Last Updated: February 5th, 2021
Who we are
Data Protection Officer
Principles of processing your personal data
How we use your personal data
The personal data we collect from you
When and how we share your personal data with others
Transfer of your personal data to other countries
The security of your personal data
Our storage and retention of your personal data
California Privacy Rights
1. Who we are
2. Data Protection Officer
Email address: email@example.com
Mail: 5 Penn Plaza, 19th Floor, New York, NY
3. Principles of processing your personal data
We process your personal data based on the following principles of:
3.1. Fairness and lawfulness
We process your personal data only after obtaining your consent for the processing, and for a determined specific purpose, unless otherwise expressly specified by law. Pingometer has developed clear procedures regarding the processing of personal data based on lawfulness.
We process your personal data in a fair and transparent manner, and only with your knowledge and in respect of your given rights.
3.3. Purpose limitation
We ensure that your personal data is only processed within the purposes as outlined in the consent form and only by those Pingometer employees needed to be involved in the processing operations to fulfil these purposes. Subsequent changes to the purpose are only possible to a limited extent, and require substantiation and your additional consent.
We will ask for your consent before using information for a purpose other than is set out in this Policy.
3.4. Data minimization
We collect and process only your personal data if actually needed in order to achieve its processing purposes. Pingometer also does not retain your personal data longer then is required to achieve the relevant purposes.
Personal data must be accurate and, where necessary, kept up-to-date. We take every reasonable step to ensure that your data, when inaccurate or incomplete, is either erased or corrected. We ensure that inaccurate or misleading data will be corrected as soon as possible.
3.6. Storage limitation
Pingometer is limiting the storage scope and time to a level appropriate and necessary to fulfil the purposes of the processing of your data in line with your consent. Therefore, we have specified limited periods for personal data storage.
3.7. Integrity and confidentiality
We acknowledge personal data to be subject to data secrecy. Our priority is to secure the confidentiality and integrity of your processed personal data. Pingometer secures your personal data with suitable organizational and technical measures to prevent unauthorized access, illegal processing or distribution, as well as accidental loss, modification or destruction.
We will be responsible for and be able to demonstrate compliance with the aforesaid six data protection principles.
4. How we use your personal data
We use the collected data for various purposes:
In case the purpose of processing will be changed to a contradictory purpose, we will obtain additional consent from you for the processing.
5. The personal data we collect from you
Information You Provide to Us
Information We Collect Automatically
The cookies may be used by us to help us manage the Website and provide functionality and customized messages to you, but we do not provide this information to third parties, except as required by law. Pingometer also uses session cookies. These are not permanent cookies, and are removed when your browser closes or your computer is powered off.
More information about Pingometer cookies you can read in the Cookie section below.
6. When and how we share your personal data with others
We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below.
Pingometer will share your information in the following ways:
Service Providers. Pingometer may provide access to or share your information with select third parties who perform services on our behalf. These third parties provide a variety of services to us, including without limitation billing, sales, marketing, provision of content and features, advertising, analytics, research, customer service, data storage, security, fraud prevention, payment processing, and legal services. Please, contact our DPO in case you want to receive the list of our service providers with whom we are sharing your personal data.
Third-Party Integrations. When you initiate a connection with a third-party integration through the Services, we will share information about you that is required to enable your use of the third-party integration through the Services.
Legal Requests. In the event of a subpoena, court order, or request of the government or a regulatory authority, Pingometer reserves the right to disclose any such personal information necessary to comply with such subpoena, court order, request, or applicable law.
7. Third-party content/links
Users will find content and products of other companies or organizations on our Website and/or links to the websites and services of our suppliers, licensors or other third parties. While we make reasonable efforts to monitor the websites or services, we do not control them. Each such third party is solely responsible for complying with the laws, rules and regulations applicable to its business and operation of its website. We are not responsible for the privacy practices, the content, or the legal and regulatory compliance of such websites or their owners and operators. These websites and services may have their own privacy policies and customer service policies, or no policies at all. We encourage you to review the privacy policies of any third party websites before providing your information to them.
8. Transfer of your personal data to other countries
Your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.
9. The security of your personal data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
10. Our storage and retention of your personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, tax or reporting requirements.
11. Children's Information
Pingometer does not knowingly collect any Personal Identifiable Information from children under the age of 16. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
Cookies are files or pieces of information that may be stored on your computer (or other devices, such as smartphone or tablet) when you visit our Site. This allows our Site to distinguish your device from those of other users of the Site. A cookie will usually contain the name of the website the cookie has come from, the lifetime of the cookie (i.e. how long it will stay on your device), and the value, which is usually a randomly generated unique number.
These cookies are used by Pingometer or a third-party service provider to analyse how the Sites are used and their performance. For example, they track the most visited pages, and where the visitors come from. They include, for example, Google Analytics cookies.
These cookies let us operate the Site in respect to the choices you make and actions you take. They allow us to remember your device in-between the visits. For example, our systems can recognize your user name and remember how you customized the Site and services (changed the text size, fonts, languages and other configurable elements), and provide you the same customizations during the future visits.
First-party and third-party cookies
“First-party cookies” are cookies, which belong to us, and located on your device. “Third-party cookies” are cookies, which another party places on your device through our Site. Pingometer may contract with third-party service providers to send emails to users, who have shared their contact information with us. To help measure and improve the effectiveness of our email communications, and/or to determine if users have opened the messages and have clicked the links, the third-party service providers may place cookies on the devices of these users. For more information on how third parties collect and use information on our behalf, please refer to their privacy policies.
We use the following types of cookies:
The data collected by the Site and/or through cookies, which may be placed on your device, will be stored only as long as is needed to fulfil the purposes mentioned above.
13. Your rights
We provide you with data protection rights, prescribed by the European Union laws, in particular the General Data Protection Regulation, and the relevant national laws. You have, for example, the following rights.
the right to obtain any information about the processed personal data within one month;
the right to access your personal data;
the right to correct or erase your personal data;
the right to be aware of any correction or erasure of your personal data, restriction of processing, and recipients of personal data;
the right to object to the processing of your personal data;
the right of data portability;
the right not to be subject to a decision, based solely on the automated processing; and
the right to lodge a complaint with a data protection authority.
You may exercise these rights by sending a request to firstname.lastname@example.org.
14. California Privacy Rights
For purposes of this section "Personal Information" has the meaning given in the California Consumer Privacy Act (“CCPA”).
How We Collect, Use, and Share your Personal Information
We might collect the following statutory categories of Personal Information:
Personal Information: Your personal information includes all of the data you provide us when you sign up for an account or enroll in our services, including your name, email address, telephone number. If you make a payment for services, your card information is not held by us, it is collected by our third party payment processors, who specialize in the secure online capture and processing of card transactions. If you apply to our open job position, we collect from you your CV and other relevant support information.
Geolocation data, such as IP address. We collect this information from your device.
Other personal information, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the Service.
Your California Rights
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
The right of access means that you have the right to request that we disclose what Personal Information we have collected used and disclosed about you in the past 12 months.
The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
Pingometer does not sell Personal Information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018).
How to Exercise your California Rights
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your Personal Information.
Please use the contact details above, if you would like to:
Access this policy in an alternative format;
Exercise your rights;
Learn more about your rights or our privacy practices; or
Designate an authorized agent to make a request on your behalf.