Privacy Policy
PRIVACY POLICY
Last Updated: October 18, 2021
Prior version of the Privacy Policy available here.
This Privacy Policy (“Privacy Policy”) describes how Riot Accessories LTD and our subsidiaries and affiliates (collectively, “Pony-O,” “us,” “we,” or “our”) collect, use and share your personal information in connection with our website at www.ponyo.com and any other websites we operate that link to this Privacy Policy (collectively, the “Site”), our social media profiles, our email communications, and our related products, sales, marketing, or events (collectively, the “Platform”), and the choices that you have with respect to your personal information.
We reserve the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the top of this Privacy Policy. Your continued use of the Platform following posting of changes constitutes your acceptance of such changes.
Categories |
Examples |
A. Individual Identifiers and Demographic Information |
Contact information, such as your name, address, phone number, and email address. Demographic information, such as general location information like city, state and geographic area. |
B. Commercial Information |
Payment information, such as your payment card number, billing address, and other payment details. We use third party payment providers to process payments on our behalf. Communications, such as email messages, phone calls, social media interactions, and other communications with us. Preferences, such as your preferences for receiving marketing and other communications and your product interests. |
C. Internet or Network Activity |
Device information, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state or geographic area. Online activity information, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access. |
D. Inferences Drawn from Personal Information |
Profiles reflecting your preferences and other characteristics, such as inferences regarding the type of products you like to purchase. |
We may also collect other personal information that is not specifically listed here, which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.
Unless we specifically request it, we ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services, or otherwise to us.
- Personal Information You Provide. We collect personal information when you voluntarily submit it to us. For example, we may collect or receive personal information when you make a purchase on the Platform, sign up to receive our newsletters and emails, participate in our promotions, contests, or surveys, submit a request to our customer service team, interact with us on social media, or otherwise.
- Automatically Collected Personal Information. We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your activity over time on our Platform and other sites and online services, including the device information and the online activity information described in the table above. Like many online services, the Platform uses cookies and similar technologies to facilitate automatic data collection, such as:
- Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising. For more information, please visit our Cookie Policy.
- Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
- Personal Information Obtained from Third Parties. We may also receive personal information about you from other third party sources. For example, we may receive personal information from our business and advertising partners, event sponsors, joint marketing partners, affiliates and related companies, and social media sites. We may also receive personal information from any third-party platforms or services that you connect with our Platform when completing your order or otherwise, so that we can complete your order or provide you with other feature, products, or services that you request.
We may use your personal information for various purposes, including the uses below and as otherwise described in this Privacy Policy or at the time of collection:
- provide you with the products, content, features, and services that you request;
- process your transactions and orders;
- communicate with you about the Platform and your orders (including by sending announcements, updates, security alerts, and support and administrative messages);
- understand your interests, personalize your experience on the Platform, and deliver information about products and services relevant to your interests; and
- respond to your inquiries and requests for customer support, including to investigate and address your concerns and monitor and improve our responses.
In addition to the specific situations discussed elsewhere in this Privacy Policy or as otherwise described at the time of collection, we may share your personal information with the following categories of recipients:
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information.
You can make the following choices with respect to your personal information.
Pony-O is headquartered in the United States of America. If you are from a country outside of the United States of America with laws governing data collection, use, and disclosure that may differ from U.S. law and you provide personal information to us, please note that any personal information that you provide to us may be transferred to the United States of America. By providing your personal information, where applicable law permits, you hereby specifically and expressly consent to such transfer and processing and the collection, use, and disclosure set forth herein or in any applicable terms of service.
Our Platform may contain links to websites, mobile applications or other online services operated by third parties. When you click on a link to any other website, mobile application or online service, you will leave our Platform and go to another site, and another entity may collect personal information or anonymous data from you. In addition, our content may be included on other online services that are not associated with us. We have no control over, do not review, and are not responsible for, these third party online services or for their content or actions. Other online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of other online services that you visit or use. The links to third party online services are for your convenience and do not signify our endorsement of, or affiliation with, any third party or its services.
Our Platform is not intended for use by minors under the age of 16. If we learn that we have collected personal information of a minor under 16 without the consent of the child’s parent or guardian as required by law, we will delete it as soon as possible. If you believe that we might have any personal information collected online from a minor under 16, please contact us at support@ponyo.com.
