Privacy Policy
1 Introduction
The effective date of this policy is 4th December 2021.
This privacy policy explains our privacy practices for Positive Impact Technologies’ websites pi2.Life, pi2Life.com and mobile applications (together referred to as the "Platform"), Pattern by pi2Life, pi2Life’s public Application Programme Interface (the “API”), and our other services provided by Positive Impact Technologies LLC, Chemin de Montelly 48, 1007 Lausanne, Switzerland ("pi2Life," together with "we", "us", and "our") and covers our processing activities as a data controller. We'll refer to the Platform, the Apps, Pattern by pi2Life, the API, and our other services as the "Services". This policy does not apply to the practices of third parties (including other Users who sell using the Services or API users) who may also collect or receive data in connection with your use of the Services.
The following are some definitions of terms that we use in this policy:
"Personal data" means any information which relates to a living, identifiable person. It can include names, addresses, telephone numbers, email addresses, date of birth, log files, browser information, IP address, user-provided content and any other information relating to that person or combination of information which, if put together, means that the person can be identified.
"Processing" covers all activities relating to the use of personal data by an organisation, from its collection through to its storage and disposal and everything in between. pi2Life’s use of your Personal data complies with the principles of the Swiss Federal Data Protection Act and the EU General Data Protection Regulation with regard to:
Lawfulness, fairness and transparency
Purpose limitation
Data Minimization
Accuracy
Storage Limitation
Integrity and confidentiality
1.1 Accepting the Privacy Policy
We need to process your personal information to run our business and provide you with the Services. By accepting our Terms of Service, you are confirming that you have read and understood this policy, including how and why we use your information. If you don’t want us to collect or process your personal information in the ways described in this policy, you shouldn’t use the Services. We are not responsible for the content or the privacy policies or practices of any of our Users, websites hosted by pi2Life, third-party websites, or third-party apps.
pi2Life’s Terms of Service require all account owners to be at least 18 years of age. Minors under 18 years of age and at least 13 years of age are permitted to use pi2Life's Services only if they have the appropriate permission and direct supervision by the owner of the account. Children under age 13 are not permitted to use pi2Life or the Services. You are responsible for any and all account activity conducted by a minor on your account.
By using the Services, you acknowledge that pi2Life will use your information in each country where pi2Life operates. Please be aware that the privacy laws and standards in certain countries, including the rights of authorities to access your personal information, may differ from those that apply in the country in which you reside. We will transfer personal information only to those countries to which we are permitted by law to transfer personal information, and we will take steps to ensure that your personal information continues to enjoy appropriate protections.
1.2 Information Collected or Received
In the course of providing our Services, we collect or receive your personal information in a few different ways. Often, you choose what information to provide, but sometimes we require certain information for you to use and for us to provide you the Services.
1.2.1 Registration, Account Setup, Service Usage
In order to use the Services, you need to provide us with a valid email address, and for Services that require registration, a name associated with your account that you can choose to represent your identity (first name at least) on pi2Life. You may review or change that name through your account settings. You need to provide this information to enable us to provide you with the Services. Depending on which services you choose to use, additional information, such as a company name, address, telephone number may be necessary in order for us to provide a particular service. You are not required to provide us with this information to sign up, but we will need it to provide certain services. Platform in order to use certain products or services on pi2Life, you may be required to complete an application; information that you submit through the application processes will not be displayed publicly and will only be used internally by pi2Life, unless otherwise specified.
1.2.2 Profile
You may be asked to provide your name and other personal information (such as gender, location) in connection with your account and activity. You can edit or remove this information through your account settings.
1.2.3 Confidential Information
You shall pay extra attention prior to sharing any information (for example password) that you may regard as confidential with other Users on the Platform or posting it on the Platform.
Similarly, do not post other User’s confidential information without their prior written consent.
In either case, pi2Life will not be responsible if your confidential information is either disclosed or compromised on our Platform.
1.2.4 Automated Information
pi2Life automatically receives and records information from your browser or your mobile device when you visit the Platform or use the Apps or use certain other Services, such as your IP address or unique device identifier, cookies, and data about which pages you visit in order to allow us to operate and provide the Services. This information is stored in log files and is collected automatically. We may combine this information from your browser or your mobile device with other information that we or our partners collect about you, including across devices. This information is used to prevent fraud and to keep the Services secure, to analyse and understand how the Services work for Users, and to provide advertising, including across your devices, and a more personalised experience for Users.
