Pearl Thinks Privacy Policy

Effective January 1, 2020

Pearl Thinks takes data privacy seriously. This privacy policy explains who we are, how we collect, share and use Personal Information, and how you can exercise your privacy rights. 

As used in this privacy policy, “Personal Information” means an individual’s personal information, including but not limited to (i) general personal information (e.g., names, dates of birth, home and business addresses, email addresses, Internet protocol addresses and telephone numbers); (ii) identification information and government-issued identification numbers, social security numbers, national identification numbers, tax identification numbers, driver’s license numbers, passport numbers, and photographs); (iii) sensitive personal information (e.g., biometric identifiers, racial or ethnic origin, religious or philosophical beliefs, political affiliations and opinions, trade union membership, and background check data); (iv) medical and health information (e.g., medical records, sexual orientation, and disability data); and (v) financial information (e.g., credit and debit card numbers, credit reports, passwords, and pin numbers).

We recommend that you read this privacy policy in full to ensure you are fully informed. However, to make it easier for you to review the parts of this privacy policy that apply to you, we have divided up the document into sections that are specifically applicable to  Visitors (Section 2), Subscribers/Customers (Section 3), and Contacts (Section 4).  Sections 1 and 5 are applicable to everyone.

If you have any questions or concerns about our use of your Personal Information, then please contact us using the contact details provided at the end of Section 5.

To the extent we provide you with notice of different or additional privacy policies, those policies will govern such interactions.

1.                  About Us

Pearl Thinks, LLC  ("we,” "us,” "our,” "Pearl Thinks,” and “Pearl”) provides an end-to-end, marketing data delivery solution built around its certified SaaS CDP technology.  The company is headquartered in the State of Massachusetts in the United States.

Our Platform provides marketing campaign performance reporting, data analytics and insights and audience segmentation and delivery to marketing channels.

2.                  Privacy for Visitors 

This section applies to Personal Information that we collect and process when you visit the Pearl Thinks website, and in the usual course of our business, such as in connection with our recruitment, events, sales and marketing activities or when you visit our offices. In this section, "you" and "your" refer to Visitors.

A. Information We Collect

(i) Information you provide to us on the Pearl Thinks websites or otherwise: Our websites offer various ways to contact us, such as through form submissions, email or phone, to inquire about our company and our various service offerings (the “Service”). For example, we may ask you to provide certain Personal Information when you express an interest in obtaining information about us or our Service, take part in surveys, subscribe to marketing, apply for a role with Pearl Thinks, or otherwise contact us. We may also collect Personal Information from you in person when you attend our events or trade shows, if you visit our offices or via a phone call with one of our sales representatives. You may choose to provide additional information when you communicate with us or otherwise interact with us, and we may keep copies of any such communications for our records.

The Personal Information we collect may include:

  • Business contact information (such as your name, phone number, email address and country);
  • Professional information (such as your job title, institution or company); 
  • Nature of your communication;
  • Marketing information (such as your contact preferences); and 
  • Any information you choose to provide to us when completing any ‘free text’ boxes in our forms.

(ii) Information we collect automatically through the Pearl Thinks website: When you visit our Pearl Thinks website or interact with our emails, we may use cookies and similar technologies such as pixels or web beacons, alone or in conjunction with cookies, to collect certain information automatically from your browser or device. In some US states and some countries, including countries in the EEA, this information may be considered Personal Information under applicable data protection laws. Our use of cookies and other tracking technologies is discussed more below.

The information we collect automatically includes:

  • Device information: such as your IP address, your browser, device information, unique device identifiers, mobile network information, request information (speed, frequency, the site from which you linked to us (“referring page”), the name of the website you choose to visit immediately after ours (called “exit page”), information about other websites you have recently visited and the web browser you used (software used to browse the internet) including its type and language)
  • Usage data: such as information about how you interact with our emails, Pearl Thinks websites, and other websites (such as the pages and files viewed, searches, operating system and system configuration information and date/time stamps associated with your usage).
B. Use of Personal Information

We may use the information we collect through our Pearl Thinks website and in connection with our events and marketing activities (alone or in combination with other data we collect) for a range of lawful business and commercial reasons in reliance on our legitimate interests, including:

