LAST UPDATE: April 17, 2019
This Policy describes the types of personal information we collect through the Site and how that personal information may be used and/or with whom it may be shared. This Policy also describes how you can reach us to update your personal information, access and control the use of the personal information, or get answers to questions you may have about our privacy practices at this Site. Please read this Policy carefully, because by accessing and using this Site you are acknowledging that you understand and agree to the terms of this Policy.
Consent to Data Collection and Processing
You hereby agree with and consent to the collection and processing of your personal information as described in this Policy.
Consent to International Data Transfers
Your personal information may be collected, processed and stored by Pineapple or its services providers in the United States and other countries where our servers reside. Please be aware that the privacy protections and legal requirements, including the rights of authorities to access your personal information, in some of these countries may not be equivalent to those in your country. You hereby agree with and consent to the transfer of your personal data to the United States and other countries where Pineapple operates.
Withdrawal of Consent
You have the right, at any time, to withdraw your consent to Pineapple’s collection and processing of your information, or to the transfer of your personal data to the United States and other countries where Pineapple operates. You may withdraw your consent by emailing Pineapple at email@example.com.
2. COLLECTION AND USE OF PERSONAL INFORMATION
As you interact with Pineapple, there may be opportunities for you to provide us with your information. Additionally, we may collect certain information about you or your Pineapple services as further described below.
You may provide us with information about you through a number of sources including, without limitation, sales records relating to Pineapple services.
The information Pineapple collects about you and your Pineapple services may be used:
· To provide services and maintain customer relationships
· To improve the quality, safety, and security of our services
· To administer your account(s) and process your payments for services
· To operate our websites and applications, including online registration processes
· To autofill data fields on our websites to improve your online experience
· To develop new services
· To provide support for our services
· To provide information and service updates
· To evaluate Pineapple service performance
· For research, evaluation of use, and troubleshooting purposes
· To verify eligibility for Pineapple service purchases
· For marketing and analytics purposes
· To customize and improve communications
· To comply with legal, regulator, or contractual requirements
Communications with you in connection with these uses may be via mail, telephone, e-mail, text message, social medial, or other electronic messages, or via our websites and applications.
Personal Information You Provide
The privacy and security of the personal information that Pineapple collects from you is a priority for Pineapple. When you visit this Site you may be asked or choose to provide personal information that could reasonably be used to contact you or to identify you personally including, but not limited to: your name, address, telephone number, birth date, and email address.
You may choose to receive certain communications from Pineapple via your email address upon interaction with the Site. From time to time Pineapple may include surveys, information requests, or other features on the Site which ask you to provide personal information such as your name, telephone number, email address or mailing address. Any information you may provide will be used by Pineapple to allow you to participate in the particular feature being offered. Pineapple may also retain any information you provide in order to send you information about Pineapple’s services that may be of interest to you. Pineapple will provide you with the opportunity to opt-out of receiving such communications. We may use one or more service providers to administer these messages, but we do not share your email address with spammers or any other third parties without your permission.
You will be informed what personal information is required and what information is optional when asked to submit personal information to us. By submitting personal information to Pineapple at this Site, you hereby consent to Pineapple’s collection, use and disclosure of such personal information.
We may combine the personal information you submit directly through this Site with other personal information we have collected from you, whether on- or offline. We may also combine it with information we receive about you from other sources, such as other companies, publicly available information sources (including information from your publicly available social media profiles), and other third parties.
Passive Information Collection and Use
As you navigate around this Site, certain information can be passively collected (that is, gathered without you actively providing the information), using various technologies. We passively collect and use information in a variety of ways, including:
· Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system version, and Internet browser type and version. We may collect similar information, such as your device type and identifier, if you access this Site through a mobile Device.
· You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) to disable existing cookies; or (iii) to set your browser to automatically reject any cookies. If you set your browser to reject cookies, part of the Site may not work for you.
