PRIVACY POLICY

If you have any questions about our Privacy Policy, our collection practices, the processing of user information, or if you would like to report a security violation to us directly, please contact us at contact@frisaga.com

General Data: The use of our services will automatically create information that will be collected. For example, when you use our Services, your geographic location, how you use the Services, information about the type of device you use, your Open Device Identification Number, date/time stamps for your visit, your unique device identifier, your browser type, operating system, Internet Protocol (IP) address, and domain name are all collected. This information is generally used to help us deliver the most relevant information to you and administer and improve the Site. 

Log Files: As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information to maintain and improve the performance of the Services. 

Analytics: We use analytics services (including, but not limited to, Google Analytics) to help analyze how users use the Site. Analytics services use Cookies to collect information such as how often users visit the Site and we use the information to improve our Site and Services. The analytics services’ ability to use and share information collected by them is restricted by their terms of use and privacy policy, which you should refer to for more information about how these entities use this information. 

Location Information: If you have enabled location services on your mobile device, we may collect your location information to improve the Services we offer. If you do not want this information collected, you can disable location services on your device. 

Cookies: “Cookies” are small pieces of information (text files) that a website sends to your computer’s hard drive while you are viewing the website. These text files can be used by websites to make the users experience more efficient. The law states that we can store these cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission. To that end, this site uses different types of cookies. Some cookies are placed by third party services that appear on our pages. We and some third parties may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Services and to market the Services or other products. Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers. This tracking is done on an anonymous basis and, while not an exhaustive list, some of the companies we work with are Google, AppNexus, Criteo, Rubicon, Pubmatic and DistrictM. 

Use of Your Personal information 

In general, personal information you submit to us is used either to respond to requests that you make, aid us in serving you better, or market our Services. We use your personal information in the following ways: 

●  Operate, maintain, and improve our site(s), products, and services; 

●  Respond to comments and questions and provide customer service; 

●  Link or combine user information with other personal information we get from third parties, to help understand your needs and provide you with better service; 

●  Develop, improve, and deliver marketing and advertising for the Services; 

●  Provide and deliver products and services you request; 

●  Identify you as a user in our system; 

We may store and process your personal information on servers located in both the United States and Europe. We may also create anonymous data records from your personal information by completely excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site functionality. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties at our sole discretion. 

We may receive testimonials and comments from users who have had positive experiences with our Services. We may publish such content. When we publish this content, we may identify our users by their first and last name. We obtain the user’s consent prior to posting this information along with the testimonial. 

Disclosure of Your Personal information 

We disclose your personal information as described below and as described elsewhere in this Privacy Policy. 

Third Parties Designated by You: When you use the Services, the personal information you provide will be shared with the third parties that you authorize to receive such information. 

Third Party Service Providers: We may share your personal information with third party service providers to: provide you with the Services that we offer you through our Services; conduct quality assurance testing; to provide technical support; market the Services; and/or to provide other services to us. 

Information We Share: We may disclose aggregated information about our users and information that does not identify any individual without restriction. In addition, we may disclose personal information that we collect or you provide: 

●  To fulfill the purpose for which you provide it, for any other purpose disclosed by us when you provide the information, or with your consent; 

●  T o third parties designated by you; 

●  With our subsidiaries and affiliates; 

●  To third parties to process payments made through the Services; 

●  With contractors, service providers and other third parties we use to support our business; 

●  To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or 

transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by us about users is among the assets transferred; and 

Other Disclosures: Regardless of any choices you make regarding your Personal information (as described below), frisaga.com may disclose Personal information if it believes in good faith that such disclosure is necessary: (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on our company; (iii) to protect or defend the rights or property of frisaga.com or users of the Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use. 

Third Party Websites 

Our Site may contain links to third party websites. When you click on a link to any other website or location, you will leave our Site or Services and go to another site, and another entity may collect personal information or anonymous data from you. We have no control over, do not review, and are not responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of your personal information after you click on links to such outside websites. We encourage you to read the privacy policies of every website you visit. The links to third party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites. 

Your Choices Regarding Information 

Choices: We offer you choices regarding the collection, use, and sharing of your personal information. We may periodically send you emails that directly promote the use of our Services. When you receive promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly. Despite your indicated email preferences, we may send you service related communications, including notices of any updates to our Terms of Use or Privacy Policy. 

Cookies: If you decide at any time that you no longer wish to accept cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser’s technical information. If you do not accept cookies, however, you may not be able to use all portions of the Services or all functionality of the Services. If you have any questions about how to disable or modify cookies, please contact us at contact@frisaga.com 

Your Rights 

As a user of our site you have the following rights, any of which you may exercise by contacting us at office@frisaga.com 

Pico Digital Marketing (“Pico” or “Pico Digital” or “We” or “Us”) respects our customers (“Users”) concerns about privacy. We understand that visitors to our website may have questions about whether and how this website collects and uses information, and are committed to protecting your privacy. We only use the personally identifiable information (“personal information” or “personal data”) that you provide in accordance with the terms outlined below.

