PRIVACY
POLICY
Introduction
1. Information We Collect or Track.
2. How We Use Your
Data.
3. Information We
Share With Others.
4. Your California
Privacy Rights.
5. Cookies /
Tracking Technologies.
6. Links to Other Sites,
Networks, Platforms, and Apps.
7. Age
Restrictions; Children's Privacy.
8. Choice / Opt
Out.
9. Security.
10. File a
Complaint.
11. Users in the
European Union and European Economic Area.
12. Retention of Personal Data
13. Contact Us.
This Privacy Policy applies
to your use of our Sites and Services.
a.
Services.
This
Privacy Policy ("Policy") covers how Pinnacle Group ("Pinnacle",
“we”, “us”, “our”) treats personal information that it receives, tracks or
collects in connection with your use of the online websites and properties
provided by Pinnacle that link to this Policy, including the Pinnacle Supplier
Portal ("Sites") and any services provided through them
(collectively, the "Services").
Clients use our Services to locate and manage suppliers.
Suppliers use our services to try to obtain additional customers. Pinnacle uses services to manage its
relationships and communications with both clients and suppliers.
This
Policy tells you, among other things, what information we gather from you when
you visit or use our Sites or Services, how we may use or disclose that
information, how to review or edit it, and our efforts to protect it.
Please
read this Policy carefully. By visiting, accessing or using any Services, you
agree to this Policy. Among other things, you consent to the collection,
tracking and use of your personal information as outlined in this Policy, as
such Policy may be amended from time to time.
b.
Changes.
Changes to the Privacy Policy apply to your use
of our Services after the effective date of the policy.
Pinnacle
may change this Policy or any other terms, at any time. Pinnacle will notify
You of a change through our Services, such as when You next log-in, or by other
means. The new terms may be displayed on-screen and You may be required to read
and accept them to continue Your use of the Sites. Pinnacle may also post the
terms at www.pinnacle1.com and they are effective immediately upon
posting. If You choose not to accept any new terms, You
may close your account and/or discontinue using our Services. You acknowledge that continued use of our
Services after we post or send notice of the changes means that your personal
data is subject to the updated Privacy Policy.
1. Information We
Collect or Track.
We
may collect or track the following information:
a.
Information
we collect
We
collect the data that you provide to us.
When you register for our Services, we may request certain information
from you, including your:
·
Contact information: (e.g., name, address, email address, phone
number, one or more social media handles, user name,
password, address, personal or employer websites)
·
Business information: (e.g., job title, work experience, areas
of responsibility, name and address of employer).
After you have registered for the Services, we
may also collect certain information from you.
For example, this could include information regarding meetings and
communications: (e.g., information that we learn about you or your company,
purchasing history for you or your company, etc.
We collect data when you
interact with and use our Sites and Services and when you share information
from the Sites and Services with others.
We gather certain information automatically. We may also collect
information from the mobile phone, tablet, computer or other device that you
use to access the Services. This information may include your domain and/or
Internet Protocol ("IP") addresses, browser type, Internet Service
Provider ("ISP"), the referring or exiting website address, operating
system, access times and history, information relating to your activities and
preferences on the Services, device, unique device identifiers, mobile platform
advertising identifiers (e.g., IFA/IDFA or Android ID), telephone number,
mobile carrier, language, CPU, iOS, screen, display, plug-ins, Mime, font,
storage, time, canvas, images or other posted content, downloaded content,
communications on the Services with other users, posts in public forums, and
information from cookies or other technology.
We may also infer location from IP addresses or other information,
for example, Wi-Fi access points and mobile towers. Among other things, this
information allows the creation of device fingerprints and profiles about the
possible relationships among different browsers and devices.
We also collect data when You interact with and use the Services.
For example, we collect data on traffic, views, clicks, and potential matches.
WE DO NOT RESPOND TO "DO NOT TRACK" SIGNALS.
If you send us personal correspondence, such as an email, letter,
or other message, we may collect such information into a file specific to you.
