Pilothouse Digital Privacy Policy

Updated: May 13, 2021

This privacy policy (“Policy”) describes how Pilothouse Digital Ltd. (“Pilothouse,” “we,” and “our”) processes, collects, uses, and shares personal data when you access and use this website https://www.pilothouse.co/ (the “Website”). Please read the following Policy carefully to understand our practices regarding the collection, processing, and use of your personal information and data, and to understand your rights regarding the collection, processing, and use of such information and data. 

BY ACCESSING THE WEBSITE, OR USING ANY PRODUCTS AND/OR ENGAGING IN ANY SERVICES MADE AVAILABLE TO YOU THROUGH THE WEBSITE OR BY PILOTHOUSE, YOU HEREBY ACKNOWLEDGE THAT YOU HAVE READ AND AGREE TO THE TERMS AND CONDITIONS OF THIS POLICY IN ITS ENTIRETY.

i. Personally identifiable information collected and used by Pilothouse will:

  • Be collected and processed fairly, lawfully, and with the customer’s/user’s/data subject’s knowledge and explicit consent.
  • Be obtained only for specific, lawful purposes.
  • Be adequate, relevant, and not excessive during the collection process.
  • Be accurate and kept up to date.
  • Not be held for any period of time that is longer than necessary, or as required by applicable law, rule, or regulation.
  • Processed in accordance with the rights of the customer/user.
  • Be protected in appropriate ways, no less than in accordance with industry standards.
  • Not be transferred outside of the European Economic Area (EEA) in accordance with the General Data Protection Regulation (GDPR), unless that country or territory also ensures an adequate level of protection.

ii. For the purposes of this Policy, personally identifiable information and personal data may include, but is not limited, to:

  • Names of individuals
  • Postal addresses
  • Email addresses
  • Telephone numbers
  • Birthdate
  • IP Addresses
  • Essentially, any information and data that can personally identify an individual (also known as a data subject)

‍iii. Lawful Basis for Processing Data:

In certain jurisdictions, the processing of your personal information and data is lawful only if it is permitted under data protection legislation. In this case, we have a lawful basis for each of our processing activities (unless an exemption applies) as outlined below:

  • Consent. By using the Website, or otherwise submitting your personal information and data to us, you consent to our collection, use and sharing of your information as described in this Policy.
  • Legitimate Interest. We will process your personal information and data based on Legitimate Interest, and particularly where it is used for marketing and business purposes, and to contact you to start a conversation regarding your use of the Website, your use of any products and/or services made available to you through the Website, your use of any products and/or services made available to you from Pilothouse, or to respond to any communication that you have initiated with Pilothouse.
  • Legal Obligation. We may also process your personal information and data based on other lawful basis such as where the processing is necessary to comply with applicable law.
  • Contract. We may process your personal information and data where such processing is required in order to fulfill an agreement or contract with you.

iv. How We Collect and Use Personal and Anonymous Data:

When you access and use the Website, register for any associated products and/or services made available to you through the Website or by Pilothouse, or opt-in to receive newsletters and other communications from us, we may collect personal data and anonymous data from you. We may also collect personal data and anonymous data when you directly contact us or complete and submit any forms made available to you on the Website. Pilothouse does not knowingly collect any sensitive personal data or any data defined under special categories of the applicable law(s). We do not (knowingly) collect personal information from persons under the age of (16) sixteen. If you, or a parent or guardian becomes aware that a person under the age of (16) sixteen has provided us with personal information and data, Pilothouse should be notified immediately. We will remove and delete such information from our systems as soon as possible.

 

We may use personal information and data for the following purposes:

  • to fulfill your requests to access and use the Website, and to access and use any associated product(s) and/or service(s) that are being made available to you through the Website, or by engaging with or using any product(s) and/or service(s) provided by Pilothouse;
  • for use relating to internal business analytics;
  • to prevent fraud;
  • to send you information about technical notices, updates, security alerts, and support and administrative messages;
  • to engage with third-party service providers so that you can access and use the Website and any associated product(s) and/or service(s) made available through the Website, or any product(s) and/or service(s) made available from Pilothouse;
  • to respond to your communications with Pilothouse;
  • to communicate with you about products and services offered by Pilothouse, its affiliated companies, and its selected partners;
  • to contact you to resolve problems that you may encounter with the Website and any associated product(s) and/or service(s) made available through the Website, or any product(s) and/or service(s) made available from Pilothouse; and
  • to periodically conduct product and market research regarding your use of (i) the Website; (ii) any associated product(s) and/or service(s) that are being made available to you through the Website; and/or (iii) any associated product(s) and/or service(s) that are being made available to you from Pilothouse and/or through any of our affiliated companies.

