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Privacy Policy

 

Last modified: February 5, 2020

Pinckney Hugo Group (“Company,” “us,” “our,” “we,” etc.) respects your privacy and is committed to protecting it through compliance with this policy.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website, www.pinckneyhugo.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies to information we collect:

  • On this Website.
  • In email, text, and other electronic messages between you and this Website.
  • Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
  • When you interact with our advertising and applications on third-party websites and Websites, if those applications or advertising include links to this policy.

This Privacy Policy does not apply to information collected by:

  • Us through any other means, including on any other website operated by Company or any third party; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

We use your personal data to provide and improve our Website. By using our Website, you agree to the collection and use of information in accordance with this Privacy Policy.

 

COLLECTING AND USING YOUR PERSONAL DATA

Types of Data Collected

Personal Data

While using our Website, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies, Tracking Data, and Usage Data
  • Internet or other electronic network activity information

Usage Data

Data may be collected from you automatically when you access our Website.

We may collect information about how you access and use the Website (“Usage Data”). Usage Data may include information such as your device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Website with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Technologies and Cookies

We may use cookies for statistical reporting for the Website and for other purposes relating to making our Website available to you. Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses. We use cookies and similar tracking technologies to track activity on our Website and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Website.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Website.

We use the following cookies for the purposes set out below:

  • Session Cookies: These cookies are essential to provide you with services available through the Website and to enable you to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.
  • Acceptance Cookies: These cookies identify if users have accepted the use of cookies on the Website.
  • Preference Cookies: These cookies allow us to remember choices you make when you use the Website, such as remembering your preferences and various setting.
  • Tracking and Performance Cookies: These cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these cookies may directly or indirectly identify you as an individual visitor.

For more information about the cookies we use and your choices regarding cookies, please visit our Cookie Policy.

How we Collect Your Personal Data

The Company collects most of your personal data directly from you, in person, by telephone, email, and via our Website. We may also collect information directly from a third party, from cookies on our Website, or via our IT systems.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Website, including to monitor the usage of our Website.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services you have purchased or of any other contract with us through the Website.
  • To contact you: To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide you with news, special offers and general information about other goods, Websites and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage your requests: To attend and manage your requests to us.
  • To provide customer support.
  • To detect, prevent, and address technical issues.
  • To gather analysis or valuable information so that we can improve our services.

 

Our Reasons

This data is collected for our legitimate business interests or those of our service providers as outlined below.

  • To allow the performance of services we provide and/or contracts we may have with you.
  • To make sure we can keep in touch with you to provide these services.
  • To allow us to be efficient so that we can deliver the best service and product possible.
  • To prevent and detect criminal and/or fraudulent activity that would be damaging to you and us.
  • To promote our business to new and existing customers.

 

Promotional Communications

We may use your Personal Data to connect you with newsletters, marketing or promotional materials and other information that may be of interest to you. We have a legitimate interest in using your data for promotional purposes (see “Our Reasons” above). You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

 

We (and our service providers) may share your personal information in the following situations:

  • With Website Providers: We may share your personal information with Website Providers to monitor and analyze the use of our Website. (See Analytics below).
  • Service Providers: We may share your personal information with Service Providers to help us deliver our services to you.
  • For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.
  • With affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates may include any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • With business partners: We may share your information with our business partners to offer you certain products, Websites or promotions.
  • With third party vendors: We may share your information with to provide behavioral remarketing or advertising services.
  • With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a third-party social media website, your contacts on the third-party social media website may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile.

 

Retention of Your Personal Data

The Company will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), provide services to you, perform contracts with you, resolve disputes, and enforce our legal agreements and policies.

Transfer of Your Personal Data

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.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Personal Information We Sell or Disclose for Business Purposes

In the past 12 months we have not sold your personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with you or your household to one or more third parties.

In the past 12 months we have disclosed to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with you or your household:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies, Tracking Data, and Usage Data
  • Internet or other electronic network activity information

DISCLOSURE OF YOUR PERSONAL DATA

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. If required by applicable law, we will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other Legal Requirements

The Company may disclose your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Website
  • Protect the personal safety of users of the Website or the public
  • Protect against legal liability

Security of Your Personal Data

The security of your Personal 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.

Detailed Information on the Processing of Your Personal Data

We may employ third-party companies and individuals to facilitate and enhance our Website experience (“Service Providers” or “Website Providers”). These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Website Providers to monitor and analyze the use of our Website.

Google Analytics

Google Analytics is a web analytics website offered by Google that tracks and reports (non-personally identifiable) website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google Websites. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

 

You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

 

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

 

Social Media, Widgets and Open Forums

Our Website may allow you to engage with social media services, such as Facebook, Twitter, Instagram, LinkedIn, and YouTube (“Social Networks”), and widgets such as the “Share this” button, or interactive mini-programs that run on our Website or which link from Social Networks to our Website (“Social Functions”). These Social Functions may access, collect and integrate with your Social Network accounts and information. For example, these Social Functions may collect your IP address, identify which page you are visiting on our Website, or set a cookie. If you choose to use these Social Functions, you may be sharing certain Social Network profile elements with us. This sharing is subject to each Social Network’s own privacy policy and terms of use. We do not control those Social Networks or your profiles on those services. We do not modify your privacy settings on those services or establish rules about how your personal information on those services will be used.  Social Functions are either hosted by a third party or hosted directly on our Website. Your interactions with them are governed by the privacy policy of the company providing them. Please refer to the privacy settings in your Social Network account to manage the data that is shared with us through your account.

