This Policy governs the way Prinvy collects, uses, maintains, and discloses information collected from users (each, a “User”) of the Site. This Policy applies to all Users of the Site and all products and services offered by Prinvy.
Please note that, if Users are entering a sweepstakes operated by Prinvy, participation is subject to the Rules applicable to that contest. If this Policy conflicts or is inconsistent with a statement in the Rules concerning User privacy, the terms of the Rules control. Please note that this Policy applies only to Site-specific information gathering and dissemination practices and does apply in any other context.
1. Personal Identification Information (“PII”):
PII refers to information that, when used alone or with other relevant data, can allow for identification of an individual, including name, email address, mailing address, phone number, and credit card information. Prinvy may collect PII from Users for different purposes, including, but not limited to, when Users visit the Site and enter a sweepstakes contest or otherwise contact Prinvy, and in connection with other activities, services, features, or resources made available on the Site. Users may, however, visit the Site anonymously. Prinvy collects PII from Users only if voluntarily submitted. Users can always refuse to supply PII, except that it may prevent them from engaging in certain Site related activities. By submitting PII to Prinvy, User authorize it to store and utilize User information as necessary to complete the purpose for which it was submitted and as otherwise allowed.
Non-personal identification information (“NPII”):
NPII refers to information that does not allow for direct identification of any specific person. When Prinvy refers simply to the term “information” in this Policy, it is referring to how it collects, uses, or shares both the PII and the NPII. Prinvy may collect NPII from Users whenever they interact with the Site. NPII may include, but not be limited to, the browser name, the type of computer and technical information about Users means of connection to the Site, such as the operating system and the Internet service providers utilized and other similar information. Much of the NPII is collected using third-party tracking services, which includes Google Analytics, and other means, as further described below.
User can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage. To opt-out of Google Analytics relating to User use of the Sites, User can download and install the Browser Plugin available via this link: https://tools.google.com/dlpage/gaoptout?hl=en.
3. Web browser cookies:
4. Web Beacons:
Certain pages on the Site contain “web beacons” (also known as Internet tags, pixel tags and clear GIFs). These web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, the type of browser used to view the page, and the information in cookies set by the third party. Web beacons also may be used to track whether Users have opened an HTML email. When the email is opened, a part of the code that makes up the HTML page calls a web server to load the web beacon that then generates a record showing that the email has been viewed. Web beacons may also recognize when the email was opened, how many times it was forwarded, and which URLs (links within the email) were clicked.
5. IP Addresses:
When Users visit and interact with the Site, Prinvy and third parties with whom Prinvy has contracted may collect Internet Protocol addresses (each an “IP Address”), as well as browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and page navigation. An IP Address is a unique identifier number that certain electronic devices used to identify and to communicate with each other on the Internet; User Internet Service Provider automatically assigns an IP Address to the computer that Users are using. Prinvy gathers this information to track web site visitor movement in the aggregate, and to gather broad demographic information for aggregate use. Prinvy’s goal in gathering this information is to learn how Prinvy customers and the public are using Prinvy’s service. Prinvy may use this information to enhance the Site or for other lawful purposes.
6. Do Not Track Notice:
User browser and other mechanisms may permit User to send do-not-track signals or other similar signals to express User preferences regarding online tracking. To the extent User employ such browser do-not-track signals or other similar mechanisms, Prinvy will use commercially reasonable efforts to honor such requests received by Prinvy to the extent Prinvy have the capacity and resources to identify and process User request. Due to the potential for rapid and diverse developments of technology in this area, Prinvy cannot guarantee that Prinvy can process every type of request that exists or may be developed in the future. As noted above, third parties, such as Prinvy advertising partners, may collect data that relates to User. Prinvy cannot control third parties' responses to do-not-track signals or other such mechanisms. Third parties' use of data relating to User and responsiveness to do-not-track signals is governed by their respective privacy policies.
7. Use of Information:
Prinvy collects, stores, and uses User’s information for the following purposes:
- to improve customer service – the information helps Prinvy to effectively respond to customer service requests and support needs.
- to personalize User experiences – information helps Prinvy understand how Users use the services and resources provided on the Site.