  • To provide, operate, optimize, and maintain the Pearl Thinks website.
  • To send you marketing information, product recommendations and non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us, in accordance with your marketing preferences, including information about our products, services, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent.
  • For recruitment purposes if you have applied for a role with Pearl Thinks.
  • To respond to your online inquiries and requests, and to provide you with information and access to resources or services that you have requested from us.
  • To manage the Pearl Thinks website and system administration and security.
  • To manage event registrations and attendance, including sending related communications to you.
  • To register visitors to our offices for security reasons and to manage non-disclosure agreements that visitors may be required to sign.
  • To improve the navigation and content of the Pearl Thinks website.
  • To identify any server problems or other IT or network issues.
  • To process transactions and to set up online accounts.
  • To compile aggregated statistics about site usage and to better understand the preferences of our Visitors.
  • To help us provide, improve and personalize our marketing activities.
  • To facilitate the security and continued proper functioning of the Pearl Thinks website.
  • To carry out research and development to improve our Pearl Thinks website, products and services.
  • To conduct marketing research, advertise to you, provide personalized information about us on and off our Pearl Thinks website, and to provide other personalized content based on your activities and interests.
  • To carry out other legitimate business purposes, as well as other lawful purposes, such as data analysis, fraud monitoring and prevention, identifying usage trends and expanding our business activities in reliance on our legitimate interests.
  • To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Pearl Thinks website and Service, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, or responding to lawful requests.
C. Public Information and Third-Party Websites
  • Blog. We have public blogs on the Pearl Thinks website. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, please email us at privacy@pearlthinks.com. If we are unable to remove your information, we will tell you why.
  • Social media platforms and widgets. We maintain presences on social media platforms, including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
  • Links to third-party websites. The Pearl Thinks website may include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.
  • Contests and sweepstakes. We may, from time to time, offer surveys, contests, sweepstakes, or other promotions on the Pearl Thinks websites or through social media (collectively, "Promotions"). Participation in our Promotions is completely voluntary. Information requested for entry may include Personal Information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer our Promotions. We may also, unless prohibited by the Promotion’s rules or law, use the information provided to communicate with you, or other people you select, about our Service.
D. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect and use Personal Information about you, including to serve interest-based advertising.

E. Other Data Protection Rights

Depending on the country or U.S. state in which you reside, you may have the following data protection rights:

  • To access; correct; update; port; delete; restrict or object to our processing of your Personal Information. You can exercise these rights by emailing privacy@pearlthinks.com.
  • You may also have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.
  • Similarly, if we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. You can also contact us at any time to update your marketing preferences

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

3.                  Privacy for Pearl Subscribers/Customers

This section applies to the Personal Information we collect and process from a Subscriber/Customer or potential Subscriber/Customer through the provision of the Service. In this section, "you" and "your" refer to Subscriber/Customer and potential Subscriber/Customer.

A. Information We Collect

The Personal Information that we collect depends on the context of your interactions with Pearl Thinks, your Pearl Thinks account settings, the products and features you use, your location, and applicable law. However, the Personal Information we collect broadly falls into the following categories:

(i) Information you provide to us: You (or your organization) may provide certain Personal Information to us when you sign up for a Pearl Thinks account and use the Service, consult with our customer service team, send us an email, integrate the Service with another website or service (for example, when you choose to connect your e-commerce account with Pearl Thinks), or communicate with us in any other way.

This information may include:

  • Business contact information (such as your name, job title, organization, location, phone number, email address, and country);
  • Marketing information (such as your contact preferences);
  • Account log-in credentials (such as your email address or username and password when you sign up for an account with us);
  • Troubleshooting and support data (which is data you provide, or we otherwise collect in connection with support queries we receive from you. This may include contact or authentication data, the content of your chats and other communications with us, and the product or service you are using related to your help inquiry); and
  • Payment information (including your credit card numbers and associated identifiers and billing address).

(ii) Information we collect automatically: When you use the Service, we may automatically collect or receive certain information about your device and usage of the Service (collectively “Service Usage Data”). In some (but not all) countries, including countries in the European Economic Area (“EEA”), this information is considered Personal Information under applicable data protection laws. We use cookies and other tracking technologies to collect some of this information.

Service Usage Data may include:

  • Device information:We collect information about the device and applications you use to access the Service, such as your IP address, your operating system, your browser ID, and other information about your system and connection
  • Log data:Our web servers keep log files that record data each time a device accesses those servers and the nature of each access, including originating IP addresses and your activity in the Service (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take (for example, which features you used)), device event information (such as system activity, error reports (sometimes called ‘crash dumps’)), and hardware settings. We may also access metadata and other information associated with files that you upload into our Service.
  • Usage data:We collect usage data about you whenever you interact with our Service, which may include the dates and times you access the Service and your browsing activities (such as what portions of the Service you used).

(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners. 

Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), online behavioral data (such as information about your use of social media websites, page view information and search results and links), shopping habits (such as the type of products you have purchased) and finances (such as net worth, discretionary income, bankruptcy and debt). Our Subscribers/Customers use this information, alone or in combination with other Personal Information we collect, to enhance their ability to provide relevant marketing communications and customer experiences to you and to develop and provide you with more relevant products, features, and service .

B. Use of Personal Information

We may use the Personal Information we collect or receive through the Service (alone or in combination with other data we source) for the purposes and on the legal bases identified below:

  • To bill and collect money owed to us by you (or your business) to perform our contract with you for the use of the Service or where we have not entered into a contract with you (or your business), in accordance with our legitimate interests to operate and administer our Service. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to process your orders and credit card payments.
  • To send you system alert messages in reliance on our legitimate interests in administering the Service and providing certain features. For example, we may inform you about temporary or permanent changes to our Service, such as planned outages, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.
  • To communicate with you about your account and provide customer support to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and supporting our Service.
  • To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
  • To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements in reliance on our legitimate interests.
  • To prosecute and defend a court, arbitration, or similar legal proceeding.
  • To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  • To provide, support and improve the Service to perform our contract with you for the use of the Service or where we have not entered into a contract with you, in reliance on our legitimate interests in administering and improving the Service and providing certain features. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to you. When we share your Personal Information with third parties, we take steps to protect your information in a manner that is consistent with our obligations under applicable privacy laws.
  • To provide suggestions to you and to provide tailored features within our Service that optimize and personalize your experience in reliance on our legitimate interests in administering the Service and providing certain features. This includes adding features that compare Subscribers’/Customers’ email campaigns, using data to suggest other publishers your Contacts (defined and discussed below) may be interested in, or using data to recommend products or services that you may be interested in or that may be relevant to you or your Contacts. Some of these suggestions are generated through analysis of the data used in our data analytics projects, as described below.
  • To perform data analytics projects in reliance on our legitimate business interests in improving and enhancing our products and services for our Subscribers/Customers . Our data analytics projects use data from Pearl Thinks accounts, including Personal Information of Contacts, to provide and improve the Service. We use information like your Contacts’ purchase history, so we can make more informed predictions, decisions, and products for our Subscriber/Customer. For example, we use data from Pearl Thinks accounts to enable product recommendation, audience segmentation, and predicted demographics features for our Subscribers/Customers. If you or your Contact prefers not to have their data used for this purpose your Contact can opt out of data analytics projects at any time by emailing us at privacy@pearlthinks.com. As always, we take the privacy of Personal Information seriously, and will continue to implement appropriate safeguards to protect this Personal Information from misuse or unauthorized disclosure.
C. Cookies and Tracking Technologies

We and our third-party partners may use various technologies to collect and store Service Usage Data when you use our Service (as discussed above), and this may include using cookies and similar tracking technologies, such as pixels and web beacons. Web beacons allow us to collect information such as the recipient’s IP address, browser, email client type and other similar data.

D. Subscribers/Customers Contact Lists

In order to send a marketing campaign and use certain features in your account, you need to upload a contact list or integrates another website, platform or service (eCommerce, Point of Sales, CRM, Email Service Provider, etc.) with Pearl or when you sign up for a Subscribers’/Customers’ Distribution List on a web site signup form the Subscribers/Customers may provide us with information, such as names and email addresses. We use and process this information to provide the Service in accordance with our contract with you or your organization and this privacy policy. 

We do not, under any circumstances, sell or rent your contact lists. If someone on your contact list complains or contacts us, we might then contact that person. We will only share your contact list with a third-party as explicitly directed in writing by you or your organization.

If we detect abusive or illegal behavior related to your contact list, we may share your contact list or portions of it with affected ISPs or anti-spam organizations to the extent permitted or required by applicable law.

E. Your Data Protection Rights

Depending on the country or U.S state in which you reside, you may have the following data protection rights:

  • To access; correct; update; port; delete; restrict; or object to our processing of your Personal Information. 
  • The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority.
  • Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. If you receive these requests from Contacts, you can segment your lists within the Pearl Thinks platform to ensure that you only market to Contacts who have not opted out of receiving such marketing.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request.

4.                  Privacy for Contacts 

This section applies to the information we process about our Subscribers’/Customers’ Contacts as a data controller. Our Service is intended for use by our Subscribers/Customers . As a result, for much of the Personal Information we collect and process about Contacts through the Service, we act as a processor on behalf of our Subscribers/Customers. Pearl Thinks is not responsible for the privacy or security practices of our Subscribers/Customers, which may differ from those set forth in this privacy policy. Please check with individual Subscribers/Customers about the policies they have in place. For purposes of this section, "you" and "your" refers to Subscribers’/Customers’ Contacts.

