PRIVACY POLICY

Your privacy is important to us. People Pattern Company (“People Pattern, “We”, “Our”, “Us”), is an online audience creating company, and we are sensitive to concerns about our use of personal information. We also believe in, and support, harnessing the power of technology and the Internet to aid communications, relationships, and discourse.

By using People Pattern Service (the “Service”) and People Pattern Website (the “Site”) linking to this privacy policy (the “Privacy Policy”) as portrayed on the Terms of Service and end user license agreement, you are agreeing to comply with, and be bound by, the following Privacy Policy, and other supplemental terms and conditions or documents that may be published from time to time. Please review the Privacy Policy carefully.

WEBSITE PRIVACY POLICY

When you visit our Site, submit any information to us or click a weblink in an email you have received from us, we may use cookies to gather information about your interaction with our site and our other digital marketing materials. We may use the information you provide us to improve our products and services and your website experience.

PROCESSING OF PERSONAL DATA

Our company will process your personal data during its activities. This policy sets out the rules that we will follow when processing your personal information to preserve the right to protect your personal data, your privacy, and to ensure that your personal data is not misused. We will follow this policy for the entire period during which we process any of your personal information.

This policy sets out the procedures and principles on the basis of which we will process and handle your personal data. If anything is unclear or you would like to ask anything about your personal data, please use the contact information provided in this policy.

TYPES OF PERSONAL DATA OUR SERVICE PROCESSES

When you are using The Service, we may automatically collect certain information from your device. Service may collect, and why we collect it, follows: (a) your username, email address and contact preferences. This lets us create your account, provide you with convenient and personalized access to your account and deliver and support the Service. This information also helps us communicate with you and respond to your requests for assistance (including providing account verification support if you’re having difficulty accessing your account). In addition, we may use your Personal Information to send you direct marketing emails and special offers. (b) Your payment information required to complete a commercial transaction on the Site. We use this information to enable and fulfill your transaction. (c) Any User Content you add to your account. (d) We don’t use this information for any purpose other than to provide the Services. (e) The Service also collects and receives information from your computer or mobile device, including the activities you perform within your account, the type of hardware and software you are using (for example, your operating system, word processing or other productivity software and browser type) and information obtained from cookies. When you access the Service, that application will request access to certain information on your computing device. (f) In addition, we automatically gather non-personally identifiable information that indicates your association with one of our business partners or certain promotions. We use this information to determine the amount of revenue share payments to make to partners with whom we might have such arrangements and to provide anonymized aggregate reports. (g) If you choose to use PayPal® to finalize and pay for your order, you will provide your credit card number, directly to PayPal®. The privacy policy of PayPal® will apply to the information you provide on the PayPal® website.

HOW WE USE PERSONAL DATA

Any information that you submit to us remains your property. However, we may use it for the purposes described herein.

(I) Service. We reserve the right to use the information we collect, in order to administer, operate, and continuously improve the Service. We may also use the information to monitor and analyze trends, usage and activities in connection with the Service. Provided, however, that no Personal Information shall be disclosed to third parties within the scope of this clause, other than People Pattern has trusted affiliates which are responsible for supporting or enhancing the Services, and for such purposes only.

(II) Advertisements. We reserve the right to use information we collect to create, market and distribute anonymized audience segments to third parties. We or our trusted affiliates may customize personalized content and advertisements and connect certain demographic or other data about you (received from third parties) to data we have collected from you, such as your mobile device identifier or IP address.

(III) Aggregate Information. We compile aggregated information about our users to better optimize our Service, preferences, and to assist in our marketing efforts. We may also share aggregated data about our user base including the number of users that we have, certain trends, statistical data, etc., without disclosing any information.

(IV) Legal Disclaimer. Notwithstanding anything to the contrary, we reserve the right to share any information (a) as required by law and/or to comply with a judicial proceeding, court order or legal process served on Site; (b) when we believe that disclosure is necessary to protect our rights; (c) if we believe that you are in violation of the Terms of Service of this Privacy Policy or any other of our operating rules, code of conduct, policies and other supplemental terms and conditions or documents that may be made available by us from time to time.

