Pole
Position
Privacy
Policy
Scope of this Privacy Policy
IndyWork, Inc. (“Pole Position,” “we,” “our,” and/or “us”) values the privacy of individuals
who use our application, websites, and related services (collectively, our
“
Sites
,” “Pole Position
Platform,” “
Platform
”). This privacy policy (the “
Privacy Policy
”)
explains how we collect, use, and
share information from Pole Position users (“Users”), comprised of both of any dancer using
the service (“Dancers,” “you”) and Adult Entertainment Establishments (“Clubs”). Beyond the
Privacy Policy, your use of Pole Position is also subject to our Terms of Service.
Information we Collect.
A.
Information
You
Provide
to
Us
Registration Information. When you sign up for a Pole Position account, you give us your name,
email address, and phone number. If you decide to sign up for Pole Position using your
Facebook account, we will also get basic information from your Facebook profile, like your
name, gender, profile photo, and Facebook friends.
User Profile Information. When you join the Pole Position community, you will create a Pole
Position Profile (“Profile”) to provide information essential to requesting a booking
(“Booking”) with a Club. Filling out a profile is required; however, the level of information
required will vary from Club to Club. Your name and photos are always part of your Profile and
are required in order to use the Services provided by Pole Position. Read more below about how
you can control who sees your Profile.
User Generated Information. When you join the Pole Position Lightning Feed, we may collect
the content that you create or upload to the Platform, such as photographs, comments, and
videos (“User Generated Content” or “UGC”) and the associated metadata (such as when,
where, and by whom the content was created). Even if you are not a user, information about
you may appear in content created or published by users on the Platform. We may also collect
User Content through pre-loading at the time of creation, import, or upload, regardless of
whether you choose to save or upload that User Content, for example, to enable you to
publish images and videos faster and optimize your user experience. We also collect content
(such as text, images, and video) from your device's clipboard if you choose to copy and paste
content to or from the Platform or share content between it and a third-party platform.
We have implemented a robust, effective, and ongoing moderation of our UGC.
As part of our policies, we do not allow you to promote sexual content or profanity, including
pornography, or any content or services intended to be sexually gratifying. You are not
allowed to promote or solicit a sexual act in exchange for compensation. We do not allow
UGC that contains or promotes content associated with sexually predatory behavior or
distributes non-consensual sexual content. We do not allow content that contains nudity.
Please know that we conduct UGC moderation as is reasonable and consistent with the type
of UGC hosted by Pole Position. This includes providing an in-app system for reporting and
blocking objectionable UGC and users, and we take action against UGC or users where
appropriate. In addition, we provide in-app functionality for blocking users.
Incidental Sexual Content. Some of the content in Pole Position could be considered
“incidental” sexual content. If any content could be deemed to meet this definition, be
advised that Pole Position (1) provides access to primarily non-sexual content, and (2) does
not actively promote or recommend sexual content.
Surveys, Research, and Promotions. We may collect information that you share through
surveys or your participation in challenges, research, promotions, marketing campaigns,
events, or contests.
Payment Method. When you add a credit card or payment method to your Pole Position
account, a third party that handles payments for us will receive your card information. We do
not store full credit card information on our servers to keep your financial data secure.
Communications. If you contact us directly, we may receive additional information about you.
For example, when you contact Pole Position, we will receive your name, email address,
phone number, the contents of a message or attachments that you may send to us, and other
information you choose to provide.
B.
Information
We
Collect
When
You
Use
the
Pole
Position
Platform
Location Information. Pole Position is about connecting Dancers and Clubs by location. To do
this, we need to know where you are. When you open Pole Position on your mobile device, we
receive your location. We may also collect the precise location of your device when the app
is running in the foreground or background. If you label certain locations, such as “home” and
“work,” we receive that information, too.
Your location information is necessary for things like matching you with nearby Clubs,
determining proximity and preferences, and suggesting Clubs based on previous Bookings.
Also, if the need ever arises, our team may use and share location information to help protect
the safety of Pole Position Users or a member of the public. In addition to the reasons
described above, if you give us permission through your device settings or the Pole Position
app, we may collect your location while the app is off to identify promotions or service
updates in your area.
Transfer of Location Information. The information we collect may be stored and processed in
your region, the United States, or any other country where we or our affiliates, subsidiaries,
or service providers maintain facilities. The processing locations are chosen in order to operate
efficiently, improve performance, and create redundancies in order to protect information in
the event of an outage or other problem. We take steps designed to ensure that the
information we collect under this statement is processed according to the provisions of this
statement and applicable law wherever the information is located.
Device Information. Pole Position receives information from Users’ devices, including IP
address, web browser type, mobile operating system version, phone carrier and
manufacturer, application installations, device identifiers, mobile advertising identifiers, push
notification tokens, and, if you register with your Facebook account, your Facebook identifier.
