Last Updated Date: 06/24/2020
Pendulum participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (“EU”) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles.
Pendulum is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third-party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Personal identification information
We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our Site, register on the Site, respond to a survey, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, phone number. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personal information, except that it may prevent them from engaging in certain Site related activities.
If you are subject to the jurisdiction of the EU, please see your General Data Protection Regulation (GDPR) Personal Data Notice.
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (“IP”) addresses, browser type, internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to for purposes of analytics and to improve Site functionality.
How we use collected information
- Pendulum may collect and use Users personal information for the following purposes:
- To improve customer service
- Information you provide helps us respond to your customer service requests and support needs more efficiently.
- To personalize User experience
- We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
- To improve our Site and services
- We may use information you provide to improve and create new products and services.
- To run a promotion, contest, survey or other Site feature
- To send Users information they agreed to receive about topics we think will be of interest to them.
- To send periodic emails
- We may use the email address to respond to their inquiries, questions, and/or other requests. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email and you may also unsubscribe within your profile settings.
Updating/Correcting Personal Information
Upon request we will provide you with information about whether we hold any of your personal information. If your personal information changes, or if you no longer desire our service, you may access, update, or delete it by making the change on our member information page or also through the contact details mentioned above. We will respond to your request to access within a reasonable timeframe.
We will retain your information for as long as your account is active or as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at email@example.com. We will retain and use your information to the extent necessary and permissible under applicable law to comply with our legal obligations, resolve disputes, and enforce our agreements.
How we protect your information
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.
Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. No method of transmission over the internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
Sharing your personal information
We do not sell, trade, or rent Users personal identification information to others. We may share aggregated information regarding visitors and Users with our business partners, trusted affiliates and advertisers for the purposes outlined above. We may use third party service providers to help us operate our business and the Site or administer activities on our behalf, such as sending out newsletters or surveys. We may share your information with these third parties for those limited purposes provided that you have given us your permission.
We may also disclose your personal information as required by law such as to comply with a subpoena, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request, if Pendulum is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Third party Websites
Users may find advertising or other content on our Site that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these websites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these websites or services, including their content and links, may be constantly changing. These websites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and policies.
Our Site offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at email@example.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org.
Collection and Use of 3rd Party Personal Information
You may provide personal information about other people, such as their name, email address, phone number and job title. When you provide us with personal information about your contact information, we will only use this information for the specific reason for which it is provided. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at email@example.com.
Information Related to Data Collected through the Pendulum
Pendulum collects information under the direction of its clients and has no direct relationship with the individuals whose personal data it processes.
We collect information for our clients, if you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly.
Service Provider, Sub-Processors/Onward Transfer
Access to Data Controlled by our Clients
Pendulum acknowledges that you have the right to access your personal information. Pendulum has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Pendulum’s client, as the data controller. If the client requests Pendulum to remove the data, we will respond to their request within a reasonable timeframe.
Your acceptance of these terms
By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
Pendulum Associates, LLC
1 Little West 12th Street New York, NY 10014
Telephone Number: 646.389.0053
Email us: firstname.lastname@example.org