Privacy Policy

What is our Privacy Policy about ?

This privacy policy describes the treatment of information provided or collected on the sites and applications where this privacy policy is posted, whether on our digital properties or on applications we make available on third-party sites or platforms. We follow this privacy policy in accordance with applicable law in the places where we operate.

In some cases, we may provide additional data privacy notices specific to certain products, practices, or regions. Those terms are to be read in conjunction with this policy.

Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications), the information you provide may be separately collected by the third-party site or platform. The information we collect is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform’s privacy practices.

Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. Please also keep in mind that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

If you have questions or concerns regarding this statement, you should first contact the Pagarba administrators

We are committed to protecting your privacy and creating a safe and secure online environment for anyone who visits and buys on our Site or Application or purchases any service, solution or consulting agreement from Pagarba.

As part of our efforts to prevent unauthorized access to Personal Data, maintain data accuracy, and ensure correct use of information, we will employ reasonable and current Internet security methods and technologies. However, no security system is impenetrable.

We cannot guarantee the security of our servers, nor can we guarantee that your Personal Data will not be intercepted while being transmitted to us over the Internet.

Privacy Policy Details

Privacy Statement Summary

This privacy statement explains what information we gather about you, what we use that information for and to whom we give that information.  It also sets out your rights in relation to your information and who you can contact for more information or queries. 

What does this privacy statement cover?

This privacy statement explains how we are committed to protecting your privacy and handling your information in an open and transparent manner.

This privacy statement sets out how we will collect, handle, store and protect information about you when:

  • you use “our Website” or mobile applications or
  • we perform any other activities that form part of the operation of this Website.

When we refer to “our Website” or “this Website” in this privacy statement we mean the specific webpages of pagarba.io designated as “Global” in the upper right corner.

Pagarba.io is comprised of various global, country, regional and practice specific websites, each of which is provided by Pagarba LLC or one of its independent member firms or their related entities (collectively, the “Pagarba Network”).

Please note that the other country and regional websites contained within pagarba.io are provided by such other entities within the Pagarba Network and are not provided by us. Such websites, as well as other websites that may be linked to this Website, are not governed by this privacy statement.  We encourage visitors to review the privacy statements on each of these other websites before disclosing any personal information.

This privacy statement also contains information about when we share your personal information with other members of the Pagarba Network and other third parties (for example, our service providers).

In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.   

What information do we collect?

We may collect personal information from you when you use this Website.

We may collect or obtain such data because you give it to us (for example in a form on our Website).  We may also collect or obtain personal information from you because we observe or infer that data about you from the way you interact with us or others. For example, to improve your experience when you use this Website and ensure that it is functioning effectively, we (or our service providers) may use cookies (small text files stored in a user’s browser) and Web beacons which may collect personal information.

The personal information that we collect or obtain in such circumstances may include: your name; e-mail address; country of residence; employment and education details; your postings on any blogs, forums, wikis and any other social media applications that we provide; your IP address; your browser type and language; your access times; complaint details; details of how you like to interact with us and other similar information.

The personal information we collect may also include so-called ‘sensitive’ or ‘special categories’ of personal information, such as details about your dietary requirements (for example, where we provide you with lunch during a meeting). 

The types of personal information and special categories of personal information that we collect may vary depending on how you use our Website. In some rare circumstances, we might also gather other special categories of personal information about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.

We understand the importance of protecting children’s privacy. Our website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.

How we use information about you

Use of personal information collected via our Website
  • We may also use your personal information collected via our Website:
  • to manage and improve our Website
  • to tailor the content of our Website to provide you with a more personalized experience and draw your attention to information regarding services provided by entities within the Pagarba Network that may be of interest to you
  • to manage and respond to any request you submit through our Website.
Use of personal information for other activities that form part of the operation of our business

In addition to the purposes connected to the operation of our Website above, we may use your personal information for the purposes of, or in connection with:

  • applicable legal or regulatory requirements
  • requests and communications from competent authorities
  • sending you thought leadership or details of products and services provided by entities within the Pagarba Network that may be of interest to you; contacting you to receive feedback on these services; and contacting you for other market or research purposes;
  • protecting our rights.

The legal grounds we use for processing personal information

We are required by law to set out in this privacy statement the legal grounds on which we rely in order to process your personal information. 

We use your personal information for the purposes outlined above because of: (a) our legitimate interests in the effective delivery of our Website; (b) our legitimate interests in the effective and lawful operation of our Website so long as such interests are not outweighed by your interests; (c) the legal and regulatory obligations that we are subject to, such as keeping records for tax purposes or providing information to a public body or law enforcement agency.

To the extent that we process any sensitive personal information relating to you for any of the purposes outlined above, we will do so because either: (i) you have given us your explicit consent to process that data; (ii) the processing is necessary for the establishment, exercise or defense of legal claims or (iii) you have made the data manifestly public.

Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you. If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication or e-mail.   

To whom we disclose your information

In connection with one or more of the purposes outlined in the “How we use information about you” section above, we may disclose details about you to: other members of the Pagarba Network; third parties that provide services to us and/or the Pagarba Network; competent authorities (including courts and authorities regulating us or another member of the Pagarba Network) and other third parties that reasonably require access to personal information relating to you for one or more of the purposes outlined in the “How do we use information about you?” section above.

Our Websites and social media affiliates may host various blogs, forums, wikis and other social media applications that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this privacy statement. 