· Pixel tags, web beacons, clear GIFs, or other similar technologies: These may be used in connection with some Site pages to, among other things, track the actions of Site users and compile statistics about Site usage and response rates.
· IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits this Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many web sites. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering this Site.
· Device Information: We may collect information about your Device, such as a unique device identifier.
· Do Not Track Requests: Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively management the settings on your browser or Device to delete and disable cookies and other tracking/recording tools. Please note, depending on your type of Device or browser, it may not be possible to delete or disable all tracking mechanisms on your Device.
We may permit third-party advertising partners to use the foregoing tracking technologies to collect information about your browsing activities over time and across different websites when you use the Site. For example, we may use advertising services providing by third-party ad partners, such as Google, to market our service to you on other websites and online services. Through a process called “retargeting,” each service places a cookie on your browser when you visit the Site so that they can identify you and serve you ads on other sites around the web based on your browsing activity. To avoid use of this information for advertising by these third-party ad partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you could select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party ad partners honor the Do Not Track browser signal.
Integrated Accounts and Social Media Information
We may implement applications or "widgets" from third party providers (e.g., Facebook, Twitter, Instagram, LinkedIn, etc.) that allow interaction, integration or content sharing with third party services. These widgets or applications may be visible on a page you visit on our Site or may require log-in through the third party provider’s service. The third party providing the widget or integration may offer controls for you to manage your interactions. Any interaction with a third party widget or application typically allows the third party to collect some information about you (whether through cookies, registration information or otherwise). These third parties may even track you when you do not interact with the widget. If you have engaged any of these third party service providers, their respective privacy policies will govern their tracking and collection of information. You should review these third party policies to understand these practices.
How We Use and Disclose Information
We use and disclose personal information you provide to us as described to you at the point of collection, such as when you (1) register for a user account, (2) submit your name and e-mail address to receive service updates and marketing information, and (3) send e-mail messages or feedback, or transmit other information by e-mail. When you elect to engage in such activities, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), e-mail address, mobile telephone numbers, and payment information.
We also use and transfer personal information from or about you:
· to respond to your inquiries and fulfill your requests, such as to send you documents you request or e-mail;
· to send you important information regarding our relationship with you or regarding this Site, changes to our terms, conditions, and policies and/or other administrative information; and
· for our business purposes, such as marketing new services, data analysis, audits, developing new services or services, enhancing our Site, improving our services, identifying Site usage trends, and determining the effectiveness of our Site.
· to our third party service providers who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, credit card processing, IT services, e-mail services, marketing services, auditing services, and other services, in order to enable them to provide services;
· to verify your information, approve your registration as a user of the Site, authenticate payments and process orders, Pineapple may disclose certain financial and other information you provide to Pineapple to third parties offering services for sale on the Site, as well as to third parties that provide credit reporting, payment or order fulfillment services;
· to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); and
· when we otherwise have your consent.
In addition, we use and disclose personal information collected through this Site as we believe to be necessary or appropriate: (a) as permitted by applicable law, including laws outside your country of residence; (b) to comply with any legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to protect our operations or those of any of our affiliates; (e) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (f) to allow us to pursue available remedies or limit the damages that we may sustain. We may also use and disclose personal information collected through this Site in other ways, with your prior consent.
We also use and disclose information we collect passively as described above, under "Passive Information Collection and Use," and for any other purpose, except where we are required to do otherwise under applicable law (for example, if we are required to treat such information as personal information). In addition, we may use and disclose information that is not in personally identifiable form (such as anonymized, masked or de-identified information) for any purpose. If we combine information that is not in personally identifiable form with information that is (such as combining your name with your geographical location), we will treat the combined information as personal information as long as it is combined.
Use of Information for Marketing Purposes
Pineapple and our affiliates may send you regular promotional communications about our services, services, events and promotions. Such promotional materials may use the “Pineapple” brand and may be sent to you via different channels, such as: email, phone, SMS text messages, postal mailings, and third party social networks.
