Last Updated: 2021-04-06

1.0 Introduction

Pelcro is a membership and subscription management platform.

Pelcro Inc. provides membership and subscription management software services for web and mobile applications, including identity, billing, authorization and machine learning features.

We take your privacy seriously and commit to communicating with you transparently. We keep your personal information private and we will not sell or rent your personal information to anyone.

For more information about our services, please refer to our website:

https://www.pelcro.com/

This Privacy Policy is applicable to Pelcro, its subsidiaries and affiliated companies (“Pelcro”, “we”, “our” or “us”) as related to our services, which collectively include:

• the use of https://www.pelcro.com/ (“Website”),

• the use of the subscription management application https://www.pelcro.com/en/login (“Application”),

• the use of our products, services and integrations (“Services”).

This Privacy Policy sets out the essential details relating to your personal data relationships with Pelcro as:

• Website visitors, including job applicants and partners

• Prospective customers

• Customers (their employees and other authorized parties), and

• End-users of the Customer (“End User”)

Customers contract the use of our Application as follows:

• Customer contracts with Pelcro to get access to the Pelcro Application and Services, giving access to their employees, admins and other third parties, as solely decided by them, by creating collaborators who access their Customer accounts in the Application with their credentials, which can result in different permissions and access rights to the information held in the Customer account.

• End Users of the Customers will not have direct access to the Pelcro Application; End Users may only see the“Powered by Pelcro” in the End User interface.

2.0 Personal information we collect

2.1 Information you choose to provide to us

WHEN

We may ask you to provide personal information when:

As a Website visitor and prospective customer:

• You use the Website to download articles, data sheets or eBooks

• You request a free trial or demo

• You participate in a marketing/sales promotion

• You attend trade events and other industry networking events

• You register or attend a webinar or other event

• You participate in programs we may offer from time to time

• You participate in chats and other direct interactions with us

As a Customer and End User

• You connect with us directly via phone calls, chats, video conferencing platforms or in any other way

• We or Customer account administrators on behalf of our Customers grant you access to the Application

• You or Customer account administrators upload or enter personal information into the Application

• You participate in a marketing/sales promotion

• You participate in programs we may offer from time to time

• You subscribe to our Application

If you choose to provide us with a third party’s Personal Information (the person’s name, email and company) when taking part in our referral program, you represent that you have the third party’s permission to do so.

WHAT

The personal information we collect may include the following categories:

As a Website visitor and prospective customer:

• first and last name, business email address, phone number, company name and business address.

As a Job Applicant, we may also collect your resume and cover letter.

As a Customer and an employee of the Customer using the application:

• first and last name, business email address, phone number and company name.

As an End User of the Customer, depending on how the Customer uses the Application, we may receive information directly from you, the Customer or third-parties:

• first and last name, email address,, last 4 digits of payment cards, phone number and address.

2.2 Information we collect automatically

WHEN

We collect information about your visits to the Website and the Application when you land on any of our web pages through cookies and similar tracking technology.

For further information about the types of Cookies we use, you can access our Cookie policy at this link.

WHAT

The information collected includes:

• access times

• subscriptions

• the pages you view

• the links you click on

• the search terms you enter

• actions you take in connection with any of the visited pages

• your device information such as IP address, location, browser type and language

• the Uniform Resource Locator (URL) of the website that referred you to our website and

• the URL you browse away from our pages if you click on an external link

We may also collect information when you open email messages from us or click on links within those email messages.

2.3 Information we may collect from third parties

WHEN

We may combine the information we collect as a result of your direct interactions with us with information obtained through other third-party sources. We also obtain and/or purchase lists from third parties about individuals and companies interested in our products.

We offer functionality to allow our Customer’s End Users to give a subscription to a specific Customer service, as a gift to another individual. In this situation, the donor enters the name and email address of the gift recipient. The donor is responsible for the recipient’s approval for the use of his/her personal information.

WHAT

The personal information collected includes your name, email address, business address, job title, company name, and telephone number.

HOW TO GIVE OR WITHDRAW YOUR CONSENT

When you submit or upload any personal information to our Application, you impliedly consent to providing that information to us.

We treat all personal information as described in this Privacy Policy.

You may withdraw your consent at any time, subject to contractual terms that you may have entered into with Pelcro. To do so please contact us at [email protected]. Following your withdrawal of consent. we may not be able to provide any Services to you or the same level of Services as previously provided.

3.0 How we use personal information

We use your Personal Information to:

• Deliver the contracted Services and allow full use of the Application functionality as purchased by the Customers

• Deliver training and support to our Application and/or carry out the transactions you have requested

• To communicate with you directly through emails, calls, chats, video conferencing

• Process payments for Application subscriptions

• Send communications to you about:

• new Application features and upgrades

• our services and offerings

• event announcements

• product notices and changes to our terms and policies

• particular programs in which you have chosen to participate

• promotional offers and surveys

• scheduling demos and managing free trials

• Advertise and market our products and services, including delivering interest-based advertisements on this Website and other sites or content syndication platforms and websites.