Please note that some of the recipients of your personal information referenced above may be based in countries outside of the European Union whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal information that comply with our legal obligations. The adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of personal information to third countries.

Further details of the transfers described above and the adequate safeguards used by us in respect of such transfers are also available from us by contacting the Privacy Office.

We may also need to disclose your personal information if required to do so by law, by a regulator or during legal proceedings.

We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.

Protection of your personal information

We use a range of physical, electronic and managerial measures to ensure that we keep your personal information secure, accurate and up to date. These measures include:

  • education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal information
  • administrative and technical controls to restrict access to personal information on a ‘need to know’ basis
  • technological security measures, including fire walls, encryption and anti-virus software
  • physical security measures, such as staff security passes to access our premises.  

Although we use appropriate security measures once we have received your personal information, the transmission of data over the internet (including by e-mail) is never completely secure.  We endeavor to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.

How long do we keep your information?

We will hold your personal information on our systems for the longest of the following periods: (i) as long as is necessary for the relevant activity or services; (ii) any retention period that is required by law; (iii) the end of the period in which litigation or investigations might arise in respect of the services. 

Your rights

You have various rights in relation to your personal information. In particular, you have a right to:

  • obtain confirmation that we are processing your personal information and request a copy of the personal information we hold about you
  • ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete
  • ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information
  • object to our processing of your personal information.

To exercise any of your rights, or if you have any other questions about our use of your personal information, please contact us.

Right to complain

If you are unhappy with the way we have handled your personal information or any privacy query or request that you have raised with us, you have a right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction. If you would like to be directed to the appropriate DPA, please contact us.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield

Pagarba and its subsidiaries participate in and has certified compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Economic Area (EEA) member countries, the United Kingdom, and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list.

Pagarba is responsible for the processing of personal data it receives under each Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Pagarba complies with the Privacy Shield Principles for all onward transfers of personal data from the EEA, the United Kingdom, and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Pagarba is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Sensitive Information

We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g. information related to racial or ethnic origin, political opinions, religion or other beliefs, genetic characteristics, trade union membership or criminal background) on or through the Pagarba Services or otherwise to us, except where explicitly requested or consented to.

Cross-border transfer

Pagarba products, solutions & services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your Personal Information may be stored and processed in any country where we have facilities, including the United States, or in which we engage service providers, and by using Pagarba products, solutions & services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

Some of the non-European Economic Area (“EEA”) countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses with our vendors (based on the clauses published at http://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A32010D0087, a copy of which can be obtained by Contacting Us, see below) and/or participation in the E.U.-U.S.

Privacy Rights regarding your Personal Information

This section provides specific information for California residents, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”) as well as other jurisdictions and regulations that allow for individual privacy rights such as the European Economic Area, including the United Kingdom, and the General Data Protection Regulation (“GDPR”).

Explanation of Individual Rights

Right to a Copy/Access or Portability: You may have the right to request, free of charge, a copy of the specific pieces of Personal Information that we have collected about you in a readily useable format that allows you to transmit this information to another entity without hindrance.

Right to Know: You may have the right to request, free of charge, that we provide certain information about how we have handled your Personal Information, including the categories of Personal Information collected; categories of sources of Personal Information; business and/or commercial purposes for collecting your Personal Information; categories of third parties/with whom we have shared your Personal Information; and whether we sell any categories of Personal Information to third parties (however, we do not sell your Personal Information).

Right to Deletion: You may have the right to request deletion of your Personal Information that we have collected, subject to certain exemptions. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). We may also retain residual information, such as records to document that your request has been fulfilled.

Right to Non-Discrimination: You may have the right not to receive discriminatory treatment on the basis of exercising your privacy rights under applicable law.

Right to Correct/Rectify: You may have the right to rectify any incorrect Personal Information we may hold about you.

Right to Object/Restrict: You may have the right to object to a specific use of your Personal Information as it is laid out in this Privacy Policy subject to our legitimate business interests.

Submitting a Request

Where applicable law allows for such a right, if you would like to request to access, correct, object to the use, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may submit a request by contacting Pagarba with a subject line “Data Subject Request”.
We will respond to your request consistent with applicable law.

If you are an End User you may, depending on Pagarba to be able to access, correct or request deletion of Personal Information that you have previously provided to us through your online customer account. These Data Subject Requests and other rights, including objection, restriction and portability (to the extent this right to data portability is provided to you by applicable law), can also be made directly to the relevant Subscriber.

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.

Where applicable law allows for an authorized agent to submit such a request, please contact us with a subject line “Data Subject Request – Agent Request” and someone will be in touch with the agent and the End User to verify the request.

We will try to comply with your request as soon as reasonably practicable. Moreover, where you are an End User, Pagarba may need to forward your request and refer you to your Subscriber who may be better placed to address your request.

If you are under 18 years of age and a user of the Pagarba products, solutions or services, you may also be entitled to ask us to remove content or information that you have posted by submitting a request to Pagarba administration .

Please note that your request does not ensure complete or comprehensive removal of the content or information if doing so infringes on the rights of another user.

If you are an End User of one of our Subscribers and would no longer like to be contacted by one of our Subscribers, or would like request the exercise of a right as set out above in relation to Personal Information held by a Subscriber, please contact the Subscriber directly.

Changes to this privacy statement

We may modify or amend this privacy statement from time to time.

To let you know when we make changes to this privacy statement, we will amend the revision date at the top of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information

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