Pinnacle prioritizes your privacy. Explore our approach.
2. INFORMATION WE COLLECT
Some portions of the Site require us to learn more about you so that we can best meet your needs.
2.1 PERSONAL INFORMATION WE COLLECT DIRECTLY FROM YOU
We receive personal information directly from you when you voluntarily provide us with such personal information, including, without limitation, the following:
- (1) personal information (such as your e-mail address, phone number, or profile photo);
- (2) company information (such as your company’s address); and
- (3) other identifying information that you voluntarily choose to provide to us, including without limitation unique identifiers such as passwords, and personal information in messages that you send to us.
We may also collect additional information, which may be personal information, as otherwise described to you at the point of collection or pursuant to your consent.
2.2 INFORMATION WE AUTOMATICALLY COLLECT WHEN YOU USE OUR SITE
In order to access and use certain areas or features of the Site, you consent to our collection and use of certain information about your use of the Site through the use of tracking technologies or by other passive means. Your consent to our access and use of this “passively collected” information includes, but is not limited to, the domain name of the website that allowed you to navigate to the Site, search engines used, the internet protocol (IP) address used, the length of time spent on the Site, the pages you looked at on the Site, other webpages you visited before and after visiting the Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics, including the following:
- Traffic Data We also may automatically collect certain data when you use the Site, such as: (1) IP address; (2) domain server; (3) type of device(s) used to access the Site; (4) web browser(s) used to access the Site; (5) referring webpage or other source through which you accessed the Site; (6) geolocation information; and (7) other statistics and information associated with the interaction between your browser or device and the Site (collectively, “Traffic Data”). Depending on applicable law, some Traffic Data may be personal information.
3. HOW WE COLLECT INFORMATION
We collect information (including personal information and Traffic Data) when you use and interact with the Site, and in some cases from third party sources. Such means of collection include:
- When you use the Site’s interactive tools and services;
- When you voluntarily provide information in free-form text boxes through the Site or through responses to surveys, questionnaires and the like;
- If you use a location-enabled browser, we may receive information about your location and mobile device, as applicable;
- Through cookies, web beacons, analytics services and other tracking technology (collectively, “Tracking Tools”), as described below; and
- When you use the “Contact Us” function on the Site, send us an email or otherwise contact us.
4. TRACKING TOOLS, BEHAVIORAL ADVERTISING, AND OPT OUT OPTIONS
4.1. TRACKING TOOLS
We may use tools outlined below in order to provide our Site to, advertise to, and to better understand users.
- Some cookies are placed by a third party on your device and provide information to us and third parties about your browsing habits (such as your visits to our Site, the pages you have visited, and the links and advertisements you have clicked). These cookies can be used to determine whether certain third party services are being used, to identify your interests, and to serve advertisements relevant to you. We do not control third party cookies.
- Web Beacons “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files embedded in a web page or email that may be used to collect information about the use of our Site, the websites of selected advertisers and the emails, special promotions or newsletters that we send. The information collected by Web Beacons allows us to analyze how many people are using the Site, using selected publishers’ websites or opening emails, and for what purpose, and also allows us to enhance our interest-based advertising (discussed further below).
- Web Service Analytics We may use third-party analytics services in connection with the Site, including, for example, to register mouse clicks, mouse movements, scrolling activity and text typed into the Site. We use the information collected from these services to help make the Site easier to use and as otherwise set forth in Section 5 (How We Use Your Information). These analytics services generally do not collect personal information unless you voluntarily provide it and generally do not track your browsing habits across web services that do not use their services.
- Mobile Device Identifiers As with other Tracking Tools, mobile device identifiers help Pinnacle learn more about our users’ demographics and internet behaviors in order to personalize and improve the Site. Mobile device identifiers are data stored on mobile devices that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of personal information (such as media access control, address and location) and Traffic Data.
4.2. BEHAVIORAL ADVERTISING
We may use a type of advertising commonly known as interest-based or online behavioral advertising. This means that some of our partners use Tracking Tools to collect information about a user’s online activities to display Pinnacle ads to the user based on the user’s interests (“Behavioral Advertising”). Such partners may include third-party service providers, advertisers, advertising networks or platforms, traffic measurement service providers, marketing analytics service providers, and other third party service providers (collectively, “Advertising Service Providers”). Other Tracking Tools used by our partners may collect information when you use the Site, such as IP address, mobile device ID, operating system, browser, web page interactions, geographic location and demographic information, such as gender and age range. These Tracking Tools help Pinnacle learn more about our users’ demographics and internet behaviors.