Anonymous data refers to data about you that is not associated with or linked to your personal information and data. Anonymous data does not permit the identification of individual persons.

To make the Website more useful to you, our servers (which may be hosted by a third-party service provider) may collect personal data or anonymous data from you such as browser type, operating system, computer or mobile device operating system name and version number, device manufacturer and model type, Internet Protocol (IP) address, domain name, browser language, screen resolution size, Website usage, actions and statistics, and/or a date/time stamp of your visit to the Website. We may also use cookies and navigational data like Uniform Resource Locators (URL) and referring URLs to gather information regarding the date and time of your visit. We may also use personal data and anonymous data for market research purposes and to improve our products and services and the Website.

We may share anonymous data with selected third parties and business partners, however, we will not share any anonymous data if such information is, contains, or will be linked to your personal information and data, unless we have given you notice, as described in this Policy, and you have given us authorization to do so. Pilothouse will use personal data and IP addresses to identify users of the Website if and when we feel it is necessary to enforce compliance with the Website’s policies or to protect our products and services, the Website, or other users of the Website and/or the products and services being made available through the Website or being made available from Pilothouse.

v. Sharing of Personal Information and Data:

We will never sell, trade, or rent any personal information and data or any anonymous data that may contain personal information and data, to any third party without your explicit consent.

In certain special cases, we may disclose personal information and data when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action against someone who may be causing injury to you, or is otherwise injuring or interfering with our rights, property, operations, services, other users of the Website or any associated product(s) and/or service(s) made available through the Website, any product(s) and/or service(s) made available from Pilothouse, or anyone who could be harmed by such activities. We may also disclose your personal information and data when we believe the law requires it or in response to any demand by law enforcement authorities in connection with criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation.

If we determine, in our sole discretion, that you have engaged in conduct that might be considered unlawful, fraudulent, or might harm or damage the reputation or standing of Pilothouse with either the general public or with a business partner or potential business partner of Pilothouse, we reserve the right to release your personal information and data to such persons or third parties, as we consider necessary, to prevent you from causing injury to, or otherwise injuring or interfering, now or in the future, with our rights, property,  operations, or service, or otherwise the rights, property or operations of anyone which could be harmed by such conduct.

 

vi. Cookies:

When you access and use the Website or access and use any of the products and/or services made available to you by Pilothouse, we may collect certain information using “cookies.” Cookies are small data files that are generated by certain websites and stored on your computer or mobile device by your web browser when you are visiting the website. The information collected by cookies is used to enhance your experience with the Website, for marketing analysis, for targeted and display advertising, and for quality improvement of the Website and our products and services. No personal information or data is collected or stored by Pilothouse during this process. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on the Website.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when you revisit the Website; and (2) third-party cookies, which are served by third-party service providers on the Website, and can be used by such service providers to recognize your computer or mobile device when you visit certain other websites.

If you do not wish to receive cookies, you may set your web browser to reject cookies or to alert you when a cookie is placed on your computer or mobile device. You are not required to accept cookies, however, if your web browser rejects our cookies you may not be able to use all of the features and functionality of the Website.

 

Disabling cookies

You can typically remove or reject cookies via your web browser settings. In order to do this, follow the instructions provided by your web browser (usually located within the “settings,” “help” “tools” or “edit” options). Many web browsers are set to accept cookies by default unless you make changes to your web browser settings.

 

Do Not Track

If you opt-out of having your information collected through cookies and other web technologies, your existing display advertising cookie(s) will be deleted and a new cookie will attempt to be placed that instructs third-party service providers not to track your future activities when that cookie is detected (a “do-not-track” cookie). If your browsers are configured to reject cookies when you visit our opt-out page, a “do-not-track” cookie cannot be set on your computer. Also, if you subsequently erase “do-not-track” cookies, use a different computer or mobile device or change web browsers, you will need to opt-out again. We currently do not respond to browser "do-not-track" signals.

 

Cookies we use:

Essential Cookies

Essential cookies allow you to access and use certain services and features available through the Website. For example, they allow you to log in to secure areas of the Website and allow for content on certain requested pages to load faster. Without these essential cookies, certain requested services will not be available and you won’t be able to enjoy the full experience of the Website.

Functionality Cookies

Functionality cookies remember certain choices you make when you access and use the Website. These choices may include remembering your language preferences, remembering your login details, and remembering the changes you make to certain areas of the Website that can be customized. The purpose of these cookies are to provide a more personalized experience by eliminating the need to re-enter your preferences each time you visit and use the Website.