HOW WE PROCESS YOUR PERSONAL DATA

Below are our guidelines on how we process personal data at each stage from collection to final erasure. In order to ensure that the guidelines are met in our daily work, we have procedures that take into account and cover all the steps in the processing of personal data listed below. In addition, where applicable, we include procedures for the processing of personal data in the terms of reference we have with the respective customer.

COLLECT AND RECORD

We will only collect personal data that we are legally obliged to process based on our business or that can be considered essential to fulfill our existing obligations to our customers and employees as our business stands today. We will not collect personal data for the purpose of using it in the future for any purpose other than that for which it is intended today.

The only exceptions to the above are personal data that is used for marketing and sales purposes to persons in their capacity as directors of companies within our target group and personal data that is provided to us in connection with the recruitment of staff.

We will never collect personal data for the purpose of directly or indirectly selling them.

Based on the above points, we believe that we do not need consent in any case to collect the personal data we process, and therefore we should never ask for consent.

The collection of personal data shall be carried out in such a way that the personal data shall be transferred to the systems or storage location where they are to be used as soon as possible after we receive them. This is to ensure the secure storage of personal data. This means that personal data should never remain in emails, web forms, physical paper or similar documents unless these documents can be considered as part of the long-term storage of personal data and the protection of personal data is therefore adequate.

STRUCTURE, ORGANISE, PROCESS AND USE

We only use personal data for its primary purpose, i.e. in accordance with the purposes and reasons for which it was originally collected or transferred to us. These purposes are set out in contracts or other types of agreements with our customers and employees or in routine documents that govern the use of specific personal data in detail.

Where we structure or process personal data, this is never done for a purpose or in a way that alters the original purpose of use or allows the personal data to be analysed in a way that is incompatible with that purpose.

STORE AND PROTECT

We only store personal data where we can ensure that it is adequately protected. This means the following:

Digital storage on your own server is protected by firewalls from leading manufacturers. Only authorised personnel have access to the server room.

Digital storage in the cloud takes place only in CRM systems (and similar) with large established providers that guarantee at least the security justified by the nature of the personal data and the contractual obligations we have in relation to our customers.

Antivirus software is installed on all servers and clients. Antivirus definitions are automatically updated daily.

Access to data (both from our own server and from the systems in the cloud) is controlled by permissions based on the principle that no employee should have access to data that is not required for us to fulfil our obligations to customers and authorities. All employees have their own login with passwords created and changed in accordance with high security recommendations.

DISTRIBUTE AND TRANSFER

We never disclose or transfer personal data to third parties, except for what we are required by law to report to authorities.

We interpret the framework to mean that we can still distribute personal data to the data subject or to the controller via email. However, to ensure a high level of privacy protection when distributing personal data, the following applies:

We never distribute so-called sensitive personal data via regular unencrypted emails, but use higher security distribution methods.

We avoid emailing personal data together with other data in order to make it easier for the recipient to delete the email once the personal data is stored in accordance with the recipient's guidelines.

DELETE

We must always delete personal data when it is no longer needed for the purposes for which it was collected and used. In many cases, however, we rely on the systems we use for processing personal data to be adapted to delete data in an administratively manageable way. We currently apply the following guidelines for the deletion of personal data for which there are no longer any reasons to keep:

All such data must be deleted within two years at the latest.

Upon request by the controller to erase a large amount of personal data, this shall be done as soon as administratively possible, but within three months at the latest.

Upon direct request from the controller or from a data subject to erase personal data relating to an individual data subject, the data shall be erased as soon as possible, but within one month at the latest.

Any sensitive data must be deleted as soon as possible.

When we terminate engagement with a customer, we will return all personal data to the customer or to another party referred by the customer upon request. Thereafter, all personal data related to the customer will be deleted. In some cases, parts of our contractual obligation may remain for a transitional period. This may include, for example, the obligation to report data to authorities. In such cases, the personal data will be deleted when this obligation ends.

