Privacy Policy Effective Date – July 1, 2024
This privacy notice discloses the privacy practices for Polymath Principal Partners, Inc. and its related organizations and affiliates (“Polymath Partners” or “we”) website(s) (“Sites”) and about information we collect, use, and disclose about users of our products, services, tools, features and functionalities (“Services”).
This privacy notice applies solely to information, including personal information, collected by the Sites and through your use of the Services. Personal information is information that identifies or can identify a specific individual. This notice includes the following:
• What personal information is collected from you through the Sites, how it is used and with whom it may be shared.
• What choices are available to you regarding the use of data about you.
• The security procedures in place to protect against the misuse of personal information about you.
• What rights do you have to your personal information.
1. Information Collection and Use
We access and collect information that you voluntarily give us via email or other direct contact you have with us. We do not sell or rent personal information. We also sometimes obtain information from third party sub-processors to ensure your personal information is valid and belongs to you. For example, when you register a credit card or debit card with us to use the Service, we will use card authorization and fraud screening services to verify that your card information matches other information that you may supply to us and that the card has not been reported as lost or stolen. We collect personal information via cookies, beacons, invisible tags, unique IDs, and similar technologies on our Services (collectively referred to as cookies “cookies“). For more information on our use of cookies, please see our Cookies section below. We collect data to offer you Services. We only collect and process personal information required to help you create an account or for us to offer and provide the Services.
We use information we maintain about you, and other information we obtain from your current and past activities: (1) to perform the Services; (2) to troubleshoot problems and enforce our agreements; (3) to operate and improve the Sites, including using usage data to understand utilization and improve the Sites and Services; and (4) to resolve disputes.
Our computer systems and those of our partners are currently based in the United States, so personal information about you will be transferred, stored, and processed by us in the United States in accordance with applicable law. By entering personal information on the Sites or through using the Services, you consent to such processing of personal information about you.
You provide information directly to us when you create an account, when you submit form requests on the Sites or when you contact us for support. Some of that information includes:
• First & Last Name
• Job Title
• Company
• Email addresses
• Phone Numbers
• Areas of interest
• Answers to security questions related to identity verification
Support inquiries
Also, we reserve the right to use and disclose any information that is in an aggregate format or does not contain personal information (such as statistics and survey results that do not identify you individually by name).
2.Why is your information being processed?
We process information about you so that we can offer you our Services and communicate with you.
Contractual Relationship
When we process personal information about you in relation to our Services (including for our records, dealing with customer requests, providing customer services, administration, statistical analysis, assessing financial standing, recovery and collection of debts, dealing with regulatory and compliance issues, transfer of our business, security messages, processing payments, sending you receipts of transactions) we rely on the lawful basis of having a contractual relationship with you. This information is required to enable us to fulfill our contract with you. If you do not provide this information, we cannot provide you with our Services.
Consent
When we process personal information about you to communicate with you (including notifying you of our promotions, newsletters, operational emails about updates, outages, changes to service; targeted advertising and marketing of services), we rely on the lawful basis of consent to process such information.
You will be asked specifically if you would like to opt for each of these communications, and you can choose whether to receive some, all or neither of these communications. However, note that operational emails are required to keep you current on any changes with our system; they are rarely sent.
You will be given an opportunity to unsubscribe each time we communicate with you. Note that your decision to withhold or withdraw your consent to certain uses of personal information may restrict our ability to provide a particular service or product.
Legitimate Interest
There are times when we will process personal information about you on the lawful basis of our legitimate interest, for example to operate our Sites and provide our Services, when contacting you about new product offerings and conducting customer satisfaction surveys to enhance the provision of our Services. We will always consider the effect of such processing on your fundamental rights and freedoms, and if we believe it would be an infringement on your rights, we will not proceed with that processing.
Other purposes
Subject to applicable law, we may collect, use, or store personal information for the following limited circumstances:
• as instructed by local authorities in emergency situations that threaten an individual's life, health, or personal security such as emergency warnings for tsunami or earthquakes;
• to protect ourselves and our users from fraud;
• enforce our terms of service;
• to investigate an anticipated breach of an agreement or a contravention of the law; and
• when such collection, use or disclosure of personal information is required by law.
