Privacy Statement
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Point B, Inc. (“Point B”) and its affiliated companies, provide a variety of consulting and related services as described at www.pointb.com (“Site”). Throughout this Privacy Policy, “Sites” refers to this Site and, as applicable, any other website, channel, application, mobile feature and/or platform we operate. Under this Privacy Policy, Point B and its affiliates are referred to as “Point B” or “we, us, and/or our.” Except where otherwise provided, other capitalized terms have the meanings set forth in the Terms and Conditions at pointb.com/terms-and-conditions/(“Terms”). Together with the Terms, this Privacy Policy is a legally binding agreement between you and Point B.
PURPOSE
This policy (“Privacy Policy”) describes, among other things:
- The Personal Information (as defined below) we collect about you
- How we use the Personal Information we collect
- The categories of third parties with whom we share Personal Information about you
- Your right to review and correct Personal Information we have collected about you
- What we do to protect Personal Information we have collected about you
- Your right to opt-out of commercial email messages
- How we interact with linked sites
- Specific terms applicable to California residents
- Specific terms applicable to EU data
- Our right to change the terms of this Privacy Policy
This Privacy Policy outlines how we handle Personal Information we collect from all residents, including those residents of California and the European Union, which includes the purpose and legal basis for collecting that information, how long we retain it, and your right to object to the collection of the information.
Together with the Terms, this Privacy Policy is a legally binding agreement between you and Point B. By accessing or using the Sites or by requesting information, purchasing or subscribing to any services provided by Point B (the “Services”), you consent to the Terms and this Privacy Policy, including our collection, use, and disclosure of your Personal Information as described below. Please read this Privacy Policy carefully.
SCOPE
This Privacy Policy applies only to Personal Information. It does not cover data we collect that cannot be used to identify an individual or to pseudonymous data. Nor does it include encoded or anonymized information or aggregated data which we collect or create about a group or category of services, features or users which does not contain personally identifying information. We reserve the right to share aggregate, encoded, or anonymized information with potential partners or other third parties without restriction.
WHAT IS PERSONAL INFORMATION?
For the purposes of this Privacy Policy, Personal Information is your first and last name, your email address, your home or other physical address, including a street name and name of a city or town, your telephone number, your social security number, any payment or financial information, or any other identifier that permits Point B to contact a natural human person, like you, and/or any information that we maintain that could be used to identify you in combination with any of the identifying information described above.
INFORMATION WE COLLECT
We collect Personal Information you provide to us and when you use the Sites and/or our Services. We collect Personal Information in order improve our services, to deliver services and perform obligations under contracts we have with you, to comply with our own legal obligations, and for other purposes as described below.
Information You Give Us: We receive and store any Personal Information you post to the Sites or provide to us when you contact us, request information, sign up for our newsletters or promotions, purchase Services, or apply for employment. For example, if you request information about our Services or contact us through the Sites, we may ask you for information such as name, telephone number, email address, state of residence and company affiliation to process your request. We may use your email address to contact you about your request and, if necessary, may use the other information to contact you for help to process the request. You can choose not to provide such Personal Information, in which case you will not be able to access or use portions of the Sites or some of their features.
Automated Collection: We automatically receive and store certain types of information when you visit the Sites, such as the name of the domain and host from which you access the Internet; the IP address of the computer you are using and the browser and operating system you are using; the date and time you access the Sites; the Internet address of the website from which you linked to the Sites; any search terms you used to find the Sites; the device identifiers and mobile and network information, and your actions on the Sites. This information will be treated as Personal Information if we combine or link it to any of the identifying information above. Otherwise, this information constitutes aggregate information.
Log Data: Our web servers may collect “log data.” Log data provides aggregate information about the number of visits to different pages on the Sites. We use log data for troubleshooting purposes and to track which pages people visit in order to improve the Sites. We do not link log data collected to Personal Information. Third-party vendors may also collect aggregate log data independently from us.
Cookies and Other Technologies: We automatically receive and store certain types of information when you visit the Sites through the use of cookies, web beacons, or similar programs to collect the information described above. Cookies are strings of text that a website may store on your computer. Cookies enable the Sites to keep track of your preferences and activities when you use or visit the Sites.
The Sites create session cookies for each visit in order to facilitate your visit. The session cookie expires at the end of the session.
We may also use “persistent” cookies, which remain on your device for much longer. Cookies do not corrupt or damage your computer or computer files.