A. Information We Collect Relating to Contacts

The Personal Information that we may collect or receive about you broadly falls into the following categories:

(i) Information we receive about Contacts from our Subscribers/Customers: A Subscribers/Customers may provide Personal Information about you to us through the Service. When a Subscriber/Customer integrates another website, platform or service (eCommerce, Point of Sales, CRM, Email Service Provider, etc.)) or when you sign up for a Subscribers’/Customers’ Distribution List on a web site signup form, the Subscribers/Customers may provide us with certain contact information or other Personal Information about you such as your name, email address, address, or telephone number. You may have the opportunity to update some of this information by electing to update or manage your preferences via an email you receive from a Subscriber/Customer.

(ii) Information we collect automatically: When you interact with an email campaign that you receive from a Subscribers/Customers or browse or purchase from a Subscriber/Customer connected store, we may collect information about your device and interaction with an email. We use cookies and other tracking technologies to collect some of this information.

  • Device information: We collect information about the device and applications you use to access emails, such as your IP address, your operating system, your browser ID, and other information about your system and connection.
  • Usage data:  We may also collect usage data about your interactions with marketing campaigns (and/or emails), which may include dates and times you access campaigns (and/or emails) and your web browsing activities (such as what pages are viewed and which emails are opened).

(iii) Information we collect from other sources: From time to time, we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners. 

Examples of the information we receive from other sources include demographic information (such as age and gender), device information (such as IP addresses), location (such as city and state), online behavioral data (such as information about your use of social media websites, page view information and search results and links), shopping habits (such as the type of products you have purchased) and finances (such as net worth, discretionary income, bankruptcy and debt). Our Subscribers/Customers use this information, alone or in combination with other Personal Information we collect, to enhance their ability to provide relevant marketing communications and customer experiences to you and to develop and provide you with more relevant products, features, and service.

  1. Use of Personal Information

We may use the Personal Information we collect or receive about you in reliance on our (and where applicable, our Subscribers/Customers) legitimate interests for the following purposes:

  • To enforce compliance with our Terms of Use and applicable law. This may include utilizing usage data and developing tools and algorithms that help us prevent violations.
  • To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
  • To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
  • To prosecute and defend a court, arbitration, or similar legal proceeding.
  • To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  • To provide, support and improve the Service. For example, this may include sharing your information with third parties in order to provide and support our Service or to make certain features of the Service available to our Subscribers/Customers. When we share Personal Information with third parties, we take steps to protect your information in a manner that is consistent with applicable privacy laws. For further information about how we share information please email privacy@pearlthinks.com.
  • To perform data analytics. Our data analytics use data from Pearl Thinks accounts, including your Personal Information, to provide and improve the Service. We use information, like your purchase history, provided to us by Subscribers/Customers, so we can make more informed predictions, decisions, and products for our Subscribers/Customers. For example, we use data from Pearl Thinks accounts to enable product recommendation, audience segmentation, and predicted demographics features for our Subscribers/Customers. If you prefer your data not to be used in this manner, you can opt out of data analytics projects at any time by emailing us at privacy@pearlthinks.com
  • To carry out other business purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.
C. Cookies and Tracking Technologies

We and our third-party partners may use various technologies to automatically collect and store certain device and usage information when you interact with a Subscribers’/Customers’ email campaign or connected store, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. When you receive and engage with a Subscribers’/Customers’ campaign, web beacons track certain behavior such as whether an email sent was delivered and opened and whether links within the email were clicked. Web beacons also collect information such as your IP address, browser, email client type, and other similar data.

D. Your Data Protection Rights

Depending on the country or U.S state in which you reside, you may have the following data protection rights:

  • To access; correct; update; port; delete; restrict or object to our processing of your Personal Information.
  • You also have the right to complain to a data protection authority about our collection and use of your Personal Information.

As described above, for much of the Personal Information we collect and process about Contacts through the Service, we act as a processor on behalf of our Subscribers/Customers. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by Pearl Thinks as a processor on behalf of our individual Subscribers/Customers, you should contact the relevant Subscribers/Customers that is using the Pearl Thinks Service, and refer to their separate privacy policies.

If you no longer want to be contacted by one of our Subscribers/Customers through our Service, please unsubscribe directly from that Subscribers’/Customers’ newsletter or contact the Subscribers/Customers directly to update or delete your data. If you contact us directly, we may either forward your request to the relevant Subscribers/Customers or provide you with the identity of the Subscribers/Customers to enable you to contact them directly.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.