This Privacy Policy covers any personal information we obtain when you visit us, use our services, or access the features on the websites that Pico Digital owns or controls (today or in the future), including https://www.choosepico.com/ and our mobile site (together, the “Sites”). You can access the Sites from a computer or mobile phone, and this Privacy Policy will apply regardless of the means of access. This Privacy Policy also governs the use of personal information we obtain from you from any third-party site or application where we post content or invite your feedback or participation, including (“Third Party Sites”). Pico cannot control the privacy policies or practices of Third Party Sites or of companies Pico does not own or control, and cannot control the actions of people Pico does not employ or manage. You should always check the privacy policies of Third Party Sites and your privacy settings.

1. Notice to EU Residents

This Policy is intended to provide adequate and consistent safeguards for the handling of personal information in accordance with Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“the Directive”) and all the relevant transposing legislation of the Directive in the European Union/European Economic Area, the Swiss Federal Data Protection Act, as such laws may from time to time be amended and valid during the application of this Policy, the Privacy Shield, and any other privacy laws, regulations and principles concerning the collection, storage, use, transfer and other processing of personal data transferred from the European Economic Area to the United States including but not limited to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“the General Data Protection Regulation”) as of its entry into force on 25 May 2018.

2. Processing Personal Information

We are committed to protecting your personal information in compliance with the applicable legislation. We agree to observe the following principles when processing personal information:

• Data will be processed fairly and in accordance with applicable law.
• Data will be collected for specified, legitimate purposes and not processed further in ways incompatible with those purposes.
• Data will be relevant and not excessive for the purposes for which they are collected and used. For example, data may be rendered anonymous if deemed reasonable, feasible, and appropriate, depending on the nature of the data and the risks associated with the intended uses.
• Data subjects in the EU will be asked to provide their clear and unequivocal consent for the collection, processing, and transfer of their personal data.
• Data will be accurate and, where necessary kept up up-to-date. Reasonable steps will be taken to rectify or delete personal information that is inaccurate or incomplete.
• Data will be kept only as it is necessary for the purposes for which it was collected and processed. Those purposes shall be described in this Policy.
• Data will be deleted or amended following a relevant request by the concerned data subject, should such notice comply with the applicable legislation each time.
• Data will be processed in accordance with the individual’s legal rights (as described in this Policy or as provided by law).
• Appropriate technical, physical, and organizational measures will be taken to prevent unauthorized access, unlawful processing, and unauthorized or accidental loss, destruction, or damage to data. In case of any such violation with respect to personal data, we will take appropriate steps to end the violation and determine liabilities in accordance with applicable law and will cooperate with the competent authorities.

3. Information We Collect

Personal Information

Users may be asked for, as appropriate: name, email address, phone number, and company name.

Users may, however, visit our Sites anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personally identification information, except that it may prevent them from engaging in certain Sites related activities.

Personal information will be kept for up to 180 days.

Non-personal Information

We may collect non-personal identification information about Users whenever they interact with our Sites. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Sites, such as the operating system and the Internet service providers utilized and other similar information.

Web Browser Cookies

We collect information about how you use our Sites by setting and accessing cookies on your computer. A cookie is a small piece of information sent by our Sites that is saved on your hard drive by your computer’s browser. The cookie holds information our Sites may need to personalize or enhance your experience and to gather statistical data, such as which pages are visited, the internet provider’s domain name and the addresses of the sites visited immediately before coming to and immediately after leaving the Sites. The information in the cookie lets Pico trace “clickstream” activity (i.e., the paths taken by visitors to our Sites as they move from page to page) to enable us to better serve our customers by revealing which portions of our Sites are the most popular. We may link the anonymous visitor ID from your cookie to a user ID in our database to help us analyze web traffic and statistics. From time to time, other companies may help us with data research and analysis, but they will be prohibited from using that data for any other purpose. You may disable cookies on your browser. Please review your browser’s instructions for doing so. Note that certain features of the Sites may not be available if you delete or reject cookies.

Pixel Tags

We may use pixel tags (also called web beacons or clear gifs) on our Sites. They can help us analyze what our customers do on our Sites and the effectiveness of our features and advertising. They can also help us customize your browsing experience. We may use information collected through pixel tags or tracked links in combination with your personal information. We may also combine personal information you provide to Pico with other personal information. If we work with other companies to help us track, collect, and analyze this information, they will be prohibited from using this information for any other purpose.

4. How We Collect Information

We may collect personal information from Users in a variety of ways, including when Users: visit our site, subscribe to our newsletter, fill out a form, and/or in connection with other activities, services, features, or resources we make available on our Sites.

In 2019, we collected personal information via Sites usage, newsletter subscriptions and form fills. This information included name, email address, company name, and telephone number. We also collected cookie data as outlined in Section 3 of this policy. We did not sell this information to any third party. The information was used in accordance with Section 5 of this policy.

5. How We Use Collected Information

Pico collects and uses Users personal information for the following purposes: to personalize user experience, to improve our Sites, to improve customer service, to share your information with third parties, to send Users information they agreed to receive about topics we think will be of interest to them, and if a User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Sites.