We use cookies for authentication, to remember your settings, to keep track of your activity during a visit to the Site, to conduct usability tests, to improve Site performance, and to implement certain features of the Site.
We use analytics and customisation cookies, including third party cookies, to gather information on how our Sites are being used by our visitors and to measure how popular our marketing campaigns are. We use the data we get to help customise our Sites and services for you and make the content you see as relevant as possible. We may also use the data we collect to help identify and prevent fraud, and to track visits from our affiliates or partners.
Social networking cookies allow visitors to share our pages and content through third-party social networking websites.
You can control the use of cookies at the individual browser level. You are asked to consent to the placement of cookies and, if you do, you can later withdraw your consent by changing your preferences on our Site or through your browser. If you reject cookies, you may still use our Sites, but your ability to use some features or areas of our Sites may be limited. If you do not wish to receive these cookies, you may set your browser to reject the cookies (consult the instructions for your particular browser on how to do this), although doing so may affect your ability to perform certain transactions on the Sites.
Web Beacons: Some of the pages on the Sites may contain electronic images known as web beacons that allow us to count the number of users who have visited those pages. These collect only limited information such as a cookie number, time and date of a page view, and a description of the page on which the web beacon resides. These web beacons do not carry any personal Information and you cannot opt-out or refuse them. However, where they operate with cookies, you can render them ineffective by opting out of cookies or changing the cookie setting in your browser.
Advertisements: We use third party service providers to serve and host our advertisements. You may receive our ads on these third party sites. These third parties use persistent cookies to track the number of times our site is accessed and whether the site was accessed from the advertisement. The cookies generated from the advertisements do not contain Personal Information and may remain on your hard drive three or more years unless you delete them. If you do not want Personal Information about you used for this purpose, you may opt-out by following the procedure described below. Note, however, that where we use a third party to provide advertising, email marketing or similar services, each such third party will have its own opt-out process, which it will manage and control. You will need to follow those procedures to opt-out of the services they provide.
OUR USE OF PERSONAL INFORMATION
We may use the Personal Information provided or obtained through the Sites to:
- Process applications for employment;
- Perform research and analysis about your use of, or interest in, our services, or content;
- Communicate with you by email, regular mail, telephone, or mobile devices, about services that may be of interest to you;
- Develop and deliver our newsletter;
- Tailor your user experience;
- Enforce our Terms;
- Manage our business;
- Notify you of changes to our services;
- Send you information you have requested;
- Carry out obligations under any contract we have with you;
- Perform functions as otherwise described to you at the time of collection;
- In connection with the processing of your requests for information; and
- In connection with the processing and fulfillment of services you purchase.
We generally store Personal Information in the United States as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, as we determine is necessary for business records, and as required under applicable law. However, we may transfer your Personal Information from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our business. By providing any information to Point B, you consent to such transfer, storage, and processing.
Disclosure of Personal Information to Third Parties
General: We do not share the Personal Information provided or obtained through the Sites with third parties, except as described below and as otherwise specified in this Policy. We may share Personal Information as follows:
- With the third parties that perform(s) maintenance and operation of the Sites on our behalf. These parties are bound by a confidentiality agreement prohibiting the unauthorized disclosure and/or use of your Personal Information.
- With other third parties that perform services or functions on our behalf. We do not authorize such third parties to use your Personal Information for any other purposes.
- With third parties, such as social sites (including Facebook and Instagram), to which you subscribe in order for you to link to them through our site and view our content through those sites.
- As we believe is necessary to comply with applicable laws, statutes, or regulations, and/or to enforce this Privacy Policy and the Terms and to protect our rights and the rights of others.
- As required by a court or government agency or to respond to a claim by you or a third party
- As part of a transfer of our assets, for example in the event of a merger, acquisition, corporate change or, in the unlikely event of a bankruptcy, involving Point B.
- As you may otherwise request or agree.
Affiliates: We share much of our data, including Personal Information about you, with our affiliated entities and joint ventures when it is reasonably necessary for the purposes otherwise permitted in this Privacy Policy. This includes the owners of the Properties we manage or operate.