We may also automatically collect device-specific information when you install, access, or use our Services. This information may include information such as the hardware model, operating system information, app version, app usage and debugging information, browser information, IP address, and device identifiers. For more information about these online tools and how we use them, see our Cookies & Similar Technologies Policy and “Information Uses, Sharing & Disclosure” section below.
1.2.5 Location Information
We may collect information about your use of the Services for advertising, for analytics, to serve content and to protect the Services. This may include your IP address, browser information (including referrers), device information (such as iOS IDFA, IDFV for limited non-advertising purposes, Android AAID, and, when enabled by you, location information provided by your device). When you use the Platform, your geolocation details will be read by pi2Life Platform in order to use functions like our local shop finder.
We may obtain location information you provide in your profile or your IP address. With your consent, we may also determine location by using other information from your device, such as precise location information from GPS or information about wireless networks or cell towers near your mobile device. We may use and store information about your location to provide features and to improve and customise the Services, for example, for pi2Life’s internal analytics and performance monitoring; localisation, regional requirements, and policies for the Services; for local content, search results, and recommendations; for shipping and mapping services; and (using non-precise location information) marketing. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you may revoke your consent to the sharing of that information through the settings on the Apps or on your mobile device. Certain non-precise location services, such as for security and localised policies based on your IP address or submitted address, are critical for the Platform to function. We will only share your geolocation details with third parties (like our mapping, payments, or, to the extent applicable, advertising providers) in order to provide you with the Services. You may also choose to enable the Apps to access your mobile device’s camera to upload photographs to pi2Life.
1.2.6 Analytics Information
We use data analytics to ensure Platform functionality and improve the Services. We use mobile analytics software to allow us to understand the functionality of the Apps on your phone. This software may record information such as how often you use the Apps, what happens within the Apps, aggregated usage, performance data, app errors and debugging information, and where the Apps were downloaded from. We do not link the information we store within the analytics software to any personally identifiable information that you submit within the mobile application.
1.2.7 Information from Third Parties
Some Users may choose to connect to pi2Life or register a pi2Life account using an external third-party application, such as Facebook, or an app developed using the pi2Life API. pi2Life may receive information from those connected third-party applications. Connecting your pi2Life account to third-party applications or services is optional. If you choose to connect your account to a third-party application, pi2Life may receive information from that application. We may also collect public information in order to connect with you. We may use that information as part of providing the Services to you. You can also choose to share some of your activity on pi2Life on certain social media networks which are connected to your pi2Life account, and you can revoke your permission anytime in your account settings.
1.3 Platform Choice & Control
We know that Users of our community value having control over their own information, so pi2Life gives you the choice of providing, editing or removing certain information, as well as choices about how we contact you. You may change or correct your pi2Life account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. You can also request the deletion of the personal information in your account.
Depending on your location, you may also have certain additional rights with respect to your information, such as: (i) data access and portability (including the right to obtain a copy of your personal data you provided to pi2Life, via your settings); (ii) data correction (including the ability to update your personal data, in many cases via settings); (iii) data deletion (including the right to have pi2Life delete your personal information, except information we are required to retain, by contacting us); and (iv) withdrawal of consent or objection to processing (including, in limited circumstances, the right to ask pi2Life to stop processing your personal data, with some exceptions, by contacting us).
You may also control the receipt of certain types of communications from pi2Life in your account settings. pi2Life may send you messages about the Services or your activity. Some of these messages are required, service-related messages for Users (such as transactional messages or legal notices). Other messages are not required, such as newsletters. You can control which optional messages you choose to receive by changing your account settings, and you can learn more in the “Messages from pi2Life” section of this policy.
We partner with third parties to manage our advertising on other sites. Our third-party partners may use cookies or similar technologies in order to provide you with advertising based upon your browsing activities and interests. If you have chosen to connect your account to an external third-party application, such as Facebook, or an app developed using the API, you can change your settings and remove permission for the app by changing your account settings.
If you no longer wish to use the Services or receive service-related messages (except for legally required notices), then you may close your account.
Many changes that you make to your account settings are updated immediately, but some may take a few days to take effect, particularly those that impact email or marketing preferences. Some major requests, such as changes to account data deletion, may require verification of identity before they can be processed.
1.4 Messages from pi2Life
On occasion, pi2Life may need to contact you. Primarily, these messages are delivered by email or by push notifications for a variety of reasons, including marketing, transactions and service update purposes. If you no longer wish to receive push notifications, you can disable them at device level. You can opt out of receiving marketing communications via email in your account settings or by following the unsubscribe link in any marketing email you receive. To ensure you properly receive notifications, we will need to collect certain information about your device, such as operating system and user identification information. Every account is required to keep a valid email address on file to receive messages. pi2Life may also contact you by telephone to provide User support or for transaction-related purposes if you request that we call you.
