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Privacy Policy

 

Pivot Technology Solutions, Ltd. and its global affiliates (collectively “Pivot”, “our, “we” and “us”) respects the privacy of its customers and visitors to our websites.  We are pleased to offer our website users the convenience of our web-based technologies and we strive to use any information that we collect in a conscientious and appropriate fashion.

This Privacy Statement (the “Statement”) outlines the use of personally identifiable information relating to you (“Personal Data”) that we will collect from you or that you provide to us through our Sites. Your personal data will be held by us as a controller.  This Statement, together with our Terms of Use applies to your use of the Site.

If you have any questions regarding this Statement or our practices regarding your Personal Data, please contact our Chief Compliance Officer at compliance@pivotts.com.

 What information is collected on our Site?

We strive to collect a minimal amount of information from you. We only collect information that will enhance your site visit and enable you to do business with us.

We do not collect personally identifiable information about the pages that visitors browse, but we may collect blind, aggregate information to advise us as to how many individuals have viewed our pages, when they have viewed them, and any referring websites.

We do not collect any Personal Data on our website.  However, you can contact us by emailing us at the email addresses listed on the site and choose to provide us with Personal Data such as your name, email address, and other contact information (“Correspondence Information”).

 

Correspondence Information·    You may choose to give us information such as your name, e-mail address, address, telephone number and other details when contacting us at the email address listed on the Site. It is not necessary for you to provide this information in order to view the Site.

How & why we process your Personal Data

The following table details the legal bases on and purposes for which we collect and process Correspondence Information, which is Personal Data that you opt to provide by contacting us:

Legal BasisPurpose(s)

Compliance with a Legal Obligation

It may be necessary for us to collect and process your Personal Data in order to comply with certain legal obligations.

·   To ensure our compliance with applicable laws.

To Defend, Establish or be a Party to Legal Claims

We may process your Personal Data as necessary in order for us to investigate, exercise or defend a legal claim to which you are a party.

·   To file legal proceedings.

·   To investigate, establish, exercise or defend a legal claim.

·   To settle legal claims.

Legitimate Interests

·   For purposes of improving and monitoring website efficiency and enhancing the Site.

·   For purposes of our legitimate interests to process your Personal Data to respond to any inquiries or requests submitted by you to us.

 

Improving Site Functionality and Efficiency

·   To provide, improve, test and monitor the effectiveness of the Site;

·    to monitor metrics such as total number of visitors, traffic data and demographic patterns; and

·    to ensure the content on the Site is presented in the most effective manner.

Responding to Questions

·   To process and respond to any inquiries or requests that you submit to us by emailing us on any of our email channels.

How does Pivot share information that it collects?

We do not share your information with third parties for marketing purposes, nor do we conduct joint marketing with third parties.

We may share your information within the Pivot family of companies: ACS (US), Inc., Sigma Solutions, New ProSys, TeraMach, Pivot Shared Services, Ltd., Pivot Acquisition Corp., and Pivot Technology Solutions, Ltd.

Transfers of your Personal Data

Pivot is primarily based in Canada and the United States.  Therefore, the Personal Data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area. Where such transfers occur, it is our policy that: a) data transfers do not occur without our prior written authority; and b) that an appropriate transfer agreement is put in place to protect your Personal Data. If you would like to find out more about any such transfers, please contact our Chief Compliance Officer at compliance@pivotts.com.

Retention of your Personal Data

In general, we expect to keep your Personal Data for as long as is reasonably necessary for the purposes for which it was obtained. Once we have determined that we no longer need to hold your Personal Data, we will delete it from our systems.

Please note that in certain circumstances, we may hold your data for a longer period, for example, if we believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your Personal Data.

How can customers or visitors view collected information or request to change it?[1]

By contacting us at the Contact Us link on our Site, you may request a copy of the information that we have collected from you via email, and also request changes to that information.

How does Pivot protect this information?

To protect your information from unauthorized access, use, disclosure, alteration or destruction, we have in place security measures which meet reasonable commercial standards of technology and operational security, including computer safeguards and secured files and buildings.

How can customers or visitors opt out of having their information collected?

Customers who do not wish to have this information collected may opt out of using our Site and contact us pursuant to the Contact Us link for sales via telephone. Visitors may opt not to view our Site.

Use of Our Policy and Updates:

Our Statement may change from time to time at our discretion.  When we make changes to this Statement, we will amend the revision date at the bottom of this page. We encourage you to periodically review this Statement to stay informed about how we are protecting your information. Any changes will be effective immediately upon communicating the revised notice to you.

If at any time we decide to use your Personal Data in a manner significantly different from that stated in this notice, or otherwise disclosed to you at the time it was collected, we will notify you by the contact details you provide us with, and you will have a choice as to whether or not we use your Personal Data in the new manner.

If you have any questions, comments or concerns about the way your Personal Data is being used or processed by the Company, please submit your question, comment or concern in writing to request to our Chief Compliance Officer at compliance@pivotts.com.

Your Rights

The table below sets out the rights which you have to address any concerns or questions about our processing of your Personal Data in compliance with the General Data Protection Regulation:

 

Your RightFurther Information
Right of AccessYou have the right to request a copy of the Personal Data held by us about you. We will only charge you for making such an access request where we feel your request is unjustified or excessive.
Right to RectificationYou have the right to request that we correct any inaccurate Personal Data that we have about you.
Right to Erasure

You have the right to ask us to erase your Personal Data where:

1.     your Personal Data is no longer necessary for the purposes for which they were collected or processed by us;

2.     you withdraw your consent and no other legal ground permits us to process your Personal Data;

3.     you object to the processing and there are no overriding legitimate grounds for the processing;

4.     your Personal Data has been unlawfully processed; or

5.     your Personal Data must be erased in order to comply with a legal obligation.

We may not be able to comply with a request where we require your Personal Data for compliance with a legal obligation or in connection with legal proceedings or for exercising the right of freedom of expression and information.

Right to Restriction of Processing

You have the right to ask us to restrict processing your Personal Data in the following situations:

(1)   where you contest the accuracy of your Personal Data;

(2)   where the processing is unlawful and you do not want us to delete your Personal Data;

(3)   where we no longer need your Personal Data for the purposes of processing but you require the data in relation to a legal claim; or

(4)   where you have objected to our processing of your Personal Data pending the verification of whether or not our legitimate business interests override your interests, rights and freedoms or in connection with legal proceedings.

When you exercise this right, we may only store your Personal Data. We may not further process the data unless you consent or the processing is necessary in relation to a legal claim, to protect the rights of another person, or for reasons of important public interest. We will inform you before the processing restriction is lifted.

Right to Data Portability

You may ask that we provide you with Personal Data that you have given us in a structured, commonly used and machine-readable format and to transmit your Personal Data directly to another data controller where this is technically feasible.

This right only arises where:

(1)   we process your Personal Data on your consent or where it is necessary to perform our contract with you; and

(2)   the processing is carried out by automated means.

Right to Object

You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.

You have a right to object at any time to the processing of your Personal Data for direct marketing purposes.

You can exercise any of these rights by submitting a request to compliance@pivotts.com.

We will promptly provide you with information regarding any action taken at your request in relation to any of these rights and at the latest within one month of receiving your request. Please note that we may ask you to verify your identity when you seek to exercise any of your privacy rights.

You also have the right to lodge a complaint with your applicable privacy or data protection supervisory authority.