4.3. OPTIONS FOR OPTING OUT OF COOKIES AND MOBILE DEVICE IDENTIFIERS
Some web browsers allow you to reject cookies or to alert you when a Cookie is placed on your computer, tablet or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept Pinnacle’s cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Site.
- You may opt out of receiving certain cookies and certain trackers by visiting the Network Advertising Initiative (NAI) opt out page or the Digital Advertising Alliance (DAA) opt out page, or by installing the DAA’s AppChoice app (for iOS; for Android) on your mobile computing device. When you use these opt-out features, an “opt-out” Cookie will be placed on your computer, tablet or mobile computing device indicating that you do not want to receive interest-based advertising from NAI or DAA member companies. If you delete cookies on your computer, tablet or mobile computing device, you may need to opt out again. For information about how to opt out of interest-based advertising on mobile devices, please visit http://www.applicationprivacy.org/expressing-your-behavioral-advertising-choices-on-a-mobile-device. You will need to opt out of each browser and device for which you desire to apply these opt-out features.
- Even after opting out of Behavioral Advertising, you may still see Pinnacle advertisements that are not interest-based (i.e., not targeted toward you). Also, opting out does not mean that Pinnacle is no longer using Tracking Tools — Pinnacle still may collect information about your use of the Site even after you have opted out of Behavioral Advertising and may still serve advertisements to you via the Site based on information it collects via the Site.
4.4. HOW PINNACLE RESPONDS TO BROWSER “DO NOT TRACK” (DNT) SIGNALS
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to web services that a visitor does not want to have his/her online activity and behavior tracked. If a web service operator elects to respond to a particular DNT signal, the web service operator may refrain from collecting certain personal information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many web service operators, including Pinnacle, do not proactively respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.
5. HOW WE USE YOUR INFORMATION
We may use information (including information that has been de-identified and/or aggregated) to better understand who uses the Site and how we can deliver a better user experience.
We use information, including personal information, to provide the Site and to help improve the Site, to develop new services, and to advertise (for example, to display Pinnacle ads on other web services). Specifically, such use may include:
- Providing you with the products, services and information you request;
- Responding to correspondence that we receive from you;
- Contacting you when necessary or requested, including to remind you of an upcoming appointment;
- Providing, maintaining, administering or expanding the Site, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Site, and other products and services we offer;
- Customizing or tailoring your experience of the Site, which may include sending customized messages or information;
- Notifying you about certain resources or services we think you may be interested in learning more about;
- Sending you information about Pinnacle or our products or the Site;
- Sending emails and other communications that display content that we think will interest you and according to your preferences;
- Showing you advertisements, including interest-based or online behavioral advertising;
- Using statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
- Fulfilling our legally required obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities;
- olving disputes;
- Protecting against or deterring fraudulent, illegal, or harmful actions; and
6. HOW WE SHARE YOUR INFORMATION
In certain circumstances, and in order to perform the Site, we may share certain information that we collect from you, as described in this section:
- We do not sell email addresses to third party brokerages. We may share your personal information with our partners or clients to fulfill the obligations of our client project requirements or services.
- We may share your personal information and/or Traffic Data with our partners who perform operational services (such as hosting, billing, fulfillment, data storage, security, insurance verification, web service analytics, or ad serving) and/or who make certain services, features or functionality available to our users.
- Cross Device Matching To determine if users have interacted with content across multiple devices and to match such devices, we work with partners who analyze device activity data and/or rely on your information (including demographic, geographic and interest-based data). To supplement this analysis, we also provide de-identified data to these partners. Based on this data, we may then display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of the Site across devices.
- Business Transfers We may transfer your personal information to another company in connection with a proposed merger, sale, acquisition or other change of ownership or control by or of Pinnacle (whether in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
- Other Information We may disclose information that is neither personal information and/or has been de-identified and/or aggregated at our discretion.
7. STORAGE AND SECURITY OF INFORMATION
The security of your personal information is important to us. We endeavor to follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and in storage.
We store and process your information on our servers in the United States. We maintain industry standard backup and archival systems. Although we make good faith efforts to store personal information in a secure operating environment that is not open to the public, we do not and cannot guarantee the security of your personal information. If at any time during or after our relationship we believe that the security of your personal information may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us. If you receive a notice from us, you can print it to retain a copy of it. To receive these notices, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use of e-mail as a means of such notification. If you prefer for us to use the U.S. Postal Service to notify you in this situation, please e-mail us at firstname.lastname@example.org. Please include your address when you submit your request. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use this e-mail address to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your personal information.