Analytics and Performance Cookies

Analytics and Performance cookies are used to collect information about Website traffic and how visitors access and use the Website. The information gathered may include the number of visitors to the Website, the URLs that referred visitors to the Website, the pages visited on the Website, the time and day of visits to the Website, whether visitors have accessed and used the Website before, the duration of visitors who have accessed and used the Website, and other similar information. We use this information to improve the Website and to operate the Website more efficiently, to gather broad demographic information, and to monitor the level of activity on the Website.

 

Targeted and advertising cookies

Targeted and advertising cookies allow us to display certain advertisements that may be of interest to you. These cookies use certain information that has been stored by the web browser of your computer or mobile device when you visit certain websites. Based on the use of certain cookies, and with our permission, third-party advertisers can place cookies that enable the displaying of certain advertisements that may be of interest to you on the web browser of your computer or mobile device when you are visiting certain third party websites.

 

You can disable cookies which remember your browsing habits and target advertising at you by visiting http://www.youronlinechoices.com/uk/your-ad-choices. If you choose to remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you. Even if you do choose to remove cookies by the companies listed at the above link, not all companies that serve online behavioral advertising are included in this list, and so you may still receive some cookies and tailored advertisements from companies that are not listed.

Social Media Cookies

These cookies are used when you share information using a social media sharing button or “like” button on the Website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter or Google+. The social network will record that you have done this.

 

vii.  Your Rights with Respect to Your Personal Data:

This section applies if you are located in the European Union (EU) or European Economic Area (EEA). In accordance with applicable privacy law, you have the following rights in respect of any personal information and data that we may hold about you:

  • Right of access and portability. The right to obtain access to and to receive your personal information and data.
  • Right to rectification. The right to obtain rectification and correct/update any of your personal information and data without undue delay where that personal information is inaccurate or incomplete.
  • Right to erasure. The right to obtain the erasure and removal of your personal information and data without undue delay in certain circumstances, such as where the personal information and data is no longer necessary in relation to the purposes for which it was collected or processed.
  •  Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information and data in certain circumstances, such as where the accuracy of the personal information and data is contested by you, and for a period time that would enable us to verify the accuracy of such personal information and data.
  •  Right to object. The right to object, on grounds relating to your particular situation, to the processing of your personal information and data, and to object to processing of your personal information and data for direct marketing purposes, to the extent it is related to such direct marketing.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Policy. You also have the right to lodge a complaint with your local data protection authority.

 

California Residents: Your California Privacy Rights

California Consumer Protection Act

Without being discriminated against for exercising these rights, California law gives its residents the right to request that we disclose what personal information and data we collect from you, to delete such personal information and data, and to opt-out of the sale of your personal information and data (if we sell such information), subject to certain restrictions. For security purposes, we will verify your identity – in part by requesting certain information from you -- when you request to exercise your California privacy rights. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.

Right to Know

If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:

  • The specific pieces of personal information and data we have about you;
  • The categories of personal information and data we have collected, sold, or disclosed for a business purpose about you within the last twelve (12) months;
  • The categories of sources from which the personal information and data was collected;
  • The purposes for which the personal information and data was collected or sold; and
  • The categories of third parties to whom the personal information and data was sold, disclosed for a business purpose, or otherwise shared.

If possible, we will provide this information to you in a readily usable format that allows transmission to another entity. The easiest way to submit a request and receive your report is to contact Pilothouse.

Right to Delete

If you are a California resident, you may submit a verifiable request for us to delete the personal information and data we have collected about you. The easiest way to submit a request for deletion is to contact Pilothouse.

 

Right to Opt-Out

California residents may opt out of the “sale” of their personal information and data, as defined by the CCPA. This does not include when:

  • You direct us to disclose your personal information and data or use us to interact with a third party and the third party does not sell the personal information;
  • We use or share an identifier solely to alert a third party you have opted out of the sale of your personal information and data;
  • Your personal information and data is transferred as an asset as part of a transaction in which the third party assumes control of all or part of our business, in which case the third party would have to tell you in writing if it materially changes how the information is used or shared; and
  • We use or share your personal information and data under a written contract with a service provider necessary to perform a business purpose. Here, the service(s) that the service provider performs is on our behalf, and our written contract prohibits it from keeping, using or disclosing your personal information and data for any purpose other than for the specific purpose identified in the contract.