Usage Information. To help us understand how you use the Pole Position Platform and to help
us improve it, we automatically receive information about your interactions with the Pole
Position Platform, like the pages or other content you view, your actions within the Pole
Position app, and the dates and times of your visits.
Text Information. We work with a third-party partner to facilitate communication between
Dancers and Clubs who have been connected for a Booking. We receive information about
these communications, including but not limited to the content and duration. For security
purposes, we may also monitor and/or record the contents of messages sent on the Pole
Position Platform, such as those between Dancers and Clubs.
User Feedback. At Pole Position, we want to make sure Users are enjoying the experience. We
have a comment section to provide us with your feedback.
Information from Cookies and Similar Technologies. We collect information through the use of
“cookies,” tracking pixels, and similar technologies to understand how you navigate through
the Pole Position Platform and interact with Pole Position advertisements, to learn what
content is popular, and to save your preferences. Cookies are small text files that web servers
place on your device; they are designed to store basic information and to help websites and
apps recognize your browser. We may use both session cookies and persistent cookies. A
session cookie disappears after you close your browser. A persistent cookie remains after you
close your browser and may be accessed every time you use the Pole Position Platform. You
should consult your web browser(s) to modify your cookie settings. Please note that if you
delete or choose not to accept cookies from us, you may be missing out on certain features of
the Pole Position Platform.
C.
Information
We
Collect
from
Third
Parties
Third Party Services. If you choose to register for Pole Position or otherwise link your Pole
Position account with a third party’s service (such as Facebook), we may receive the same
type of information we collect from you (described above) directly from those services.
Third Party Partners. We may receive additional information about you, such as demographic
data, payment information, or fraud detection information, from third party partners and
combine it with other information that we have about you.
No Background Information on Dancers or Clubs. Pole Position does not work with third party
providers to perform background checks for either Dancers or Clubs. It is up to the discretion
of either party to conduct these checks, and we encourage discretion when evaluating
Bookings.
How We Use the Information We Collect
We use the information we collect from all Users to:
•
Connect Dancers with Clubs;
•
Provide, improve, expand, and promote the Pole Position Platform;
•
Analyze how the Pole Position community uses the Pole Position Platform;
•
Communicate with you, either directly or through one of our partners, including for
marketing and promotional purposes;
•
Personalize the Pole Position experience for you;
•
Send you push notifications;
•
Facilitate communication; and
•
Provide you with customer support regarding Bookings.
How We Share the Information We Collect
A.
Sharing
Between
Users
Sharing between Dancers and Clubs. Dancers and Clubs that confirm a Booking are able to see basic
information about each other, such as names, photos, ratings, and any information they have
added to their Profiles. Dancers see the club location that the Club has provided.
Although we help Dancers and Clubs communicate with one another to request a Booking, we
do not share your actual phone number or other contact information with other Users. If you
report a lost or found item to us, we will seek to connect you with the relevant Club or Dancer,
including sharing actual contact information with your permission.
B.
Sharing
Between
Pole
Position
and
Third
Parties
API and Integration Partners. If you connect to the Pole Position Platform through an
integration with a third-party service, we may share information about your use of the Pole
Position Platform with that third party. We may share your information with our third-party
partners in order to receive additional information about you. We may also share your
information with third party partners to create offers that may be of interest to you.
Third Party Services. The Pole Position Platform may allow you to connect with other
websites, products, or services that we do not have control over (for example, we may give you
the ability to order clothing or accessories from a boutique from within the Pole Position app).
If you use these services, we will provide the third party with information about you to allow
them to provide the service to you. We cannot speak to the privacy practices of these third
parties, and we encourage you to read their privacy policies before deciding whether to use
their services. We do not retain any liability, nor do we guarantee the security of information
once it is passed on to a third-party service.
Links to Other Websites. Our Services contain links to other websites or services that are not
owned or controlled by Indywork, Inc. including links to websites of retail establishments and,
retail establishment affiliates and advertisers, and other business partners. This Policy only
applies to information collected by our Services. We have no control over these third-party
websites, and your use of third-party websites and features are subject to privacy policies
posted on those websites. We are not responsible or liable for the privacy or business
practices of any third-party websites linked to our Services. Your use of third parties' websites
linked to our Services is at your own risk, so we encourage you to read the privacy policies of
any linked third-party websites when you leave one of our Services.
Service Providers. We work with third party service providers to perform services on our behalf,
and we may share your information with such service providers to help us provide the Pole
Position Platform, including all of the things described in Section 3 above.
Other Sharing. We may share your information with third parties in the following cases:
•
While negotiating or in relation to a change of corporate control such as a
restructuring, merger, or sale of our assets;
•
If a government authority requests information and we think disclosure is required or
appropriate in order to comply with laws, regulations, or a legal process;
•
With law enforcement officials, government authorities, or third parties if we think
doing so is necessary to protect the rights, property, or safety of the Pole Position
community, Pole Position, or the public (in case of a Law Enforcement Request);
•
To comply with a legal requirement or process, including but not limited to, civil and
criminal subpoenas, court orders or other compulsory disclosures.