8. YOUR CHOICES
8.1 INFORMATION YOU PROVIDE
You can always choose whether or not to provide personal information on the Site. However, if you choose not to disclose certain personal information, you may not be able to register as a user of the Site, which may limit your access to certain portions of the Site. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services. You can request access to, or deletion of, your personal information that we collect and maintain through our Site by contacting us at email@example.com with “Request for Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Whichever way you elect to contact us, we may ask that you confirm and verify your identity.
8.2 YOUR RIGHTS AND YOUR PERSONAL DATA UNDER DATA PROTECTION LAWS
Unless subject to an exemption, if your personal data is subject to Data Protection Laws, the GDPR, UK GDPR, or PIPEDA, you have the following rights with respect to your personal data as applicable:
- The right to request a copy of your personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data be erased where it is no longer necessary for us to retain such data;
- The right to withdraw your consent at any time to the processing of personal data to which you provided consent for processing;
- The right to request that we provide you with a copy of your personal data and where possible, to transmit that data directly to another data controller (known as the right to data portability);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction be placed on further processing;
- The right to object to the processing of personal data (where applicable); and
- The right to lodge a complaint with a data supervisory authority.
Please note that we may verify your identity before we are able to process any of the requests described in this Section, and in our discretion, deny your request if we are unable to verify your identity. As a part of this process, government or other identification may be required.
If your personal data is subject to the GDPR or UK GDPR, we will transfer personal data from the European Economic Area (EEA) to a location outside the EEA only when there has been a documented adequacy determination, or where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place.
If your personal data is subject to PIPEDA, we will transfer personal data from Canada to locations outside of Canada only where we have confirmed adequate privacy protections. If we transfer personal data to a third party acting as our agent, we will also obligate the third party to have adequate privacy protections in place.
We may transfer personal data to and on behalf of clients and third parties with whom we have an existing service agreement or as part of our legal obligations, each of which shall be subject to our policies, and only to the extent necessary for purposes of legitimate interests pursued by the data controller (or by a third party).
Under the GDPR and UK GDPR, data subjects have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent. We do not engage in automated decision making.
Any individual may, at any time, contact us directly with any questions and suggestions concerning data protection. We encourage individuals to raise any concerns about the collection, use, or processing of your personal data using the contact information provided above. In the event of a privacy related issue or complaint, we will investigate and attempt to promptly resolve any complaints and disputes regarding use and disclosure of personal information.
For complaints that cannot be resolved, if your personal data is subject to the GDPR, we commit to cooperating with the panel established by the EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner (FDPIC), as applicable, and comply with the advice given by the DPAs or FDPIC about personal data transferred from the EU or Switzerland. Individuals in the EU can choose to contact their national DPA or use the form located at: http://ec.europa.eu/newsroom/document.cfm?doc_id=42962. Individuals in Switzerland can contact the Swiss FDPIC by visiting: https://www.edoeb.admin.ch/edoeb/de/home.html. Individuals in Canada can contact the OPC at https://www.priv.gc.ca/en/contact-the-opc/. Individuals in British Columbia can contact the OIPC at https://www.oipc.bc.ca/for-the-public/how-do-i-make-a-complaint/.
If your personal data is subject to the GDPR or UK GDPR, the data controller for the purposes of GDPR, UK GDPR or other data protection laws applicable in Member states of the European Union and other provisions related to data protection is:
Pinnacle Data Privacy Officer
If you are a California resident, you have certain rights over your Personal Information held by Pinnacle under the California Consumer Privacy Act (the “CCPA”). CCPA does not take effect until January 1, 2023. More information regarding individual data rights for California residents will be made available at that time.
8.4 FURTHER PROCESSING
9. HOW LONG WE RETAIN YOUR INFORMATION
10. INFORMATION PROVIDED ON BEHALF OF CHILDREN AND OTHERS
The Site is not intended for use by children and individuals under the age of 18 are prohibited from using the Site. Pinnacle does not knowingly collect any information from children, nor is the Site directed to children. If you are under 18, please do not attempt to register for the Site or send any personal information about yourself to us.
By accessing, using and/or submitting information to or through the Site, you represent that you are not younger than age 18. If we learn that we have received any information directly from a child under age 18 without his/her parent’s written consent, we will use that information only to respond directly to that child (or his/her parent or legal guardian) to inform the child that he/she cannot use the Site, and we will subsequently delete that information. If you believe that a child under 18 may have provided us personal information, please contact us at firstname.lastname@example.org.
If you use the Site on behalf of another person, regardless of age, you agree that Pinnacle may contact you for any communication made in connection with providing the Site or any legally required communications. You further agree to forward or share any such communication with any person for whom you are using the Site on behalf.
11. OTHER WEB SERVICES
13. CONTACT US
Attn: Information Compliance
7090 NE Westmark Drive
Hillsboro, OR 97124