PRIVACY POLICY
Last updated: August 2024
Pyralink Innovation Ltd.
(“Pyralink”, “we”, “our”, “us”), a UK corporation with office at Aidan House, Sunderland Road, Gateshead, NE8 3HU, England,
is committed to protecting and respecting your privacy. This Pyralink Privacy
Policy (“our Privacy Policy”) explains how we collect, use, process and
disclose personal information in connection with your use of Pyralink’ s
website at pyralink.co.uk and/or one
of our applications, platforms, and other online services (collectively, our
“Sites”). Please take a moment to read our Privacy Policy carefully. If you
have any questions about our Privacy Policy, please contact us at privacy@pyralink.co.uk
THIRD-PARTY PRIVACY
POLICIES
Please note our Sites
can contain links to third-party websites, applications, and services.
Information collected by third parties is governed by their privacy practices.
We do not take any responsibility for those third-party websites, applications,
and services, nor how information shared through them is used, and we expressly
disclaim all liability for the actions of third parties, including but without
limitation to actions relating to the use and/or disclosure of personal
information by third parties. We encourage you to learn about the privacy
practices of those third parties.
ACKNOWLEDGMENT OF
PRIVACY POLICY
By using our Sites you
are acknowledging the terms of our Privacy Policy and accepting our Terms of
Use, and acknowledge our collection, use, disclosure, and retention of your
personal information as described in our Privacy Policy. If you do not agree with
our Privacy Policy or our Terms of Use, you should not access our Sites.
INFORMATION WE COLLECT
When you access or use
our Sites, we collect certain categories of information about you from a
variety of sources. Some features of our Sites may require you to directly
enter certain information about yourself. You provide us with information in
the following circumstances:
- When you contact us. You provide personal information when
contacting us through our Sites. For example, we will collect your first
and last name, username, company name, job title, email address, postal
address, and phone number when you ask to download some contents (such as
white papers), register for a webcast or other event, or subscribe to
email lists.
- When you create a customer account on our
platform. You will be
required to provide us with your first and last name and email address.
Customer account holders can provide us with additional information while
using our platform’s messaging system or profile update.
- Social media platforms. Our Sites also include social media
features that may collect your IP address, which webpage you are visiting
on our Sites, and may set a cookie to enable the feature to function
properly. Your interactions with these features are governed by the privacy
policy of the company providing it.
- Other engagements. When you participate in a focus group,
activity, or other events sponsored by us or other third parties, we may
collect from you, your first and last name, company name, job title, email
address and phone number.
We also automatically
collect certain information when you visit our Sites from your computer, mobile
phone or other access device. This information includes your location, computer
operating system, Internet Protocol (IP) address, access times, browsing
history and web log information, browser type and language, and “click stream”
data, such as domain names and page views.
Finally, we obtain
information about you from third parties. Such information may include:
- Information we collect by going directly to
third parties, such as advertising publishers, and marketing or analytics
companies. We use this information to better understand our audience base
and customize our advertising and marketing.
- Your first and last name, company name, job
title, email address and phone number from event sponsors, including from
industry tradeshows and conferences.
HOW WE USE COOKIES
We use cookies to
collect information about your browsing activities on our Sites over time.
Cookies allow us to recognize and count the number of users and to see how
users move around our Sites. This helps us to improve the services we provide
to you and the way our Sites work. For information on what cookies are, which
ones we use, why we use them, and how you can manage their use, please see
our Cookies Policy.
Your browser settings
may allow you to transmit a “do not track” signal, “opt-out preference” signal,
or other mechanism for exercising your choice regarding the collection of your
personal information when you visit various websites. We respond to such signals
and requests in accordance with our legal obligations and the practices
described in our Privacy Policy. To learn more about “Do Not Track” signals,
you can visit http://www.allaboutdnt.com/.
