PRIVACY POLICY

Last Revised: March 28, 2019

1. Scope of this policy

This privacy policy (the “Policy” or the “Privacy Policy”) describes how Pearl Marketing collects, uses, consults or otherwise processes an individual’s Personal Data. For the purposes of this policy, “Pearl” refers to Pearl Marketing & Design, LLC, a limited liability company under the law of the state of New Hampshire having its registered seat and its offices at 7 Auburn Street Nashua, NH 03064 email address [email protected]. In all cases described in this Policy, Pearl Marketing will process your personal data as a data Controller.  Furthermore, Pearl Marketing and Pearl Marketing Academy is a dba name of Pearl Marketing & Design, LLC.

We are committed to protecting the privacy of our users and customers. This Privacy Policy is especially directed at:

• visitors and subscribers of the websites of Pearl;
• natural persons contacting us through the contact or other forms available on   the websites;
• subscribers to our newsletter(s);
• users signing in to use our services;
• users signing in to download Free eBooks;
• users signing in to attend and/or watch webinars;

This Privacy Policy is intended to inform you how we gather, define, and use information that could identify you, such as your name, email address, address, other contact details, online identifiers or other information that you provide to us when using our websites or when relying on our services. Please take a moment to read this Privacy Policy carefully.

This policy includes a description of your data protection rights, including a right to object to some of the processing activities we carry out.

2. Collection of Information

The purpose of the Website is to create an online community of professionals who would like to interact with other professionals.

As part of our effort to create this online community, we receive and store information about you such as:

a) Personal Information

Content published on Pearl Marketing Academy is accessible by all visitors. However, certain Pearl Marketing Academy features and services may require registration. Users may register (“sign-up”) on-site (for example, at WEBSITE URL FOR SIGN UP). Upon signing-up, an account is created for the user (“Account”). Users who sign-up on-site are required to confirm their registration by clicking on an activation link which is sent to them via email.

Users are required to provide part or all of the following information below, depending on the features or services they wish to access:

• First and last name
• Email address
• Company name, size, industry, state and country
• Job title, focus, and level
• Purchasing authority
• Work phone

Once you complete activation, and you will be able to create your profile (“Profile”).

You may be required to provide us with additional information and consent to our terms as described here(LINK TO T&C)which are part of our general TOS and Privacy Policy.

3. Use of Information

We use your information to provide, analyze, administer, enhance and personalize our services and marketing efforts, to process your registration, your orders and your payments and to communicate with you on these and other topics. For example, we use information to:

a) We use your Information in order to resolve disputes; troubleshoot problems; help promote safe matching; collect fees owed; measure consumer interest in Services; inform you about offers, products, services, and updates; customize your experience; detect and protect us against error, fraud and other criminal activity; enforce our TOS; and as otherwise described to you at the time of collection. We may compare and review your Business Information for errors, omissions and for accuracy.

b) Email marketing: we may send you emails about our site and related course(s), registration, course content, your course progress or other updates. We may also use your email to inform you about changes to the course, survey you about your usage, or collect your opinion.

c) We may use your Business Information in order to provide benchmark analysis and aggregate statistics. This particular Business Information will be anonymized, will not contain personal identification and will not be transferred or sold to third parties in any way or format that identifies you.

d) We use Website navigation data to operate and improve the Website. We may also use Website navigation data alone or in combination with your Business Information to provide aggregated information about Pearl Marketing Academy. We automatically track and collect certain non-personal information such as Website navigation data, Internet Protocol (“IP”) addresses, timestamps and URLs. We use this information to do internal research on our users’ demographics, interest, and behavior to better understand, protect and serve you and our users.

e) We collect the IP Addresses to track when you use our Website. We use IP Addresses to monitor the regions from which you navigate our Website and sign-up to use our Services. Your IP-address is also registered for statistical purposes and to better our advertising and layout of the Website. In specific, we use your IP Addresses for the following reasons:

i) Send the most appropriate advertising based on geographic area or information derived from your IP address. Many IP addresses are commonly associated with Internet service providers, universities, or major corporations in specific regions or localities. Aggregate information derived from IP addresses may also be reported to advertisers.