Pinnacle may participate in public events and events with multiple
sponsors, such as trade shows and seminars. The events generally collect
certain information from all attendees and distribute this data in whole or in
part to all the event sponsors including Pinnacle. We do not control and are not responsible for
the practices of other sponsors for these events.
You may choose to provide your SNS profile (e.g., Facebook,
LinkedIn, Twitter, YouTube, etc.) and provide comprehensive insight into your
capabilities. By linking your SNS
profile, we may collect information from SNS, such as name, gender, date of
birth, geo-location, interests, when you "Like" or click links
provided by or through the Apps and other information available through your
SNS page. It is your responsibility to read and accept the relevant terms of
service and privacy policy associated with the particular SNS
service. We may have also collected information regarding Likes, Views and other
engagement data.
We collect data through
cookies, other tracking technologies, third party analytics, and third party websites and services. Links to these third parties’ privacy
policies are provided in this section.
We may permit advertisers or other third parties to collect
information from the Services. For example, a third party may place cookies or
similar tracking technologies (such as advertising IDs or deep linking
technology) and may send its own cookies to your cookie file. We may also
utilize third parties to analyze data collected from the Services. We may
permit third parties to collect personally identifiable information over time
and across different websites and across multiple mobile apps.
We use your data to provide, develop, support,
customize, market, and protect our Services.
We
use the information we collect or track about you to provide you with relevant,
useful and customized Services. In order
to do that, we use your information in the following ways:
3. Information We Share With Others.
We share your data with
our clients, third party vendors, and application developers. We may also share certain information with
other service provides, for example to assist us with
data analytics or for development of new and better services.
We may provide information about you to our affiliates and other
businesses or individuals, including third-party vendors and other businesses
("Vendors") and Application Programming Interface ("API")
Developers. We may combine information
internally across different Services so that we may provide better and more
customized services. We contract with
companies who help with parts of our operations and/or to enhance our services
and we require them to only use your personal information in connection with
the services they perform. We may also
share aggregated non-personally identifiable information publicly.
We may share your data
if required or necessary by law. We may
also do so to exercise, defend, or protect our, your, or others’ rights.
Pinnacle will cooperate with law enforcement inquiries, other
government agency inquiries and requests, and criminal or civil subpoenas. Pinnacle
will also disclose your personal information when necessary to comply with
state and federal laws and regulations. Pinnacle may also disclose information
to exercise or defend our legal rights, to protect the security of our Services
and business, to investigate and prevent illegal or tortious activity, to
protect the property or safety of Pinnacle or others, and to enforce Pinnacle
agreements or other policies.
We may share your data
if some or all of our business is sold, acquired, or
merged with another company.
As we develop our business, we may buy or sell some or all of our assets and, depending on the transaction, your
personal information may be one of the transferred assets. Similarly, if Pinnacle
should ever merge with or be acquired by another company, we may share your
personal information with any entity resulting from such transaction. Any entity that acquires your data in this
manner will have the right to use your data as set forth in this Policy. Separately, if Pinnacle should ever file for
bankruptcy, the bankruptcy trustee has the right to sell the information you
provide to us to a third party.
While we try, we cannot 100%
guarantee the security of your data.
Please see the Security measures we take below.
We cannot ensure that all of your private
communications and other personal data will never be disclosed in ways not
otherwise described in this Policy. By way of example (without limiting the
foregoing), we may be required to disclose personal information to the
government or third parties under certain circumstances, third parties may
unlawfully intercept or access transmission of private communications, or users
may abuse or misuse your personal information that they collect from the
Services.
4. Your California Privacy Rights.
If you are a California resident, then you may
have certain rights relating to whether any third parties have received your
information for their direct marketing purposes. Please note the included California Privacy Policy.
5. Cookies / Tracking Technologies.
We collect data through cookies and other
tracking technologies.
We
may use cookies, pixels, scripts, etags, advertising
IDs, IFA/IDFA, log files, clear gifs, web beacons, deep linking or other
technology. We may use these technologies in a variety of ways, including but
not limited to:
You
can refuse cookies by turning them off in your browser. However, if you turn
off cookies, then you may not be able to utilize certain features of the Sites
or Services. Turning off and/or deleting cookies does not affect other tracking
technologies, such as device fingerprinting.