• Carry out market research to understand how to improve our Services and their delivery

• Create and manage marketing campaigns

• Generate sales leads and increase our market share

• Analyze user clicks and usage of the Application and Website to improve user experience and maximize usage of our Services

• Manage our Website and Application in order to maintain and deliver the contracted functionality and services,

• Enforce our Website and Application Service Terms and/or separate contracts (if applicable) with you

• Prevent fraud and other prohibited or illegal activities

• Protect the security or integrity of the Website, Application, our business or Services; or

• Otherwise, as disclosed to you at the point of collection or as required or permitted by law.

Please note that sometimes we may record the video conferencing call in which you participate in order to analyze and improve our staff’s product knowledge and communication skills. If we do so, we will be announcing it at the beginning of the conference call as well as in the meeting invite and we will be providing a link to our Privacy Policy in the meeting invites and on the registration page.

We do not sell your information to any third party.

4.0 How we share personal information

Our Application and Services

If you are the employee of any of our Customers and an End User of our Application, your personal information may be viewed by other users with access to the Application as permitted by their roles within the Application.

Service Providers

We use third parties to help us provide our Services. They will have access to your information as collected by the Website or the Application, as reasonably necessary to perform the contracted tasks on our behalf. We sign contractual agreements to obligate them to protect the personal information, to only use it to deliver the contracted services to us, to prohibit them from selling it and not to disclose it without our knowledge and permission.

The following third-party services transparency report gives you an overview of which external services we use, how and why: https://www.pelcro.com/legal/sub-processors .

Integrations

The Application provides a number of integrations as well as functionality allowing Customers to enable any other integrations as desired. See more information at https://docs.pelcro.com/docs.

Personal information may be transferred to the vendors of these integrations to allow the integrations to function properly.

The Customers are solely responsible to ensure they comply with all applicable privacy laws when transferring personal information to the vendors of these integrations.

Legal disclosures

It is possible that we may need to disclose personal information when required by law, subpoena, or other legal processes as identified in the applicable legislation.

We attempt to notify our Customers about legal demands for their personal data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency.

Change in Control

We can also share your personal data as part of a sale, merger or change in control or in preparation for any of these events.

Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

5.0 How we secure personal information

The personal data collected from Customers is held on servers in the USA.

The personal data collected from website visitors, prospective customer and job applicants is stored in Europe and the USA.

We take all reasonable steps to protect information we receive from you from loss, misuse, or unauthorized access, disclosure, alteration and/or destruction. We use a variety of physical, administrative and technical safeguards designed to help protect it from unauthorized access, use and disclosure. We have implemented best-practice standards and controls in compliance with internationally recognized security frameworks. We use encryption technologies to protect data.

6.0 Your rights

We provide the same suite of Services to all of the individuals with whom we interact, including Customers and End-Users within North America, Europe, and Australia.

We have adopted the most comprehensive Privacy guidelines to provide the following rights to all individuals regardless of their location or applicable privacy regulations.

For personal information we have about you, you can:

• Access your personal information or request a copy.

You have the right to obtain information about what personal information we process about you or to obtain a copy of your personal information.

If you have provided personal information to us, you may contact us to obtain an outline of what information we have about you or a copy of the information.

If you are an End User of the Application, you can log in to see the personal information in the account or approach your employer for more information.

• You have the right to be notified of what personal information we collect about you and how we use it, disclose it and protect it.

This Privacy Policy describes what personal information we collect and our privacy practices. We may also have additional privacy notices and statements available to you at the point of providing information to us directly.

• Change or correct or rectify your personal information.

You have the right to update/correct/rectify your personal information or ask us to do it on your behalf.

You can edit your information through the user account in the Application or ask us to change or correct it by contacting us at [email protected].

• Delete or erase your personal information.

You have the right to request deletion of your personal information at any time. We will communicate back to you within reasonable timelines the result of your request. We may not be able to delete or erase your personal information, but we will inform you of these reasons and any further actions available to you.

• Object to the processing of your personal information

You have the right to object to our processing of your personal information for direct marketing purposes. This means that we will stop using your personal information for these purposes.

• Ask us to restrict the processing of your personal information

You have the right to ask us to limit the way that we use your personal information.

• Export your personal data

You have the right to request that we export to you in a machine-readable format all of the personal information we have about you.

• Lodge a complaint

You have the right to lodge a complaint with the local organizations in charge with enforcing the privacy legislation applicable in your territory.