5. General Information 
A. How We Share Information

We may share and disclose your Personal Information to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, "you" and "your" refer to Visitors, Subscribers/Customers and Contacts, and unless otherwise indicated):

(i) Our service providers: Sometimes, we share your information with our third-party service providers working on our behalf for the purposes described in this privacy policy. For example, companies we’ve hired to help us provide and support our Service or assist in protecting and securing our systems and services and other business-related functions. We also may share your information with third-party services for the purposes of enriching Contact records with publicly available demographics, location and social media information to enable Subscribers/Customers to provide more personalized, relevant marketing communications and customer experiences.  Other examples include analyzing data, hosting data, engaging technical support for our Service, processing payments, and delivering content.

(ii) Advertising partners: We may partner with third-party advertising networks, exchanges, and social media platforms to manage and serve Subscribers/Customers advertising on other sites, and we may share Personal Information of Subscribers/Customers and Visitors with them for this purpose. We and our third-party partners may use cookies and other similar tracking technologies, such as pixels and web beacons, to gather information about your activities on the Pearl Thinks Sites and Subscribers/Customers sites in order to provide you with targeted advertising based on your browsing activities and interests.

(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.

(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this privacy policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Pearl Thinks Site.

(v) Any other person with your consent.

B. Legal Basis for Processing Personal Information (EEA and UK Persons Only)

If you are a resident of California or located in the EEA or UK, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.

However, we will normally collect and use Personal Information from you where the processing is in our legitimate interests and not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests are described in more detail in this privacy policy in the sections above titled “Use of Personal Information,” but they typically include improving, maintaining, providing, and enhancing our technology, products, and services; ensuring the security of the Service and our Pearl Thinks websites; and supporting our marketing activities.

If you are a Subscribers/Customers, we may need Personal Information to perform a contract with you. In some limited cases, we may also have a legal obligation to collect Personal Information from you.

Where required by law, we will collect Personal Information only where we have your consent to do so.

If you have questions or need further information concerning the legal basis on which we collect and use your Personal Information, please email us at privacy@pearlthinks.com.

C. Your Choices and Opt-Outs

Subscribers/Customers and Visitors who have opted into our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.

Also, all opt-out requests can be made by emailing us at privacy@pearlthinks.com. Please note that some communications (such as service messages, account notifications, billing information) are considered transactional and necessary for account management, and at privacy@pearlthinks.com cannot opt out of these messages unless you cancel your Pearl Thinks account.

D. Our Security

We take appropriate and reasonable technical and organizational measures designed to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at privacy@pearlthinks.com.

Pearl Thinks accounts require a username and password to log in. Subscribers/Customers must keep their username and password secure, and never disclose it to a third party. Because the information in a Subscribers’/Customers’ Pearl Thinks account is private, we cannot resend forgotten passwords. Subscribers/Customers may utilize the “Forgot Password?” on the Pearl Thinks login page.

E. International Transfers

We operate in the United States.  Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy.

F. Retention of Data

We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:

  • Whether we have a legal or contractual need to retain the data.
  • Whether the data is necessary to provide our Service.
  • Whether our Subscribers/Customers have the ability to access and delete the data within their Pearl Thinks accounts.
  • Whether our Subscribers/Customers would reasonably expect that we would retain the data until they remove it or until their Pearl Thinks accounts are closed or terminated.

When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

G. California Privacy

The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA (which includes us and may include our Subscribers/Customers with whom you have a relationship) disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right. 

When offering services to its Subscribers/Customers, Pearl Thinks acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Subscribers/Customers in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to the Subscribers/Customers with whom you have a direct relationship. 

Consistent with California law, if you choose to exercise your applicable CCPA rights, we won’t charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us. 

H. Do not Track

Certain state laws require us to indicate whether we honor “Do Not Track” settings in your browser. Pearl Thinks adheres to the standards set out in this Privacy Policy and does not monitor or follow any Do Not Track browser requests.

I. Changes to this Policy

We may change this privacy policy at any time and from time to time. The most recent version date of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Pearl Thinks websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Pearl Thinks website.

J. Questions & Concerns

If you have any questions or comments, or if you have a concern about the way in which we have handled any privacy matter, please email us at privacy@pearlthinks.com.

You may also contact us by postal mail or email at:

Pearl Thinks, LLC
Attn: Privacy Officer
64J Concord Street, Wilmington, MA 01887
privacy@pearlthinks.com

You may also contact us by clicking on the “Contact Us” button below:

 

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