In order to provide you with the best personalized experience, sometimes these communications may be tailored to your preferences (for example, as you indicate these to us, as we may have inferred from your Site visits, or based on the links you click in our emails). When required by applicable law, we will obtain your consent before starting these activities. In addition, you may withdraw your consent (opt-out) at any time.
In particular, you can opt-out from receiving marketing-related emails by following the unsubscribe instructions provided in each email. If you can sign-in to your Pineapple account, you may be able to change your communication preferences under the relevant section of the Site. You can also contact us using the contact details provided below to opt-out from receiving marketing-related communications.
Please note that even if you opt-out from receiving marketing communications, you might still receive administrative communications from us, such as technical updates of our services, order confirmations, notifications about your account activities, and other important notices.
3. GENERAL PRINCIPLES FOR THE PROCESSING OF PERSONAL INFORMATION
Personal information will be collected, stored, processed and transmitted in accordance with Pineapple’s established policies and applicable federal, state, local and foreign laws, rules and regulations.
The principles of Pineapple with respect to the processing of personal information are as follows: (1) personal information will be processed fairly and lawfully, (2) personal information will be collected for specified, explicit, and legitimate purposes and not further processed for incompatible purposes, (3) personal information collected by Pineapple will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are collected and processed, (4) personal information collected by Pineapple will be accurate and, where necessary, kept up to date to the best of our ability, (5) personal information collected by Pineapple will be retained as identifiable data for no longer than necessary to serve the purposes for which the personal information was collected, and (6) personal data will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
If Pineapple engages in the processing of personal information for purposes other than those specified in this Policy, Pineapple will provide notice of these changes, the purposes for which the personal information will be used, and the recipients of personal information.
4. THIRD PARTY SITES AND SERVICES
This Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any site or web property (including, without limitation, any application) that is available through this Site or to which this Site contains a link. The availability of, or inclusion of a link to, any such site or property on this Site does not imply endorsement of it by us or by our affiliates.
Third parties may offer services on the Sites and collect information about you by requesting certain information necessary to provide a particular service or service. Pineapple may also obtain certain information about its users from third party customer research groups (e.g., demographic information) which Pineapple uses to learn more about its customers. Pineapple does not control the policies and practices of third parties in relation to the use and disclosure of any information about users collected by third parties on the Site or in market research programs conducted by such third parties and any use or disclosure of such information by third parties is not governed by this Policy.
5. CHOICES AND ACCESS
We give you choices regarding our use and disclosure of your personal information. Pineapple provides you with the opportunity to receive information by email, regular mail or telephone calls from Pineapple, or third parties which may be of interest to you, including information relating to new services offered on the Site by Pineapple, or other third parties. If you do not want to receive any information by email, regular mail or telephone calls, you may opt-out of further communications provided by Pineapple at any time by: (i) sending Pineapple an email at firstname.lastname@example.org; or (ii) writing to Pineapple at 11 Stanwix Street, Suite 1202, Pittsburgh, PA 15222. Please note that Pineapple can only comply with requests relating to email, regular mail or telephone communications provided by Pineapple. If you no longer wish to receive further information by email, regular mail or telephone from any third party, you will need to contact such third party directly to opt-out of further communications being provided to you. We will seek to comply with your request(s) as soon as reasonably practicable.
If applicable, and you would like to review, correct, update, or delete the personal information that you have provided via this Site, please contact us. We will try to comply with your request as soon as reasonably practicable.
It is your responsibility to provide Pineapple with accurate personal information. Except as otherwise set forth in this Pineapple, Pineapple shall only use personal information in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. To the extent necessary for these purposes, Pineapple shall take reasonable steps to ensure that personal information is accurate, complete, current and relevant to its intended use.
7. YOUR RIGHTS OVER YOUR INFORMATION
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. You can also ask for it to be erased and you can ask for us to give you a copy of the information. You can also ask us to stop using your information and limit how we use your information.