In these cases, the disclosure of your personal information and data would not be considered a “sale” under CCPA. We use and share your personal data as described in this Policy and do not believe this use and sharing is a sale as defined by the CCPA. We have not sold personal information and data about you in the last twelve (12) months and currently have no plans to do so in the future. However, we have provided you with a system to record your preference that your personal information and data not be sold in the future. You may make this request by contacting Pilothouse.

 

Right to be Free from Discrimination

We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our owned and/or operated websites, including this Website.

 

Authorized Agents

If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.

 

viii. Third-Party Relationships

Third-party Links. The Website and our product(s) and/or service(s) may contain links to other third-party owned and/or operated websites and, where you request information from third-party providers, we may transfer you directly to the websites of such third-party providers. Pilothouse is not responsible for the privacy practices or the content of such third-party websites. In some cases, you may be required to provide certain information to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Pilothouse has no responsibility or liability relating to them. We do not endorse, nor are we responsible for the accuracy of, the privacy policies and/or terms and conditions of such third-party website. These third-party entities are independent third parties and are not affiliated with Pilothouse.

ix. Third-party Technology/Software/Service/Solutions Providers

The Website, and any product(s) and or service(s) being made available through the Website or from Pilothouse, may contain certain software technologies and services licensed from third-party providers. Pilothouse may engage with certain third-party services and solutions providers. These third-party providers have separate privacy and data collection practices and policies, and Pilothouse has no responsibility or liability relating to them. We do not endorse, nor are we responsible for the accuracy of the terms and conditions of any third-party privacy policies. These third-party entities are independent third parties and are not affiliated with Pilothouse.

Pilothouse may be using or sharing your personal information and data for Legitimate Interest purposes with third-party service providers, which may include, without limitation:

 

x. Security of Data

Pilothouse is committed to protecting the security of any personal information and data that it collects and stores. We use a variety of industry-standard security technologies and procedures to help protect any personal information and data from unauthorized access, use, or disclosure. Despite these measures, no method of transmission over the Internet, or method of electronic storage is 100% secure. Pilothouse cannot fully eliminate security risks associated with the collection and storage of any personal information and data, including without limitation, any mistakes and security breaches that may happen. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. In the unlikely event of a data breach where your personal information and data has been compromised, Pilothouse will promptly notify you, the applicable authorities and supervisory authorities or data protection authorities.

If you are located in the EU/EEA and Pilothouse is required to transfer your personal information and data in accordance with this Policy, we exert commercially reasonable efforts to ensure that any transfer of your personal information and data outside of the EU/EEA is protected under industry-standard contractual clauses and any subsequent data protection safeguards. Where EU Data Protection Law applies, Pilothouse shall not process its collected personal information and data (nor permit its collected personal information and data to be processed) in a territory outside of the EU/EEA unless it has taken such measures as are necessary to ensure the transfer is in compliance with EU Data Protection Law. Such measures may include (without limitation) transferring its collected personal information and data to a recipient in a country that the European Commission has decided provides adequate protection for personal information and data, to a recipient that has achieved binding corporate rules authorization in accordance with EU Data Protection Law, or to a recipient that has executed standard contractual clauses adopted or approved by the European Commission.

 

xi. Data Retention Period

Any personal information and data that is collected and stored by Pilothouse will be retained only for as long as required in order to provide certain products and/or services to you, or as required by applicable law. Any personal information and data that is no longer required by Pilothouse will be destroyed.

 

xii. Contact Information

If you have any questions regarding this Policy, would like to review, update or remove your personal information and data, or would like more information on our data collection, usage, and privacy practices, please contact us at:

Pilothouse Digital Ltd.

1011 Government St.

Victoria, BC V8W 1X6

Canada

privacy@pilothouse.co

We reserve the right to limit or deny your request to view, update, or remove your Personal Data if you have failed to provide us with sufficient information to verify your identity.

 

xiii. Changes to This Privacy Policy

We reserve the right, in our sole discretion, to modify, update and change this Policy from time to time without prior notice to you. Notice regarding any Policy changes will be placed in a prominent location on the Website and will take effect immediately upon posting on the Website. Please check the Website periodically for any changes. Your continued use of the Website following the posting of changes to this Policy will constitute your acknowledgment and acceptance of any and all changes.


Withdrawal of Data Processing Consent

By completing and submitting this form, you are agreeing to the following.

"I hereby withdraw the consent to process my personal data from Pilothouse Digital. Pilothouse Digital no longer has my consent to process my personal data for which it was previously granted."

Withdrawal of personal data may take up to thirty (30) days.

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