We may also use information in the aggregate to understand how our Users as a group use the services and resources provided on our Sites.

6. How We Protect Your Information

We adopt appropriate data collection, storage and processing practices, and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information and data stored on our Sites. We do not collect any sensitive or purchase-related User information.

We will notify you in writing if there is a data breach on our website.

7. Sharing your personal information

We may share your information with third parties:

• to help us operate our business and the Sites or administer activities on our behalf, such as sending out newsletters or surveys for those limited purposes provided that you have given us your permission;
• to provide you with offers and marketing that may be of interest to you.

We will always obtain your express permission at the time we collect information before sharing it with third parties for marketing purposes.

Any third party we share your information with will use your information consistent with this Privacy Policy.

We may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

8. Third-party websites

Users may find advertising or other content on our Sites that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors, and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Sites. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Sites, is subject to that website’s own terms and policies.

9. Children

The Sites are not directed to children under the age of 13 and Pico does not intentionally collect any information from or about children under the age of 13. If you believe a child has provided us with information, contact us at info@choosepico.com.

10. EU-US Privacy Shield

If you are providing your information from the European Union, Pico complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the EU to the United States. Pico has certified to the Department of Commerce that we adhere to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, the Privacy Shield Principles, and to view our certification, please visit https://www.privacyshield.gov/. Our participation in the Privacy Shield applies to all personal information that is received from the European Union and European Economic Area.

Pico remains responsible and liable under the Privacy Shield Principles for onward transfers if third-party agents that we engage to process personal information on our behalf do so in a manner inconsistent with the Principles unless we can prove that we are not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, Pico commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Pico at info@choosepico.com

We have further committed to refer unresolved Privacy Shield complaints to JAMS (Judicial Arbitration and Mediation Services, Inc), an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint.  The services of JAMS are provided at no cost to you.

For all complaints left unresolved by all other available mechanisms, you may invoke binding arbitration with the Privacy Shield Panel, which consists of a pool of 20 arbitrators designated by the Department of Commerce and the European Commission, from which the parties will be able to select either one or three arbitrators.

If there is any conflict between this Policy and the Principles, the Principles will govern. To learn more about the Frameworks please visit www.privacyshield.gov. You can view our certification at www.privacyshield.gov/list

Pico is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

11. Your Rights

You have the right, without discrimination, to be provided with information as to the nature of the personal information stored or processed about you by Pico and may request deletion or amendments.

You may email info@choosepico.com or call us directly at +1(720)943-8616 to review, update, and revise your personal information.

If access is denied, you have the right to be informed about the reasons for the denial. You may resort to the dispute resolution described in this policy as well as in any competent regulatory body or authority. Pico shall handle in a transparent and timely manner any type of internal dispute resolution procedure about personal information.

If any information is inaccurate or incomplete, you may request that the data be amended. It is your responsibility to provide us with accurate personal information about yourself and to inform us of any changes. (e.g. new home address or change of name).

If you demonstrate that the purpose for which the data is being processed in is no longer legal or appropriate, the data will be deleted, unless the applicable law requires otherwise. You also have the right to request the deletion of your personal data for any reason by emailing info@choosepico.com. Exceptions to deletion may include, where necessary: complete a transaction/perform a contract; security purposes; debugging; free speech; comply with CECPA; research in the public interest; consumer expected internal uses; a legal obligation; and lawful and compatible internal uses.

12. Additional Enforcement Rights and Mechanisms

If at any time, you believe that your personal information has been processed in violation of this Policy, you may report the concern to the competent Pico official. In particular, if you have any inquiries or complaints about the use or limitation of use of your personal information, you may contact our office:

6105 S. Main Street, Suite 200

Aurora, CO 80016

or email us at info@choosepico.com

13. California Privacy Rights

If you are a California resident, you have the right to request information from us regarding the manner in which Pico shares certain categories of personal information with third parties for their direct marketing purposes, in addition to the rights set forth above. Under California law, you have the right to send us a request at the designated address listed below to receive the following information:

1. The categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
2. the names and addresses of the third parties that received the information; and
3. if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.

This information may be provided in a standardized format that is not specific to you. The designated email address for these requests is: info@choosepico.com

Also, please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.

14. Obligations to Data Protection Authorities

We will respond diligently and appropriately to requests from DPAs about this Policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of personal information, we will (i) cooperate with inquiries from the DPA responsible for the entity exporting the data and (ii) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.

15. Your Consent and Updates to this Policy

You acknowledge that this Privacy Policy is part of the Terms of Use for your use of the Sites, and you agree that using the Sites signifies your assent to Pico’s Privacy Policy. Pico reserves the right to change this Privacy Policy at any time. If we decide to change our Privacy Policy, we will post those changes on this page so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it. As we may make changes from time to time without notifying you, we suggest that you periodically consult this Policy. Your continued use of the Sites after the effective date of any modification to the Policy will be deemed to be your agreement to the changed terms.

If you have any questions about your privacy or security on our Sites, please contact us using the following information:

info@choosepico.com

6105 S. Main Street, Suite 200

Aurora, CO 80016