Privacy Policy

I. Introduction

At PickPillar, Inc, data privacy is important to us. This PickPillar, Inc Privacy Policy (“Privacy Policy”) details our privacy practices for the activities described in this Privacy Policy. Please take the time to read this Privacy Policy carefully in order to understand how we collect, share, and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding our processing of your Personal Data.

In this Privacy Policy, “PickPillar, Inc,” “we,” “our,” and “us” each mean PickPillar, Inc and the applicable PickPillar, Inc affiliate(s) involved in the processing activity. “Customer,” “you,” “your,” or “user” will refer to you, your employer, or the entity you are representing.

This Privacy Policy may be updated from time to time, to reflect changes in our practices, technologies, additional factors, and to be consistent with applicable data protection and privacy laws and principles, and other legal requirements. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a notice on our website or by contacting you using the email address you provided.

II. PickPillar, Inc’S. Roles & Responsibilities

PickPillar, Inc is the controller of your Personal Data, as described in this Privacy Policy, unless otherwise stated. Please note that this Privacy Policy does not apply to the extent that we process Personal Data in the role of a processor (or a comparable role such as “service provider” in certain jurisdictions) on behalf of our Customers, including where we offer to our Customers various cloud products and services, through which our Customers (and/or their affiliates) connect their own websites and applications to our hosted platform, sell or offer their own products and services, send electronic communications to other individuals, or otherwise collect, use, share or process Personal Data via our cloud products and services.

Each of our Customers, not PickPillar, Inc, controls whether they provide your subscription to the PickPillar, Inc cloud service, and if they provide you with a subscription/access, they control what information about you that they submit to our service. This content may include contact information (such as your first and last name, email address, and phone number), professional information, or other types of information a Customer chooses to submit. Use of this content by PickPillar, Inc is governed by agreements between PickPillar, Inc and the Customer.

For detailed privacy information applicable to situations where a Customer (and/or a Customer affiliate) who uses PickPillar, Inc’s. services is the controller, please reach out to the respective Customer directly. We are not responsible for the privacy or data security practices of our Customers, which may differ from those set forth in this Privacy Policy. If not stated otherwise either in this Privacy Policy or in a separate disclosure, we process such Personal Data in the role of a processor or service provider on behalf of a Customer (and/or its affiliates), who is the responsible controller of the applicable Personal Data.

If your Personal Data has been submitted to us by or on behalf of a Customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable Customer directly. Because we may only access a Customer’s data upon instruction from that Customer, if you wish to make your request directly to us, please provide to us the name of the PickPillar, Inc Customer who submitted your Personal Data to us. We will refer your request to that Customer and support them as needed in responding to your request within a reasonable timeframe.

III. Personal Data We Collect and Data Sources

Covered Data Processing Activities

This Privacy Policy applies to the processing of Personal Data that we collect in the following ways, as detailed in this section.

We collect information about you when you provide it to us, when you interact with our website’s dashboard, and electronic systems, and when you attend events (virtual or in-person), and when other sources provide it to us, as further described below.

Information you provide to us

Based on our current practices we collect the following categories of information about you:

• Contact and Professional Data: We may collect contact and/or professional data about you in person, through communications, including communications from you or your colleagues, and through our websites, such as telephone number, email address, and mailing address, and professional data includes details such as the organization you are affiliated with, your job title, and industry.

• Biographical and Support-related Data: We may also collect various types of biographical and support-related Personal Data. Additionally, you may provide Personal Data to us when you create user-generated content, provide PickPillar, Inc with feedback, or when you participate in interactive features, trainings, online surveys, contests, promotions, sweepstakes, activities, or events. You may also be asked to provide contact information, a summary of the problem you are experiencing, and any other information that would be helpful in resolving a Customer support request.

• Contract and Payment Data: We may receive contract details (like signatures) from you or your organization and use third-party payment processing services to collect payment and billing information, which may contain Personal Data such as billing name, billing address and payment card details, in connection with some of our products and services.

• Audio, Electronic, or Visual Data: If you attend a PickPillar, Inc in-person or virtual event or agree to be recorded in a telephone or video meeting, we may record some or all of that event or meeting. We use this information for business and marketing purposes to better inform the public about PickPillar, Inc, its events, and provide testimonials about our products and services.