This Privacy Policy covers the use of cookies and other
technologies by these Services only.
Pinnacle
may also utilize third party tracking technology, such as deep linking, to
leverage cross-app and cross-site functionality.
Another
tracking technology is a script that collects device information to permit what
is known as device fingerprinting. (see, e.g., FTC Consumer Guide on
Online Tracking -
What is device fingerprinting?) For example, this data collection may permit
generation of device fingerprints and cross-device profiles to better
understand who visits particular Influencers, how
often, unique visits, repeat visits, and more.
You agree Pinnacle is not liable for the content or use of
personal information by third parties, including, without limitation, SNS and Vendors,
and including their use of cookies and other tracking technologies. You should
consult the privacy policies and terms of service for those individual websites
and services.
By
agreeing to the terms of this Policy and by using our Services, you consent to
the cookies and other tracking technologies referenced above. In order for you to be a registered and active user of the
Services, you must agree to accept cookies and other tracking technologies. If
you wish to opt-out of cookies and other tracking technologies altogether, then
visit our Choice/Opt-Out Section.
6. Links to Other Sites, Networks, Platforms, and Apps.
You may encounter Linked Technologies that have
their own privacy policies.
The
Sites and Services may contain links to third-party sites or services. Similarly, third-party sites or services may
contain links to our Sites and Services (collectively "Linked
Technologies"). However, please be
aware that Pinnacle is not responsible for and cannot control the terms of
service or privacy policies of such other Linked Technologies. We encourage you
to be aware when you leave the Sites or Services, and to read the applicable
agreements and privacy policies for each and every
Linked Technologies. The Agreement applies solely to these Services. Pinnacle is not responsible for and makes no
representations or warranties regarding Linked Technologies, including without
limitation, the content, accuracy, opinions, functionality, or services
provided in such Linked Technologies. Inclusion of any Linked Technologies on
the Services does not imply approval or endorsement by Pinnacle. If You decide
to access any Linked Technologies, then You do so at your own risk.
7. Age Restrictions; Children's Privacy.
Our Services are not for use of anyone under the
age of 13.
These
Services are not for use for anybody under the age of 13. By using these
Services, you verify that you are over the age of 13 and in compliance with
this provision. Pinnacle will not knowingly collect or use personal information
from anyone under 13 years of age. If Pinnacle obtains actual knowledge that it
has obtained personal information about a child under the age of 13, that
information will be permanently deleted from our records.
You have choices about how your data is collected,
the ability to delete certain data, and the ability to close your account.
Cookies. You may be able to
delete and/or turn off cookies as your browser or device permits. Unless you
block or control cookies going forward, deleting cookies will only address
cookies on your device at that moment. If you disable cookies entirely, Pinnacle
Services may not function properly. Please note that other tracking
technologies, such as device fingerprinting, are not stopped or impacted by
turning off or deleting cookies.
Flash Cookies. Some
newer versions of browsers will let you control and/or delete Flash cookies. If
you use a browser or device that does not let you delete Flash cookies, then
try Adobe's Website
Storage Settings. Similar to regular cookies, deleting Flash cookies will only
address the Flash cookies on your device at that moment. Please note that other
tracking technologies, such as device fingerprinting, are not stopped or
impacted by turning off or deleting Flash cookies.
Other Tracking Technologies. You may be able to turn off and/or delete some scripting
functionality as your browser or device permits. If you disable scripting
functionality, Pinnacle Services may not
function properly. Please note that other tracking technologies, such as device
fingerprinting, are not stopped or impacted by turning off some script
functionality.
Effect of Opting Out: You will need to renew your opt-out
choice if you use a different device, use a different browser, or erase cookies
from your browser.
Unsubscribing from emails: You may opt out at any time by using the Opt-Out or Unsubscribe
option at the bottom of most of our mass email communications, or by contacting
us through the "Contact Us" section of the Services.
Account: You may also choose to
close your account at any time.
Although we work to protect your data, we cannot
warrant or ensure its ultimate security.