Some messages from pi2Life are service-related and necessary for Users. You agree that pi2Life can send you non-marketing emails or messages, such as those related to transactions, your account, security, or product changes. Examples of service-related messages include an email address confirmation/welcome email when you register your account, notification of an order, service availability, modification of key features or functions, relaying Conversations with buyers, and correspondence with pi2Life’s Support team.
When you register for an account, subscribe to a newsletter, or provide us with your email address or phone number you receive notice of and agree to receive marketing emails and messages from us. You can unsubscribe at any time from marketing emails through the opt-out link included in marketing emails or messages. Users may also control which marketing emails or messages they receive from pi2Life through their account settings. Please note that some changes to your account settings may take a few days to take effect.
If someone in your contact list is not already a User, you may invite them to join pi2Life, and an email will be sent to them on your behalf. Recipients of email invitations may opt out of receiving future invitations by following instructions in the email invitation message. You may send an invitation only to someone who has given you consent to receive one.
1.5 Information Uses, Sharing, & Disclosure
When you access or use the Services, we collect, use, share, and otherwise process your personal information as described in this policy. We rely on a number of legal bases to use your information in these ways. These legal bases include where:
Necessary to perform the contractual obligations in our Terms of Service and in order to provide the Services to you;
You have consented to the processing, which you can revoke at any time;
Necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims;
Necessary for the purposes of our or a third party’s legitimate interests, such as those of Users, or partners;
You have expressly made the information public;
Necessary in the public interest; and
Occasionally necessary to protect your vital interests or those of others.
Note that we principally rely on consent to send marketing messages, for third-party data sharing related to advertising, and, to the extent applicable, (iii) for the use of location data for advertising purposes. We rely on consent for targeted online and offline marketing. We or our Users may advertise our Services or our User’s Vegan products and services through a variety of different mediums and rely on your consent to do so off our-Platform. As part of this, we may work with advertising partners.
Where we process your information on the basis of legitimate interests, we do so as follows:
1.5.1 Providing and Improving our Services:
We may use your information to improve and customise our Services, including sharing of your information for such purposes, and we do so as it is necessary to pursue our legitimate interests of improving our Services for our users. This is also necessary to enable us to pursue our legitimate interests in understanding how our Services are being used, and to explore and unlock ways to develop and grow our business. It is also necessary to allow us to pursue our legitimate interests in improving our Services, efficiency, interest in Services for users, and obtaining insights into usage patterns of our Services.
1.5.2 Keeping our Services Safe and Secure
We may also use your information for safety and security purposes, including sharing of your information for such purposes, and we do so because it is necessary to pursue our legitimate interests in ensuring the security of our Services. This includes enhancing protection of our community against spam, harassment, intellectual property infringement, crime, and security risks of all kind.
We respect your privacy. pi2Life will not disclose your name, email address or other personal information to third parties without your consent, except as specified in this policy.
We use your information to provide and improve the Services and our products, for billing and payments, for identification and authentication, and for general research and aggregate reporting. We may use information you provide to resolve disputes with pi2Life or other Users. We may learn the sorts of products that you’re interested in from your browsing and posts on the Platform or Apps and suggest potential purchases as a result. As a core part of our Services, we have a legitimate interest in customising your on-Platform experience to help you search for and discover relevant items and recommended purchases, including using this information to help Businesses find the best ways to market and promote their products on pi2Life. You may control your privacy settings through the opt-out buttons in your account settings privacy tab. Please note that some changes to your privacy settings may take a few days to take effect. We or our Business users may advertise our Services or our Business user’s products and services through a variety of different mediums and rely on your consent to do so off-Platform. As part of this, we may use analytics aggregated from usage information including, for example, search keywords, favourites, browsing history and purchase history. In addition to consent as noted above, we also rely on our legitimate interest to send you marketing messages and for pi2Life's advertising programs.
1.5.3 Legal and Safety
pi2Life may also retain, preserve, or release your personal information to a third party in the following limited circumstances: in response to lawful requests by public authorities, including to meet legitimate national security or law enforcement requirements; to protect, establish, or exercise our legal rights or defend against legal claims, including to collect a debt; to comply with a subpoena, court order, legal process, or other legal requirement; or when we believe in good faith that such disclosure is reasonably necessary to comply with the law, prevent imminent physical harm or financial loss, or investigate, prevent, or take action regarding illegal activities, suspected fraud, threats to our property, or violations of pi2Life's Terms of Service. In these cases, our use of your information may be necessary for the purposes of our or a third party’s legitimate interest in keeping our Services secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage. Such use may also be necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims. It may also be necessary in the public interest (such as to prevent crime) or to protect vital interests (in rare cases where we may need to share information to prevent loss of life or personal injury).
