device’s contact book, we will collect information about your contacts, including but not limited to name, email address, and phone number. We will use this information to personalize the Service for you and others. For example, we will let you know which of your contacts is already using the Service, and provide recommendations for new friends on the Service. Similarly, if you appear in other users’ contact books, we will collect information about you, and we will let them know that you have joined the Service and suggest you as a recommended friend to those users.
• Location-based information. Our Service uses location-based services in order to verify your location and deliver you relevant content and ads based on your location, as well as for our and our FBO Users’ internal analytics purposes, including to help us improve our platform.
• Payment information needed to complete your transactions and donations with us, including name, payment card information, and billing information. This information is processed by our payment service providers, which may handle your payment information in accordance with their own privacy policies.
• Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise, as well as communications that users may exchange with others users through the Services.
• Usage information, such as information about how you use the Services and interact with us, including information associated with any content you upload to the Services or otherwise submit to us, and information you provide automatically when you use any interactive features of the Services.
• Marketing information such as your preferences for receiving our marketing communications and details about your engagement with them.
• Other information not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We, our service providers, and our advertising partners may automatically log and combine information about you, your computer or mobile device, and your interactions over time with the Services, online resources, and our communications, such as:

• Device data, including your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, and general location information such as city, state, or geographic area.
• Online activity data, including pages, screens and/or features you viewed, accessed and/or used, how long you spent on a page,  screen and/or feature, the website you visited before browsing to the Services, navigation paths between pages or screens, information about your activity on a page, screen and/or feature, access times, duration of access, and whether you have opened or otherwise engaged with our communications, such as our marketing emails, or clicked links or files within them.

We use cookies, web beacons (e.g., pixel tags), and local storage technologies to collect some of this information. For more information on how we use these technologies, please visit our Cookie Policy.

Information we obtain from other sources:

• Social media information. When you connect the Services to your social media account, we may collect certain information from your account, depending on the privacy permissions you have configured within that account. Further, we may maintain pages on social media platforms, such as Facebook, Twitter, and Instagram. When you visit or interact with our pages on those platforms, you or the platforms may provide us with information through the platform.
• Third-party login information. When you link, connect, or login to the Services with a third party service (e.g. Google), you direct the service to send us information (e.g., contact information) controlled by that service or as authorized by you via your privacy settings at that service.
• Other sources. We may obtain personal information (e.g., demographic information) from other third parties, such as marketing partners, publicly-available sources, and data providers.

Information about non-users. 

• Contact book. Users may provide information about non-users when they upload their device’s contact book (including but not limited to contacts’ names, email addresses, and phone numbers), which we will use to personalize the Service as described in the “Contact book information” section above and in accordance with this Privacy Policy.
• FBO Users’ congregants. Our FBO Users may provide the contact information of congregants who have not yet signed up to use the Services, including to help our FBO Users onboard those congregants onto the Services.
• Communications and other interactions. We allow users to send communications to and interact with individuals who do not use the Services (e.g., such as sending a message to a friend that may not be a user of the Services). In order to do so, users may provide information about the non-user (e.g., name, email address, and telephone number) to facilitate the interaction.

How We Use Personal Information

We use personal information for the following purposes or as otherwise described at the time of collection:
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To provide our Services. We use personal information to operate, maintain, and provide you with our Services, including to facilitate payments. In particular, we use personal information to perform our contractual obligations under our terms of service.

To communicate with you about our Services. It is in our legitimate business interests to use personal information to respond to your requests, provide customer support, and communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages.

To improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes:

• understanding your needs and interests, and personalizing your experience with the Services and our communications;
• troubleshooting, testing and researching, and keeping the Services secure; and
• investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.

For research and development. We may use personal information for research and development purposes where it is in our legitimate business interests, including to analyze and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified, or other anonymized data from personal information we collect. We make personal information into anonymized data by removing information that makes the data personally identifiable to you. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.
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For marketing and advertising. We, our service providers, and our third-party marketing and advertising partners may collect and use personal information for the following marketing and advertising purposes:

• Direct marketing. We may send you direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the “Opt-out of marketing communications” section below.
• Interest-based advertising. We may engage third-party advertising companies to display our ads on their online services. We may also share information about our users with these companies to facilitate advertising to them or similar users on other online platforms.

Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time, including by following the opt-out instructions in the “Privacy Rights and Choices” section below.