• Job Applicant Data: You provide your contact and professional information, including your resume with educational and work background, when you apply for a job with PickPillar, Inc You may also provide us with sensitive information, like your Social Security Number or other government identifier, racial or ethnic origin, or other such Personal Data in connection with your job application.

Personal Data We Collect From Other Sources

We may receive Personal Data and other information from other third parties for our business or commercial purposes. This information varies and typically falls into a few categories:

• Business contact information (such as name, job title, business email, phone number, and address), social profile including other details about your company for sales and marketing purposes, including to better inform you about PickPillar, Inc products and services.

• Third-party platform usernames and identifying information.

• Details about you as a job candidate as permitted under law; and

• Data used for security purposes to protect our products and services.

We receive business contact information that contains Personal Data for commercial purposes, including details about your company from third parties for marketing and business intelligence, such as analyzing business opportunities, identifying potential new Customers, and providing our audience with more relevant content and advertising. Typically, we receive this information about you from a few sources, such as: (i) third-party marketing initiatives; (ii) companies, such as information aggregators and similar entities, from whom we have licensed business contact information; and (iii) referrals. In some situations, we may combine such business contact information with other non-personal and Personal Data we possess or that you have provided to us. For example, we may combine business contact details with details about your organization, such as its address or revenue range, and analyze this information for business opportunities or use this to send you tailored content.

For our professional services work, as a service provider, PickPillar, Inc may also receive Personal Data about you to perform its obligations under its contract with a third party. PickPillar, Inc partners may also share your business contact information with PickPillar, Inc as part of their recommendation to your company to become a PickPillar, Inc Customer. If PickPillar, Inc is interested in partnering with, acquiring, investing in, or partners with, acquires, or invests in your employing or retaining company, PickPillar, Inc may receive Personal Data about you through the transaction for its business purposes.

Device Data, Usage Data, and Metadata We May Collect

Like most websites, applications, and software across the Internet, PickPillar, Inc collects certain Personal Data. This type of data collection allows us to better understand how individuals use our websites, products and services and how they perform. For example, we may collect metadata about you, including technical data about your performance or use of our website, products and services. We may also collect device data about you to help us determine that users from one type of device use our websites, products and services in different ways than users of a different type of device, which in turn allows us to improve our websites, products and services, making sure Customers’ users have a more efficient user experience.

One common technology we use to collect metadata that may be considered Personal Data is our use of cookies. Cookies are small text files that are placed on your web browser and that help us recognize your browser or device as a unique visitor in different ways based on the type of cookie. The main types of cookies are:

• Essential and functional cookies. Essential cookies are required for website functionality and security. For example, authentication, security, and session cookies may be required for our website or products to work. We may also use functional cookies to help enhance our websites’ performance, for market research, or other analytics or advertising that is not tied to a specific individual. These types of cookies are different from browser cookies in the amount and type of data they store and how they store it.

• Targeting or advertising cookies. We may use targeting and advertising cookies to help us understand our marketing efforts and to reach potential Customers across the web. For example, we contract with third-party advertising networks that may track your activity over time and across different channels, including our websites, email activity, and other websites and applications that display advertisements. They may use this tracking information to understand and predict your interests, to display an advertisement for PickPillar, Inc on another website, or email you with a marketing communication for a PickPillar, Inc product.

• Beacons. A second common technology we may use to collect metadata that may be considered Personal Data is beacon technology. We use beacons in our websites and in email communications to you. Beacons provide us with information about your activity and help us to improve our business operations and strategy, such as by understanding our email communications’ functionality and improving our websites and content.

Data Collected from the COMPANY Service and Ancillary Products

We offer products that collect both customer data and usage data. Our collection of both types of data enables us to provide and innovate upon the PickPillar, Inc’s. service, which in turn allows us to act as a service provider to our Customers and to continuously improve upon the services we provide to our Customers. In conjunction with the services and products we make available to our Customers, we may collect additional data, such as user-agent and browser version, IP address, the URLs you visit, logs of your usage and click activities, logs about your login history, identity confirmation, and device data (such as whether your device is managed by an administrator, the operating system installed on the device, certain device configurations, and similar device or version information). We may collect data including the applications that are installed on your device (“Ancillary Data”). Some of the Ancillary Data we receive is dependent on your organization’s policies and settings and what it permits to be shared with PickPillar, Inc PickPillar, Inc uses Ancillary Data to improve security and to provide and improve its products to Customers, including to better understand Customer behavior to create new features and provide threat-related insights for our Customers. For example, we may use the URL you visit to let you better manage your passwords for the websites you visit.