SPECIAL NOTICE REGARDING CHILDREN
Our Services are not directed to children under 16. We do not knowingly collect personal information from children under 16. If you become aware that a child has provided us with personal information without the proper consent, please contact us and we will take steps to remove such information and terminate the account, as necessary.
3. Information Processing
We process personal information about you when necessary to fulfill the purposes identified herein. We request information from you on our order or registration form. To buy from us, you must provide contact information (like name and shipping address) and financial information (like credit card number and expiration date). This information is used for billing purposes and to fill your orders. If we have trouble processing an order, we will use this information to contact you.
4. Information Sharing
We do not use or disclose personal information about you for any additional purposes unless we have a lawful basis to do so or as otherwise provided herein.
We do not sell, rent, license or exchange personal information about your customer lists or personal information about you to other parties except as otherwise provided herein.
We use an outside credit card processing company located in the United States to bill users for goods and services, and it does not retain, share, store or use personal information for any secondary purposes beyond filling your order.
We partner with other businesses to provide specific production services. When the user signs up for these services, we will share names or other contact information necessary for the third party to provide them.
Information disclosed in chat forums, blogs, and the like, should they be offered on the Sites, and any information that you disclose in these types of forums becomes public information, which could be read, collected, or used by others to send you unsolicited messages.
We may also disclose personal information and the content of communications to: (a) comply with the law or respond to lawful requests or legal process; or (b) act in good faith to protect the rights or property of our business, employees, suppliers, or customers.
5. Cookies
Cookies are small text files of letters and numbers stored and accessed on your browser or device's hard drive. We use cookies to collect information about your browsing activities and to distinguish you from other users of our Services. This will improve your experience when you browse our Services and allow us to enhance the functionality of our Services, increase security, and measure the use and effectiveness of our Services. The information we collect through cookies includes your IP (Internet Protocol) address, browser type, data/time stamp, cookie information and the page you requested with referring/exit pages.
We use the following types of cookies:
• Strictly necessary cookies: These cookies are necessary for the Sites to function and cannot be switched off in our systems. They allow us to enable security, prevent fraud and debug the Sites and are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, registering for, and/or attending an event or meeting or filling in forms. You can set your browser to block or alert you about these cookies, but then some parts of the Sites will not work.
• Analytical or Performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Services. They help us to know which pages are the most and least popular and see how visitors move around the Sites. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our Sites and cannot monitor its performance.
• Functional cookies: These are used to recognize you when you return to our Services. This enables us to personalize our content for you, greet you by name and remember your account preferences.
We use both persistent cookies and session cookies. Persistent cookies stay on your device for a set time or until you delete them, while session cookies are deleted once you close your web browser. The cookies placed through your use of our Services are either set by us (first-party cookies) or by a third party at our request (third-party cookies).
6. Your Control over your Information
In connection with marketing promotions or other projects, we may ask you whether you have objections to a certain kind of data use or sharing. If you opt-out under such circumstances, we will respect your decision. You may opt out of any future contacts from us at any time by calling us or sending us a notice to the contact email listed.
You can always unsubscribe or choose not to receive promotional information from us by following the specific instructions in the email you receive or by notifying us via the method above. It may take a reasonable time to process your request, no longer than 10 business days for e-mail promotions, and 30 days (about 4 and a half weeks) for direct mail and telephone promotions. Some communications about the Service are considered part of our Services, which you may receive periodically unless you cancel the Service.
At any time (and subject to certain exemptions), you may request your information to be exported and sent to you for review, and we promptly honor any requests by you to have your information deleted and forgotten in accordance with applicable laws. Please also see Section 9 below (Rights to your Information) for further information.
7. Security
In connection with marketing promotions or other projects, we may ask you whether you have objections to a certain kind of data use or sharing. If you opt-out under such circumstances, we will respect your decision. You may opt out of any future contacts from us at any time by calling us or sending us a notice to the contact email listed.