 

Further, information you include and transmit online in a publicly accessible blog, chat room or Social Network, or that you share in an open forum such as an in-person panel or survey, may be viewed and used by others without any restrictions. As noted above, we do not control such uses of your personal information.  By using such services, you assume the risk and acknowledge that the personal information provided by you may be viewed and used by us and/or third parties for any number of purposes, and that the usage restrictions set forth in this Privacy Policy do not apply to such services.

GDPR PRIVACY

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

  • Consent: You have given your consent for processing Personal Data for one or more specific purposes.
  • Performance of a contract: The Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
  • Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which the Company is subject.
  • Vital interests: Processing Personal Data is necessary in order to protect your vital interests or of another natural person.
  • Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company.
  • Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by the Company.

Your Data Protection Rights under the GDPR

If you located in the European Union (“EU”), you may have certain data protection rights.

In certain circumstances, you have the following data protection rights with respect to the data we process about you:

  • Request access to your Personal Data. The right to access, update or delete the information we have on you. Please contact us to assist you.
  • Request correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate information we hold about you corrected.
  • Object to processing of your Personal Data. You have the right to object to our processing of your Personal Data including when we are processing your Personal Data for direct marketing purposes.
  • Request erasure of your Personal Data. In certain circumstances, you have the right to ask us to delete or remove Personal Data.
  • Request the transfer of your Personal Data. We will provide to you, or to a third-party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw your consent. You have the right to withdraw our consent at any time when Company relied on your consent to process your personal information.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (“EEA”), please contact your local Data Protection Authority in the EEA.

CCPA PRIVACY

Your Rights under the CCPA

If you are a resident of California, you may have certain data protection rights.

In certain circumstances, you have the following data protection rights with respect to the data we process about you:

  • The right to notice. You must be properly notified which categories of Personal Data are being collected and the purposes for which the Personal Data is being used.
  • The right to access / the right to request. The CCPA permits you to request and obtain from the Company information regarding the disclosure of your Personal Data that has been collected in the past 12 months by the Company or its subsidiaries to a third-party for the third party’s direct marketing purposes.
  • The right to say no to the sale of Personal Data. You also have the right to ask the Company not to sell your Personal Data to third parties. We do not sell your Personal Data.
  • The right to know about your Personal Data. You have the right to request and obtain from the Company information regarding the disclosure of the following:
  • The categories of Personal Data collected
  • The sources from which the Personal Data was collected
  • The business or commercial purpose for collecting or selling the Personal Data
  • Categories of third parties with whom we share Personal Data
  • The specific pieces of Personal Data we collected about you
  • The right to delete Personal Data. You also have the right to request the deletion of Your Personal Data that have been collected in the past 12 months.
  • The right not to be discriminated against. You have the right not to be discriminated against for exercising any of your Consumer’s rights, including by:
  • Denying goods or Websites to you
  • Charging different prices or rates for goods or Websites, including the use of discounts or other benefits or imposing penalties
  • Providing a different level or quality of goods or Websites to you
  • Suggesting that you will receive a different price or rate for goods or Websites or a different level or quality of goods or Websites

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can email or call us using the information below.

The Company will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

Do Not Sell My Personal Information

We do not sell your personal information. If you wish to contact us regarding your personal information you may do so by following the instructions below.

“Do Not Track” Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Website does not respond to Do Not Track (“DNT”) signals.

However, some third party websites do keep track of your browsing activities. Do Not Track is a preference you can set in your web browser to inform websites you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children’s Privacy

Our Website is intended for use only by individuals who are at least 16 years of age, or the age or majority in their applicable jurisdiction. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we will take steps to remove that information from our servers.

Links to Other Websites

Our Website may contain links to contain links to third-party sites, content and resources that are not affiliated with the Website or Company. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or Websites.

CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Website, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

CONTACT US

If you have any questions about this Privacy Policy, you can contact us:

  • By email: dataprivacy@pinckneyhugo.com
  • By phone number: 866-924-0296

 

 

DEFINITIONS

For the purposes of this Privacy Policy:

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
    • For the purpose of the GDPR, Service Providers are considered Data Processors.

 

  • Personal Data is any information that relates to an identified or identifiable individual.
    • For the purposes for GDPR, Personal Data means any information relating to you such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.
    • For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with you.
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data. For the purposes of this Privacy Policy, we are the Data Controller of your Personal Data gathered on our Website.

 

  • Do Not Track (DNT) is a concept that has been promoted by US regulatory authorities, in particular the U.S. Federal Trade Commission (FTC), for the Internet industry to develop and implement a mechanism for allowing internet users to control the tracking of their online activities across websites.

 

  • Business, for the purpose of the CCPA (California Consumer Privacy Act), refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.

 

  • Consumer, for the purpose of the CCPA (California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.

 

  • Sale, for the purpose of the CCPA (California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s Personal information to another business or a third party for monetary or other valuable consideration.