Last updated: February 15th, 2020
P39 Tech LLC (“Peer39,” “we,” “us,” “our,”) is committed to protecting and respecting your privacy. This policy describes how we collect, use, and disclose information that we obtain from or about visitors to our website or at other publicly-available websites we operate (collectively, the “Site”), as well as in connection with the products and services available through our technologies and online services platform (collectively, our “Service”), and it sets out the basis on which any personal information that we receive from or about you will be processed by us.
Please read the following carefully to understand our practices regarding your personal information and how we treat it. By visiting the Site or otherwise providing us your consent or agreement, you are accepting and consenting to the practices and terms described in this policy. If you do not agree to this policy, please do not use the Site or our Service.
Your use of our Site or Service, and any dispute over privacy, is subject to this policy and any other terms with us that you have accepted, including their applicable limitations on damages and the resolution of disputes.
As further described below, Peer39’s Service is privacy-friendly. We do not collect or use personal information of consumers in the operation of our Service.
Peer39 is the operator of our Site, and we collect personal information from visitors to our Site who provide their information to us (such as by filling out a contact form) as well as to enhance our Site and marketing efforts as further described in this policy. With respect to the use of our Site by EU data subjects, we are either a controller or processor of your data, depending upon the circumstances that give rise to our processing of your data. Peer39 is a United States company registered in the State of Delaware and located in New York City.
Meaning of Personal Information
In this policy, the term “personal information” means data that identify you as an individual or relate to an identifiable individual. Personal information may also be referred to as “personal data” under EU and other laws. Examples of personal information we may collect are:
- Postal address
- Telephone number
- Email address
- Geolocation information
- Social media account ID, profile photo and other data publicly available, or data made available by linking your social media and loyalty accounts
- Credit card and billing information (if submitted as payment for the Service)
- Other data that you authorize us to process
Information collected through our Service
We do not collect or process personal information of individuals in the operation of our Service, other than from individuals who have relationships with Peer39, such as our employees or our customers’ personnel who log into our Service. Instead, Peer39’s Service is intentionally designed to enable advertisers and marketers to deliver digital ads without using individuals’ personal information to target them. We do this by using information we know about the content and context of website pages to enable ads to be delivered that are relevant to that page’s content, or to avoid delivering ads to pages that may have undesirable content. For example, an advertiser who wants to market to people interested in travel can use our Service to identify websites whose content indicates the website may be interesting to travelers. This service is called contextual advertising. Since we work with third parties who use personal information for targeted advertising, these third parties may send us unsolicited personal information, such as detailed geolocation information that we have not requested. In fact, we take steps to prevent our customers and partners from submitting consumers’ personal information to the Service. If we do receive personal information in the Service inadvertently, we do not use it to provide our Service or otherwise, and we promptly delete it.
How We Collect Personal Information
Information you give us.
This is information about you that you give us by filling in forms on the Site or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you request information from us or one of our partners, register to use our Site, subscribe to our Service, make a payment on our Site, download our reports and when you report a problem with our Site or Service. The information you give us may include your name, address, e-mail address and phone number, and other information such as the data listed in the examples of personal information section above. Note that this is not an exhaustive list.
We may ask you for similar information at other times, such as when you apply for a job through our Site or contact our customer service team.
We also collect Personal information that employees, contractors, or agents of our customers provide to us when they register for access to use our Service or to work with us in other ways. The information we may collect includes name, address, company name, email address, phone number and account password.
Information we collect about you.
With regard to each of your visits to our Site, we will automatically collect information about your visit, which may include the following information: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, HTTP protocol elements, HTTP cookies, the timestamp request, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about your visit, including the full Uniform Resource Locators (URL), the query-string portion of the URL, search terms, clickstream to, through and from our Site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
Information we receive from other sources.
We work with third parties (including, but not limited to, business partners, sub-contractors in technical, payment and delivery services, advertising networks, and analytics providers) to deliver and market our services and may receive information about you from them. We may use third-party website analytics tools (such as Google Analytics) to collect information about your visits to our Site.
Cookies and advertising technologies
We may use the following types of cookies and digital technologies:
- Cookies are used for various purposes, including Strictly Necessary cookies, Performance cookies, Targeting (Advertising) cookies, and Social Media cookies. To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails or other electronic marketing communications from us, other than emails related to your use of the Service or management of your account. Please see the Access and Your Choices section below.
- On our Site (but not our Service), we might also use a pixel tag which is a small graphic file that allows us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site and our e-mails. These tags may collect the IP address from the device which you loaded the page, your browser type, and other data. Pixel tags also may be used by our third parties to collect information when you visit our Site, the links and other actions you take on our Site, and we may use this information in combination with cookies for our marketing activities.
- Other data technologies may be used that collect comparable information for security and fraud detection purposes.