HOW WE USE INFORMATION
WE COLLECT
To fulfil our contract
with you, we process your personal information to administer your account and
provide the services described in our Terms of Use. Additionally, to be
responsive to you, to provide effective services to you, and to maintain our
business relationship, as a matter of our legitimate interests, we will use the
information we collect from you to:
- personalize our Sites to ensure content
from our Sites is presented in the most effective manner for you and your
device;
- monitor and analyze trends, usage and
activity in connection with our Sites and services to improve our Sites;
- measure and understand the effectiveness of
the content we serve to you and others;
- communicate with you;
- keep our Sites safe and secure, which
includes enforcing our Terms of Use;
- communicate with you about products,
services, promotions, events and other news and information we think will
be of interest to you; or
- provide third parties with statistical
information about our users (but those third parties will not be able to
identify any individual user from that information).
We obtain your consent
to process your personal information for the following reasons:
- Sign you up for our newsletter or alerts;
- Personalize our services for you; and
- If you opted into marketing, to communicate
with you about products, services, marketing, promotions, events and other
news and information we think will be of interest to you.
In addition, we will
use some or all of the above personal information to comply with any applicable
legal obligations and to protect or defend our rights, the rights of our users,
or others.
HOW WE DISCLOSE YOUR
INFORMATION
We do not disclose your
personal information with third parties other than as described above and as
follows:
- We disclose your personal information with
service providers who help with parts of our business operation, such as
cloud storage providers, IT service providers, and analytics and search
engine providers that assist us in the improvement and optimization of our
Sites.
- We may disclose your personal information
with advertising publishers, marketing and analytics companies.
- We may disclose your personal information
with third parties in order to (a) comply with laws and respond to lawful
requests and legal process, (b) enforce our Terms of Use, including
investigation of potential violations thereof, (c) detect, prevent, or
otherwise address fraud, security or technical issues, or (d) protect
against harm to the rights, property or safety of Pyralink, its users or
the public as required or permitted by law.
- We may disclose or transfer your personal
information to a third party if we sell, transfer, divest, or disclose all
or a portion of our business or assets to another company in connection
with or during negotiation of any merger, financing, acquisition,
bankruptcy, dissolution, transaction, or proceeding.
- We will otherwise disclose your information
as directed by you or subject to your consent.
- With respect to those users who have a
username (and personal photo or avatar, if any, provided by you and
associated with your username), such information will be displayed on our
Sites.
Information you provide
through your participation in research projects, community discussions, chats,
and any correspondence through our Sites, will be disclosed to other users, our
customers or otherwise displayed on our Sites.
CALIFORNIA RESIDENTS
This section applies
only to California residents.
Processing of
Personal Information
In the preceding 12
months, we collected and disclosed for a business purpose the following
categories of personal information about residents:
Categories of Personal Information |
Categories of Recipients |
Identifiers, such as your first and last name, username,
Internet Protocol (IP) address and email address |
Cloud storage providers, IT service providers,
analytics and search engine providers |
Personal information categories listed in the
California Customer Records statute, such as your postal address and phone
number |
Cloud storage providers, IT service providers,
analytics and search engine providers |
Internet or other similar network activity, such as
your computer operating system, access times, browsing history and web log
information, browser type and language, and “click stream” data, such as
domain names and page views |
Cloud storage providers, IT service providers,
analytics and search engine providers |
Geolocation data, such as information about your
location |
Cloud storage providers, IT service providers,
analytics and search engine providers |
Professional or employment-related information,
such as your company name and job title |
Cloud storage providers, IT service providers,
analytics and search engine providers |
Other information, such as any information customer
account holders provide us with during their use of our platform’s messaging
system |
Cloud storage providers, IT service providers,
analytics and search engine providers |
We do not collect, use,
or disclose personal information for purposes other than those specified in our
Privacy Policy. The purposes for which we collect your personal information are
described in the section above, How We Use Your Information, and
the categories of sources from which we collect your personal information are
described in the section above, Information We Collect. We
disclosed personal information over the preceding 12 months for the business
purposes described in the section above, How We Disclose Your
Information. Finally, the criteria we use to determine how long to retain
personal information is described in the section below, Security and
Retention of Your Information.
SELLING OR SHARING
PERSONAL INFORMATION / OPTING-OUT OF TARGETED ADVERTISING
Pyralink does not
“sell” (as “sell” is traditionally defined) personal information about our
consumers. We do not make available or provide consumer’s names, phone numbers,
physical addresses, email addresses, or other personal information to third
parties in exchange for money. Like many companies, however, we have
shared (as that term is defined in the CCPA) personal information in the
preceding 12 months with third parties to provide you with personalized
advertising about our Services when you visit other websites, better
understanding our audience base, and customizing our advertising and marketing
campaigns. This is considered a (1) “sale’’ or a (2) a “share” of personal
information to target advertisements to a consumer under the CCPA, which is
subject to a right of opt-out in some jurisdictions.
