Pinpoint Predictive 

Privacy Policy

®

Pinpoint Predictive, Inc. (together with our affiliates, "Pinpoint", "we" or "us") takes data privacy very seriously.  This “Privacy Policy” explains how we collect, share and use information and the rights and choices available to individuals with respect to their information.  We recommend that you read this in its entirety so that you may be fully informed.

Last updated:  September 18, 2019

1.    General Terms


a. Pinpoint provides audience analysis and consumer marketing services via the www.pinpoint.ai website (the “Site”) and via a variety of first and third-party software, applications, and other technologies and associated documentation (together with the Site, the “Services”).  The Services enable, among other things, more personalized marketing activities.


b. This Privacy Policy applies with respect to information we collect about: (1) customers that have an account to utilize the Services (“Merchants”); (2) such Merchants’ customers (“Consumers”); and (3) visitors to the Site (“Visitors”).


c. This Privacy Policy does not apply (and Pinpoint is not responsible for) a Merchant’s use of a Consumer’s information, including any information that Pinpoint may provide to a Merchant via the Services.  If you are a Consumer, you should review the applicable Merchant’s terms and privacy policies.


d. We may make changes to this Privacy Policy from time-to-time due to changes to the Services, to account for developments under applicable law, or for any other reason.  If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site.  We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner through the Service.  Any changes will become effective upon posting the new terms to the Site, and if you do not agree to any such amendment, you must stop using the Services.  In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.


e. We provide important additional information for individuals located in California in Section 12.


2.    Information from Merchants


a. In this Section 2, "you" and "your" refer to Merchants.  If you are not a Merchant, Sections 3 and/or 4 of this Privacy Policy may be more applicable.


b. What Merchant information do we collect and how do we use it?


1. Pinpoint collects your business and personal contact information, such as your name, professional title, company name, address, email address, phone number(s), payment details (when applicable), the username and password you may use to establish an account with us, as well as any information you provide when you contact us with questions, feedback or other correspondence.


i. We use this information to enable you with secure access to the Services, to enable customer support interactions, to provide you alerts, to market to you, to invoice you (when applicable) and to provide, operate and to improve the Services.


2. Pinpoint collects data about how and when you access the Services, including information about the device and browser you use, your network connection and your IP address.


i. We use this information to provide, operate and to improve the Services.


3.    Pinpoint collects information that you share with us about Consumers, such as names, email addresses, phone numbers,     shipping addresses and behavioral information.


i. We use this information to provide, operate and to improve the Services.


4.    In addition to the above, we use Merchant information:


i. to enable customer support interactions, to provide you alerts, to market to you, to operate and enhance our Services, to develop new products and services, and to respond to your requests, questions and feedback;


ii. to: (a) prevent, investigate, or take action regarding illegal activities, suspected fraud, violations of our Terms of Service; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) enforce the Terms of Service; or (d) as otherwise necessary or appropriate to comply with applicable laws, lawful requests, and legal process; and


iii. as otherwise described in this Privacy Policy.


c.    When do we collect Merchant information?


1. We collect Merchant information when you sign-up for the Services, when you access and use the Services, and when you otherwise provide us with information.


d.    When and why do we share Merchant information with third parties?


1. Pinpoint works with a variety of third-party technology partners and service providers that help us to provide the Services and we may share Merchant information with them to support these efforts.


2. Pinpoint works with professional advisors such as lawyers, bankers, auditors and insurers, and we may share Merchant information with them in support of the professional services they provide for us.


3. We may also share Merchant information in the following circumstances:
 

i.    with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy;


ii.    to prevent, investigate, or take action regarding illegal activities, suspected fraud, violations of our Terms of Service, or as otherwise required by law;


iii.    to conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities; or


iv.    to help us conduct marketing campaigns.


4. Merchant information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding.


5. We also share Merchant information as otherwise described in this Privacy Policy.


3. Information about Consumers


a. In this Section 3, "you" and "your" refer to Consumers.  If you are not a Consumer, Sections 2 and/or 4 may be more applicable.


b.    What Consumer information do we collect and how do we use it?


1. Pinpoint collects Consumer information that is shared with us by Merchants in support of the Services, sometimes inclusive of names, email addresses, phone numbers, shipping addresses and behavioral information.


i. We use this information to provide, operate and to improve the Services.


2. Pinpoint also collects Consumer information that is shared with us by other third parties, such as marketing partners, publicly-available sources and data providers.


i. We use this information to provide, operate and to improve the Services.