Your California Privacy Rights
Under California’s “Shine the Light Law”, California residents who provide personal information in obtaining services or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.
To obtain this information on behalf of Pineapple, please send an email message to email@example.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in the response. Please be aware that not all information is covered by the “Shine the Light “ requirements and only information on covered sharing will be included in our response. For an explanation of our privacy practices, please review our Privacy Statement by clicking the “Privacy Statement” link on our home page.
8. RETENTION PERIOD
We retain your personal information for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or allowed by law or to otherwise fulfill a legal obligation.
Pineapple has implemented security measures designed to protect personal information provided by you against unauthorized access and use. Pineapple also uses commercially reasonable efforts to establish secure connections with your web browser for any transactions conducted online using a credit card or other financial information you may provide to Pineapple. Please be aware, however, that no data transmission over the Internet is 100% secure and any information disclosed online can potentially be collected and used by parties other than the intended recipient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us in accordance with the CONTACTING US section below.
10. USE OF SITE BY MINORS
We do not intentionally collect information from individuals under the age of 13. The Site is not directed to individuals under the age of 13 and we request that these individuals not provide personal information through this Site.
11. COMPLIANCE WITH LOCAL LAWS
We may change this Policy. Please review the LAST UPDATE legend at the top of this page to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on this Site. Your use of this Site following these changes means that you accept the revised Policy.
Pineapple will use a self-assessment approach to verify compliance with this Policy and periodically verify that the Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented and accessible.
If you believe that your personal information has been processed or disclosed in violation of this Policy, Pineapple encourages you to raise any concerns using the contact information provided in this Policy. Pineapple will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.
14. YOUR RIGHT TO COMPLAIN
If you have a complaint as to our use of your information, you may file a complaint with us, the GDPR supervisory authority (for residents of the European Union, European Economic Area, or Switzerland), any other governmental agency, and/or a judicial body.
A complaint may be submitted directly to Pineapple:
· For residents of the European Union, European Economic Area, or Switzerland, in writing by filling out the Complaint Form;
· In writing by sending an email to Pineapple firstname.lastname@example.org;
· In writing by sending a letter to Pineapple at 11 Stanwix Street, Suite 1202, Pittsburgh, PA 15222, Attn: Legal Department; or
· Orally by directly contacting Pineapple (412) 235-7235;
15. CONTACTING US
If you have any questions about this Policy, please contact Pineapple’s Data Protection Officer or Pineapple directly.
The current Pineapple DPO is:
· Name: Brian Gross
Address: 11 Stanwix
Street, Suite 1202
Pittsburgh, PA 15222
· Telephone: 412-430-4175
· Email: email@example.com
· Our contact information is as follows:
Pineapple Payments Opco, LLC
11 Stanwix Street, Suite 1202
Pittsburgh, PA 15222
Attention: Legal Department
412-235-7235 (Monday to Friday, 8am – 5pm CST)
Reporting a complaint to Pineapple Data Protection Officer (DPO)
All individuals whose personal data has been collected or processed by Pineapple are encouraged to inform Pineapple DPO of material privacy issues that can be perceived as violations of their rights.
The DPO may also be able to provide advice or guidance that may be helpful in responding to the complaint
The purpose of this Complaint Form is to assist the DPO in identifying any infringement on the data subject’s rights.
Any complaint can be reported as follows:
· By email
· By phone
· By mail
o Pineapple Payments Opco, LLC
o 11 Stanwix Street, Suite 1202
o Pittsburgh, PA 15222
1. Your Identity
· First and Last Name
· Preferred contact address
· Email Address
· Other relevant identification you wish to provide
2. Your Complaint
· Object of your complaint.
· Please identify as much information as possible.
· Identify any specific individuals or operational groups.
Please submit this form through email to: firstname.lastname@example.org
or by mail to: Pineapple Payments Opco, LLC, 11 Stanwix Street, Suite 1202, Pittsburgh, PA 15222