Privacy Policy

Effective May 24, 2019


Privacy Policy

Effective May 24, 2019

Your Privacy Matters

Pangian’s mission is to connect top talent around the world with remote and global employers to empower human creativity and productivity.

 

Pangian is fully committed to be transparent about the data we collect about you, how it is used and with whom it is shared. This Privacy Policy applies when you use our Services (described below). We offer our users choices about the data we collect, use and share as described in this Privacy Policy, Cookie Policy, and Terms and Conditions.

 

Your privacy is important to us and maintaining your trust is our priority.

Pangian, LLC. (“Pangian,” “we,” or “us“), respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit one of the websites listed below, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

The websites covered by this Privacy Policy are: www.pangian.com, chat.pangian.com and our Mobile Applications (collectively, the “Website”).

 

This Privacy Policy applies to data we collect:

  • On this Website.
  • In email, text, and other electronic messages between you and this Website.
  • Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

 

You may have different privacy rights under applicable laws depending on the country you are in when you visit or access our Website.

0. Introduction

We are a professional social network and online platform for professionals and employers around the world. People use our Services to find and be found for job opportunities and to connect with others and share information. Our Privacy Policy applies to any Member or Visitor to our Services.

Our registered users (“Members”) share their professional identities, engage with their network, exchange knowledge and professional insights, post and view relevant content, learn and find career opportunities. Content and data on some of our Services is viewable to non-members (“Visitors”). We use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.

0.1 Services

This Privacy Policy, including our Cookie Policy applies to your use of our Services.

This Privacy Policy applies to Pangian.com, Pangian communities on social media and email communications and all services (“Services”).

0.2 Data Controllers and Contracting Parties

Pangian LLC will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services; you are entering into the User Agreement with Pangian LLC.

 

As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.

0.3 Change

Changes to the Privacy Policy apply to your use of our Services after the “effective date.”

Pangian (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

 

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

1. Data We Collect

Personal Data

As permitted by applicable law in the country from which you access our Website and use our services, we may collect, use, store and transfer different kinds of Personal Data about you. We have grouped these into the following categories of Personal Data:

  • Identity Data such as first name, maiden name, last name, resume/CV, Social Media profile, username or similar identifier.
  • Contact Data such as billing addresses, email addresses and telephone numbers.
  • Financial Data such as payment card details. However, please note that payment methods (e.g., credit card number and/or PayPal and/or bank account details) are not collected by us directly, but by secure payment service providers.
  • Transaction Data such as details about payments to and from you, and details regarding the services that you have subscribed to in relation to this Website.
  • Technical Data such as Device IDs, your login data, access dates and times, browser type and version, device information, cookie data, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Website.
  • Profile Data such as your username and password, orders made by you, preferences, user-generated content, job searches, candidate searches, job applications, feedback and survey responses.
  • Usage Data such as information about how you use our Website, products and services.
  • Marketing and Communications Data such as your preferences in receiving marketing from us and our third-parties and your communication preferences.

Non-Personal Data

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Data but is not considered Personal Data since it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

If You Fail to Provide Personal Data Where Required to Provide Services to You

Where we need to collect Personal Data by law, or under the terms of a contract we have with you, or a prospective contract, and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). If so, we may have to cancel the service you have with us (or have requested from us), and you accept that as a condition of service.

Data That You Should Not Provide to Us

We do not require any Special Categories of Personal Data about you. Accordingly, please do not provide this type of personal data to us.

1.1 Data You Provide To Us

You provide data to create an account with us.

1.1.1 Registration

To create an account you need to provide data including your name, email address and/or mobile number, and a password. If you are an employer, you will need to provide payment (e.g., credit card) and billing information. You create your Pangian profile (a complete profile helps you get the most from our Services).

1.1.2 Profile

You have choices about the information on your profile, such as your education, work experience, skills, photo, languages, country and others. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping employers and Pangian to identify job opportunities for you. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

You give other data to us, such as by syncing your address book or calendar.

1.1.3 Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data), respond to a survey, share your job preferences with our community or submit a resume. If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list).

If you sync your contacts or calendars with our Services, we will collect your address book and calendar meeting information to keep growing your network by suggesting connections for you and others, and by providing information about them, e.g. times, places, attendees and contacts.

You don’t have to post or upload personal data; though if you don’t, it may limit your ability to grow and engage with your network over our Services.

1.2 Data From Others

Others may post or write about you.

1.2.1 Content and News

You and others may post content that includes information about you (as part of articles, posts, comments, videos) on our Services. Unless you opt-out, we collect public information about you, such as professional-related news and accomplishments (e.g., patents granted, professional recognition, conference speakers, projects, etc.) and make it available as part of our Services (e.g. suggestions for your profile, or notifications of mentions in the news).

Others may sync their contacts or calendar with our Services.

1.2.2 Contact and Calendar Information

We receive personal data (including contact information) about you when others import or sync their contacts or calendar with our Services, associate their contacts with Member profiles, or send messages using our Services (including invites or connection requests). If you or others opt-in to sync email accounts with our Services, we will also collect “email header” information that we can associate with Member profiles.

Customers and partners may provide data to us.

1.2.3 Partners

We receive personal data about you when you use the services of our customers and partners, such as employers, prospective employers and applicant tracking systems providing us job application data.

1.2.4 Related Companies and Other Services

We receive data about you when you use some of the other services provided by us or our affiliates, including Udemy.

1.3 Service Use

We log your visits and use of our Services.

