Privacy Policy

This Privacy Policy explains how information about you is collected, used and disclosed by Picko, Inc. when you access or use our website (https://picko.one), including through our associated point-of-sale or mobile applications (the “Site”), or our online payroll, benefits, human resources, financial, and other services (collectively, the “Services”). By accessing the Site or using the Services, you agree to our collection, use and disclosure of your information as outlined in this Privacy Policy. If you access our Services through your employer or another entity (our “Customer”), please note that this data and your account are controlled by the Customer and we process this data at their direction.

1. Information We Collect and How We Collect it

When you access our Site or use the Services, we collect and store certain information about you, including “personal information.” Personal information is information that, alone or in combination with other information in our possession, could be used to personally identify you. We collect the following categories of personal information and other information as described below.

A. Information you provide

Information You Provide Directly. We may collect or receive the following categories of personal information when you, your employer, or your employer’s designated administrator or accountant access the Site, request to receive information about Gusto or its Services, create an account, verify your identity, use any of the Services, or otherwise communicate with us, including through customer support channels.

Identification Information, such as:

• Name, mailing address, email address, phone number, birthdate;
• Social Security number, Taxpayer Identification number;
• Government-issued documentation, such as drivers license or passport.

Other Information You Voluntarily Choose to Provide. We may collect information, including personal information, that you voluntarily provide to us when you:

• Participate in surveys, contests, sweepstakes, or promotions;
• Register for, attend, or participate in conferences, webinars, or events;
• Provide us feedback or comment on our blogs or social media pages;
• Submit information to us so that we can assess potential business opportunities.

B. Information collected automatically

We automatically collect certain information when you access the Site or use the Services.

Electronic & Online Identifiers (IDs), such as:

• If on a mobile device: mobile carrier, device IDs, and mobile advertising IDs;
• If using a browser: operating system, browser type, and Internet Protocol (IP) address.

Geolocation Information, such as:

• Approximate location derived from IP address (if using a browser)

Internet Activity Information, such as:

• Your “log-in” and “log-out” information;
• The pages that you visit before, after, and while using our Services;
• Pages you visit, links you click, and the content you view on the Site.

We collect information using Tracking Technologies, such as:

• Cookies, which are small text files that websites send to your computer or mobile device. This includes session cookies (which are deleted once you close your browser) and persistent cookies (which remain on your computer or device until you delete them or they expire)
• Pixel tags (also known as web beacons), which are pieces of code embedded in our Services that collect information about engagement on our Site or emails. To make it easier, we call cookies and pixel tags/web beacons “Tracking Technologies”

We use the third-party analytics tools, including:

• Google Analytics. For more information, visit Google Analytics’ Privacy Policy.

We use Tracking Technologies for the following purposes:

• When it is operationally necessary for us to provide you access to our Site or Services. This also includes tracking behavior in order to protect against irregular, fraudulent, or possibly illegal behavior on our Site or Services;
• To assess the performance of how you and others use our Site and Services (for more information, read the Analytics section below);
• To enhance the functionality of our Site or Services. This includes identifying you when you sign into our Services and keeping track of your preferences, interests, or past items viewed;
• To target our advertising to you using Tracking Technologies that we or our third-party partners place on our Site or other websites.

2. How We Use Your Information

We use information that we collect about you for the following purposes:

To develop and provide you with the Site and Services, including to:

• Operate the Site, manage accounts and provide the Services;
• Improve, personalize, and enable your use of the Site and Services;
• Develop new products and features.

To communicate with you as part of your use of Services, including to:

• Respond to requests or questions you submit to our support staff;
• Send you surveys and get your feedback about the Services;
• Otherwise contact you with Services-related notices.

To advertise and market to you, including to:

• Determine your eligibility for certain programs, events, and offers;
• Inform you of our or our partners’ products, services, features or promotions;
• Provide you with newsletters, articles, reports, and announcements;
• Develop “interest-based” or “personalized advertising,” including through cross-device tracking.

For any other purpose for which you, your employer, or your employer’s agent expressly authorize us to use your information.

3. When and with Whom We Share Your Information

We will only share your information with the categories of third parties listed below for the purposes described above in the “Use of Your Information” section, unless otherwise noted at the point of collection.

Advertising Partners that deliver advertisements about us to you, including Advertising Partners that utilize Tracking Technologies in order to deliver advertisements that are personalized to you when you visit their websites (“interest-based advertising” or “personalized advertising”).

Government agencies, including taxing authorities and their authorized collectors, in the countries in which we operate, only as necessary for us to provide you with the Services.

Other parties under the circumstances described below:

• For legal reasons, including:
• With companies that verify your identity for us and detect fraud;
• With legal and financial advisors, auditors, examiners, and certain (including potential) investors;
• With companies that may acquire us, if we are involved in a merger, acquisition, or sale of assets.

• To comply with applicable law, regulation, or legal process, including to:
• Comply with law enforcement or national security requests;
• Comply with legal process, such as a court order or subpoena (including in a country other than your home country);
• Protect your, our, or others’ rights, property, or safety;
• Enforce our policies or contracts and collect amounts owed to us;
• Assist with an investigation or prosecution of suspected or actual illegal activity.

For any other purpose and to any other person with whom you, your employer, or your employer’s agent expressly authorize us to share your information

4. Your Privacy Choices and Rights

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Other parties under the circumstances described below:

• Email and Text Messages.

You can opt out of our promotional emails by using the unsubscribe link located at the bottom of our promotional emails, contacting us as described below. You can opt out of text messages from us by replying “STOP” or contacting us as described below. If you decide to opt-out, we may still send you non-promotional communications such as your payday emails and messages about your account.

• “Do Not Track.”

Do Not Track (“DNT”) is a privacy setting you can set on some web browsers that signals to websites like ours that you don’t want your online activities to be tracked. At this time, we do not respond to DNT signals sent to us by your web browser.

• Cookies and Interest-Based Advertising.

You may stop us from sending Tracking Technologies to your browser by changing the settings on your browser. However, if you block all Tracking Technologies, our Services may not work properly. Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the following rights. To exercise these rights, please contact us as set forth below.

• Access personal information about you, including confirming whether we are processing your personal information and obtaining access to your personal information
• Request correction of your personal information where it is inaccurate or incomplete
• Request deletion of your personal information
• Request restriction of or object to our processing of your personal information
• Withdraw your consent to our processing of your personal information.

5. Important Information

Security

We employ administrative, physical and technical measures designed to protect your information from unauthorized access and to comply with applicable privacy laws in the states and countries in which we operate. Your personal information will be kept on our servers or on those of our service providers and only those employees that require it for the purposes of their duties will have access to your personal information. We have also implemented controls which require our third-party service providers and partners to have appropriate safeguards to protect your personal information However, despite these efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed to prevent any interception or other type of misuse. We also depend on you to protect your information. If you become aware of any breach of security or privacy, please notify us immediately. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

Links to Other Sites

This Privacy Policy only covers the privacy practices of Picko. It does not apply to the practices of third-party websites, services, or applications, even those who we have partnered or integrated with. Third-party services handle your information in accordance with their own practices and privacy policies. We are not responsible for their policies, practices, or handling of your information.

Changes to this Privacy Policy

Any information that we collect is subject to the Privacy Policy in effect at the time such information is collected. We may, however, modify and revise our Privacy Policy from time to time. If we make any material changes to this policy, we will notify you of such changes by posting them on the Site, informing you through the Services, or sending you an email or other notification, and we will indicate when such changes will become effective. By continuing to access or use the Site or the Services after those changes become effective, you agree to be bound by the revised policy.