Last updated February 1, 2020
Pentadata is firmly committed to the protection of your Personal Information and believes that you should have certain controls over how this sensitive information is used. Pursuant to this end, Pentadata believes in the following principles, which are intended to promote the fair, efficient, and effective use of consumer data:
- The Right to Transparency – You have the right to be provided with a clear, understandable explanation of how your Personal Information is collected, used, shared, and retained by that business. This includes being presented with a clear notice about the purpose of the data collection in the context of the relationship between you and the business.
- The Right to Consent – You have the right to be presented with an explicit consent to the processing of your Personal Information. This consent should clearly explain why the business needs to process your Personal Information.
- The Right to Choice and Control – Businesses should give you a choice over how your Personal Information is used, and the ability to limit the disclosure of your data. Unless required to perform a service, and where it’s not covered under the business’s privacy statement, you also have the right (1) to know what Personal Information is disclosed to third-parties, (2) to request such disclosure not take place, or (3) to prohibit marketing of your personal data.
- The Right to Access – You have the right to access your Personal Information held by the business. This also includes any observational data, inferences derived from your browsing history, social media, or location tracking.
- The Right to Data Portability – You have the right to receive a copy of your Personal Information from the business in a readable and easy-to-use format.
- The Right to Correct and Delete Data – You have the right to ensure that your Personal Information is correct and accurate. You also have the right, to correct inaccuracies of such data and have such data deleted.
- The Right to Data Security – You have the right to ensure that your Personal Information is secured in a way that is appropriate for the sensitivity of the data and current established standards.
You are free to exercise any of these rights in your interactions with Pentadata.
What Personal Information does Pentadata collect?
Through its websites and third-party data contributors, Pentadata may collect the following Personal Information about you, which is immediately tokenized and encrypted to protect you upon receipt:
- Contact Information including your name, username, mailing address, telephone number, email address, or social media profile names.
- Card transaction information, including your personal account numbers, merchant names and locations, transaction dates and amounts, as well as other information about you provided by financial institutions or other merchants.
- Information about the products and services you purchase, including registration and payment information.
- How you access the Pentadata website, including information about your device and mobile app usage, and related information collected through cookies and similar technologies.
- If you apply for a job with Pentadata, we collect your job application and related information.
How does Pentadata use Personal Information?
Pentadata may use your Personal Information in the following ways:
- Provide you with customized offers, services, content, and advertising on the Pentadata website and other third party sites.
- Operate and improve Pentadata’s business and operations.
- Learn more about you, including your preferences or other characteristics which we also consider to be Personal Information.
- Disclose Personal Information to third parties, solely with your informed consent.
- Generate aggregated datasets and share such de-identified information with third parties, in which case your Personal Information will never be disclosed.
- To comply with a legal obligation, such as in response to a subpoena from law enforcement agencies, regulators, or courts in the United States and other countries where we operate.
- Processing your job application.
Pentadata will specifically notify you at the time of collection in the event we use your Personal Information for any purpose not listed here.
Online Tracking and Privacy
Pentadata sometimes uses third party companies to display advertisements on our sites. These ads may also contain cookies, but are collected by the advertisers and not Pentadata. We do not have access to this information but we can put you in contact with these parties at your request.
How will Pentadata handle the information in my job application?
If you apply for a job at Pentadata, the Personal Information you share with us will be used and retained for recruiting, compliance, and other standard human resources purposes.
How does Pentadata handle information about children?
The Pentadata platform is not directed to, or intended for, children.
How do I contact Pentadata?
Feel free to contact Pentadata with any questions you have about your privacy. We can be reached by phone at 650-393-4177, by email at firstname.lastname@example.org and the following mailing address:
851 Burlway Avenue, Suite 711
I’m a California resident. How does the California Consumer Privacy Act apply to my Personal Information and interactions with Pentadata?
The California Consumer Privacy Act (“CCPA”) defines ‘Personal Information’ as information that identifies, relates to, or could reasonably be linked directly or indirectly with a particular California resident, and for the purposes of this section we will use that CCPA definition. CCPA, however, does not apply to certain information, such as information subject to the Gramm-Leach-Bliley Act (“GLBA”).
Your CCPA Rights
Under CCPA, and subject to certain limitations and exceptions, if you are a California resident, you may have the following rights with respect to information that Pentadata has collected about you that constitutes “Personal Information” under CCPA:
- To request we disclose to you, free of charge, the following information covering the 12 months preceding your request:
- the categories of Personal Information about you that we collected;
- the categories of sources from which the Personal Information was collected;
- the purpose for collecting Personal Information about you;
- the categories of third parties to whom we disclosed Personal Information about you and the categories of Personal Information that was disclosed (if applicable) and the purpose for disclosing the Personal Information about you; and
- the specific pieces of Personal Information we collected about you;
- To request deletion of your Personal Information unless CCPA recognizes an exception;
- To opt-out of any “sales” of your Personal Information, if a business is selling your information; and
- To not be discriminated against for exercising these rights.
To exercise your data protection rights you can submit a request using our online form (available here), or contact us as described in the “How do I contact Pentadata?” section above. You may need to provide additional information in order to confirm your identity before we can respond to your request.
You may also designate an authorized agent to contact Pentadata and make requests under the CCPA on your behalf. You may need to provide additional information in order to confirm you consented to this designation, as well as to confirm your identity before we can respond to your request. You may also designate Pentadata as your authorized agent to obtain this information on your behalf from other businesses.
We will consider all such requests and provide our response within a reasonable period of time. Please note, however, that certain information may be exempt from such requests. For example, if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims.
Collection and Disclosure of Personal Information
In the past 12 months, Pentadata has collected and disclosed to third parties for our business purposes the following categories of Personal Information relating to California residents covered by this disclosure:
- Identifiers, such as name or government-issued identifier (e.g., Social Security number)
- Personal information, as defined in the California safeguards law, such as contact information and financial information
- Commercial information, such as transaction information and purchase history
- Internet or network activity information, such as browsing history and interactions with our website
- Geolocation data, such as device location and Internet Protocol (IP) location
- Inferences drawn from any of the Personal Information listed above to create a profile about, for example, an individual’s preferences and characteristics
The categories of sources from whom we collected this Personal Information are:
- Directly from a California resident or the individual’s representatives
- Our data contributors, service providers, financial institutions, payment processors, credit card companies, retailers and other merchants, consumer data resellers, and other third parties
- Website/mobile app activity; social media
- Information from client-directed third parties or institutions representing a client or prospect.
The categories of third parties to whom we disclosed Personal Information for our business purposes described in this privacy disclosure are:
- You and, where appropriate, your family, your associates and your representatives
- Our data subscribers
- Accountants, auditors, financial advisors, lawyers, and other outside professional advisors to Pentadata, subject to confidentiality obligations
- Data aggregation services
- Third party service providers (such as payment services providers; shipping companies; etc.)
- Governmental, legal, regulatory, or other similar authorities and/or local government agencies, upon request or where required
- Third party acquirers, in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation)
Use of Personal Information subject to CCPA
In the past 12 months, we have used Personal Information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Performing services, including matching and tracking transactions and credit/debit card-linked offers, providing customer service, verifying customer information, providing advertising or marketing services, providing analytic services, or providing similar services
- Undertaking activities to verify or maintain the quality or safety of a service controlled by us, and to improve, upgrade, or enhance the service controlled by the business
- Complying with laws and regulations and to comply with other legal process and law enforcement requirements
Sale of Personal Information
As Pentadata understands CCPA, we have not disclosed Personal Information in a manner that would constitute a sale under CCPA.