Service Providers: We use third party service providers to provide specific business support services to us which may involve limited access to Personal Information. We require these companies to use the information only to provide the contracted services and prohibit them from transferring the information to another party except as needed to provide the contracted services. Examples of such services include sending emails, conducting and administering promotions, executing surveys, providing customer service, performing business analysis, and processing payments. When we employ another company to perform a function for us, we only provide them with the information that they need to perform their specific function. We are not responsible for the actions of service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties.
Business Transactions: We may disclose your Personal Information as part of any merger, sale of company assets or acquisition, as well as in the event of an insolvency, bankruptcy or receivership. The recipient of Personal Information following such actions may have privacy policies that differ from those in this Policy. You will be notified via email and/or a prominent notice on the website, and you may opt- out of the use of your existing information in a new manner.
Other purposes: We may use and share Personal Information for other purposes with your consent.
Disclosure: Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. To request this information please contact us at security@pointb.com.
Other Privacy Policies: Any third parties to whom we may disclose Personal Information may have their own privacy policies that describe how they use and disclose Personal Information. Those policies will govern use, handling, and disclosure of Personal Information once we have shared it with those third parties as described in this Policy. If you want to learn more about their privacy practices, we encourage you to visit the websites of those third parties.
CHILDREN
The Sites are not directed at children, and we do not knowingly collect Personal Information directly from users under the age of 13 or from other web sites or services directed at children. Consistent with the Federal Children’s Online Privacy Protection Act of 1998 (COPPA), we will not knowingly request or collect Personal Information from any child under age 13 without obtaining the required parental consent.
CORRECTIONS AND UPDATES
If you want to view your Personal Information, or delete or modify such information that is inaccurate, you may do so by sending an email to security@pointb.com. In making modifications you must provide only truthful, complete, and accurate information. We may limit your right to make changes to Personal Information where the burden or expense of providing access would be disproportionate to the risks to your privacy or where the legitimate interests of other persons may be violated.
Please note that notwithstanding your request to change or delete Personal Information, we may be required to keep this information and not modify or delete it, or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements. When we delete any information, it will be deleted from the active database, but may remain in our archives. In some instances, however, Personal Information that you requested to be removed may be retained in certain files for a period of time in order to troubleshoot problems. In addition, some types of Personal Information may be stored indefinitely on back-up systems or within log files due to technical constraints or financial or legal requirements. Therefore, you should not always expect that all of your Personal Information will be completely removed from our databases in response to your request.
In addition to deleting Personal Information, you may choose to opt-out of receiving future newsletters, promotions or any other email communications from us by following the unsubscribe instructions included in the communications, or by contacting us via email as provided above. All promotional emails from us include an opt-out link which can be processed within 24-hours. You may also opt-out of promotions by sending us an email in response with “unsubscribe” or “opt-out” in the subject line of the email. Opting out of promotional communications does not affect our communications with you via telephone or email related to any business we may have with you or other transactional emails.
We reserve the right to verify the identity of any person making a request to opt-out or to delete or modify incorrect Personal Information, to charge you a fee before providing access and to deny such requests, except as prohibited by law; provided, however, that we will have no liability of any kind resulting from false or erroneous requests or any change or deletion we make for any reason.
STORING YOUR PERSONAL INFORMATION
We will retain the Personal Information you give us or we collect for as long as you maintain your User Account or subscription to our newsletters or other content, participate in any of the features on the Sites, enter any promotions or use any of our other Services, and for a reasonable time thereafter. We will retain and use Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Otherwise we will retain Personal Information for up to twenty- four (24) months and thereafter may store it in aggregate. If you would like us to delete the Personal Information you have provided to us, please contact us at security@pointb.com and we will respond in a reasonable time. Please note that some or all of this information may be required in order for you to make use of services and features available via the Sites. If you remove this information, you may no longer be able to use these features.
SECURITY
We utilize a combination of reasonable physical and electronic security technologies, procedures, and organizational measures to help protect your Personal Information from unauthorized access, use, or disclosure. While we strive to safeguard your Personal Information, we cannot guarantee or warrant the security of any information you disclose or transmit to us.
SOCIAL MEDIA
The Sites may include social media features, such as the Facebook Like button, and widgets such as the “Share” button or interactive mini-programs that run on the Sites. These features may collect your IP address, which page you are visiting on the Sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Sites. Your interactions with these features are governed by the privacy policy of the company providing each feature.