Please note, some
transfers of personal information may not be subject to this opt-out, and your
selection does not affect other sharing of personal information about you as
outlined in our Privacy Policy. For questions, please email privacy@pyralink.co.uk.
WHERE WE STORE YOUR
PERSONAL INFORMATION
Our Sites and the
servers upon which our Sites are hosted are located in the United Kingdom. The
personal information that we collect from you will be transferred to the United
Kingdom. The personal information held by us will be stored in the United Kingdom.
We will take all steps reasonably necessary to ensure that your personal
information is treated securely and in accordance with our Privacy Policy.
In case of transfers of
personal information out of Europe, see the “EU-US Data Transfers” section of
our Privacy Policy.
SECURITY AND RETENTION
OF YOUR INFORMATION
We follow generally
accepted industry standards to protect personal information submitted to us
from unauthorized access, both during transmission and once we receive it.
However, no data transmission over the Internet or other network can be
guaranteed to be 100% secure. As a result, while we strive to protect
information transmitted on or through our Sites, we cannot and do not guarantee
the security of any information you transmit on or through our Sites, and you
do so at your own risk.
We retain the Personal
Information we process for as long as needed to provide services to our users
or as necessary to fulfil the purpose(s) for which it was collected. We will
retain and use this Personal Information as necessary to comply with our legal
obligations, resolve disputes, and enforce our agreements.
AGE LIMITATIONS
We do not knowingly
collect personal information from children under 16. If we learn that we have
collected the personal information of a child under 16, we will take steps to
delete the information as soon as possible.
YOUR DATA PRIVACY
RIGHTS
You may have rights
under relevant data privacy laws, including the CCPA, the General Data
Protection Regulation (EU) 2016/679 (the GDPR), the UK GDPR and other
applicable laws and regulations.
Depending on where you
are based, those rights can include the right to:
- Access/Know: Request access or copies of your personal
information Pyralink processes and details of how we use it, and who we
share it with;
- Correction: Rectify incorrect personal information;
- Erasure: In certain circumstances, you have the
right to request that we delete your personal information;
- Restriction: Restrict the processing of your personal
information other than for storage purposes, in certain circumstances;
- Portability: Request a commonly structured,
machine-readable copy of your personal information and that such
information is transferred to another data controller in certain
circumstances and with certain exceptions;
- Right to Opt out of Sale or Sharing: direct us not to “sell” or “share” your
personal information (as those terms are defined under the CCPA). To
exercise this right, see the opt-out section;
- Objection: Object to our processing of your
personal information;
- Complain: Lodge complaints with the competent data
protection supervisory authority in the EEA country in which you live or
work or where you think we have infringed data protection laws or with the
UK Information Commissioner’s Office, as applicable to you, though we
would encourage you to contact us in the first instance to relay any
concerns; and/or
- Non-discrimination: Not to be discriminated against for
exercising any of these rights.
Please note that a
number of these rights only apply in certain circumstances, and all of these
rights may be limited by law. For example, these rights may be limited where
fulfilling your request would adversely affect other individuals or our trade
secrets or intellectual property, where there are overriding public interests
or where we are required by law to retain your personal information.
To exercise these
rights, or to ask questions or relay concerns, please contact us via email
at privacy@pyralink.co.uk,
phone at +44 (0) 191 691 9300 or by mail at: Pyralink Innovation LTD, Attn:
Legal Department, Aidan House Sunderland Road Gateshead, NE8 3HU, England.
To respond to some
rights, we may need to verify your request either by asking you to log in and
authenticate your account or otherwise verify your identity by providing
information about yourself or your account. Authorized agents can make a
request on your behalf if you have given them legal power of attorney or we are
provided proof of signed permission, verification of your identity, and, in
some cases, confirmation that you provided the agent permission to submit the
request.
