P I V O T A L A C C E S S I B I L I T Y

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Privacy Policy

Last updated: 7 June 2021

GENERAL INFORMATION

About the Privacy Policy:

This Pivotal Accessibility Privacy Policy (the “Privacy Policy”) governs the processing of personal data collected from natural persons (“you” and “your”) through the website https://www.pivotalaccessibility.com, the related domain names, software applications, and services (collectively, “Pivotal Accessibility”). The Privacy Policy does not cover any third-party websites, applications, software, products, or services that integrate with Pivotal Accessibility or are linked to from Pivotal Accessibility

Owner of Pivotal Accessibility:

Pivotal Accessibility is owned and operated by Pivotal Accessibility having an address at B-1/401, Janakpuri, New Delhi, 110058 India (“we,” “us,” or “our”).

Our role as a data controller and data processor:

We act in the capacity of a data controller and a data processor with regard to the personal data processed through Pivotal Accessibility in terms of the applicable data protection laws, including the EU General Data Protection Regulation (GDPR). Our role depends on the specific situation in which personal data is handled by us, as explained in detail below

  • Data controller: We are responsible for the collection of your personal data through Pivotal Accessibility and their further use. We make decisions about the types of personal data that should be collected from you and purposes for which such personal data should be used. Therefore, we act as a data controller with regard to the personal data collected directly through Pivotal Accessibility (e.g., when you send us an inquiry or request a demo). We comply with the data controller’s obligations set forth in the applicable laws
  • Data processor: Weact in the capacity of a data processor in situations when you submit files   or generate data for processing through one or more of our products (“Your Data”) and Your Data contains other individuals’ personal data. We do not own, control, or make decisions about Your Data. We process Your Data only in accordance with the instructions issued by a respective data controller. To ensure that Your Data is processed in accordance with the strictest data protection standards, we have drafted and offer for conclusion a data processing agreement (the “DPA”) that you can receive by contacting us.

Your consent:

Before you submit any personal data through Pivotal Accessibility, you are encouraged to read this Privacy Policy that is always available on Pivotal Accessibility to understand on what legal bases (other than your consent) we rely when handling your personal data. In some cases, if required by the applicable law, we may seek to obtain your informed consent for the processing of your personal data. For example, your consent may be necessary if:

  1. we intend to collect other types of personal data that are not mentioned in this Privacy Policy;
  2. we would like to use your personal data for other purposes that are not specified in this Privacy Policy; or
  3. we would like to transfer your personal data to third parties that are not listed in this Privacy Policy

Minors:

Pivotal Accessibility is not intended for use by children (i.e., persons who are minors in their country of residence). Therefore, we do not knowingly collect minors’ personal data. If you, as a parent or a legal guardian of a child, become aware that the child has submitted his/her personal data to us, please contact us immediately. We will delete your child’s personal data from our systems without undue delay

Term and termination:

This Privacy Policy enters into force on the effective date indicated at the top of the Privacy Policy and remains valid until terminated or updated by us. 1.7 Amendments. The Privacy Policy may be changed from time to time to address the changes in laws, regulations, and industry standards. We encourage you to review our Privacy Policy to stay informed. For significant material changes in the Privacy Policy or, where required by the applicable law, we may seek your consent

WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSES DO WE USE IT?

Sources of personal data:

We obtain your personal data from the following categories of sources:

  • Directly from you. For example, if you submit certain personal data directly to us when contacting us;
  • Directly or indirectly through your activity on Pivotal Accessibility. When you use Pivotal Accessibility, we automatically collect technical information about your use of Pivotal Accessibility; and
  • From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a legal basis for disclosing your personal data to us.

Types and purposes of personal data:

We respect data minimization principles. Thus, we collect only a minimal amount of personal data through Pivotal Accessibility that is necessary to ensure the proper provision of Pivotal Accessibility as described below. We use your personal data for limited, specified, and legitimate purposes explicitly mentioned in this Privacy Policy. We do not use your personal data for any purposes that are different from the purposes for which it was provided. When processing personal data, we make sure that we do so by relying on one of the available legal bases. You can find more information about the legal bases below

  • Demo request and contact form. When you request a demo or send us a message through the contact form, we collect your full name, email address, phone number, company name, industry domain, country, and any information that you decide to provide in your message. We use the said information to contact you, provide you with the requested demo, set up a contract with you, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you,’ ‘pursuing our legitimate business interests’ (operate, analyse, grow, and administer Pivotal Accessibility), and ‘your consent’ (for optional personal data). We store such data until you stop communicating with us or until you terminate your service contract with us.
  • Inquiries. When you contact us by email, we collect your name, email address, and any information that you decide to include in your message. When you contact us via our contact form, we collect your name, email address, phone number, and any information that you decide to include in your message. We use such data to respond to your inquiries. The legal bases on which we rely are ‘pursuing our legitimate business interests’ (grow and promote our business) and ‘your consent’ (for optional personal data). We store such data until you stop communicating with us.