ii) Estimate the total number of Internet users visiting our Website from specific countries or regions of the world.

f) We do not transfer, sell or rent your Business Information to third parties for their marketing purposes other than what is stated in this Privacy Policy. We request only the information that we need to operate our Services and improve our Website’s user experience.

g) Correspondence information

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on our Website, we may store such information on our servers.

h) Payment Information

To protect you against fraud, unauthorized transactions (such as money laundering), claims and other liabilities, we only collect an identification number and order details, which enable us to match each user to the payments he makes. We do not collect credit card information.

We allow our third party payment vendor to collect information for the purpose of collecting fees from users on the Website. We do not have access to the payment information that you provide to our third party payment vendor and this information is subject to the privacy policy of the third party payment vendor. For more information regarding what payment information our third party payment vendor collects and how it uses this information, please see their privacy policy

If you make a purchase on our site, we use a third party payment processor such as Worldpay or Paypal. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS). Your purchase transaction data is stored only as long as is necessary to complete your purchase transaction.

All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover.

PCI-DSS requirements help ensure the secure handling of credit card information by our site and related courses and its service providers.

i) Disclosure

We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service [INSERT LINK to your Terms of Service].

4. Use of Business Information by other third parties

a) We make reasonable efforts to make sure that our users, who use our Services, will use the information available to them solely for Pearl-related purposes. However, we cannot control their use of that information outside this scope and we are not responsible for such unauthorized uses.

b) Pearl Marketing Academy reserves its right to share your Information with a third party in case of sale merger, control changes, reorganization or liquidation of the Company. All actions will naturally be completed in compliance with applicable laws of personal data and privacy.

Our legal basis for collecting and using the personal information described in this Privacy Policy will depend on the personal information concerned and the specific context in which we collect and use it. We will normally collect personal information from you where we need the personal information to perform a contract with you (for example to provide our services to you), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights an freedoms (for example our direct marketing activities in accordance with your preferences), or where we have your consent to do so (for example, for you to participate in specific surveys and focus groups).

In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example to prevent payment fraud or confirm your identity).

For questions about our use of your personal information (including legal basis and transfer mechanisms we rely on) please contact our Data Protection Office/Privacy Office by mail at: [email protected]

5. Protection of Information

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information. Indicatively:

a) All our employees, independent contractors and agents have executed non-disclosure agreements, which provide explicit confidentiality protections. Any employee, independent contractor or agent who violates such privacy and/or security policies is subject to possible termination and civil and/or criminal prosecution.

b) We do not make any of your Information available to third parties for their marketing purposes.

If however, we share your Information with third parties, we will notify you. Please note that no transmission over the internet can guarantee confidentiality and non-disclosure, and as such, you transmit at your own risk.

c) We use robust security measures to protect data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of data. When the Services are accessed using the internet, Secure Socket Layer (SSL) technology protects your Information, using both server authentication and data encryption. These technologies help ensure that your Information is safe, secure, and only available to you and to whom you have granted access.

d) We do not tolerate Spam. To report spam, please contact us at [email protected]. You may not use our communication tools to send spam or otherwise send content that would violate our TOS. We may check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited content of the Website, but we will not permanently store messages sent through these tools.

e) Pearl Marketing does its utmost to secure communications and data storage in order to protect confidentiality of your Information against loss and interception by third parties. However, it is important to know that there is no zero-risk against loss or interception by others of your Information. You are responsible for maintaining the security and confidentiality of your Account’s username and password.

6. Storage of Information

We save your Information in our database in order to improve our Website’s and user experience and in accordance with our TOS. If you wish that your Business Information be permanently deleted from our database when you stop using our Services, please notify us at support@pearlmarketing.