The Ancillary Data we may collect includes details about your login session, IP address, user-agent, and the web application name and website address, as well as other information that is not personal in nature. In addition, we may collect interaction data about your use of the PickPillar, Inc browser plugin. We use the information collected through the PickPillar, Inc browser plugin for security purposes and to provide features, such as by allowing you to better manage your passwords for websites that you visit.

COMPANY as a Business

As with most websites, whenever you visit a PickPillar, Inc website, take a PickPillar, Inc training, engage with the PickPillar, Inc, or when you interact with PickPillar, Inc promotional content, PickPillar, Inc may receive both Personal Data about you from information-gathering tools and passive information collection on our websites, including Personal Data from our websites you visit or emails we send. This information collection typically includes information such as cookies, beacons, demographic information, company and role details, market research and publicly-available information, IP address, device and browser details, usage information, timestamps, pages viewed, searches, interaction with and action taken by you on our websites or content, as well as other non-Personal Data.

We use the information we collect as a business to analyze and predict results arising from our sales and marketing efforts, improve the performance of our websites, products and services and Customer support, identify potential Customers, opportunities, and potential new product areas, ascertain trends, improve our websites’ functionality, improve our security, and provide us with general business intelligence, including through the use of machine learning technology. We may also combine the metadata and usage information collected from our websites with other information to help further the purposes described in the previous sentence.

Disclosures to Third Parties

As part of the functionality we make available on our websites and to better reach our Customers and prospective Customers, there may be categories of third parties that are authorized by us to operate on our websites and access your Personal Data, such as your contact data, IP address or cookies. These categories of third parties include, but are not limited to, advertising networks and social networks. At any time, you may choose to withdraw your decision to share personal data with these third parties through our websites by submitting your request to the contact information below.

IV. How We Use Personal Data

How we use the Personal Data we collect depends in part on how you choose to communicate with us, how you use our websites and interact with us, and any preferences you have communicated to us. In general, we use your Personal Data as is necessary to run our business and carry out our day-to-day activities. In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Data to accomplish the following tasks:

• Communicate with you about our products and services and facilitate other interaction. We may use your Personal Data, such as contact data, Ancillary Data, and metadata, to send you transactional communications, notices, updates, security alerts, and administrative messages regarding our products and services that may be useful to you and your organization.

• Support safety, security, and manage operations. We use Personal Data, such as contact data, Ancillary Data and other metadata, about you and your use of our products, services, and offices to verify accounts and activity, monitor suspicious or fraudulent activity, assist our Customers in their monitoring of suspicious or fraudulent activity, and identify violations of policies regarding the use of our products and services.

• Market and promote our products and services. We may use your Personal Data, such as contact data, Ancillary Data, and other metadata, about how you use the products and services to send promotional communications that may be of specific interest to you and your organization, including by email and by displaying PickPillar, Inc marketing communications on other companies’ websites and applications. These communications are aimed at encouraging engagement and maximizing the benefits that you and your organization can gain from PickPillar, Inc’s. products and services, including information about new products and features, survey requests, newsletters, and events we think may be of interest to you and your organization.

• Process payments. We process Personal Data, such as contact information, contract-related data, financial information, biographical information, and payment information to process payments to the extent that doing so is necessary to complete a transaction and perform our contract with you or your organization.

• Recruiting. We process your Personal Data, such as contact, job applicant, and biographical data, to assess your application and to evaluate and improve the recruitment system, our application tracking and recruitment activities. We also use your Personal Data to communicate with you regarding your application or opportunities at PickPillar, Inc that appear over time that we believe may be of interest to you.

