Last updated May 01, 2016
PELCRO complies with the US-EU Safe Harbor Framework and US-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. PELCRO has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement (the "Principles "). To learn more about the Safe Harbor program, and to view our certification page, please visit https://www.export.gov/safeharbor/.
INFORMATION WE COLLECT
We collect information in various ways when you use our Sites, Applications and Services.
Information You Provide Us
We collect information you provide us voluntarily. For example:
- We collect your first and last name, email address, and password when you create an account to log in to our network (“Account”);
- We may retain information on your behalf that you store using your Account, including postal address, phone number, fax number, company name and credit card payment information.
- If you use our Services on your mobile device, including through our Application(s), we may collect your mobile carrier and the unique device id number.
- If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information.
- We may also collect personal information, such as at other points in our Site that state that personal information is being collected.
Information Collected Via Technology
We automatically collect certain information via technology:
- When you visit our Sites or use our Application, some information is automatically collected. This may include information such as the Operating System (OS) running on your device, Internet Protocol (IP) address (which may be used to obtain your geolocation), access times, browser type, and language, and the website you visited before our Sites. We also collect information about how you use PELCRO's Sites, Application and products, including the elements you have interacted with, metadata and other details about these elements, clicks, change states and other user actions.
- Pixel Tags. In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages and determine whether those e-mails have been opened, to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ personal data.
- Mobile Services. We may also collect non-personal information from your mobile device if you have downloaded our Application(s). This information is generally used to help us deliver the most relevant information to you and improve our Services and analytics platform. Examples of information that may be collected and used include how you use the Application(s) and information about the type of device you use. In addition, in the event our Application(s) crash on your mobile device, we will receive information about your mobile device model and OS version, which allows us to identify and fix bugs and otherwise improve the performance of our Application(s).
HOW WE USE INFORMATION WE COLLECT
In general, we use the information we collect primarily to provide, maintain, protect and improve our current products and to develop new ones. We use personal information collected through our Sites and Application(s) as described below and described elsewhere in this Policy to:
- Facilitate the creation of and securing of your Account on our network;
- Identify you as a user in our system;
- Improve our Services, Application(s), Sites and how we operate our business;
- Understand and enhance your experience using our Sites, products and services;
- Provide and deliver products and services you request;
- Respond to your comments or questions and for our Support team to provide service;
- Send you related information, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;
- Communicate with you about promotions, upcoming events and news about products and services offered by PELCRO and our selected partners, and for other marketing purposes of PELCRO;
- Link or combine it with other information we get from third parties, to help understand your needs and provide you with better service; and
- Protect, investigate and deter against fraudulent, unauthorized or illegal activity.
User Feedback. We often receive feedback and comments from users who have had positive experiences with our Services. We may post user feedback on the Sites from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name and a profile picture along with your feedback, we will obtain your consent prior to posting your name with your feedback.
Creation of Anonymous Data. We may create anonymous data records from personal information by excluding information (such as your name) that makes the data personally identifiable to you. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of our Services and improve Application and Site navigation. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.
SHARING OF PERSONAL INFORMATION
Information You Share
We may collect and retain any comments or other content you send, post or provide through the Service ("User Content"); we treat this information as Personally Identifiable Information when it is combined and stored with Personally Identifiable Information. In all other cases we treat it as Non-Personally Identifiable Information, even where the User Content itself may identify you.
When you Subscribe third-party apps, websites or other services that use, or are integrated with, our Services, they may receive personally identifiable information about you, what you post or share. For example, when you Subscribe to a third party website to access their content, the content creator or website may get information about your activities on their website as well as information about you such as your name and email. In addition, when you download or use such third-party services, they can access your Public Profile, which includes your name and country/language as well as any information that you share with them. Information collected by these apps, websites or integrated services is subject to their own terms and policies.
Following termination or deactivation of your Pelcro account, we may retain and continue to use the information we have collected from you, including User Content, indefinitely. User Content posted to the Service is available to the public and may be viewed and used by others. We are unable to control such uses of your User Content, and by using the Service you assume the risk that your User Content may be viewed and used by third parties. If you remove User Content from the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information. Pelcro reserves the right, but has no obligation, to monitor the User Content you post on the Service. We reserve the right, and Partner Sites also reserve the right, to remove any such information or material for any reason or no reason, including without limitation if in our sole opinion such information or material violates, or may violate, any applicable law or our Terms of Service, or to protect or defend our rights or property or those of any third party. Pelcro also reserves the right to remove information upon the request of any third party.