3.    In addition to the above, we use Consumer information:


i. to enable customer support interactions, to provide you alerts, to market to you, to operate and enhance our Services, to develop new products and services, and to respond to your requests, questions and feedback;


ii. to: (a) prevent, investigate, or take action regarding illegal activities, suspected fraud, violations of our Terms of Service; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) enforce the Terms of Service; or (d) as otherwise necessary or appropriate to comply with applicable laws, lawful requests, and legal process; and


iii. as otherwise described in this Privacy Policy.


c. When do we collect Consumer information?


1.    We collect Consumer information when a Merchant chooses to utilize our Services and provide us with Consumer information or when a third party provides us with such information.


d. When and why do we share Consumer information with third parties?


1. Pinpoint works with a variety of third-party technology partners and service providers that help us to provide the Services and we may share Consumer information with them to support these efforts.


2. Pinpoint works with professional advisors such as lawyers, bankers, auditors and insurers, and we may share Merchant information with them in support of the professional services they provide for us.


3. We may also share Consumer information in the following circumstances:


i. with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy;


ii. to prevent, investigate, or take action regarding illegal activities, suspected fraud, violations of our Terms of Service, or as otherwise required by law; or


iii. to conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities.


4. Consumer information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding.


5. We also share Consumer information as otherwise described in this Privacy Policy.


4. Information from Visitors


a. In this Section 4, "you" and "your" refer to Visitors.


b.    What information do we collect from Visitors and how do we use it?


1. We collect information about the device and browser you use, your network connection, your IP address, and information about the cookies installed on your device.  We also collect any personal information that you submit in the process of requesting information or support from us.  We also collect any additional information that you might provide to us via the Site.


i. We use this information to enable customer support interactions, to provide you alerts, to market to you, to operate and enhance our Services, to develop new products and services, and to respond to your requests, questions and feedback.


ii. We use this information to: (a) prevent, investigate, or take action regarding illegal activities, suspected fraud, violations of our Terms of Service; (b) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (c) enforce the Terms of Service; or (d) as otherwise necessary or appropriate to comply with applicable laws, lawful requests, and legal process.


iii. We also use this information as otherwise described in this Privacy Policy.


c.    When do we collect information from Visitors?


1. We collect this information when you visit our Site, use Services offered on our Site or engage with us either by email, web form, or post content on or through our Site.  


d.    When and why do we share information from Visitors with third parties?


1. Pinpoint works with a variety of third-party technology partners and service providers that help us to provide the Services and we may share Visitor information with them to support these efforts.


2. Pinpoint works with professional advisors such as lawyers, bankers, auditors and insurers, and we may share Merchant information with them in support of the professional services they provide for us.


3. We may also share Visitor information in the following circumstances:


i.  with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy;


ii. to prevent, investigate, or take action regarding illegal activities, suspected fraud, violations of our Terms of Service, or as otherwise required by law; or


iii. to conform to legal requirements, or to respond to lawful court orders, subpoenas, warrants, or other requests by public authorities.


4. Visitor information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding.


5. We also share Visitor information as otherwise described in this Privacy Policy.


5. De-Identified Data


a. When and how do we collect De-Identified Data?


i. We may create anonymous, aggregated or de-identified data (“De-Identified Data”) from your Merchant, Consumer or Visitor information, or from information we obtain from other third parties.  


ii. We create De-Identified Data by removing all information that makes data personally identifiable.


b.    When and why do we use De-Identified Data?


i. We may use De-Identified Data for our lawful business purposes, including to provide, operate and to improve the Services and to promote our business.


c.    When and why do we share De-Identified Data with third parties?


i. We may share De-Identified Data with third parties for our lawful business purposes, including to provide, operate, improve and market our products and services.


6. For How Long Do We Retain Information?


a. In general, we retain personal information for as long as necessary to fulfill the purposes for which we collected it.  For example, we keep your information throughout your relationship with us.


1. For Merchants, this means that we will keep your information as long as you use the Services.  If you are a Merchant, when you terminate your account, your account and the Consumer information associated with your account is deleted pursuant to our standard processes.


2. For Consumers, this means that we will keep your information as long as the Merchant that provided your information to us uses the Services.


b. Notwithstanding the foregoing, we will retain your personal information for legitimate business purposes such as to establish or defend a contractual claim, for audit purposes, to comply with any legal, accounting, or reporting requirements, or for fraud prevention purposes.


c. We will continue to store De-Identified Data indefinitely for our lawful business purposes, including to operate and improve the Services and to promote our business.


7. Security Practices


a. The Security of your personal information is important to us.  We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect.  Our information security systems apply to people, processes and information technology systems on a risk management basis.


b. No method of transmission over the Internet, or method of electronic storage, is 100% secure.  Therefore, we cannot guarantee the security of your personal information.