You can always unsubscribe or choose not to receive promotional information from us by following the specific instructions in the email you receive or by notifying us via the method above. It may take a reasonable time to process your request, no longer than 10 business days for e-mail promotions, and 30 days for direct mail and telephone promotions. Some communications about the Service are considered part of our Services, which you may receive periodically unless you cancel the Service.
At any time (and subject to certain exemptions), you may request your information to be exported and sent to you for review, and we promptly honor any requests by you to have your information deleted and forgotten in accordance with applicable laws. Please also see Section 9 below (Rights to your Information) for further information.
8. Retaining your Personal Information
We will retain information in accordance with applicable law.
If you create an account with us or use our Sites or Services, we will retain personal information for only so long as is reasonably necessary to provide the requested Services or for as long as we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements). This includes data you or others provided to us and data generated or inferred from your use of our Services.
If you create an account with us, we will retain personal information about you if you have an active account. If you choose to close your account, we will mark your account in our database as “Closed,” but we may be required to keep a certain amount of information in our database to comply with our legal obligations or for 7 years, whichever is shortest.
In general, if you do not create an account with us, we will delete personal information associated with you within one year of the date on which the processing's purposes are satisfied.
9. Rights to your Personal Information
Access
Subject to applicable law, you have the right to request access to your personal information and to know how we use your personal information and to whom it has been disclosed, subject to certain limited exceptions.
You may email us with a personal information access request, and we will take all reasonable steps to assist you with any legitimate request for access. Any request to access personal information must be made in writing and provide enough detail to identify the personal information you seek.
We will make the requested information available within one calendar month or provide written notice of an extension where additional time is required to fulfill the request. It may be the case that we may not be able to respond to a data access request, for example, where fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, or where there are overriding public interests. If a request is refused in full or in part, we will notify you in writing, providing the reasons for refusal.
Correction
Subject to applicable law, you have the right to make sure that the personal information that we have concerning you is accurate and to correct any of your personal information that is inaccurate.
If you are a registered user of our Services, we provide you with tools to access or modify your personal information you provided to us and associated with your Account. You may also request correction of your personal information to ensure its accuracy and completeness. Any request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
Erasure
Subject to applicable law, you have the right to obtain the erasure of personal information concerning you.
Any request for the erasure of personal information must be made in writing and provide sufficient detail to identify the personal information and the erasure being sought.
We will respond to requests for erasure within one calendar month or provide written notice of an extension where additional time is required to fulfill the request.
We may not be able to respond to an erasure request, for example, where there are overriding public interests or where we are required by law to retain your personal information. If a request is refused in full or in part, we will notify you in writing, providing the reasons for refusal.
We may also retain, use, and share your anonymized information that we previously collected prior to the deletion of your Account.
Other rights
Subject to applicable law, you may also have the following certain rights in relation to your personal information:
• Portability: You have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions; and
• Restriction of processing to storage only: You have the right to require us to stop processing the personal information we hold about you, other than for storage purposes, in certain circumstances.
Lodge a complaint
You have the right to communicate with us about any issues that you may have relating to your personal information.
10. Links
The Sites contain links to other sites (e.g., social media links/widgets). Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our Sites and to read the privacy statements of any other site that collects personal information.
11. Effect of Sale of Business
Information about you, our clients and registrants, including personal information, may be disclosed as part of any merger, acquisition, or sale of the company or its assets, as well as in the event of insolvency, bankruptcy, or receivership, or a similar business transaction, in which case the personal information would be transferred as one of the business assets of the company.
12. Policy Changes
We may revise this privacy policy sometimes. If we make any material changes, we will notify you by posting an announcement on the Sites and/or sending you an email if you have a separate agreement with us, as appropriate.
13. Notice to California Residents
The following applies to California residents.
Shine the Light.