For more detailed information on cookies, a list of the cookies we use on our Site, and your options for managing your cookie preferences, see our Cookie Notice.
Third Party Analytics
Third Party Advertisers
How we use personal information
We use information held about you in the following ways:
Information you give to us
We will use this information:
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
- to provide you with information about other services we offer that are similar to those that you have already purchased or inquired about;
- to provide you with information about goods or services we feel may interest you;
- to ensure that content from our Site is presented in the most effective manner for you and for your computer or mobile device.
- to communicate with you about our Service, such as to provide you with support for our Service or notify you about changes to the Service;
Information we collect about you
We will use this information:
- to administer our Site and for internal operations, including troubleshooting, data analysis, user analysis, testing, research, statistical and survey purposes;
- to improve our Site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our Service when you choose to do so, such as to access and use your account;
- as part of our efforts to keep our Site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our Site about goods or services that may interest you or them.
Information we receive from other sources
We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure of Personal information
We may disclose your information, including personal information to third parties and otherwise as described below:
- if Peer39 or substantially all of its assets are acquired by a third party, or merged with another company, if all or some portion of our assets are transferred to another company, or as part of a bankruptcy proceeding, financing due diligence, reorganization, or receivership, we may transfer the information we have collected from you to the other company or bankruptcy trustee or administrator;
- We may share statistical or aggregated non-personal information about our customers and visitors to this Site with advertisers, business partners, sponsors and other third parties.
- We may share your personal information with our service providers who help us operate our business, including the Service and our Site,
Our Site may, from time to time, contain links to and from the websites of our partners. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.
Our Site is built to protect your private information. We have implemented commercially reasonable and appropriate precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. For example, we protect the personal information that you submit to us through encryption and access controls.
Unfortunately, the transmission of information via the internet is not completely secure. Although we take the steps outlined above to protect your personal information, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk. When using our Service, you should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access and your choices.
You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at the address below.
Managing Cookies and Other Data Technologies
To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, including through the use of advertising industry services that can assist you with managing cookies, visit our Cookie Notice.
Modifying personal information
You may modify personal information that you have provided to us by sending a request to us at the email in the Contact Us section below. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time and in accordance with our data retention policies.
Opting out of email
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.
EU Privacy RightsThis section applies if you are an EU data subject (for these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, where applicable, Switzerland). Peer39 is the data controller for processing personal information that we receive in relation to the Site. As noted in the Collection of personal information section above, we do not process personal information in our Service. PEER39 IS A UNITED STATES COMPANY AND PROCESSES DATA IN THE UNITED STATES. BY ACCESSING OUR SITE OR PROVIDING US WITH YOUR PERSONAL INFORMATION, YOU CONSENT TO THE TRANSFER OF YOUR PERSONAL INFORMATION TO AND OUR PROCESSING OF YOUR PERSONAL INFORMATION IN THE UNITED STATES. We rely on the following legal bases for processing your personal information:
- Processing of your personal information based on your consent, such as when you provide your email address and authorize us to send you marketing information about our products and services or sign up for an account in our Service.
- Processing of your personal information that you provide to us when you request a demo of the Service or when you otherwise send inquiries about our Service and such processing is necessary to respond to or implement your request or to enter into a contract with you for the Service.
- When you apply for employment, including through our Site, processing of your contact details and data about your employment history and education (as needed to evaluate your job application, to conduct job interviews, and as is otherwise needed for recruitment) is necessary to respond to your request to process your application for employment. If you do not provide this data, we will not be able to process the application that you submit.
- We use account-related data to set up accounts for users in the Service and to administer and support those accounts (such as usernames, email address and billing information), provide you with access to the Service, contact you regarding your use of the Service or to notify you of important changes to the Service. Such use is necessary for the performance of the contract between you and Peer39.
- We may send you information by email or through other electronic communications on our new products or services or other promotions even if you have not opted-in to these marketing emails, either because we are relying on an exception to opt-in requirements or because of our legitimate interest to promote the success of our business.
- Our use of data relating to your use of the Site and/or the Service, described above, is necessary for our legitimate interests in understanding how the Site and the Service are being used by you, to improve your experience on it and our Service offerings.
- We also have a legitimate interest in aggregating and/or anonymizing or de-identifying the information that we collect through our Site and/or the Service and using this information for our business purposes, as described above.
- When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal information for activities where our interests are overridden by the impact on you, unless we have your consent for our processing activities or those activities are otherwise required or permitted by law. You have the right to object to processing that is based on our legitimate interests, as further described below.
- Right of access: If you ask us, we will confirm whether we are processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your personal information that we control is inaccurate or incomplete, you are entitled to have it rectified or completed. Note that we may not be able to rectify data obtained from a third party such as a governmental agency or other data that we do not control, and you will need to contact that third party directly. If we have shared your personal information with others, we will tell them about the rectification where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your personal information so that you can contact them directly.