• Other purposes for our legitimate interests. Where required by law or where we believe it is necessary to protect our legal rights, interests, or the interests of others, we may use your Personal Data in connection with the management of our business, including, but not limited to, for operational purposes, legal claims, compliance, regulatory, and audit functions, protecting against misuse or abuse of our products and services, and protecting personal property or safety.

• Other purposes with your consent. We may use your Personal Data if you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured Customer stories to promote our products and services or record phone calls for quality and training purposes, with your permission.

Legal Bases for Processing Personal Data (for European Economic Area Users)

If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have a legal basis or bases for doing so under applicable EU laws. The legal bases depend on the products and services that your organization has purchased from PickPillar, Inc Inc., how such products and services are used, and how you choose to interact and communicate with PickPillar, Inc’s. website, systems, and whether you attend PickPillar, Inc events. This means we collect and use your Personal Data only where:

• We need it to operate and provide you with our products and services, provide Customer support and personalized features, and to protect the safety and security of our products and services;

• It satisfies a legitimate interest of PickPillar, Inc’s. (which is not overridden by your data protection interests), such as for research and development, to provide information to you about our products and services that we believe you and your organization may find useful, and to protect our legal rights and interests;

• You give us consent to do so for a specific purpose; or

• We need to comply with a legal obligation.

If you have consented to our use of Personal Data about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your Personal Data because we or a third party (for example, your employer) have a legitimate interest to do so, you have the right to object to that use; however, in some cases, this may mean that you may no longer use our products and services.

V. Personal Data Shared by PickPillar, Inc

Service Providers. For all categories of information that we collect, we share Personal Data with our service providers for various business purposes, including, but not limited to, auditing interactions with users, debugging our websites, products and services, security purposes, internal research and gleaning insights through machine learning, short-term uses such as credit verification, payment processing, IT services, quality control and safety, gift fulfillment, event management, as well as to perform other services on our behalf.

Partners and Resellers. We share your Personal Data, such as contact information, business details, and content interest and activity details, with our partners and resellers for business purposes, such as to carry out our business or for joint marketing efforts to reach our Customers and prospective Customers.

Protection of Rights, Security and Fraud Detection. For all categories of data we collect, we share your Personal Data with third parties for business purposes to protect our Customers, users, secure our physical and intellectual property, and to prevent or investigate security or fraudulent attempts against our users through our platform.

Law Enforcement and Legal Requests. We may share Personal Data to comply with applicable law or respond to valid legal requests, such as a subpoena, from law enforcement or other authorities.

With our Affiliates, Related to Corporate Transactions, and Provision of Professional Services. We may share Personal Data among our affiliates and subsidiaries for business purposes, including any service providers and agents that work on our behalf. We may also share your information as required for us to carry out a corporate transaction or share your Personal Data with our professional service providers as needed for us to run our business.

Advertising and Marketing. We share your Personal Data, such as metadata and contact data, with third-party advertising and marketing providers, to allow us to better reach our Customers and prospective Customers, and to sell our products and services. In some circumstances we may ask you to consent to directly disclosing your Personal Data with these third parties prior to sharing your Personal Data, such as via a consent banner on our website.

Anonymous or De-identified Usage Data. We share anonymized or aggregated usage data or security threat information with third parties or the public.

PickPillar, Inc Documentation, Help Center, and Other Content. We may make available certain documentation, tutorials, as well as blogs and other means for you to post information on our websites. This is publicly-available information that you choose to share and it may be read, collected, and used by others that visit these websites.

Recruitment Data. When you apply for a job at COMPANY, we share your Personal Data, including applicant data, biographical information, and other Personal Data we possess with our affiliate companies for business reasons, such as human resource management and internal reporting; our service providers for business reasons, such as the recruitment platform and to manage background checks; and law enforcement or government authorities, or as otherwise necessary to comply with law.

PickPillar, Inc Social Media Outlets. PickPillar, Inc’s. websites may use social media features, such as the Facebook “like” button, the Instagram “heart” button, Twitter sharing features, and other sharing widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share content with others within your network. Social Media Features are either hosted by the respective social media network, or hosted directly on our websites. To the extent the Social Media Features are hosted by the respective social media networks and you click through to these from our website, the latter may receive information showing that you have visited our website. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile. Your interactions with Social Media Features are governed by the privacy policies of the respective companies that provide the relevant Social Media Features.