To
protect your privacy and security, we take reasonable steps (such as requesting
a unique password, Secure Sockets Layer, or Transport Layer Security) to verify
your identity before creating your account. The user who created the account is
responsible for maintaining the secrecy of their unique password and account
information at all times.
We
use what we believe to be appropriate procedures to protect information against
unauthorized access and disclosure. However, information you elect to provide
through the Sites, Services, emails, and other information you send to us, may not
be encrypted, and such transmissions cannot be considered a secure means of
transmitting sensitive information.
You
should be aware of the limitations of security, authentication, encryption, and
privacy measures used in connection with the Internet and that any information
you transmit through the Services may be damaged, corrupted,
"sniffed" and/or accessed by another person without your permission.
Regardless of the precautions taken by you or by us, "perfect
security" does not exist on the Internet. Third parties may unlawfully
intercept or access transmissions or private communications, and other users
may abuse or misuse your personal information that they collect from the
Services. Therefore, although we work very hard to protect your privacy, we do
not promise, and you should not expect, that your personal information or
private communications will always remain private. We cannot ensure or warrant
the ultimate security of any information you transmit.
If
for some reason you believe Pinnacle has not adhered to the principles of this
Policy, please notify us at legal@pinnacle1.com. For
those in the EU / EEA, send complaints or questions to legal@pinnacle1.com.
11. Users in the European Union and European Economic Area.
If you are in the EU / EEA, then this section
applies to you.
Personal Data is any information relating to an identified
or identifiable natural person in the European Union (“EU”) and European
Economic Area (“EEA”).
b. Data Controller.
Pinnacle is the data
controller of Personal Data you provide on our Sites and Services.
You may contact Pinnacle via email at legal@pinnacle1.com or by mail at:
Pinnacle Technical Resources, Inc.
5501 Lyndon B. Johnson Freeway, Suite 600
Dallas, Texas 75240
Attn: Privacy Officer
c. Purposes of Processing and Legal Basis for Processing.
We have lawful bases to collect, use, and share
your data.
As explained above, we
process Personal Data in various ways depending upon your use of our Sites or Services. We process Personal Data on the following
bases: (1) with your consent; (2) as necessary to perform a contract when you
request Services; and (3) as necessary for our legitimate interests in
providing you with our products and Services, enhancing and customizing our
Services, conducting analytics and delivering relevant advertising as set forth
above.
d. Your Rights Regarding Personal Data.
If you are in the EU / EEA, then you have
certain rights relating to your personal data.
·
Access
and Confirmation. You have the right to ask us if we process
Personal Data about you, and in some circumstances, to obtain a copy of your
Personal Data.
·
Deletion
and Blocking. Under certain circumstances, you may have the
right to have your Personal Data deleted or blocked without undue delay.
·
Direct
Marketing. You have the right to object to our
processing of Personal Data for direct marketing purposes.
·
Consent. To the
extent we are processing Personal Data on the basis of
your consent, you have the right to withdraw consent at any time.
·
Data
Portability. Under certain circumstances, to the extent we
are processing your Personal Data on the basis of consent, or that it is
necessary to perform a contract with you, and the processing is carried out by automated
means, you have the right to receive the Personal Data in a structured,
commonly used and machine-readable format.
To exercise those rights, please contact us at:
Pinnacle Technical Resources, Inc.
5501 Lyndon B. Johnson Freeway, Suite 600
Dallas, Texas 75240
Attn: Privacy Officer
Email: legal@pinnacle1.com
·
Right
to Lodge a Complaint. You have the right to lodge a complaint about
our data collection and processing actions with the supervisory authority in
your country.
e.
Transfers.
We transfer, store, and
process your data outside your country.
We are headquartered in the United States of America. Personal Data may be accessed by us or
transferred to us in the United States. The European Commission has not
determined that the United States ensures an adequate level of protection for
Personal Data. By providing us with
Personal Data, you consent to this transfer. We will protect the privacy and
security of Personal Data according to this Privacy Policy, regardless of where
it is processed or stored.