- to improve the Site and Prinvy’s work – Prinvy continually strives to improve its Site offerings based on the information and feedback we received from Users. Prinvy may aggregate the PII that Users provide with the PII that other users provide to conduct research, analysis, or studies for Prinvy own purposes (i.e., not related to providing User with specific services), including improving Prinvy’s services and future sweepstakes.
- to process transactions – Prinvy may use the information Users provide about themselves when placing an order to provide service to that order. It does not share this information with outside parties except to the extent necessary to provide the service.
- to maintain contact with Users – the email address Users provide for order processing will be used to send them information and updates pertaining to their order. It may also be used to respond to their inquiries, and/or other requests or questions. Prinvy may also use the information that User provides to communicate with User about Prinvy activities, future events, and sweepstakes or to notify User about any changes to Prinvy’s services. Users may also receive emails that may include company news, updates, related product or service information, or new contest information. If at any time User would like to unsubscribe from receiving future emails or other contacts, Prinvy includes detailed unsubscribe instructions at the bottom of each email or User may contact Prinvy via the Site.
8. Sharing of Information:
Prinvy may disclose all the information (described herein) that Prinvy collects, as stated in this Policy including in accordance with the terms set forth in this section. Except as stated in this Policy and as detailed below, Prinvy does not rent, sell, or share User information with other people or companies. The following describes how Prinvy may share User information:
(a) Sharing User Information with Subcontractors. In Prinvy efforts to provide the best quality service and experience to User, Prinvy may share information with subcontractors that provide Prinvy with services. These services may include, among other things, helping to provide services that User request, helping to create or maintain Prinvy databases, helping to research and analyze the people who request services information from Prinvy, and/or helping to process payment card information.
(b) Sharing User Information as Permitted by Law. Prinvy may share User information with others as required by, or permitted by, law. This may include sharing User PII with governmental entities, or third parties in response to subpoenas, court orders, other legal processes, or as Prinvy believe is necessary to exercise Prinvy legal rights, to defend against legal claims that have been brought against Prinvy, or to defend against possible legal claims that Prinvy determine in Prinvy sole discretion might be brought against Prinvy.
(c) Sharing User Information with Law Enforcement. Prinvy may report to law enforcement agencies any activities that Prinvy reasonably believe to be unlawful, or that Prinvy reasonably believe may aid a law enforcement investigation into unlawful activity. In addition, Prinvy reserve the right to release User information to law enforcement agencies if Prinvy determine, in Prinvy sole judgment, that either User have violated Prinvy policies or the release of User information may protect the rights, property or safety of Prinvy, User, or another person.
(d) Business Transition. If Prinvy becomes involved in a merger, acquisition, or any form of sale or transfer of some or all its assets, User information will be transferred to the acquiring entity.
(e) User Comments. If User post a Comment to the Site, the information that User choose to post, including any personal information that User choose to post, may be available generally to the public.
(f) Marketing Companies. Generally, Prinvy only provides limited NPII (e.g., the city, or the state, in which a device is located or information about User search or posting history), usually in conjunction with a randomly assigned number or a number assigned to User’s Prinvy account and not in conjunction with User’s name. However, for certain campaigns, Prinvy may provide third party advertisers with User’s email address which may be used by such companies to provide User with information about other products, services, or companies.
(g) Sharing User Information with Charities and Prize Providers. If User enter a sweepstakes, whether by making a donation or using an alternate method of entry, make a donation in connection with entering into a sweepstakes, User agree that Prinvy may share User name and contact information with Charities Aid Foundation America (“CAFA”), a U.S. 501(c)(3) tax-exempt public charity that is the legal recipient of all donations through the Prinvy platform, as well as the charity Prinvy designate as the benefiting charity for such sweepstakes and with any entity providing prizes for that sweepstakes, each of which may use User information for marketing purposes. If a designated benefiting charity is ultimately determined to be ineligible to receive a grant from CAFA, User information will not be sent to such charity.
(h) Sweepstakes Winners. As further explained in the Rules, by entering a sweepstakes, Users grant Prinvy the right to disclose their name, biographical information, pictures/portraits, video images, likenesses and/or voice to the public if they end up being a sweepstakes winner.
(i) Credit Card Information. Please note, when Users use a credit card to donate, Users are being redirected to a third-party provider. PRINVY DOES NOT COLLECT, ACCESS, STORE OR PROCESS ANY CREDIT CARD INFORMATION.
