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PRIVACY POLICY

Updated: September 1, 2023

This Privacy Policy explains how information about you is collected, used and disclosed by Penthera Partners, Inc. (“Penthera”, “we,” “us,” and “our”) as the operator of the website www.penthera.com and any other websites owned and operated by Penthera (collectively, the “Sites”). This Privacy Policy also describes the choices available to you regarding our use of your personal information and how you can access and update this information. This Privacy Policy applies to our Sites throughout the world. Any additional privacy terms that relate to specific Penthera products or services should be read in conjunction with this Policy.

Please read this Privacy Policy and feel free to contact us if you have any questions at info@penthera.com. By accessing, visiting, and using the Sites, you expressly agree to our collection, storage, use and disclosure of your information as described in this Privacy Policy. You must not provide us with your personal information or interact with the Sites if you do not agree with the practices described in this Privacy Policy.   

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in the event of material change, we will provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Sites or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy. Your use of the Sites following our posting of any changes will constitute your acceptance of such changes. Should you not wish to be bound by the modified Privacy Policy, do not use the Sites.

 

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information that you voluntarily submit to us.  You may provide some of the following types of personal information when you fill out a form, download a white paper, apply for a job, request customer support, or otherwise communicate with us: your name, email address, postal address, phone number, your company name, business type and title, and other contact information. When we conduct or sponsor market research activities — such as surveys and product testing — we may collect the information you provide, such as your name, email address, and certain demographic data, such as your age, gender, race, and ethnicity.  You may choose not to provide any personal information; however, certain actions and information may be limited to those who elect to provide certain information. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. Please make sure you have permission before you provide this information to us.

 

Information We Collect Automatically 

 

When you access or use our Sites, we automatically collect information about you using device-based tracking technologies, such as cookies, pixels, tags, beacons, scripts, and similar technologies. For more information about tracking technologies, please see “Cookies and Other Tracking Technologies“ below. The types of information we may collect automatically include device identifiers such as IP address (including approximate location information), cookie ID, and other unique identifiers, such as the type of browser you use, your Internet Service Provider, access times and length, pages viewed, your IP address, and the page you visited before navigating to our Sites. For more information about cookies, and how to disable them, please see “Your Choices, Rights and Controls” below.

Information from Third Parties 

  • Services Provided by Others. We may allow business partners to provide services on our behalf, such as analytics. The information our business partners provide to us varies depending on the nature of their services and may include IP addresses, device IDs or other unique identifiers, information about your interests, demographic data, and your online activity.  

  • Social Media. If you connect with us through a social media platform or navigate to a social media platform from one of our Sites, the social media platform will collect your information separately from us. The Sites may offer social sharing features and other integrated tools (such as the option to post on LinkedIn), which let you share actions you take on our Sites with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. We may also collect information you have publicly posted using your social media accounts. You should review the social media platforms’ privacy policies to understand how they are using your information and your rights in relation to such information.

  • Third Party Sites. The Sites may contain links to other websites or may make third-party applications available to our users. Please be aware that we are not responsible for the privacy practices or the content of such other websites or applications. We encourage our users to read the privacy statements of each website they visit or application they use. This Privacy Policy applies solely to information collected by us related to the Sites and does not apply to these third-party websites or applications. The ability to access information of third parties from Penthera, or links to other websites or locations, is for your convenience and does not signify our endorsement of such third parties, their products, their services, other websites, locations or their content.


USE OF INFORMATION

We may use information about you for various purposes, including to:

 

  • Provide, maintain and improve our Sites;

  • Detect, investigate and prevent illegal activities and protect the rights and property of Penthera and others;

  • Consummate a business merger, sale, acquisition or transition where some or all of our assets (including your personal information) are sold or transferred; 

  • Carry out any other purpose for which the information was collected;

  • Respond to your comments, questions and requests, and provide customer service;

  • Communicate with you about products, services, offers and promotions offered by Penthera and others, and provide news and information we think will be of interest to you; and

  • Monitor and analyze trends, usage and activities in connection with our Sites.

​SHARING OF INFORMATION

 

​We do not sell or otherwise provide personal information to other companies for the marketing of their own products or services.  We may share information about you as follows or as otherwise described in this Privacy Policy:

  • With vendors, consultants and other service providers who need access to such information to carry out work on our behalf; 

  • For compliance purposes, such as security and legal support;

  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;

  • If we believe your actions are inconsistent with our policies, or to protect the rights, property and safety of Penthera or others;

  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;

  • Between and among Penthera and its current and future parents, affiliates, subsidiaries and other companies under common control and ownership; and

  • With your consent or at your direction.

YOUR CHOICES, RIGHTS AND CONTROLS

Many countries, states and localities have adopted or are in the process of adopting privacy laws, some of which may apply to you.  It is not practicable to recite all the applicable laws in this Policy and we encourage you to become familiar with the privacy laws applicable to you.  Depending on where you live, you may have certain rights, including those set forth below, with respect to your information. 