By providing us with Personal Data, you consent to the storage or
processing of Personal Data in the United States and acknowledge that the
Personal Data will be subject to the laws of the United States, including the
ability of governments, courts or law enforcement or regulatory agencies of the
United States to obtain disclosure of your Personal Data.
12. Retention of
Personal Data
The
Personal Data we obtain about you may be retained up to seven years or for up
to five years past the termination of a contract pursuant to which it was
collected.
You can contact us for complaints or questions.
Any
notices or communication sent to you by Pinnacle will be sent to your email
address on file with Pinnacle, which may be updated by you in writing at any
time. It is your responsibility for ensuring that Pinnacle has
your current email address at all times. Any notice sent to you via such
email address by Pinnacle shall be deemed given, received, and read by you, whether or not it actually is received and/or read.
Any
notices or communications sent by you to Pinnacle pursuant to this Policy must
be in writing and sent to the address specified herein or such other address as
Pinnacle may specify in writing.
All notices will be sent to:
Pinnacle Technical
Resources, Inc.
5501 Lyndon B. Johnson Freeway, Suite 600
Dallas, Texas 75240
Attn: Privacy Officer
Email: legal@pinnacle1.com
For those in the EU /
EEA, send complaints or questions to legal@pinnacle1.com.
25220416v.1
Effective Date: March1,
2020
1.
PRIVACY
STATEMENT-CALIFORNIA
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
supplements the information contained in Pinnacle Group’s Privacy Policy
(collectively, “we,” “us,” or “our”) and applies solely to clients, suppliers,
visitors, users, and others who reside in the State of California (“consumers”
or “you”). We adopt this notice to comply with the California Consumer Privacy
Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined
in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect information that identifies,
relates to, describes, references, is capable of being associated with, or
could reasonably be linked, directly or indirectly, with a particular
consumer or device (“personal information”). The categories of
information set forth in the chart below are those defined in the CCPA. This does not mean that all examples of that
category of personal information were in fact collected, but
reflects a good faith belief that to the best of our knowledge that some of
that information may have been collected.
With that in mind, we have collected the following categories of
personal information from consumers within the last twelve (12) months:
|
Category |
Examples |
Collected |
|
A. Identifiers. |
A real name, alias, postal address, unique personal
identifier, online identifier, Internet Protocol address, email address,
account name, Social Security number, driver's license number, passport
number, or other similar identifiers. |
YES |
|
B. Personal information categories listed in the California
Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, Social Security number, physical
characteristics or description, address, telephone number, passport number,
driver's license or state identification card number, insurance policy
number, education, employment, employment history, bank account number,
credit card number, debit card number, or any other financial information,
medical information, or health insurance information. Some personal
information included in this category may overlap with other categories. |
YES |
|
C. Protected classification characteristics under California
or federal law. |
Age (40 years or older), race, color, ancestry, national
origin, citizenship, religion or creed, marital status, medical condition,
physical or mental disability, sex (including gender, gender identity, gender
expression, pregnancy or childbirth and related medical conditions), sexual
orientation, veteran or military status, genetic information (including
familial genetic information). |
YES |
|
D. Commercial information. |
Records of personal property, products or services purchased,
obtained, or considered, or other purchasing or consuming histories or
tendencies. |
NO |
|
E. Biometric information. |
Genetic, physiological, behavioral, and biological
characteristics, or activity patterns used to extract a template or other
identifier or identifying information, such as, fingerprints, faceprints, and
voiceprints, iris or retina scans, keystroke, gait, or other physical
patterns, and sleep, health, or exercise data. |
NO |
|
F. Internet or other similar network
activity. |
Browsing history, search history, information on a consumer's
interaction with a website, application, or advertisement. |
NO |
|
G. Geolocation data. |
Physical location or movements. |
NO |
|
H. Sensory data. |
Audio, electronic, visual, thermal, olfactory, or similar
information. |
NO |
|
I. Professional or employment-related information. |
Current or past job history or performance evaluations. |
YES |
|
J. Non-public education information (per the Family
Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part
99)). |
Education records directly related to a student maintained by
an educational institution or party acting on its behalf, such as grades,
transcripts, class lists, student schedules, student identification codes,
student financial information, or student disciplinary records. |
NO |
|
K. Inferences drawn from other personal information. |
Profile reflecting a person's preferences, characteristics,
psychological trends, predispositions, behavior, attitudes, intelligence,
abilities, and aptitudes. |
YES |
Personal information does not include:
We obtain the categories of personal
information listed above from the following categories of sources:
Use of Personal
Information
We may use or disclose the personal
information we collect for one or more of the following business purposes:
We will not collect additional categories of
personal information or use the personal information we collected for
materially different, unrelated, or incompatible purposes without providing you
notice.