This section applies only to California residents. It describes how we collect, use and share personal information of California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“CCPA”), and their rights with respect to their personal information. For purposes of this section, “personal information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In some cases we may provide a different privacy notice to certain categories of California residents, in which case that notice will apply instead of this section.
- the categories of personal information we may have collected about you in the preceding 12 months in the section above called “Personal Information We Collect”;
- the categories of sources from which we collect your personal information in the section above called “Sources of Personal Information”;
- the business and commercial purposes for which we collect this information in the section above called “Use of Personal Information”; and
- the categories of third parties to whom we disclose this information in the section above called “Sharing of Personal Information”.
Pony-O must also disclose whether the following categories of personal information are disclosed for a “business purpose” or “valuable consideration” as those terms are defined under the CCPA. The CCPA also calls this latter category a “sale.” Note that while a category below may be marked, that does not necessarily mean that we have personal information in that category about you.
In the preceding twelve months, we have disclosed the following categories of personal information in the manner described:
Category |
Personal Information is Disclosed for a Business Purpose |
Personal Information is Disclosed for Valuable Consideration |
A. Individual Identifiers and Demographic Information |
Yes |
Yes |
B. Commercial Information |
Yes |
No |
C. Internet or Network Activity |
Yes |
Yes |
D. Inferences Drawn from Personal Information |
Yes |
No |
- Right to Access. You have the right to request that Pony-O disclose certain information to you about our collection and use of your personal information over the past 12 months, including:
- The categories of personal information we collected about you.
- The categories of sources of the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- Right to Erase/Delete. You have the right to request that Pony-O delete any of your personal information that we collected from you and retained, subject to certain exceptions.
- Right to Opt-Out of Sales. If we “sell” your personal information, you can opt-out.
- Right to Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form or legally prohibited increases in the price or decreases in the quality of our products and services.
Please note, these rights are not absolute and in some cases we may not be able to respond your request, such as when a legal exemption applies or if we are not able to verify your identity.
- Access and Deletion Rights. To exercise the access and deletion rights described above, please submit a request to us and provide the information we request that is required to verify your request by:
- Emailing us at support@ponyo.com, or
- Riot Accessories Ltd., 25587 Conifer Road, Unit 105-234, Conifer, CO 80433
- Right to Opt-Out of the “Sale” of Personal Information. Under California law, some of the data we share with our advertising partners may qualify as a “sale” as defined under the CCPA. To exercise your right to opt-out of such “sale”, please:
- Email us at support@ponyo.com
When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
You may also designate an authorized agent to make a request on your behalf. If you do so, we may require the requester’s proof of identification, the authorized agent’s proof of identification, and any other information that we may request in order to verify your request, including evidence of valid permission for the authorized agent to act on your behalf.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.
We try to respond to all legitimate requests within 45 days of your request. Occasionally it may take us longer than 45 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.
The information provided in this section applies only to individuals in the European Union, the European Economic Area, and the United Kingdom (collectively, “Europe”). Except as otherwise specified, references to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Processing Purpose (as described above in the “Use of Personal Information” section) |
Legal Basis |
To Provide the Platform and Our Products and Services |
Processing is necessary to perform the contract governing our operation of the Platform or our products and services, or to take steps that you request prior to purchasing our products or engaging our services. Where we cannot process your personal data as required to provide the Platform, our products, and our services on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the products or services you access and/or request. |
For Research and Development |
Processing is based on our legitimate interests in performing research and development as described in this Privacy Policy. |
For Marketing and Promotional Communications |
Processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business and showing you tailored relevant content. |
Advertising |
Processing is based on your consent where that consent is required by applicable law. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Platform. |
To Comply with Laws and Regulations |
Processing is necessary to comply with our legal obligations. |
For Compliance, Fraud Prevention, and Safety |
Processing is necessary to comply with our legal obligations or based on our legitimate interests in protecting our or others’ rights, privacy, safety, or property. |
With Your Consent |
Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consented or in the Platform. |
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 your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by contacting us using the information provided below. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
You may contact us via email at support@ponyo.com or by writing to us at the address below:
Riot Accessories LTD
Attn: Privacy
Riot Accessories Ltd.
25587 Conifer Road
Unit 105-234
Conifer, CO 80433