9. Protection of Information:
Prinvy employs reasonable data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of User information. While Prinvy will use such efforts, Prinvy cannot and will not ensure the security of User information. Accordingly, Prinvy assumes no liability for any disclosure of data due to errors in transmission, unauthorized third-party access, or other acts of third parties, or acts or omissions beyond Prinvy’s reasonable control.
10. Third Party Websites:
Users may find advertising or other content on the Site or Prinvy emails that links to the websites and services of Prinvy partners, including PLF and its charitable grantees, suppliers, advertisers, sponsors, licensors and other third parties. Prinvy does not control the content or links that appear on these sites and is not responsible for the practices employed by websites linked to or from the Site. In addition, these sites, or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies. In addition, the Site or Prinvy emails may link to a variety of third-party social media sites and/or websites – such as YouTube, Twitter, Facebook, and others - as a service to User, and to provide User additional information and/or content related to the work that Prinvy does, or additional venues in which User can learn about and discuss the activities of Prinvy. Prinvy has no affiliation with any of these other parties and/or websites and cannot control and is not responsible for the information collection, use, and disclosure practices of such third parties; Prinvy encourages User to review and understand their privacy practices and policies, if any, before using providing any personally identifying information to them or initiating any financial transactions. Prinvy is not responsible for the content or information of any third-party or partner websites, or any other use of the linked website.
11. Children’s Privacy:
Except as may be provided by a parent or guardian, Prinvy does not knowingly collect, use, or disclose PII about persons younger than 18 years of age and directs that persons under the age of 18 not access or view the Site. If User is the parent or guardian of a child under 18 years of age and believes that the child has disclosed PII to Prinvy, please contact Prinvy so that Prinvy may delete the child’s information. If a child under the age of 18 submits information to Prinvy through any part of the Site and Prinvy becomes aware that the user submitting the information is under the age of 18, the information provided will be deleted as soon as it is discovered and not used for any purpose.
12. Information from Outside the United States:
The Site is hosted in the United States and is governed by US law, and each Sweepstakes drawing takes place within the United States. Accordingly, by submitting any personal information to Prinvy or entering a sweepstakes, Users are transferring User personal information to the United States and Users consent to such transfer. Prinvy does not represent or warrant that the Site, or any part thereof, is appropriate or available for use in any geographic location. If Users choose to access the Site, they do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules, and regulations applicable in User’s jurisdiction. If User is visiting the Site from outside the United States, please be aware that User’s information will be transferred to, stored, and processed in the United States where Prinvy’s servers are located and Prinvy’s central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in User’s country. By using the Site, User consents to information being transferred to Prinvy facilities and to the facilities of those third parties with whom Prinvy shares it as described in this Policy.
13. How to Contact Prinvy:
If Prinvy needs, or is required, to contact User concerning any event that involves User’s information, Prinvy may decide to do so by email, telephone, or mail.
14. Policy Changes:
Prinvy may revise this Policy from time to time to reflect changes in its practices or to comply with changes in applicable law or regulatory requirements. PLEASE CHECK THIS POLICY PERIODICALLY FOR UPDATES AS IT MAY CHANGE AT ANY TIME IN PRINVY’S SOLE DISCRETION. USERS OF THE SITE ACKNOWLEGE AND AGREE THAT IT IS THEIR RESPONSIBILITY TO REVIEW THIS POLICY PERIODICALLY AND BECOME AWARE OF MODIFICATIONS. Prinvy reserves the right to modify this Policy at any time by posting the revised Policy on the Site. User’s continued use of the Site after the posting of any modifications to this Policy will be deemed User’s agreement to the new terms.
15. California Privacy Rights:
If User is a California resident, User may have certain rights under California law, including but not limited to the California Consumer Privacy Act of 2018 (“CCPA”). This California Privacy Statement (“CA Privacy Statement”) supplements the information contained in the Policy above and applies solely to visitors, users, and others who reside in the State of California and access the Site from California (“CA Resident(s)”, “User” or “User”). Any terms defined in the CCPA have the same meaning when used in this CA Privacy Statement.