Sharing Personal
Information
We may disclose your personal information to a
third party for a business purpose. When we disclose personal information
for a business purpose, we enter a contract that describes the purpose and
requires the recipient to both keep that personal information confidential and
not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have
disclosed the following categories of personal information for a business
purpose:
Category
A:
Identifiers.
Category
B:
California Customer Records personal information categories.
Category
C:
Protected classification characteristics under California or federal law.
Category
I:
Professional or employment-related information.
We may disclose your personal information for
a business purpose to the following categories of third parties:
In the preceding twelve (12) months, we have
not sold any personal information.
Your Rights and
Choices
The CCPA provides consumers (California
residents) with specific rights regarding their personal information. This
section describes your CCPA rights and explains how to exercise those rights.
Access to Specific
Information and Data Portability Rights
You have the right to request that we disclose
certain information to you about our collection and use of your personal
information over the past 12 months. Once we receive and confirm your
verifiable consumer request, we will disclose to you:
Deletion Request
Rights
You have the right to request that we delete
any of your personal information that we collected from you and retained,
subject to certain exceptions. Once we receive and confirm your verifiable
consumer request, we will delete (and direct our service providers to delete)
your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining
the information is necessary for us or our service providers to:
Exercising Access,
Data Portability, and Deletion Rights
To exercise the access, data portability, and
deletion rights described above, please submit a verifiable consumer request to
us by either:
Only you or a person registered with the
California Secretary of State that you authorize to act on your behalf, may
make a verifiable consumer request related to your personal information. You
may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer
request for access or data portability twice within a 12-month period. The
verifiable consumer request must:
We cannot respond to your request or provide
you with personal information if we cannot verify your identity or authority to
make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account
with us. We will only use personal information provided in a verifiable
consumer request to verify the requestor's identity or authority to make the
request.
Response Timing and
Format
We endeavor to respond to a verifiable
consumer request within 45 days of its receipt. If we require more time
(up to 90 days), we will inform you of the reason and extension period in
writing. If you have an account with us, we will deliver our written
response to that account. If you do not have an account with us, we will
deliver our written response in the same manner in which
we received the request. Any disclosures
we provide will only cover the 12-month period preceding the verifiable
consumer request's receipt. The response we provide will also explain the
reasons we cannot comply with a request, if applicable. For data
portability requests, we will select a format to provide your personal information
that is readily useable and should allow you to transmit the information from
one entity to another entity without hindrance.
We do not charge a fee to process or respond
to your verifiable consumer request unless it is excessive, repetitive, or manifestly
unfounded. If we determine that the request warrants a fee, we will tell
you why we made that decision and provide you with a cost estimate before
completing your request.
Non-Discrimination
We will not discriminate against you for
exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Changes to Our Privacy
Notice
We reserve the right to amend this privacy notice
at our discretion and at any time. When we make changes to this privacy notice,
we will notify you by email or through a notice on our website homepage.
Contact Information
If you have any questions or comments about
this notice, our Privacy Statement, the ways in which we collect and use your
personal information, your choices and rights regarding such use, or wish to
exercise your rights under California law, please do not hesitate to contact us
at:
Phone: 214-740-2424
Website: pinnacle1.com
Email: helpdesk@pinnacle1.com or
legal@pinnacle1.com
Postal Address: 5501 Lyndon B Johnson Freeway, Suite 600, Dallas,
TX 75240
Attn: Privacy Officer