If pi2Life receives a lawful, verified request for a User’s records or information in one of the limited circumstances described in the previous paragraph, pi2Life may disclose personal information, which may include, but may not be limited to, a User’s name, address, phone number, email address, and company name.
1.5.4 Affiliated Businesses
pi2Life is affiliated with a variety of businesses and works closely with them for a variety of purposes, including assisting us to perform and improve the Services. These businesses may sell items or services to you through the Services or, with your consent, offer promotions (including email promotions) to you. pi2Life may also provide services or sell products jointly with affiliated businesses, including providing information to such partners to allow them to more effectively market to you. We rely on consent (which can be withdrawn at any time) to send marketing messages and for third-party sharing relating to advertising.
1.5.5 Aggregated Information
pi2Life may share demographic information with partners, but it will be aggregated and de-personalised so that personal information is not revealed.
1.5.6 Service Providers
pi2Life also needs to engage third-party companies and individuals (such as payment processors, research companies, and analytics and security providers) to help us operate, provide, and market the Services. These third parties have only limited access to your information, may use your information only to perform these tasks on our behalf, and are obligated not to disclose or use your information for other purposes. Our engagement of service providers is often necessary for us to provide these Services to you, particularly where such companies play important roles in helping us keep our Service operating and secure. In some other cases, these service providers aren’t strictly necessary for us to provide the Services, but help us make it better, like by helping us conduct research into how we could better serve our users. In these latter cases, we have a legitimate interest in working with service providers to make our Services better.
1.5.7 Business Reorganisation
In some cases, pi2Life may choose to buy or sell assets. Such transactions may be necessary and in our legitimate interests, particularly our interest in making decisions that enable our business to develop over the long term. In these types of transactions (such as a sale, merger, liquidation, receivership, or transfer of all or substantially all of pi2Life’s assets), User information is typically one of the business assets that is transferred. If pi2Life intends to transfer information about you, pi2Life will notify you by email or by putting a prominent notice on the Platform and the App, and you will be afforded an opportunity to opt out before information about you becomes subject to a different privacy policy.
1.5.8 Third Parties
Third-party plug-ins also may collect information about your use of the Platform. For example, when you load a page on pi2Life that has a social plug-in from a third-party site or service, such as a “Like” or “Send” button, you are also loading content from that third-party site. That Platform may request cookies directly from your browser. These interactions are subject to the privacy policy of the third-party site. In addition, certain cookies and other similar technologies on the Platform are used by third parties for targeted online marketing and other purposes. These technologies allow a partner to recognise your computer or mobile device each time you use the Services. Please be aware that when you use third-party sites or services, their own terms and privacy policies will govern your use of those sites or services. pi2Life chooses and manages these third-party technologies placed on its Sites and Apps. However, these are third-party technologies, and they are subject to that third party's privacy policy. For more information, see our Cookies & Similar Technologies Policy. We rely on your consent to drop and read non-technically necessary cookies.
We can speak only for ourselves; this policy does not apply to the practices of third parties (such as other Users who sell using the Services or API users) that pi2Life does not own or control or individuals that pi2Life does not employ or manage. If you provide your information to such third parties in connection with your use of the Services, different practices may apply to the use or disclosure of the information that you provide to them. While pi2Life requires these third parties to follow pi2Life’s privacy and security requirements, pi2Life does not control the privacy or security policies of such third parties. To the full extent applicable in your jurisdiction, pi2Life is not responsible for the privacy or security practices of these third parties, API users, or other websites on the internet, even those linked to or from the Services. We encourage you to read the privacy policies and ask questions of third parties before you disclose your personal information to them. For the purposes of European law, these sellers and API users are independent controllers of data, which means that they are responsible for providing and complying with their own policies relating to any personal information they obtain in connection with the Services.
1.6 Transfers
pi2Life operates a global service.
Each country has different laws. When your information is moved from your home country to another country, the laws and rules that protect your personal information in the country to which your information is transferred may be different from those in the country in which you live. For example, the circumstances in which law enforcement can access personal information may vary from country to country.