User Rights and Choices
The CCPA provides CA Residents with specific rights regarding their Personal Information. The CCPA defines Personal Information as any information that “identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household” (hereinafter, “PII”). This CA Privacy Statement describes User CCPA rights in relation to Prinvy use of User PII and explains how to exercise those rights.
Right to Know/Access
As a California Resident, Users have a right to know:
- The categories of PII Prinvy has collected, sold, or disclosed for business purposes about User.
- The categories of sources from which Prinvy collected User PII.
- The business or commercial purpose for collecting or sharing User PII.
- The categories of third parties with whom Prinvy has shared, sold, or disclosed for business purposes User PII; and
- The specific pieces of User PII Prinvy has collected.
As part of User’s “right of access”, User has the right to request that Prinvy provide User’s PII to User. Once Prinvy receives and confirms User’s “verifiable consumer request” (as describe below) Prinvy will provide the PII Prinvy has collected and currently holds to User in a portable and, to the extent technically feasible, in a readily usable format.
Right of Deletion
As a California Resident, User has a right to request that Prinvy delete the PII Prinvy has collected from or about User, subject to certain exceptions. Once Prinvy receives and confirms User’s verifiable request (as described below), Prinvy will delete (and ask Prinvy service providers to delete) User’s PII from Prinvy records, unless an exception applies. Please note, Prinvy may deny User deletion request if retaining the information is necessary for Prinvy or Prinvy service providers to:
- Complete the transaction for which Prinvy collected the PII, provide a good or service that User requested, take actions reasonably anticipated within the context of Prinvy ongoing business relationship with User, or otherwise perform Prinvy contract with User.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Enable solely internal uses that are reasonably aligned with consumer expectations based on User relationship with Prinvy.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which User provided it.
Process to Submit A Request
To submit a verified request for User PII User may contact Prinvy at email@example.com.
Verification; Verification Method
Only User - or a person registered with the California Secretary of State that User authorize to act on User’s behalf - may make a verifiable consumer request related to User PII. User may also make a verifiable consumer request on behalf of User’s minor child. To ensure Prinvy does not inadvertently delete User PII based on a fraudulent request, Prinvy will verify User’s identity before Prinvy responds to User’s request. To verify User identity, Prinvy will generally match the identifying information provided in User’s request with the information Prinvy has on file about User. Depending on the sensitivity of the PII requested to be deleted, Prinvy may also utilize more stringent verification methods to verify User identity, including but not limited to requesting additional information from User. Please note User may only make a verifiable request for access (and data portability) twice within a 12-month period. To be considered a verifiable consumer request, User must:
- Provide sufficient information that allows Prinvy to reasonably verify User is the person about whom Prinvy collected PII or an authorized representative.
- Describe User’s request with sufficient detail that allows Prinvy to properly understand, evaluate, and respond to it.
Prinvy cannot respond to a User request or provide User with PII if Prinvy cannot verify User identity or authority to make the request and confirm the PII relates to User. Making a verifiable consumer request does not require User to create an account with Prinvy. Prinvy will only use PII provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
Prinvy endeavors to respond to verifiable consumer requests within 45 days of receipt. If Prinvy requires more time (up to 90 days), Prinvy will inform User of the reason and extension period in writing. If User has an account with Prinvy, Prinvy will deliver Prinvy’s written response to that account. If User does not have an account with Prinvy, Prinvy will deliver Prinvy’s written response by mail or electronically, at User’s option. Any disclosures Prinvy provides will only cover the 12-month period preceding the verifiable consumer request's receipt. The response Prinvy provides will also explain the reasons Prinvy cannot comply with a request, if applicable. For data portability requests, Prinvy will select a format to provide User PII that is readily useable and should allow User to transmit the information from one entity to another entity without hindrance.
Prinvy does not charge a fee to process or respond to a User’s verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Prinvy determine that the request warrants a fee, Prinvy will tell User why Prinvy made that decision and provide User with a cost estimate before completing User’s request.
Right to Opt-Out
As a California resident, Users have the right to opt-out of the sale of User PII to third parties. To exercise this right, please click here.
Right of Non-Discrimination
Users have a right to exercise User rights under the CCPA without suffering discrimination. Accordingly, Prinvy will not discriminate against User in any way if User chooses to exercise User’s rights under the CCPA. Unless permitted by the CCPA, Prinvy will not:
- Deny User goods or services.