THIRD PARTY WEBSITES
The Sites may contain links to other websites. We do not control, and make no representations whatsoever regarding, such other websites or the products and services offered by or through websites accessed through links on the Sites, even those with which we may have an affiliation. If you decide to access third party websites linked through the Sites you do so at your own risk. You should carefully review the privacy policy and terms of these websites.
COMMERCIAL ELECTRONIC MESSAGE CONSENT
By providing your email address to us through the Sites, you affirmatively and expressly consent to receiving commercial emails from Point B, and those parties that process email communications on our behalf. Point B and these third parties may send you commercial emails in order to deliver the Newsletter, to provide you with more information about available services you have purchased, and to provide you with updates, and other information, including but not limited to Site updates.
OTHER TERMS AND CONDITIONS
Your access to and use of the Sites and our services are also subject to our Terms and Conditions found at Your access to and use of the Sites and our services are also subject to our Terms and Conditions found at www.pointb.com/terms-and-conditions/.
CONTACT US
If you have any questions about this Privacy Policy or our privacy practices, contact us at security@pointb.com. We will respond to your request within 30 days.
HOW TO EXERCISE YOUR RIGHTS
If you would like to exercise any of your rights as described in this Privacy Policy, please:
- Complete this Data Access Rights Request form; or
- Email us at security@pointb.com;
- Mail us at 1420 Fifth Avenue, Suite 2200, Seattle, WA 98101.
When you contact us, you will need to provide us with:
- Enough information to identify you (e.g., your full name, address and customer or matter reference number, and country and/or state of residence);
- Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
- A description of what right you want to exercise and the information to which your request relates.
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.
Any Personal Information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to change or modify this Privacy Policy as we deem necessary or appropriate due to changes in our business practices or changes in the law. If you have provided us with your email address, we will attempt to notify you by that address of any material changes to how we use your Personal Information.
CALIFORNIA PRIVACY RIGHTS
The following provisions apply to residents of the State of California.
Under California Civil Code Section 1798.83, if an individual who is a California resident has provided Personal Information to a business in connection with a business relationship that is primarily for personal, family, or household purposes, and if that business has within the immediately preceding calendar year disclosed such an individual’s Personal Information to a third party and knows or should have known that such third party used the information for its own direct marketing purposes, then that business is obligated to disclose in writing to such individual upon request, what Personal Information was shared and with whom it was shared.
Any request for a disclosure required under this California law should be sent to us via email at security@pointb.com or via regular mail at:
1420 Fifth Avenue
Suite 2200
Seattle, WA 98101
Please note that under this law, you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period and we are not required to respond to your request more than once in a calendar year, nor are we required to respond to any request that is not sent to the email or mailing address designated above. The California Consumer Privacy Act of 2018 (“CCPA”) provides you with specific rights regarding your Personal Information, including information that could be linked with or used to identify your household. You have the right under the CCPA and certain other privacy as data protection laws, as applicable, to exercise the following rights free of charge:
Disclosure of Personal Information We Collect About You
You have the right to know:
- The categories of Personal Information we have collected about you;
- The categories of sources from which the Personal Information is collected;
- Our business or commercial purpose for collecting or selling Personal Information;
- The categories of third parties with whom we share Personal Information, if any; and
- The specific pieces of Personal Information we have collected about you.
Please note that we are not required to:
- Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or
- Provide the Personal Information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose
In connection with any Personal Information we may sell or disclose to a third party for a business purpose, you have the right to know:
- The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and
- The categories of Personal Information that we disclosed about you for a business purpose.
Right to Deletion
Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:
- Delete your Personal Information from our records; and
- Direct any service providers to delete your Personal Information from their records.
Please note that we may not delete your Personal Information if it is necessary to:
- Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
- Debug to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act;
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
- Comply with an existing legal obligation; or
- Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination
You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
- Deny goods or services to you;
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Provide a different level or quality of goods or services to you; or
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your Personal Information.
The following chart includes certain information already provided in this Privacy Policy. This format is intended to be compliant with the CCPA.
Categories of Personal Information under the California Consumer Privacy Act
Personal identifiers
Category: Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver's license number, passport number, or other similar identifier.
Sources of Information: We collect this type of information from our users, customers, and business partners. We also generate identifiers internally.
How we use it
To enable use of our sites, services, and products to communicate with you, to understand how our users interact with our sites, and to improve our offerings
Types of individuals affected
People who use our Sites, create a user account, or send us an inquiry about a product or service from us
How we share it
We share this data with our service providers and with business partners, including those to whom you instruct us to send this information.