Sensitive data:

We do not collect or have access to any special categories of personal data from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data is information that relates to your health, genetics, biometrics, religious and political beliefs, racial origins, membership of a professional or trade association, sex life, or sexual orientation. If you decide, at your sole discretion, to include the said sensitive data into Your Data, we will process such data for the purpose of fulfilling our contractual obligations.

Processing of Your Data:

When you submit, upload or create Your Data through one of our products, we process Your Data as requested by you in order to

  1. provide you with the requested services and
  2. perform our contractual obligations. The legal basis on which we rely is ‘performing a contract with you. The duration of processing is the term of your service contract with us.

Refusal to provide personal data:

If you refuse to provide us with your personal data when we ask to, we may not be able to perform the requested operation and you may not be able to use the full functionality of Pivotal Accessibility or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.

Cookies:

When you browse Pivotal Accessibility, we collect your cookie-related data. We store such data until your cookies expire, you disable cookies, or you withdraw your consent, whichever earlier. We use performance cookies only that help us to understand and analyze the key performance indexes of Pivotal Accessibility and deliver a better user experience for you. We use the following cookies: _tccl_visitor (expires in 1 year) and _tccl_visit (expires in 30 minutes). Such cookies are set by our web hosting provider GoDaddy. The cookies are used for monitoring Pivotal Accessibility usage performance. Performance cookies are considered to be essential cookies that cannot identify you. Therefore, they do not require your consent. If we start using non-essential (e.g., statistics or marketing cookies), we will make sure that we obtain your consent, where necessary.

Google reCAPCHA:

We use reCAPCHA on Pivotal Accessibility. It helps us to verify whether you are a human being and not a robot. We need such information to protect Pivotal Accessibility against spam and abuse. When you use reCAPCHA, Google will collect some data from you, such as:

  • All cookies set to your browser by Google in the last 6 months;
  • Information about your mouse clicks;
  • CSS information;
  • Date;
  • Browser language;
  • Any plug-in installed in the browser; and
  • Javascript objects.

Such data will be sent to Google servers located in the United States. If you would like to read more about Google reCAPTCHA and Google’s privacy policy, please visit the following links: Google policies and Google Recaptcha Policies

Aggregated and de-identified data:

If we combine your non-personal data with certain elements of your personal data and such a combination allows us to identify you as a natural person, we will handle such aggregated data as personal data. If your personal data is de-identified in a way that it can no longer be associated with a natural person, it will not be considered personal data and we may use it for any business purpose.

Your feedback:

If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and any subsequent responses. Where reasonably possible, we remove all personal data that is not necessary for keeping such records.

HOW DO WE COMMUNICATE WITH YOU?

Commercial communication:

If we have your email address, we may, from time to time, send you information about our services. You will receive our newsletters in the following instances.

  • If we receive your express (“opt-in”) consent to receive marketing messages; or
  • If you ask us to send you information about Pivotal Accessibility; or
  • If we decide to send you information closely related to services already used by you.

Opting-out:

You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our emails or by contacting us directly.

Service-related notices:

If necessary, we will send you important informational messages, such as confirmation receipts, technical emails, and other administrative updates. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

Retention of personal data:

We store your personal data in our systems only for as long as such personal data is required for the purposes described in this Privacy Policy or until you request us to delete your personal data, whichever comes first. After your personal data is no longer necessary for its primary purposes and we do not have another legal basis for storing it, we securely delete your personal data from our systems.

Retention as required by law:

In certain cases, we are required by law to store your personal data for a certain period of time. Thus, we may keep your personal data for the time period stipulated by the applicable law and securely delete it as soon as the required storage period expires

HOW DO WE SHARE AND DISCLOSE YOUR DATA?