Information We Share
We do not share your personal information with third parties without your consent other than:
- Third Party Service Providers. With third parties who work on our behalf provided such third parties subscribe to the EU Safe Harbor Principles (or successor framework, such as the EU-US Privacy Shield), is subject to the European Union Directive on Data Protection or another adequacy finding, or enter into a written agreement with PELCRO requiring that the third party provide at least the same level of privacy protection as is required by the relevant EU Safe Harbor Principles (or successor framework);
- Lawful Requests. To comply with laws or to respond to lawful requests and legal process (provided that PELCRO will endeavor to notify you if PELCRO has received a lawful request for your information);
- Emergency. In an emergency, including to protect the personal safety of any person; and
- Corporate Restructuring. For the purposes of a business deal (or negotiation of a business deal) involving sale or transfer of all or a part of our business or assets (business deals may include, for example, any merger, financing, acquisition, divestiture or dissolution transaction or proceeding). In the event of an insolvency, bankruptcy, or receivership, personal information may also be transferred as a business asset. If another company acquires our company, business or assets, that company will possess the personal information collected by us and will assume the rights and obligations regarding your personal information as described in this Policy.
Personal Information Security
PELCRO takes reasonable steps to help protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration and destruction. It is your responsibility to protect your user names and passwords to help prevent anyone from accessing or abusing your accounts and services. You should not use or reuse the same passwords you use with other accounts as your password for our services.
We do not intentionally gather personal information for visitors who are under the age of 13. If a child under 13 submits personal information to PELCRO and we learn that the personal information is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any personal information from a child under 13, please contact us at: firstname.lastname@example.org.
YOUR INFORMATION CHOICES AND CHANGES
Email Communications. You may opt out of receiving promotional emails from PELCRO by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as emails about your PELCRO projects or our ongoing business relationship.
Changing or Deleting Your Personal Information. PELCRO retains your data while you are a customer and will delete your information upon written request. You may also send requests about your contact preferences, changes and deletions to your information including requests to opt-out of sharing your personal information with third parties by emailing email@example.com. PELCRO will respond within ninety (90) days to any request to delete your information. Individuals who have provided information to PELCRO's customers must send requests to change or delete such information to the particular PELCRO customer.
Applications. You can stop all collection of information by an Application by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
Do Not Track Signals. Some web browsers may transmit “do not track” signals to the websites and other online services with which your web browser communications. There is no standard that governs what, if anything, websites should do if they receive these signals. PELCRO currently does not respond to "Do Not Track" browser signals or similar mechanisms. If and when a standard is established, we may revise our policy on responding to these signals. Third parties may collect personal information about your online activities over time and across sites when you visit the Sites or use the PELCRO Service.
CHANGES TO THIS POLICY
PELCRO may change this Policy from time to time. If we make any changes to this Policy, we will change the "Last Updated" date above. You agree that your continued use of our Sites, Applications or Services after such changes have been published to our Policy will constitute your acceptance of such revised Policy.
Contacting PELCRO and Dispute Resolution
- Email: legal@PELCRO.com
For complaints that cannot be resolved between PELCRO and the individual concerned, PELCRO has agreed to participate in the Better Business Bureau EU Safe Harbor independent dispute resolution program. Individuals who submit a complaint or concern to PELCRO but who do not receive acknowledgement from us or who think the complaint or concern has not been satisfactorily addressed should then contact the Better Business Bureau to participate in its dispute resolution procedure.
Council of Better Business Bureaus, Inc.
BBB EU Safe Harbor 3033 Wilson Boulevard, Suite 600
Arlington, VA 22201 U.S.A.
In addition, the United States Federal Trade Commission is the statutory body that has jurisdiction to hear any claims against PELCRO regarding possible unfair or deceptive practices and violations of laws or regulations governing privacy.
If you have any questions about this Policy, please contact us at legal@PELCRO.com.