HOW CAN DATA BE DELETED?

A user of People Pattern, can delete the user account upon request (via email to support@peoplepattern.io). This data is deleted from the system immediately and cannot be recovered by any users or People Pattern employees after this point. Data which has been deleted or otherwise destroyed can not be recovered at any time. Sufficient warning is given to the account administrator before data are permanently deleted.

Data may still remain in the systems back-up files, which will be deleted periodically.

Information may be deleted from our CRM upon request to support@peoplepattern.io. We undertake to perform the deletion within one month (30 calendar days) and will send you a confirmation once the information has been deleted. Wherever possible, we will aim to complete the request in advance of the deadline.

WHY WE USE YOUR PERSONAL DATA

We use your personal information primarily to provide you with our services, perform a concluded contract, comply with legal requirements, notify you of changes in our services, improve our services, enable us to conclude the required contract or perform it, or to meet legal requirements. We may also use this information with your consent to inform you of other services and products that we or selected third parties offer, which may be of interest to you or you could use. We will always inform you of any further use of your personal data.

SECURITY

The security of your information is important to us. We follow generally accepted industry standards to protect the solicited information submitted to us, both during transmission and once we receive it. However, no method of electronic transmission or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security, and therefore you transmit information to us at your own risk. Once we receive your transmission, we make reasonable efforts to ensure its security on our systems. Access to Personal information is strictly limited, and not accessible to the public. All Personal Information of our users is restricted and used only in accordance with this Privacy Policy.

PROPER USE

You agree that you will use the Service in compliance with all applicable local, state, national, and international laws, rules and regulations, including any laws regarding the transmission of technical data exported from your country of residence. People Pattern reserves the right, but shall have no obligation, to investigate your use of the Service in order to determine whether a violation of the End User Agreement has occurred or to comply with any applicable law, regulation, legal process or governmental request.

UNSOLICITED MATERIALS

Any unsolicited materials submitted or sent to People Pattern, will be deemed to be not confidential or secret. By submitting or sending information or other material to People Pattern you:

(a) Warrant that you have all rights of any kind to the material and that to the best of your knowledge no other party has any rights to the material;

(b) Unless stated specifically otherwise therein, grant People Pattern an unrestricted, perpetual, irrevocable license to use, reproduce, display, perform, modify, transmit and distribute the material, and you further agree that People Pattern is free to use any ideas, know-how, concepts or techniques you send us for any purpose, without any compensation to you or any other person. In order to remove all doubt, People Pattern privacy related obligation of this Privacy Policy shall not apply towards unsolicited information.

LINKS TO OTHER SERVICES AND WEBSITES

The Service, as well as any advertisement or other monetization means, may contain services, products, and/or links to other services, products, and websites, that are not owned or controlled by us. Please be aware that we are not responsible for the content nor for the privacy practices of these other websites, products, and services. We encourage you to be aware when you access a third party’s website or service and to read the privacy statements of each and every website and service you visit.

BUSINESS TRANSITIONS

If we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information will likely be among the assets transferred.

CHILDREN UNDER 13 YEARS OF AGE

The services of People Pattern are not intended for persons under 13 years of age. People Pattern Website or products and services are not developed or directed at children. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal information through the Site or Service without their permission.

CHANGES TO OUR POLICY OR PRIVACY PRACTICES

We may revise this Policy or our privacy practices at any time. Any changes and/or updates to our Policy will be posted directly on this page. We encourage you to visit this page periodically to review our current Policy so that you will always know what information we gather and how we may use that information.

CONTACT US

If you have a question regarding our Privacy Policy or you feel that your privacy was not treated in accordance with our Privacy Policy, or if you believe that your privacy has been compromised by any person in the course of using the Services, please contact People Pattern at: support@peoplepattern.io and our privacy officer shall promptly investigate.

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