Under California's “Shine the Light” law, you have the right to ask us once a year if we have shared your personal information with third parties for direct marketing purposes. To make a request contact us as detailed at the end of this Policy and specify you are making a Shine the Light request.
California Consumer Privacy Act (“CCPA”).
The CCPA creates consumer privacy rights and requires businesses to make disclosures about their privacy policies and practices. Pursuant to the CCPA, both our privacy practices and your privacy rights are discussed in detail in the following information.
Personal Information We Collect and Share.
We collect your personal information when you interact with our Site or otherwise communicate with us. For the purposes of this Privacy Notice, “personal information” means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. We have collected the following categories of personal information covered by the CCPA from consumers within the past 12 months, and have used it for the following business purposes:
Identifiers, including real name, signature, postal address, Internet Protocol address, email address, telephone numbers. We use this information to market our services, communicate with you, and provide you with information and services you request. In addition, we collect your IP address anonymously to provide you more relevant content, track original Site visits, and optimize your Site experience. We share this information with service providers, including our website service providers, event registration and management service providers, email marketing automation and data analytics providers.
Internet or other electronic network activity information, including browsing history, search history, and information regarding an individual's interaction with an internet Web site, application or advertisement. We use this information to provide you more relevant content, track original Site visits, optimize your Site experience, and ensure our systems are properly functioning. We share this information with service providers, including our data analytics providers, email marketing automation, social media, and marketing service providers.
Geolocation Data. We use this information to support website functionality and identify traffic patterns. We do not share this information with any third party.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible business purposes without providing you notice.
We do not sell your personal information. However, in the past 12 months we have disclosed the information described above with our service providers for the business purposes described above.
We also may collect, use and share additional personal information about you that is governed by laws other than the CCPA, such as the Gramm-Leach-Bliley Act, and that our activities related to such personal information are not disclosed here. You can learn more about our privacy practices related to such personal information by requesting this information using the contact information below.
Source of Personal Information. To read a more detailed disclosure of the personal information we collect, see the section entitled “Personal Information We Collect” above. More broadly, we obtain the categories of personal information that are listed above in the following ways:
Directly from You. We collect identifiers from you when you provide your contact information to us, register for an event with us, submit a request to us, or interact with our social media pages.
Passively. We collect IP addresses, internet and other electronic activity information, and geolocation data from you when you visit and navigate our Site on any device or receive or interact with our communications and Site.
From Third Parties. We may receive internet or other electronic network activity information about you from other sources. For example, we get information from: our business partners, including online advertising networks, social media platforms, data analytic providers, website and webinar service providers, and email marketing and automation service providers.
Your Rights.
The CCPA gives you certain rights regarding your personal information:
Right to Know. You may request no more than twice in a 12-month period that we provide you with copies of specific personal information we have collected, sold, or disclosed about you. However, under California law, we cannot provide you with certain sensitive information, despite your request (for example, we will not send you copies of your social security number even if it is something we collected).
Right to Delete. You may request that we delete certain personal information we have collected about you, with certain exceptions. To exercise your rights above, please submit a request to us by emailing us at [email protected]. Please describe your request with sufficient detail so we can properly respond to your request. As part of your request, please specify which right you are exercising and be prepared to provide your name and contact information. We may ask for additional information to verify your identity. The information you provide in your request and any follow up information we ask for from you will be used solely to verify your request.
After receiving your request, we may need to contact you for further information and will notify you if your request has been granted or declined, or if an exception applies to your request. Only you or an individual designated as your authorized agent to act on your behalf may make a request related to your personal information. We may not discriminate against you if you choose to exercise your rights.
Responding to Your Rights Request
We will try to respond to your request within 45 days. If we need more time, we will contact you with the reason we need more time and the extension period. In response to your request to know, we will only disclose the information we have collected in the 12 months prior to our receipt of your request. Our response will also explain the reasons we cannot comply with any request, if applicable. We do not charge a fee to process or respond to your request unless your request is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate prior to completing your request.
14. Contact Us
If you have questions or concerns regarding this statement, you may contact us by [email protected]