Pearl Marketing Academy is a United States (US) company. If you are located outside the US and choose to provide information to us, Pearl transfers your Information to our servers in the US. The US may not have the same data protection laws as the country in which you initially provided the Information. When we transfer your Information to the US, we will protect it as described in this Privacy Policy. By visiting our Website or providing Pearl with your Information, you fully understand and unambiguously consent to this transfer, processing and storage of your Information in the US.

7. Information and Rights

Once you have provided your Personal Data, you have several rights, which you can in principle exercise free of charge, subject to statutory exceptions. These rights may be limited, for example if fulfilling your request would reveal Personal Data about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. To exercise any of your rights, you can file a request here [email protected]

a) Right to withdraw consent

Wherever we rely on your consent, you will be able to withdraw that consent at any time you choose and at your own initiative by logging into your account on our website (if you have one) or by contacting us at [email protected]. The withdrawal of your consent will not affect the lawfulness of the collection and processing of your data based on your consent up until the moment where you withdraw your consent.

b) Right to erasure

You have the right to erasure of your Personal Data processed by us as described in this Privacy Policy in case it is no longer needed for the purposes for which the Personal Data was initially collected or processed or in the event you have withdrawn your consent or objected to processing as described in this Privacy Policy and no other legal ground for processing applies. Should you wish to have your Personal Data erased, please file a request here [email protected].

c) Right to restriction of processing

Under certain circumstances, you may ask us to restrict the processing of your Personal Data. This is for example the case when you contest the accuracy of your Personal Data. In such event, we will restrict the processing until we can verify the accuracy of your data. Should you wish to have your Personal Data restricted, please file a request here [email protected].

d) Right to object to processing

Under certain circumstances you may object to the processing of your Personal Data, including where your Personal Data is processed for direct marketing purposes. If you no longer want to receive certain communications from us via email, simply click the un-subscription link in any of our emails.

e)Children

We do not knowingly collect or solicit Personal Data from anyone under the age of 18.

In the event we learn that we have collected Personal Data from a child under the age of 18 without verification of parental consent, steps will be taken promptly to remove that information. If you believe that we have or may have information from or about a child under 18 years of age, please contact us at [email protected].

f) Changes to this Privacy Policy

We reserve the right to modify and update this Privacy Policy from time to time. We will bring these changes to your attention should they be indicative of a fundamental change to the processing or be relevant to the nature of the processing or be relevant to you and impact your data protection rights. 

g) Data Retention

We retain your Personal Data for as long as is required to fulfil the activities set out in this Privacy Policy, for as long as otherwise communicated to you or for as long as is permitted by applicable law

8. Third Party Services

In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

Certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our course website or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.

9. Links

When you click on links on our course site, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.

10. Security

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

If you provide us with your credit card information, the information is encrypted using secure socket layer technology (SSL) and stored with a AES-256 encryption.  Although no method of transmission over the Internet or electronic storage is 100% secure, we follow all PCI-DSS requirements and implement additional generally accepted industry standards.

11. Cookies

a) Tracking Cookies

 We collect cookies or similar tracking technologies. This means information that our website’s server transfers to your computer. This information can be used to track your session on our website. Cookies may also be used to customize our website content for you as an individual. If you are using one of the common Internet web browsers, you can set up your browser to either let you know when you receive a cookie or to deny cookie access to your computer.

• We use cookies to recognize your device and provide you with a personalized experience.
• We also use cookies to attribute visits to our websites to third-party sources and to serve targeted ads from Google, Facebook, Instagram and other third-party vendors.
• Our third-party advertisers use cookies to track your prior visits to our websites and elsewhere on the Internet in order to serve you targeted ads.
• We may also use automated tracking methods on our websites, in communications with you, and in our products and services, to measure performance and engagement.
• Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.

b) Web Analysis Tools

We may use web analysis tools that are built into the BUSINESS NAME website to measure and collect anonymous session information.

12. Age of Consent

By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence.

13. Changes to this Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

If our site or course is acquired or merged with another company, your information may be transferred to the new owners so that we may continue to sell products to you.

14. Contacting us

If you have general questions about your account or how to contact Customer Service for assistance, please send us an email at [email protected].

Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.