- Right to erasure: You may ask us to delete or remove your personal information and we will do so in some circumstances, such as where we no longer need it (we may not delete your data when other interests outweigh your right to deletion, for example if we are required by law to keep it). If we have shared your data with others, we will tell them about the erasure where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your personal information so that you can contact them directly.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or object to us processing it. We will tell you before we lift any restriction on processing. If we have shared your personal information with others, we will tell them about the restriction where possible. If you ask us, where possible and lawful to do so, we will also tell you with whom we shared your personal information so that you can contact them directly.
- Right to data portability: You have the right to obtain your personal information from us that you consented to give us or that is necessary to perform a contract with you, to the extent it is available. We will give you your personal information in a structured, commonly used and machine-readable format.
- Right to object: You may ask us at any time to stop processing your personal information, and we will do so if we are processing your personal information for the Service, for direct marketing, or otherwise. However, if we are relying on a legitimate interest to process your personal information and we demonstrate compelling legitimate grounds for the processing we may continue; or you may exercise your rights by contacting us as indicated under “Contact Us." Note you will be asked to verify your identity when submitting a request.
- Rights in relation to automated decision-making and profiling: You have the right to be free from decisions that we make based solely on automated processing of your personal information, including profiling, which produce a significant legal effect on you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us, or with your explicit consent.
- Right to withdraw consent: If we rely on your consent to process your personal information, you have the right to withdraw that consent at any time. Your withdrawal of consent will not apply to or affect processing of data that was processed prior to our receipt of your withdrawal of consent.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we have handled your personal information, you can report it to the data protection authority that is authorized to hear those concerns.
California Privacy Rights
Do Not Track Disclosure
Currently, Peer39 does not respond to Do Not Track browser settings.
California Privacy and Data Protection Rights
In the past calendar year, we have not shared personal information of consumers gathered through our Site with third parties for their direct marketing purposes. We share personal information with our service providers to help us operate our business and Site, such as providers of financial, employment, and sales, marketing and website services, but we do not sell personal information to third parties.
The categories of personal information that we collect about consumers is described in the “How We Collect Personal Information” section above. The categories of sources from which we collection personal information is described in the “How We Collect Personal Information” and “Cookies and advertising technologies” sections above. The categories of third parties with whom we share personal information are described in the “Disclosure of Personal information” section above. The business or commercial purpose for collecting personal information is described in the “How we use personal information” section above.
Under California’s state data protection laws, you have certain rights, which include (subject to any exemptions and/or exceptions provided by the law and/or its associated regulations) the right to:
- Request access to your personal information from the preceding 12 months in “a readily usable format” (which you may request up to two times in a given 12-month period).
- Request deletion of your personal information.
- Opt out of the sale of your personal information (but note that we do not sell personal information).
- Not be penalized for the exercise of these rights.
- Make a complaint to a state government supervisory authority.
- Take private legal action in the event of a data breach that exposes your unredacted personal information to theft or unauthorized access.
You need not be physically present in California to exercise these rights provided that you are a resident as defined by CCPA.
You can exercise your California privacy rights by contacting us through one of the methods described in “Contact Us” below. Applicable statutes and/or associated regulations issued by California’s Office of the Attorney General may stipulate the maximum time allowed for acknowledging and responding to a request. There is no charge for making privacy-related requests.
Please note that, in order to better safeguard your privacy and the privacy of others, we may (to the extent permitted — and/or required — by applicable law/regulation) ask you to provide additional information to verify your identity and/or residency before processing any data-related requests.
Peer39 will retain personal information for the period necessary to provide our Service or for the purposes for which it was collected, as otherwise required by our contracts or by law.
When determining how long we should keep data, we consider the length of time we will have a relationship with you or our customers to provide our Service, whether there is a legal obligation that would require us to keep the information for a specified period of time, the reasons why we process your data, the risk of harm from unauthorized use or disclosure of your personal information.
We may also anonymize or de-identify personal information so it would no longer be associated with you for research or analytical purposes. If data is anonymized or de-identified, we may use this data for as long as we have a legitimate business purpose for such use, without additional notice to you.
Policies For Children
Our Site and Service are not directed at children under 13 years of age (or older age under applicable laws that specifically address the collection of personal information from children differently from adults), and we do not knowingly collect or use any personal information from them. No information should be submitted to this Site by children, and children are not allowed to register with our Site or Service.
We invite you to contact us if you have questions about this policy. You may contact us by e-mail at privacy@peer39 or send postal mail to: Peer39, 54 West 21st Street, Suite 904, New York, NY 10010, Attention: Privacy Office.