VI. COMPANY’s Security Posture & Measures Taken

Security is a critical priority for PickPillar, Inc. We maintain a comprehensive, written information security program that contains industry-standard administrative, technical, and physical safeguards designed to prevent unauthorized access to Personal Data.

However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including Personal Data, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and maintaining the security of your devices.

If you use the COMPANY online service via a subscription purchased for you by a COMPANY Customer, then that Customer is responsible for configuring your instance appropriately.

VII. International Data Transfers

Your Personal Data may be collected, transferred to, and stored by us in the United States, and by our affiliates and third-party vendors (such as AWS) that are based in other countries. Your Personal Data may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area.

VIII. Children

PickPillar, Inc’s websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe that your child has provided us with Personal Data without your consent, please contact us via the contact email as indicated below, and we will take steps to delete such Personal Data from our systems. COMPANY has not knowingly sold Personal Data to third parties.

IX. How Long Does COMPANY Keep Your Data?

We will retain your Personal Data for a period of time that is consistent with the original purpose of the data collection, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We determine the appropriate retention period for Personal Data by considering the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

X. Your Information Rights

Direct Marketing. If you wish to withdraw from direct email marketing communications from PickPillar, Inc, you may click the “unsubscribe” button included in our emails. Please note, you cannot unsubscribe from critical transactional emails that are related to our provision of our online service (such as those related to security and your PickPillar, Inc account).

If you are a user of the PickPillar, Inc online service via a subscription purchased for you by a PickPillar, Inc Customer, to opt-out of platform-based analytics on an individual level, including participation in the PickPillar, Inc Ideas forum, please contact us at support@pickpillar.com.

Cookie Preferences. You may also adjust your web browser settings to opt-out of non-essential cookies. Please understand that blocking or deleting non-essential cookies may affect our websites’ functionality.

Your European Privacy Rights

Under the General Data Protection Regulation, if you are a European Union data subject, you have rights to understand and request information about how we collect, use, and disclose Personal Data in our capacity as a data controller, to the extent permitted by applicable law.

• Right to Access. You have the right to access your Personal Data held by us.

• Right to Rectification. You have the right to rectify inaccurate Personal Data and, taking into account the purpose of processing, to ensure it is complete.

• Right to Erasure (or “Right to be Forgotten”). You have the right to have your Personal Data erased or deleted.

• Right to Restrict Processing. You have the right to restrict our processing of your Personal Data.

• Right to Data Portability. You have right to transfer your Personal Data, when possible.

• Right to Object. You have the right to object to the processing of your Personal Data that is carried out on the basis of legitimate interests, such as direct marketing.

• Right Not to be Subject to Automated Decision-Making. You have the right not to be subject to automated decision-making, including profiling, which produces legal effects. PickPillar, Inc does not currently engage in the foregoing on our websites or in our products and services.

• If you would like to make a request and exercise your rights described above, please contact us at the email below.

Your California Privacy Rights

Under the California Consumer Privacy Act of 2018 (“CCPA”), effective January 1, 2020, if you are a California resident, you have rights to understand and request that we disclose how we collect, use, disclose, and sell your Personal Data to the extent permitted by applicable law.

• Right to Know About Personal Data Collected, Disclosed, or Sold. You have the right to request that we disclose what Personal Data we collect, use, disclose, and sell.

• Right to Request Deletion of Personal Data. You have the right to request the deletion of your Personal Data collected or maintained by us as a business.

• Right to Opt-Out of the Sale of Personal Data. You have the right to opt-out of the sale of your Personal Data by us as a business, in the event we sell Personal Data.

• Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.

• Authorized Agent. You may designate an authorized agent to make a request under the CCPA on your behalf to us with a copy of your power-of-attorney document granting that right.

• Financial Incentives. We do not provide any financial incentives tied to the collection, sale, or deletion of your Personal Data.

If you would like to make a request and exercise your rights described above, please contact us via the email address below. Since there is no reasonable way for us to verify information for which we are a service provider to our Customers, we will not respond to any requests in relation to data we hold on behalf of our Customers.

support@pickpillar.com