- Charge User different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide User a different level or quality of goods or services.
- Suggest that User may receive a different price or rate for goods or services or a different level or quality of goods or services.
If User is a California resident under the age of 18, California Business and Professions Code § 22581 permits User to request and obtain removal of content or information User has publicly posted on the Site. To make such a request, please send an email with a detailed description of the specific content or information to firstname.lastname@example.org. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information User has posted and there may be circumstances in which the law does not require or allow removal even if requested.
Shine the Light
California Civil Code § 1798.83 permits User to request information regarding the disclosure of User PII by Prinvy to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or write Prinvy at: 8742 E. Via De Commercio, Suite 100, Scottsdale, AZ 85258. Be sure to include “California - Shine the Light Request” in the subject line.
Information Prinvy Collects
As noted above, Prinvy may collect some of User’s PII. In the table below Prinvy has indicated those categories of PII that Prinvy has collected from California Residents within the last twelve (12) months:
|A. Identifiers.||May include: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||YES|
|B. PII categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||May Include: Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some PII included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||May Include: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||May Include: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||May Include: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||May include: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||May include: Physical location or movements.||NO|
|H. Sensory data.||May include: Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||May include: Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||May include: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other PII.||May Include: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||-|
Please note that PII does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
Prinvy obtained the categories of PII listed above from the following categories of sources:
- Directly from Users when Users used the Site. For example, from forms Users complete or products and services Users purchase.
- Indirectly from Users when Users used the Site. For example, from tracking User actions on the Site (as further described in the Prinvy Privacy Notice or through information Prinvy collects while providing services).
- Directly and indirectly from activity when Users use the Site.
- Directly from Prinvy clients/customers or their agents. For example, from documents that Prinvy clients provided to Prinvy related to the services for which they engaged Prinvy.
- Indirectly from Prinvy clients/customers or their agents. For example, through information Prinvy collects from Prinvy clients while providing services to them.
Use of PII
Prinvy may use or disclose the PII Prinvy collects for one or more of the following business purposes:
- To fulfill or meet the reason for which the information is provided.
- To provide User with information, products, or services that User requests from Prinvy.
- To provide User with content, and other notices, events, or news, that may be of interest to User.
- To carry out Prinvy obligations and enforce Prinvy rights arising from any contracts entered between User and Prinvy, including for billing.
- To improve the Site and present its contents to User.
- As necessary or appropriate to protect the rights, property, or safety of Prinvy, Prinvy clients or others.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to User when collecting User PII or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all Prinvy’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which PII held by Prinvy is among the assets transferred.
Prinvy will not collect additional categories of PII or use the PII Prinvy has collected for materially different, unrelated, or incompatible purposes without providing User notice.
Prinvy may disclose PII to a third party for a business purpose. When Prinvy discloses PII for a business purpose, Prinvy enters a contract that describes the purpose and requires the recipient to both keep that PII confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, Prinvy has disclosed the following categories of PII for a business purpose:
Category A: Identifiers
Category B: California Customer Records PII categories.
Category C: Professional or employment-related information.
Prinvy discloses PII for a business purpose to the following categories of third parties:
- Prinvy affiliates.
- Service providers.
- Third parties to whom User or User agents authorize Prinvy to disclose User PII in connection with products or services Prinvy provides to User.
In the preceding twelve (12) months, Prinvy has not sold any PII.
16. European Union Area, Switzerland & United Kingdom Residents:
This section of the Policy is intended to provide adequate and consistent safeguards for the handling of personal information in accordance with Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (“the Directive”) and all the relevant transposing legislation of the Directive in the European Union/European Economic Area, the Swiss Federal Data Protection Act, as such laws may from time to time be amended and valid during the application of this Policy, and any other privacy laws, regulations and principles concerning the collection, storage, use, transfer and other processing of personal data transferred from users in the European Economic Area, the United Kingdom or Switzerland (the “EU Users”) to the United States including but not limited to the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “General Data Protection Regulation” or “GDPR”)) as of its entry into force on 25 May 2018. Prinvy has developed this GDPR Privacy Notice to provide additional information about how Prinvy handles the PII collected via the Site that is subject to GDPR when Prinvy is the controller of that information. The following provisions apply only to EU Users.