Personal information
Category: Personal information defined under California Civil Code section 1798.80(e) (relating to security breaches)
Sources of information: We collect this type of information from our users, customers, and business partners.
How we use it
To enable use of our sites, services, and products, to communicate with you, to understand how our users interact with our sites, and to improve our offerings
Types of individuals affected
People who use our Sites, create a user account, or send us an inquiry about a product or service from us
How we share it
We share this data with our service providers and with business partners, including those to whom you instruct us to send this information
Protected classifications
Category: Characteristic or protected classifications under California or federal law (such as race, gender, ethnicity, etc.)
Sources of information: We collect this type of information from our users and business partners.
How we use it
To understand how our users interact with our Sites, and to conduct research into how our customers use our products and services
Types of individuals affected
People who use our Sites, create a user account, or send us an inquiry about a product or service from us
How we share it
We don’t share unless you have consented or sharing is required to enable our service provider to complete your request
Commerical information
Category: Purchase history, etc.
Sources of information: We collect this type of information from our customers, and generate it internally during transactions with our customers
How we use it
To transact with you if you use our services or products, and to enable transactions you’ve requested
Types of individuals affected
People who use our Sites, create a user account, or send us an inquiry about a product, or service from us
How we share it
We share this data with our service providers and with business partners, including those to whom you instruct us to send this information
Biometric information
How we use it
We don’t collect this data. If that changes, we will amend this privacy policy.
Types of individuals affected
None
How we share it
None
Internet or electronic network activity
Category: Internet or electronic network activity information (browsing history, search history, etc.)
Sources of information: We collect this type of information from our users and customers
How we use it
To enable use of our Sites, services, and products, to communicate with you, to understand how our users interact with our sites, and to improve our offerings
Types of individuals affected
People who use our Sites or mobile applications
How we share it
We share this data with our service providers and with business partners, including those to whom you instruct us to send this information
Audio, electronic, visual, and sensory information
Category: Audio, electronic, visual, thermal, olfactory, or similar information
Sources of information: We collect this type of information from our users and customers
How we use it
To identify you, to enable use of our Sites, services, and products, and for safety purposes
Types of individuals affected
People who call us or visit or tour a Point B office
How we share it
We share this data with our service providers
Professional or employment-related information
Sources of information: We collect this type of information from our customers and business partners
How we use it
To provide services or products you’ve requested
Types of individual affected
People who contact us in a business-to-business or employment context
How we share it
We share this data with our service providers and with business partners, including those to whom you instruct us to send this information
Education information
Sources of information: We collect this type of information from our job applicants
How we use it
For HR purposes and pre-employment review.
Types of individuals affected
People who apply for employment with us
How we share it
We share this data with our service providers and with business partners, including those to whom you instruct us to send this information
Inferences
Source of information: We generate these internally
How we use it
To understand how our users interact with our Sites, to develop and offer more relevant and useful services and products, and to improve the products and services we offer
Types of individuals affected
People who use our Sites; create a user account; or send us an inquiry about a product, or service from us
How we share it
We don’t share unless a service provider is contracted to analyze such inferences for us
“Do Not Track”
Section 22575 of the California Business & Professions Code requires website and online service operators to disclose whether they honor web browser “Do Not Track” settings. We support and honor “Do Not Track” web browser settings. If you enable Do Not Track settings in the browser you are using, we will not collect, store, or use Personal Information about websites you visit using that browser other than www.pointb.com and our other Sites. Other parties, however, may not honor Do Not Track signals. These parties may collect Personal Information about your online activities over time and across different web sites when you visit the Sites, for example by using cookies on our Sites. We have no access to or control over other parties’ Personal Information collection practices, even those with which we may have an affiliation. You should carefully review the privacy policy and terms of any website you visit. For more information about Do Not Track, please visit www.allaboutdnt.org.
INTERNATIONAL VISITORS
The Sites are hosted in and provided from the United States and are intended for those visiting the United States. If you use the Sites from the European Union (EU), Canada, or other countries or regions with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your Personal Information to the United States for storage and processing. The United States does not have the same data protection laws as the EU, Canada, and other countries or regions.
EU PRIVACY RIGHTS
The Sites are directed at consumers in the United States and the Properties we own or operate are located in the United States. In most cases, the Personal Information we collect is stored and used in the United States.
