This policy defines the commitment of the Pivotal Perspectives^®  platform to protect the privacy of Personal Information that is collected or used in the course of conducting Pivotal Perspectives^®  business. On a global basis, the Pivotal Perspectives^®  platform will, and will cause its affiliates to, establish and maintain business procedures that are consistent with this policy. The Pivotal Perspectives^®  platform adheres to the Insights Association Organization’s (formerly CASRO) Code and the European Union law requirements on personal information, as set forth in the Safe Harbor Principles regarding the transfer, collection, use or disclosure of personal information of European citizens.

The Pivotal Perspectives^®  platform will respect the legal requirements that exist regarding the privacy of Personal Information and is committed to complying with all applicable law. The Pivotal Perspectives^®  platform will, from time to time, review its Personal Information collection, use, and disclosure practices in order to assure compliance with laws and regulations.

The Pivotal Perspectives^®  platform will give notice when Personal Information is collected. All notices will explain the need for the information and describe how the information will be used. Personal Information will not be used to directly market any products or services to identifiable persons unless that possibility has been disclosed in advance and the opportunity not to participate has been given.

The Pivotal Perspectives^®  platform seeks to ensure that any personal information held about EU individuals is accurate, complete, current and otherwise reliable in relation to the purposes for which the information was obtained. The Pivotal Perspectives^®  platform collects personal information that is adequate, relevant and not excessive for the purposes for which it is to be processed. EU individuals have a responsibility to assist the Pivotal Perspectives^®  platform in maintaining accurate, complete and current personal information about them.

The Pivotal Perspectives^®  platform will maintain procedures to assure that information about children or other categories of sensitive information is only collected with explicit consent and is protected against improper use, consistent with applicable law.

The Pivotal Perspectives^®  platform will collect and use Personal Information consistently with the notices that have been provided. However, the Pivotal Perspectives ^® platform may decide to remove identifiable features from collected Personal Information and the resulting information may then be used for statistical, historic, scientific or other purposes, consistent with applicable law.

We provide access and a method of correcting data.

The Pivotal Perspectives^®  platform will grant individuals reasonable access to personal information that it holds about them. The Pivotal Perspectives platform will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

The Pivotal Perspectives^®  platform will maintain the security of Personal Information, and protect the integrity of such information, with a commercially reasonable degree of care.

The Pivotal Perspectives ^® platform will require others who acquire or provide Personal Information from or to the Pivotal Perspectives^®  platform , including those engaged to provide support services, at a minimum, to adopt and comply with the principles and objectives of this policy.

The Pivotal Perspectives^®  platform utilizes the self-assessment approach to assure its compliance with our privacy statement. Pivotal Perspectives^®  periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Safe Harbor Principles. In addition to the Pivotal Perspectives^®  platform internal Privacy Compliance Officer, the Insights Association, of which the Pivotal Perspectives^®  platform is a member, provides dispute resolution to enforce this privacy policy.

The Pivotal Perspectives^®  platform will, under certain circumstances permitted or required by law or court order, collect, use, and/or disclose Personal Information pursuant to procedures that do not require giving notice or conducting related activities (for example, in connection with law enforcement investigations).

The Pivotal Perspectives^®  platform will, and reserves the right to, modify and update this policy or its related business practices at any time. The Pivotal Perspectives^®  platform will NOT apply changes to this policy retroactively to information the Pivotal Perspectives^®  platform has previously collected.

If you are concerned about our use of your Personal Information, please contact us at team@pivotpointresearch.com with the subject line, “privacy” and you may also contact the Insights Association at inquiries@insightsassociation.org.