Purpose of this GDPR Privacy Notice
This GDPR Privacy Notice explains how Prinvy processes PII that is subject to GDPR and sets out individuals' rights related to Prinvy’s processing of such PII.
Prinvy’s processing of PII is justified by a "legal basis", that is, a specific condition. Prinvy may use PII for the following purposes, in each case as justified by a legal basis:
i. Site administration
Prinvy may use PII for the effective administration of the Site, to fulfill and/or address User requests, or to provide the functionalities and features as further described herein.
Purpose and Legal Bases for Prinvy Use of PII
This processing is necessary to establish, exercise or defend Prinvy’s legal claims and rights. It is in Prinvy’s legitimate interest or a third party's legitimate interest to use PII in such a way to ensure that Prinvy provides the very best client service Prinvy can to Users or others and comply with Prinvy’s professional and ethical duties, consistent with applicable law. In some cases, this processing is necessary to perform a contract to which Users are a party.
ii. Business administration and legal compliance
Prinvy uses PII for the following business administration and legal compliance purposes:
- To perform and maintain information for the purposes of performing conflicts of interest searches.
- To comply with Prinvy’s legal obligations (including Know User Client, Anti-Money Laundering, Anti-Bribery, conflicts, or similar obligations including, but without limitation, maintaining regulatory insurance).
- To enforce Prinvy’s legal rights. To investigate and/or settle inquiries or disputes.
- To comply with any applicable law, court order, other judicial process, law enforcement requests or the requirements of a regulator.
- To enforce Prinvy’s agreements with Users.
- To protect the rights, property, or safety of Prinvy or third parties, including Prinvy’s other clients and users of the Site or Prinvy Services.
- To maintain Prinvy’s records.
- To process business transaction data, such as in connection with a merger, or a restructuring, or sale.
- To use as otherwise required or permitted by law, consistent with these purposes.
Purpose and legal bases for Prinvy use of PII
It is necessary to enforce, establish or defend Prinvy’s legal rights, or to protect the rights of third parties. This processing is necessary to comply with EEA legal obligations imposed upon Prinvy. It is in Prinvy’s legitimate interest or a third party's legitimate interest to use PII to comply with other legal obligations. In some cases, this processing will be necessary to perform a contract to which Users are a party.
iii. Marketing and promotions
Prinvy may use PII for marketing and promotional purposes, such as to send Users news and newsletters, or to otherwise contact Users about products or information Prinvy thinks may interest Users, by email and direct (postal) mail. Prinvy may also use PII to develop new services and determine how to market Prinvy services.
Purpose and legal bases for Prinvy use of User PII
It is in Prinvy’s legitimate interest to use PII for marketing purposes to develop and grow Prinvy’s business and services and promote the reputation of Prinvy’s firm. Prinvy will, where required by applicable law, obtain User consent to send such communications.
iv. Client insight and analytics
Prinvy uses PII to better understand how Users and others use Prinvy’s services or the Site, so that Prinvy can improve the Site and services, develop new features, tools, offerings, services, and the like, and for other research and analytical purposes. Prinvy also uses the information Prinvy collects to measure the effectiveness of Prinvy’s online content and how visitors use the Site and Prinvy’s services. Prinvy may use this information and the insights Prinvy has derived for marketing purposes or to make decisions about events, news and information that may be of interest to clients, prospective clients, Users, and others.
Purpose and legal bases for Prinvy use of User PII
It is in Prinvy’s legitimate interest to use PII in a way to help Prinvy provide excellent Services to Prinvy’s clients and others, including Users, to develop and grow Prinvy’s business and Services and promote the reputation of Prinvy’s firm.
v. Prevent misconduct, abuse, and misuse
Purpose and legal bases for Prinvy use of User PII
This processing is necessary to comply with EEA legal obligations imposed upon Prinvy. It is necessary to enforce, establish or defend Prinvy’s legal rights, or to protect the rights of third parties. It is in Prinvy’s legitimate interest or a third party's legitimate interest to use PII to comply with other legal obligations. In some cases, this processing will be necessary to perform a contract to which Users are a party.