While we do not direct our Services to residents of the EU, it is possible that EU residents may access and use the Sites. If we collect Personal Information from EU residents in a manner subject to the General Data Protection Regulation then, in addition to the above, the following terms shall also apply to our collection, use and retention of that information:
Basis for Collection: As set out above, we collect and process Personal Information for which you have given your express consent at the time of collection. For example, we collect Personal Information when you elect to participate in one of our promotions. We also collect and process Personal Information in order to improve our Services, to deliver Services and perform obligations under contracts we have with you, and to comply with our own legal obligations.
Sensitive Data: We do not collect sensitive data, (as defined in General Data Protection Regulation 2016/679) for example, biometric data, health data, or data revealing racial or ethnic origin, from visitors to the Sites.
Onward Transfer: Except as otherwise provided in this Privacy Policy, we only disclose Personal Information to third parties who reasonably need to have access to it for the purpose of the transaction or activity for which it was originally collected or to provide Services or to perform tasks on our behalf or under our instruction. All such third parties must agree to use such Personal Information we provide to them only the purposes for which we have engaged them and they must either: (a) comply with the EU-US Privacy Shield Principles or another mechanism permitted by the applicable EU & Swiss data protection law(s) for transfers and processing of Personal Information; or (b) agree to provide adequate protections for the Personal Information that are no less protective than those set out in this Privacy Policy. Where we have knowledge that an entity to whom we have provided Personal Information is using or disclosing Personal Information in a manner contrary to this Privacy Policy, we will take reasonable and appropriate steps to prevent, remediate or stop the use or disclosure.
Authorized Transfer: We also may disclose Personal Information for other purposes or to other third parties when you have consented to or requested such disclosure. Please be aware that we will disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are not liable for appropriate onward transfers of Personal Information to third parties.
Data Processors: We may retain third parties to process or analyze Personal Information we collect from the Sites. For example, a Site may be maintained or hosted by a third party service provider, a promotion may be administered by a sales promotion agency, and/or products may be fulfilled by a wholesaler. These suppliers and other third parties who provide services for us are contractually obligated not to use Personal Information about you except as we authorize.
Profiling: We may analyze Personal Information we have collected about you to create a profile of your interests and preferences so that we can contact you with information that is relevant to you. We may make use of additional information about you when it is available from external sources to help us do this effectively. We may also use Personal Information about you to detect and reduce fraud and credit risk.
Your Rights: Your rights include: (a) a right to withdraw your consent to the processing of Personal Information about you to which you have previously given consent; (b) a right to object to processing of Personal Information about you for the purpose of direct marketing; and (c) a right to have any incorrect part of the Personal Information about you corrected or removed. If you wish to exercise any of these rights, send an email to us at security@pointb.com.
If you request to have incorrect Personal Information removed, we may retain some of your Personal Information as necessary for the purposes of our legitimate business interests or in furtherance of public interests in accordance with the Privacy Shield Principles. Any Personal Information you have shared publicly with others may continue to be publicly visible on the Sites.
You also have the right to obtain a copy of the Personal Information we have about you, although we reserve the right to charge a reasonable fee for this depending on the nature and frequency of your request(s) and our cost to provide the information.
Questions and Complaints: If you have questions or complaints regarding this Privacy Policy or our handling of Personal Information about you, you can exercise your rights or contact us as described above.
Enforcement and Disputes: We commit to resolve complaints about your privacy and our collection or use of your Personal Information in a timely and reasonable manner. If you do not receive timely acknowledgement of your request or have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us at security@pointb.com.
In addition to the above, you may lodge a complaint with your home data protection authority and can invoke binding arbitration for residual claims not resolved by other redress mechanisms. Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Revised: February 18, 2020
Business Conduct Form
The Point B Business Conduct Form is an ethics and business conduct reporting tool. This is a way to submit your ethics case directly to the appropriate Point B management who will promptly address/investigate the matter.
Individuals have the option to remain anonymous when reporting concerns by simply omitting any data they deem as undesired to be reported. The more information provided however will allow for Point B to perform a more complete investigation.
Share a business conduct concern.
Data Access Rights Request
If you are located in the European Union, complete the form below to submit a Data Access Rights Request.
If additional information is required, we will contact you using the contact information that was provided by you in the request.
Your request will be forwarded to the appropriate team and you will receive a response within 30 days.