Disclosure to data processors:

From time to time, your personal data is disclosed to our service providers with whom we cooperate (our data processors). For example, we share your personal and non-personal data with entities that provide certain technical support services to us, such as hosting and email distribution services. We do not sell your personal data to third parties. The disclosure is limited to the situations when your personal data is required for the following purposes:

• Ensuring the proper operation of Pivotal Accessibility;
• Ensuring the delivery of the services ordered by you;
• Providing you with the requested information;
• Pursuing our legitimate business interests;
• Enforcing our rights, preventing fraud, and security purposes;
• Carrying out our contractual obligations; or
• If you provide your prior consent to such disclosure.

List of our data processors:

We use a limited number of data processors. We choose them only if they agree to ensure an adequate level of protection of your personal data that is consistent with this Privacy Policy and the applicable data protection laws. The data processors that have access to your personal data are:

  • Our hosting and cloud storage service provider GoDaddy located in the United States;
  • Our database service provider MySql;
  • Our technical support service provider Sendinblue located in France;
  • Our developing service provider WordPress; and
  • Our independent contractors and consultants

Disclosure of technical (non-personal) data:

Your non-personal data may be disclosed to third parties for any purpose. For example, we may share it with prospects or partners for business or research purposes, for improving Pivotal Accessibility, responding to lawful requests from public authorities, or developing new products and services.

Legal requests:

If we are contacted by a public authority, we may need to disclose information about you to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.

Successors:

In case Pivotal Accessibility is sold partly or fully, we will provide your personal data to a purchaser or successor entity and request the successor to handle your personal data in line with this Privacy Policy. We will notify you of any changes of the data controller.

Selling personal data:

We do not directly sell your personal data to third parties.

Some of our data processors listed above are located outside the country in which you reside. For example, if you reside in the European Economic Area (EEA), we may need to transfer your personal data to jurisdictions outside the EEA. In case it is necessary to make such a transfer, we will make sure that the jurisdiction in which the recipient third party is located guarantees an adequate level of protection for your personal data or we conclude a data processing agreement with the respective third party that ensures such protection. We will not transfer your personal data internationally if no appropriate level of protection can be granted.

HOW DO WE PROTECT YOUR PERSONAL DATA?

Our security measures:

We implement organizational and technical information security measures to protect your personal data from loss, misuse, unauthorized access, and disclosure. The security measures are taken by us include:

  • Access control;
  • Secured networks;
  • SSL protocol;
  • Strong passwords;
  • Anonymisation of personal data (when possible); and
  • Carefully selected data processors.

Security breaches:

Although we put our best efforts to protect your personal data, given the nature of communications and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data that was caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.

WHAT RIGHTS DO YOU HAVE WITH REGARD TO YOUR PERSONAL DATA?

The list of your rights:

You have the right to control how your personal data is processed by us by exercising the rights listed below (unless, in very limited cases, the applicable law provides otherwise):

  • Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
  • Right to rectification: you can rectify inaccurate personal data that we hold about you;
  • Right to erasure (‘right to be forgotten): you can ask us to erase your personal data from our systems;
  • Right to restriction: you can ask us to restrict the processing of your personal data;
  • Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
  • Right to object: you can ask us to stop processing your personal data;
  • Right to withdraw consent: you have the right to withdraw your consent if you have provided one; or
  • Right to complaint: you can submit your complaint regarding our processing of your personal data.

How to exercise your rights:

If you would like to exercise any of your rights, please contact us by email at info@pivotalaccessibility.com or by post (you can find our postal address at the end of this Privacy Policy) and explain your request in detail. In order to verify the legitimacy of your request, we may ask you to provide us with an identifying piece of information that allows us to identify you in our system. We will answer your request within a reasonable time frame but no later than 2 weeks.

Complaints:

If you would like to launch a complaint about the way in which we process your personal data, we kindly ask you to contact us first and express your concerns. If we receive your complaint, we will investigate it and provide you with our response as soon as possible. If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.

Non-discrimination:

We do not discriminate against you if you decide to exercise your rights. It means that we will not

  1. deny any goods and services,
  2. charge you different prices,
  3. deny any discounts or benefits,
  4. impose penalties, or
  5. provide you with lower quality services

CONTACT

If you have any questions about this Privacy Policy or our data protection practices, please contact us by:

Email: info@pivotalaccessibility.com

Postal address: Pivotal Accessibility, B-1/401, Janakpuri, New Delhi, 110058, India.