WITHDRAWAL OF CONSENT
Where you have provided
your consent to us processing your personal information, you can withdraw your
consent at any time by contacting us at privacy@pyralink.co.uk.
OBJECTION TO MARKETING
You have the right to
opt-out of receiving promotional emails from Pyralink by following the
instructions in those emails. If you opt-out, we could still send you
non-promotional emails, such as emails about your Pyralink account or our
ongoing business relations. You can also send requests about your contact
preferences or changes to your information, including requests to opt-out of
disclosing your personal information with third parties, to our contact
information below.
If you have an account,
you can choose to either temporarily set your account offline or permanently
delete it. In the event you choose to set your account offline, you will not be
able to use our Sites until you decide to reactivate your account, and your
information will remain with Pyralink. In the event you delete your account, we
will delete all personal information.
EU – U.S. DATA
TRANSFERS
European Union Model
Contract Clauses
Pyralink offers
European Union Model Clauses, also known as Standard Contractual Clauses, to
meet the adequacy and security requirements for our Customers that operate in
the European Economic Area, UK or Switzerland. To the extent that Pyralink
receives from a Customer any personal information of individuals located in the
European Economic Area, UK or Switzerland, the parties will be deemed to have
entered into the applicable Standard Contractual Clauses in respect of such
transfer, whereby Pyralink is the “data importer” and the Customer is the “data
exporter,” unless otherwise agreed.
EU-U.S. Data Privacy
Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the
Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF)
Pyralink complies with
the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to
the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S.
DPF) as set forth by the U.S. Department of Commerce. Pyralink has certified
to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy
Framework Principles (EU-U.S. DPF Principles) regarding the processing of
personal data received from the European Union in reliance on the EU-U.S. DPF
and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to
the EU-U.S. DPF. Pyralink has certified to the U.S. Department of Commerce
that it adheres to the Swiss-U.S. Data Privacy Framework program Principles
(Swiss-U.S. DPF Principles) with regard to the processing of personal data
received from Switzerland in reliance on the Swiss-U.S. DPF. If there is
any conflict between the terms in this privacy policy and the EU-U.S. DPF
Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.
To learn more about the Data Privacy Framework (DPF) program, and to view our
certification, please visit https://www.dataprivacyframework.gov/.
Pyralink is subject to
the investigatory and enforcement authority of the U.S. Federal Trade
Commission. Pyralink is responsible for the processing of personal information
it receives and subsequently transfers to a third party acting as an agent on
its behalf.
Pyralink commits to
cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data
Protection and Information Commission (FDPIC) and comply with the advice given
by such authorities with regard to human resources data transferred from the EU
and Switzerland in the context of the employment relationship.
In certain situations,
Pyralink could be required to disclose personal information in response to
lawful requests by public authorities, including to meet national security or
law enforcement requirements.
PRIVACY DISPUTE
RESOLUTION
In compliance with the
EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S.
DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), Pyralink
commits to resolve complaints about our collection or use of your personal information
transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the
EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with
inquiries or complaints should first contact Pyralink via email at privacy@pyralink.co.uk, by phone at +44
(0) 191 691 9300 or by mail at: Pyralink Innovation LTD., Attn: Legal
Department, Aidan House Sunderland Road Gateshead, NE8 3HU, England.
Pyralink has further
committed to refer unresolved privacy complaints under the DPF Principles to an
independent dispute resolution mechanism, Data Privacy Framework Services,
operated by BBB National Programs. If you do not receive timely acknowledgment
of your complaint, or if your complaint is not satisfactorily addressed, please
visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for
more information and to file a complaint. This service is provided free of
charge to you.
If your DPF complaint
cannot be resolved through the above channels, under certain conditions, you
may invoke binding arbitration for some residual claims not resolved by other
redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2.
CHANGES TO THIS PRIVACY
POLICY
We update our Privacy
Policy from time to time when our privacy practices change. When we update our
Privacy Policy, we will revise the “Last updated” date above and post the new
Privacy Policy to our Sites.
CONTACT US
Please address any
questions, comments, and requests regarding this privacy statement to:
Address: Aidan House
Sunderland Road Gateshead, NE8 3HU, England.
Phone: +44 (0) 191 691
9300
Email: info@pyralink.co.uk