•
If you signed up for a promotion with another User’s referral or promotion code, with
your referrer to let them know about your redemption of or qualification for the
promotion;
•
With our insurance partners to help determine and provide relevant coverage in the
event of an incident;
•
To provide information about the use of the Pole Position Platform to potential
business partners in an aggregated or de-identified form that cannot reasonably be
used to identify you; and
•
Whenever you consent to the sharing.
Your
Choices
Email Subscriptions. You can always unsubscribe from our commercial or promotional
emails, but we will still send you transactional and relational emails about your account
use of the Pole Position Platform.
Push Notifications. You can opt out of receiving push notifications through your device
settings. Please note that opting out of receiving push notifications may impact your use
of the Pole Position Platform (such as receiving a notification that your Booking has been
approved).
Profile Information. While your name and uploaded photos will always be shared with
Clubs, you may delete any additional information that you added to your Profile at any
time if you do not want it shared with Clubs. If deleted, Clubs may request that information
in order to complete or request Bookings. Dancers will always be able to see Clubs’ names,
location, and contact information.
Location Information. While you can prevent your device from sharing location
information at any time through your Device’s operating system settings, Dancer and Club
location is core to the Pole Position Platform, and without it, we cannot provide our services
to you. If you initially consent to our collection of location information, you can
subsequently stop the collection of this information at any time by changing the
preferences on your mobile device. If you do so, certain features of our mobile applications
will no longer function. You may also stop our collection of location information by
following the standard uninstall process to remove our mobile application from your
device.
Facebook Friends. You can control whether to enable or disable the Facebook mutual
friends feature through your profile settings.
Editing and Accessing Your Information. You can review and edit certain account
information by logging in to your account settings and profile. If you would like to
terminate your Pole Position account, please contact us. If you choose to terminate your
account, we will deactivate it for you but may retain information from your account for a
certain period of time and disclose it in a manner consistent with our practices under this
Privacy Policy for accounts that are not closed. We also may retain information from your
account to collect any fees owed, resolve disputes, troubleshoot problems, analyze usage
of the Pole Position Platform, assist with any investigations, prevent fraud, comply with
our legal requirements, protect or defend our rights, enforce our contracts, enforce our
Terms of Service, or take other actions as required or permitted by law.
Other
Data Security. We are committed to protecting the data of the Pole Position community.
Even though we take reasonable precautions to protect your data, no security measures
can be 100% secure, and we cannot guarantee the security of your data. This includes, but
is not limited to, the photos and other personal information provided to us by either a
Dancer or Club.
Children’s Privacy. Pole Position is not directed to children, and we do not knowingly
collect personal information from individuals under 18. If we find out that a child under 18
has given us personal information, we will take steps to delete that information. If you
believe that a child under the age of 18 has given us personal information, please contact
us at our Help Center.
Child Endangerment. Pole Position prohibits users from creating, uploading, or distributing
content that facilitates the exploitation or abuse of children. This includes all child sexual
abuse materials. This includes but is not limited to use promoting predatory behavior
towards children, such as:
• Inappropriate interaction targeted at a child (for example, groping or caressing).
• Child grooming (for example, befriending a child online to facilitate, either online
or offline, sexual contact and/or exchanging sexual imagery with that child).
• Sexualization of a minor (for example, imagery that depicts, encourages or
promotes the sexual abuse of children or the portrayal of children in a manner
that could result in the sexual exploitation of children).
• Sextortion (for example, threatening or blackmailing a child by using real or
alleged access to a child’s intimate images).
• Trafficking of a child (for example, advertising or solicitation of a child for
commercial sexual exploitation).
We will take appropriate action, which may include reporting to the National Center for
Missing & Exploited Children, if we become aware of content with child sexual abuse
materials. If you believe a child is in danger of or has been subject to abuse, exploitation,
or trafficking, please contact your local law enforcement and contact a child safety
organization.
Changes to Our Privacy Policy. We may make changes to this Privacy Policy from time to
time. If we make any material changes, we will let you know through the Pole Position
Platform, by email, or other communication. We encourage you to read this Privacy Policy
periodically to stay up-to-date about our privacy practices. As long as you use the Pole
Position Platform, you are agreeing to this Privacy Policy and any updates we make to it.
Contact Information. Feel free to contact us at any time with any questions or comments
about this Privacy Policy, your personal information, our use and sharing practices, or your
consent choices by emailing us at info@indywork.com or by mail at
IndyWork, Inc.
11 Greenway Plaza, Suite 1515
Houston, Texas 77046
Updated: January 26, 2024