Retention of Personal Data
In general, Prinvy will retain relevant PII of Site visitors for at least 1 year from the date of Prinvy’s last interaction with User and in compliance with Prinvy’s obligations under applicable laws, or for longer if Prinvy is required to do so according to Prinvy’s regulatory obligations or where Prinvy believe necessary to establish, defend, or protect Prinvy’s legal rights and interests or those of others.
Third Party Contractors and Other Data Processors
Prinvy may appoint subcontractor data processors as required to deliver the services, such as, without limitation, IT systems or software providers, IT Support service providers, and document and information storage providers, who will process PII on Prinvy’s behalf and at Prinvy’s direction. Prinvy will conduct an appropriate level of due diligence and put in place contractual documentation in relation to any sub-contractor to ensure that they process PII appropriately and according to Prinvy’s legal and regulatory obligations.
User Information and User Choices; Withdrawal of Consent
GDPR provides EU Users with additional rights related to their PII held by Prinvy, including the following:
User right of access
If User asks Prinvy, Prinvy will confirm whether Prinvy is processing User PII and, if necessary, provide User with a copy of that PII (along with certain other details). If Users require additional copies, Prinvy may need to charge a reasonable fee.
User right to correction (rectification)
If the PII Prinvy holds about a User is inaccurate or incomplete, User is entitled to request to have it corrected. If a User is entitled to have information corrected and if Prinvy has shared User PII with others, Prinvy will let them know about the rectification where possible. If User asks Prinvy, Prinvy will also tell User, where possible and lawful to do so, with whom Prinvy has shared User PII so that User can contact them directly.
User right to erasure
User can ask Prinvy to delete or remove User PII in some circumstances, such as where Prinvy no longer needs it or if User withdraws consent (where applicable). If User is entitled to erasure and if Prinvy has shared User PII with others, Prinvy will let them know about the erasure where possible. If User asks Prinvy, Prinvy will also tell User, where it is possible and lawful for Prinvy to do so, with whom Prinvy has shared User PII with so that User can contact them directly.
User right to restrict (block) processing
User can ask Prinvy to restrict the processing of User PII in certain circumstances, such as where User contests the accuracy of that PII or User object to Prinvy’s processing. If a User is entitled to restrictions and if Prinvy has shared User PII with others, Prinvy will let them know about the restriction where it is possible for Prinvy to do so. If User asks Prinvy, Prinvy will also tell User, where it is possible and lawful for Prinvy to do so, with whom Prinvy has shared User PII so that User can contact them directly.
User right to data portability
User has the right, in certain circumstances, to receive a copy of PII Prinvy has obtained from User in a structured, commonly used, and machine-readable format, and to reuse it elsewhere or to ask Prinvy to transfer it to a third party of User’s choice.
User rights in relation to automated decision-making and profiling
User has the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects User, unless such profiling is necessary for entering into, or the performance of, a contract between User and Prinvy.
User right to withdraw consent
If Prinvy relies on User consent (or explicit consent) as Prinvy’s legal basis for processing User’s PII, User has the right to withdraw that consent at any time.
User right to lodge a complaint with the supervisory authority
If a User has a concern about any aspect of Prinvy’s privacy practices, including the way Prinvy has handled User PII, User can report it to the relevant supervisory authority.
Please note that some of these rights may be limited where Prinvy has an overriding legitimate interest or legal obligation to continue to process the PII, or where the PII may be exempt from disclosure due to applicable law, the applicable rules of professional conduct, attorney-client privilege, legal professional privilege, other applicable privileges or protections, or professional secrecy obligations. Additionally, there may be circumstances in which Prinvy is not legally required to comply with User’s request because of the laws in User’s jurisdiction or because of exemptions provided in data protection legislation in general, and the GDPR. Finally, please note that Prinvy is not responsible for removing or deleting information from the databases of third parties (such as service providers) with whom Prinvy has shared information about User, but Prinvy will make the request on User’s behalf for such removal/deletion.
Where Prinvy Transfers Personal Information
Prinvy is in the United States; when Users submit personal information to Prinvy, or when others provide personal information to Prinvy, Prinvy will receive and process it in the United States.
Children’s Privacy/To Parents of Children Residing in the EEA, Switzerland And UK
Please read and consider section 11 above which is incorporated herein.
How to Contact Us
Please read section 13 above which is incorporated herein.
Changes to This GDPR Privacy Notice
Please read section 14 above which is incorporated herein.