Rights that may be available to you

  • Access. To confirm whether we are processing your personal information and to access your personal information.

  • Opt-out. To opt out of the processing of your personal information for purposes of targeted advertising, certain profiling or the sale or sharing (for cross-context behavioral advertising purposes) of your personal information.  Please note that Penthera does not engage in any such processing.

  • Deletion. To request that we delete personal information collected about you.

  • Correction. To request correction of your inaccurate personal information.

  • Appeal. To appeal our actions related to any of your rights, if you have any unresolved privacy concerns that we have not addressed satisfactorily after contacting us.

 

To exercise any of these rights or choices, please contact us at info@penthera.com. We will take reasonable steps to verify your identity, including authenticating you through the email address.

We will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations.  Your rights and our responses will vary based on your state or country of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled. If you have any unresolved concerns, you may have the right to complain to your data protection authority. We will not discriminate against you based on your exercise of any of the rights described above.

Automated Decision Making

We may use algorithms that automatically select content or advertising that may be of interest to you and that may create a “profile” about your interests. We do not use these algorithms to make decisions that may have a legal or similarly significant effect on you.

Sensitive Personal Information

We do not collect or process sensitive personal information.

 

Deidentified Information

 

To the extent we irreversibly anonymize personal information, we will maintain and use such information in anonymized form and will not attempt to re-identify such information unless permitted by applicable law.

 

Opt-out of Marketing Messages 

To stop receiving our promotional messages, follow the unsubscribe instructions in any marketing message you get from us or contact us at info@penthera.com.

 

INTERNATIONAL TRANSFERS

 

Penthera is a global company that may transfer your personal information to a country (including the United States) that does not provide the same level of protection for your personal information. Penthera may transfer your personal information to carefully selected service providers, business partners, and other third parties for the purposes described in this policy.  Whenever we transfer your personal information, we look at the risks to your information and rely on safeguards like standard contractual clauses, where applicable, to ensure your rights are protected. If we share personal information with a third party, we will require them to protect your personal information appropriately.

NO COLLECTION OF INFORMATION FROM OR ABOUT CHILDREN

Penthera does not knowingly collect or solicit personal information from or about anyone under the age of 13. If you are under 13, you are prohibited from registering or sending any information about yourself to us, including your name, address, telephone number, or email address. No one under age 13 may provide any personal information to Penthera. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at: info@penthera.com.

RETENTION 

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in this privacy policy, or any other notice provided at the time of collection unless a longer retention period is required or permitted by applicable law, taking into account applicable statutes of limitation and our records retention requirements and policies.​

COOKIES AND OTHER TRACKING TECHNOLOGIES

We may automatically receive certain information about you and your device using browser- or device-based tracking technologies described below. These technologies allow us to ensure our services are functioning correctly and improve our services. You can manage how these tracking technologies are used by adjusting your device or browser settings and, in some countries, by selecting your preferences in a consent management solution. In some cases, you can opt out of tracking by our analytics providers by visiting their opt-out pages directly.

Tracking Technologies and Purposes

  • Cookies: Cookies are small data files stored on your browser or device. They may be served by the entity that operates the website you are visiting (“first-party cookies”) or by other companies (“third-party cookies”).

  • Pixels: Pixels are small images on a web page or in an email. Pixels collect information about your browser or device and can set cookies on your browser.

  • Local Storage: Local storage allows data about your browser or device to be stored locally on your browser or device and includes HTML5 local storage and browser cache.

  • SDKs: SDKs (also known as “software development kits”) are blocks of code, typically provided by our partners, that may be installed in our applications. SDKs may help us understand how you interact with our applications and may collect information about the device and network you use to access our Sites.                    

Managing Cookies and other Tracking Technologies

Although most browsers and devices accept cookies by default, their settings usually allow you to clear and decline cookies. Web browsers often store your preferences in a cookie. Blocking cookies may prevent the services from operating as expected and may also prevent storing your preferences and choices.  Below are links to the cookie opt-out pages of common web browsers. If your web browser is not listed here, you should review your web browser terms to learn more about your cookie choices.

To opt out of certain tracking by our analytics providers, you may visit the links below:

 

SECURITY

 

Penthera takes reasonable measures to protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction; however, we cannot guarantee that our security measures will prevent third parties from intercepting information. You acknowledge that you do not assume or expect that any content or communication that you transmit to us, or we transmit to you (such as personally identifiable or other data, questions or answers, comments, or suggestions) is confidential. Penthera shall not be liable or responsible if any information about you is intercepted and used by an unintended recipient or otherwise disclosed in a manner you did not intend.

 

CONTACT US

If you have any questions about this Privacy Policy, our Sites, or your dealings with our Sites, you can contact us at info@penthera.com.

Penthera Partners, Inc.

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