For compliance and protection. We may use personal information to comply with legal obligations,  and it is in our legitimate business interests to enforce our terms of service and to defend our business against legal claims or disputes, including to:

• protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the Services;
• prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft; and
• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

How We Share Personal Information

We may share personal information with the following individuals or entities:

Other users and non-users.

• FBO Users. If you follow or subscribe to our FBO Users’ content, we may share certain information back with the respective FBO User to give them insight into their communities (e.g., to determine which followers are most active and where those individuals reside). Additionally, if you make a donation to an FBO User’s organization, we will share your name and donation amount with that user.
• Communications and other interactions. We allow users to send communications to and interact with others on and off the platform. When users interact with others using the Services, their contact information, name or username and message will be shared with those other individuals.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services).
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Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
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Authorities and others. Law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
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Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, our business (including, in connection with a bankruptcy or similar proceedings).

Marketing and advertising partners.

• Interest-based advertising. We may share your information with third-party advertising companies, for the interest-based advertising purposes described above, which may collect information on the Services through cookies and other automated technologies.
• Marketing partners. We may present you with the option to receive certain information, e-books or other electronic materials, and/or marketing offers directly from our third-party marketing partners. If so, we will share certain information (e.g., name, email, and phone number) with those partners, who may use your information in accordance with their own privacy policies.

Privacy Rights and Choices

Opt-out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the “How to Contact Us” section below. You may continue to receive Services-related and other non-marketing communications.
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Account deactivation and deletion. You may deactivate and delete your account by contacting us as described in the “How to Contact Us” section below. Note that deactivating your account may not cause us to fully delete all of your personal information. To request that we do so, please submit a data deletion request as described in the “Personal information requests” section.
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Adjust contact book and location preferences. You can revoke our access to your contact book and your precise geolocation by adjusting your device settings.
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Personal information requests. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information:

• Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
• Correction of personal information that is inaccurate or out of date.
• Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
• Withdrawal of consent, where we have collected and processed your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• Opt out of selling of your personal information or our use or sharing of your information for interest-based advertising. To exercise this right, you can click the “Your Privacy Choices” link on the footer of our website or by enabling the Global Privacy Control setting within the browser that you use to access our Service. Learn more at the Global Privacy Control website. Please note that your opt out will be specific to the device and browser you use when you opt out. We do not have actual knowledge that we have sold or shared the personal information of children under the age of 16.
• Additional rights, such as to object to and request that we restrict our use of personal information.

To make a request, please email us or write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

‍Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.

‍Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.

Security

We use reasonable organizational, technical, and administrative measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information.

Children’s Privacy

Our Services are not intended for use by children under 16 years of age. If we learn that we have collected personal information through the Services from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

International Data Transfers

You will provide personal information directly to our Services in the United States. We may also transfer personal information to our affiliates and service providers in the United States and/or other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

International Data Transfers

Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable). 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Job Applicants

When you visit the careers portion of our websites, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resumé. This may also include diversity information that you voluntarily provide and that we process on the basis of your consent. We use this information on the basis of our legitimate business interests to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics, and to respond to surveys. We may also use this information to provide improved administration of the Services and as otherwise necessary (i) to comply with relevant laws or to respond to subpoenas or warrants served on us, (ii) to protect and defend our or others’ rights or property, (iii) in connection with a legal investigation and (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy or our terms.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. Where we do so, we will update the date of this Privacy Policy and post it on the website. If we make material changes to this Privacy Policy, we will let you know.

How to Contact Us

Responsible entity. Pray is the entity responsible for the processing of personal information under this Privacy Policy (as a controller, where provided under applicable law).

‍Contact us. If you have any questions or comments about this Policy, our privacy practices, or if you would like to exercise your rights with respect to your personal information, please contact us by email at privacy@pray.com or advice@dpocentre.com, or write to us at: 4607 Lakeview Canyon Road, Suite 456, Westlake Village, CA 91361.

Our representatives in the European Economic Area and United Kingdom are as follows:

‍European Economic Area
The DPO Centre Europe, Ltd.Address: The DPO Centre Europe, Ltd, Alexandra House, 3 Ballsbridge Park, Dublin, D04C 7H2
Phone number: +353 1 631 9460
Email: eurep@pray.com

‍United Kingdom
TheDPO Centre, Ltd.Address: The DPO Centre, Ltd, 50 Liverpool street, London, EC2M 7PY, UK
Phone number: +44 (0) 203 797 6340
Email: ukrep@pray.com