8. Your Choices


a. Access or update your personal information.


1. If you are a Merchant, you can access and update many types of personal information, such as payment or contact information, directly within your account settings.  If you are unable to access or update your personal information within your account settings, please contact us to make the required changes.


2. If you are a Consumer and wish to access, update, or limit the use of your information, please contact the Merchants directly for information on how to access or update your information.


3. If you are a Visitor and wish to access or update your personal information, please contact us to make the required changes.


b. Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.


c. Choosing not to share your personal information.  Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services.  We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.


d. Cookies and browser web storage.  We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Services and third-party websites.  Most browsers let you remove or reject cookies.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, the Site may not work properly.  Similarly, your browser settings may allow you to clear your browser web storage.


e. Opt-out of marketing communications.  You may opt-out of marketing related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us by email at legal@pinpoint.ai, or by using the contact details below.  You may continue to receive service-related and other non-marketing emails.


9.    Note about Children


a. The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 13.  If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us.  We will delete such information from our files as soon as reasonably practicable.  


10.    International Data Transfers


a. We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.


11.    How to Contact Pinpoint


a. If you have any questions or comments about this Privacy Policy or our privacy practices, please contact us at:


1.    legal@pinpoint.ai; or
2.    Pinpoint Predictive, Inc.

Attn:  Chief Operations Officer
20 N. San Mateo Drive, Suite 4
San Mateo, CA 94401


12.    Information for California Residents


a.    If you are a California resident, you have the following rights:


1.    Information.  To request that we disclose the following information about our collection and use of your personal information during the past 12 months:


i.    The categories of personal information that we have collected about you;


ii.    The categories of sources from which personal information is collected;


iii.    The business or commercial purpose for collecting or selling personal information;


iv.    The categories of third parties with whom we share your personal information;


v.    Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of recipient; and


vi.    Whether we have sold your personal information, and, if so, the categories of personal information received by each category of recipient.


2.    Access.  To request a copy of the personal information that we have collected about you during the past 12 months.


3.    Deletion.  To request that we delete personal information about you that we have collected from you. 


4.    Opt-out of sales.  To direct us not to sell your personal information if we do, and if you are under 16 years of age, we are required to ask for affirmative authorization from you (or it you are under 13, your parent or guardian) to sell your personal information before we do so.


5.    Nondiscrimination.  To exercise your rights described above free from discrimination, such as denial of goods or services; price/rate increases for goods or services (including through grants of discounts/benefits or imposing penalties); decreases in service quality; or suggesting that such discriminatory acts may occur if you exercise your rights.  However, a difference in price or service quality is not discriminatory if reasonably related to the value to our business of the personal information we are unable to use due to the exercise of your rights, and we may offer you certain financial incentives that can result in different prices, rates or service quality.


6.    Financial incentive program disclosures.  Receive a clear description of the material terms of any program involving financial incentives for the collection, sale or deletion of your personal information, and decide if you want to consent to be entered in it (you can revoke this consent at any time).  


b.    You may exercise the rights described above as follows:


1.    Right to opt-out of sales


i.    You may exercise your right to opt-out of sales of your personal information by emailing us at legal@pinpoint.ai.


2.    Right to information, access and deletion


i.    You may exercise the information, access and deletion rights described above by submitting a verifiable request to us by emailing us at legal@pinpoint.ai.


ii.    Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.  You may also make a verifiable consumer request on behalf of your minor child under 13.


iii.    The verifiable request must provide sufficient information that allows us to reasonably verify you are a California resident about whom we collected personal information or their authorized representative; and describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.


iv.    These rights are not absolute, are subject to exceptions, and we may be required or permitted by law to decline your request.


c.    Personal information that we collect, use and share


1.    The chart below provides information that we are required to give you under California law about the categories of personal information that we have collected, used and shared in the 12 months preceding the last update of this Privacy Policy.  See our Privacy Policy for a description of the sources of the personal information we collect, as well as the business and commercial purposes for which we collect, use and share this information. 

 

 

 

 

 

 

 

 

 

 

 

 

 


 

 

*For a description of these categories, see the definition of Personal Information in Section 1798.140(o)(1) of the California Consumer Privacy Act.

** See the Sections 1, 2, 3 and 4 of our Privacy Policy for a description of the business purposes for which we disclose your personal information and the categories of third parties to which we disclose it.

*** Our use of your personal information in a manner that constitutes a “sale” under California law is for analytics, marketing and advertising purposes.