1.6.1 Necessary for the Performance of the Contract between pi2Life and its Users
pi2Life provides a voluntary service; you can choose whether or not you want to use the Services. However, if you want to use the Services, you need to agree to our Terms of Service, which set out the contract between pi2Life and its Users. As we operate in countries worldwide (including in the US) and use technical infrastructure in the EU to provide you with the Services, we are not able to perform our contract with you without moving your personal data around the world. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside Switzerland and the EEA.
1.7 Security
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and after it is received. Your account information is protected by a password. It is important that you protect against unauthorised access to your account and information by choosing your password carefully and by keeping your password and computer secure, such as by signing out after using the Services.
pi2Life encrypts certain information using secure socket layer technology (SSL). pi2Life follows generally accepted industry standards to protect the personal information submitted to us, both during transmission and after it is received. Unfortunately, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, while we strive to protect your personal information, we can't guarantee its absolute security. pi2Life offers full-Platform SSL, and sign in history and notifications; you can view more information in your account settings.
1.8 Retention
pi2Life will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your pi2Life User account), as described in this policy, or as needed to provide the Services to you. If you no longer want pi2Life to use your information to provide the Services to you, you may close your account. pi2Life will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. In addition, pi2Life Businesses may also be required to retain and use your information in order to comply with their own legal obligations. Please note that closing your account may not free up your email address, username, or business name (if any) for reuse on a new account. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for Platform safety and security, to improve Platform functionality, or we are legally obligated to retain them for longer time periods.
1.9 Your Rights
You may benefit from a number of rights in relation to your information that we process. Some rights apply only in certain limited cases, depending on your location. If you would like to manage, change, limit, or delete your personal information, you can do so via your pi2Life account settings or by contacting us. Upon request, pi2Life will provide you with information about whether we hold any of your personal information. By visiting your account settings, you can access, correct, change, and delete certain personal information associated with your account. In certain cases where we process your information, you may also have a right to restrict or limit the ways in which we use your personal information. In certain circumstances, you also have the right to request the deletion of your personal information, and to obtain a copy of your personal information in an easily accessible format. Please ensure you've read the options you have under the "Choice & Control" section above. If you need further assistance, you can contact pi2Life through one of the channels listed below under “Contact”. We will respond to your request within a reasonable timeframe.
If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can always object using the unsubscribe link in such communications or changing your account settings. Please note that some changes to your account settings may take a few days to take effect.
1.10 Your Responsibilities
You are responsible for protecting user personal information you receive or process and complying with all relevant legal requirements when you use the Services. This includes applicable data protection and privacy laws that govern the ways in which you can use a user’s information. Such laws may require that you post, and comply with, your own privacy policy, which must be accessible to pi2Life users you interact with and compatible with this policy and pi2Life’s Terms of Service. For more information on the General Data Protection Regulation, see more resources at https://gdpr-info.eu/ and https://www.dataprotection.ie/.
As a data controller, to the extent that you process user personal information outside of the Services, you may be required under applicable data protection and privacy laws to honour requests received from such users for data access, portability, correction, deletion and objections to processing. Also, if you disclose personal information without the buyer’s proper consent, you are responsible for that unauthorised disclosure. This includes, for example, disclosures you make or unintentional data breaches. For example, you may receive a buyer’s email address or other information as a result of entering into a transaction with that buyer. This information may only be used for pi2Life-related communications or for pi2Life-facilitated transactions. You may not use this information for unsolicited commercial messages or unauthorised transactions. Without the buyer’s consent, and subject to other applicable pi2Life policies and laws, you may not add any pi2Life User to your email or physical mailing list, use that buyer’s identity for marketing. Please bear in mind that you're responsible for knowing the standard of consent required in any given instance.
1.11 Withdrawing Consent
You can choose to withdraw your consent to our processing of your information and your use of the Services at any time by permanently closing and deleting your account through the Privacy tab of your account settings. If your account does not have any open issues such as unresolved cases, or policy violations, you will receive an email with instructions to confirm your deletion request. This process may take up to approximately two weeks after which your account will be deleted to the extent permitted. Depending on which of our Services you've used (such as whether you've made purchases or sales on pi2Life), we may be required to retain certain information for legal, regulatory, security, or compliance reasons for a limited period of time, after which it will be deleted. This deletion is permanent, and your account can't be reinstated.
1.12 Privacy Policy Changes
We may amend or update this policy from time to time. If we believe that the changes are material, we’ll let you know by doing one (or more) of the following: (i) posting the changes on or through the Services, (ii) sending you an email or message about the changes, or (iii) posting an update in the version notes on the Apps’ Platform. We encourage you to check back regularly and review any updates.