For EU based individuals, see this link https://edpb.europa.eu/about-edpb/board/members_en

For UK based individuals, see this link https://ico.org.uk/global/contact-us/

For Canada based individuals https://www.priv.gc.ca/en/contact-the-opc/ and https://www.cai.gouv.qc.ca/english/

We do not process personal information through the use of automated means.

If you would like to exercise any of the rights described above, please contact us at [email protected].

7.0 How long we keep your personal information

We retain information as long as it is necessary to provide the Services to you and our Customers, subject to any legal obligations to further retain such information.

We may also retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Service and take other actions permitted by law.

The information we retain will be handled in accordance with this Privacy Policy.

Information connected to you that is no longer necessary and relevant to provide our Services may be de-identified or aggregated with other non-personal data to provide insights which are commercially valuable to Pelcro, such as statistics of the use of the Services.

8.0 Other Important Information

We process data in North America and Europe and rely on legally-provided mechanisms to lawfully transfer data across borders, such as contracts incorporating data protection and sharing obligations.

We will only collect and process personal data about you where we have a lawful reason for its collection.

When you visit our Website and provide us with your personal information, we collect and use it with your consent.

As an Application End User, you consent to our collection of your personal information when you log in for the first time. However, your employer has control of the account and may upload and share additional personal information. It is your employer’s responsibility to ensure the collection, use, and sharing of the personal information uploaded to the Application complies with all applicable legislation.

You can review the terms and conditions of use here: https://www.pelcro.com/en/legal/terms

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at [email protected] .

How to select your communications preferences

You may choose to receive or not receive marketing communications from us. To stop receiving marketing communications, please click the “Unsubscribe” link in the email we sent you.

You may choose which information we collect automatically from your device by controlling cookie settings on your browser or by selecting your preferences through our Cookie Policy.

Even if you opt-out of receiving marketing communications, we may still communicate with you in connection with security and privacy issues, servicing your account, fulfilling your requests, or administering any promotion or any program in which you may have elected to participate.

9.0 Contact Information

You may contact us to exercise any of your rights or ask for more information about your personal information and our privacy practices by contacting us at [email protected].

10.0 Data Protection Representative

We have appointed Prighter (Maetzler Rechtsanwalts GmbH & Co KG) as the representative in the EU for data protection matters for Pelcro. You may contact Prighter on matters related to our processing of Personal Data in the EEA using this contact form: https://prighter.com/contactus . Alternatively, you may contact Prighter using the below contact details:

Maetzler Rechtsanwalts GmbH & Co KG

Schellinggasse 3

1010 Vienna

AUSTRIA

Tel.: +43 1 9974124

Email: [email protected]

We have appointed Prighter (Prighter Ltd) as the representative in the UK for data protection matters for Pelcro. You may contact Prighter on matters related to our processing of Personal Data in the UK using this contact form: https://prighter.com/contactus . Alternatively, you may contact Prighter using the below contact details:

Prighter Ltd (UK)

20 Mortlake Mortlake High Street

London SW14 8JN

UNITED KINGDOM

Tel.: +43 1 9974124

Email:

[email protected]

Appendix

A.1 For individuals based in European Union (EU), European Economic Area (EEA) and Switzerland.

If you are based in one of these jurisdictions, Pelcro is the controller of your personal data collected in the following instances:

• When you visit our Website https://www.pelcro.com/

• When we process your personal data for sales and marketing purposes

Pelcro is a processor of all personal data processed on the Application, on behalf of our Customers. We only process the personal data under their direction. Please contact your employer or the organization that granted you access to the Application for details on their privacy practices.

We only process personal data if we have a lawful basis for doing so. The lawful bases applicable to our processing as controller are:

• Legitimate interest - We process the names, contact details, job titles, companies of our existing and prospective customers for our marketing purposes, including market research and sales leads generation.

You have the following rights under the GDPR:

• Be informed about the collection and use of your personal data

• Access your personal data

• Correct errors in your personal data

• Erase your personal data

• Object to the processing of your personal data.

• This right is also available to individuals whose personal data is processed by us for direct marketing purposes. If you object to the processing of your personal data for direct marketing purposes, we shall stop processing within 30 days of receipt of your request.

• Export your personal data

• Restrict our processing of your personal data for specific reasons, including any of the purposes supported by the legitimate interest legal bases. (see the section above).

We process personal data in Germany and US and share it with our service providers, located in Germany, US and other jurisdictions. We use standard contractual clauses as the data transfer mechanism of transferring EU data to countries subject to data transfer requirements. See more information on our service providers here .

You may contact us and reach our EU Data Representative here.

You may also lodge a complaint with your local supervisory authority, EU Data Protection Authorities (DPAs) or Swiss Federal Data Protection and Information Commissioner (FDPIC).

A.2 For individuals based in California

This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (“CCPA”).

We are Service providers under the CCPA, we process the Personal information of consumers as solely directed by our customers. We do not sell Personal information.