We log usage data when you visit or otherwise use our Services, including our sites, communities and platform technology (e.g. email marketing), such as when you view or click on content (e.g., jobs) or our blog content, perform a search, share articles or apply for jobs. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

1.4 Cookies, Web Beacons and Other Similar Technologies

We collect data through cookies and similar technologies.

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. You can control cookies through your browser settings and other tools. You can also opt-out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising.

1.5 Your Device and Location

We receive data from your devices and networks, including location data.

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS or other tools to identify your precise location.

1.6 Messages

If you communicate through our Services, we learn about that.

We collect information about you when you send, receive, or engage with messages in connection with our Services.

1.7 Sites and Services of Others

We get data when you visit sites that include our plugins, ads or cookies or log-in to others’ services with your Pangian account.

We receive information about your visits and interaction with services provided by others when you log-in with Pangian or visit others’ services that include our plugins (such as “Share on Pangian” or “Apply with Pangian”), ads, cookies or similar technologies.

1.8 Other

We are improving our Services, which means we get new data and create new ways to use data.

Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

1.9 How Data Is Collected

We use different methods to collect Personal Data from and about you including, for example:

1.9.1 Direct Interaction

You may give us your identity, contact, billing and other information by filling in forms or by corresponding with us by post, phone, e-mail or otherwise. This includes Personal Data you provide when you:

  • sign-up for a free trial
  • sign-up for a paid subscription
  • create an account on our Website
  • request information to be sent to you
  • submit your CV/resume to our resume database
  • give us some feedback
  • apply to a job posted on our Website
  • authorize Pangian to connect your account to the account of a “Connected Site” (e.g., LinkedIn, Monster, Facebook or Twitter), we may be able to access the information you have provided to the Connected Site, such as content information, timeline feeds, contact and follow lists, network statistics and updates regarding your Connected Site account
1.9.2 Automated Technologies or Interactions.

As you interact with our Website, we may automatically collect Technical Data and Usage Data about your equipment, browsing actions and patterns. We collect this Personal Data and Non-Personal Data by using cookies, server logs and other similar technologies. We may also receive Technical Data and Usage Data about you if you visit other websites employing our cookies and other Tracking Technologies (defined below). For more information regarding our use of Tracking Technologies, please refer to “Cookies and Similar Technologies” below.

1.9.3 Third Parties.

We may receive Personal Data in the form of Technical Data and Usage Data about you from various third-parties such as analytics providers or advertising networks.

2. How We Use Your Data

We use your data to provide, personalize and develop our Services.

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Services (including ads) so that they can be more relevant and useful to you and others.

2.1 Services

Our Services help you connect with employers and others, find and be found for work opportunities, stay informed, get training and be more productive.

We use your data to authorize access to our Services.

2.1.1 Stay Connected

Our Services allow you to stay in touch and up to date with colleagues, partners, clients, and other professional contacts. To do so, you will “connect” with the employers and with the professionals who you choose, and who also wish to “connect” with you. Subject to your settings, when you connect with other Members, you will be able to search each others’ connections in order to exchange professional opportunities.

 

We will use data about you (such as your profile, profiles you have viewed or data provided through address book uploads or partner integrations) to help others find your profile, suggest connections for you and others (e.g. Members who share your contacts or job experiences) and enable you to invite others to become a Member and connect with you. You can also opt-in to allow us to use your precise location or proximity to others for certain tasks (e.g. to suggest other close by Members for you to connect with, notify your connections that you are at a professional event, coworking space or other location).

 

It is your choice whether to invite someone to our Services, send a connection request, or allow another Member to become your connection. When you invite someone to connect with you, your invitation will include your name, photo, network and contact information. We will send invitation reminders to the person you invited. You can choose whether or not to share your own list of connections with your connections. Visitors your account about how we use their data.

2.1.2 Stay Informed

Our Services allow you to stay informed about work opportunities,  news, events and ideas regarding professional topics you care about, and from professionals you respect. Our Services also allow you to improve your professional skills, or learn new ones. We use the data we have about you (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to recommend relevant content and conversations on our Services, suggest skills you may have to add to your profile and skills that you might need to pursue your next opportunity. So, if you let us know that you are interested in a new skill (e.g., by watching a learning video), we will use this information to personalize content in your feed, suggest that you follow certain members on our site, or watch related learning content to help you towards that new skill. We use your content, activity and other data, including your name and picture, to provide notices to your network and others. For example, subject to your account setting we may notify others that you have updated your profile, posted a blog, took a social action, made new connections or were mentioned in the news online.

2.1.3 Career

Our Services allow you to explore remote and travel careers, evaluate educational opportunities, and seek out, and be found for, career opportunities. Your profile can be found by those looking to hire or be hired by you. We will use your data to recommend jobs or training, show you and others who work at a company, in an industry, function or location or have certain skills and connections. You can signal that you are interested in changing jobs and share information with job recruiters. We will use your data to recommend jobs to you and you to recruiters. We may use automated systems to profile and provide recommendations to help make our Services more relevant to our Members, Visitors and customers. Keeping your profile accurate and up-to-date may help you better connect to others and to opportunities through our Services.

 

2.2 Communications

We contact you and enable communications between Members. We will contact you through email, notices posted on our websites and other ways through our Services, including push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time by sending us a message at compliance@pangian.com. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.

We also enable communications between you and others through our Services.

2.3 Advertising

We serve you tailored ads both on and off our Services but you cannot opt-out of seeing other ads. We target (and measure the performance of) ads to Members, Visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

  • Data from advertising technologies on and off our Services, like web beacons, pixels, ad tags, cookies, and device identifiers;
  • Member-provided information (e.g., profile, contact information, title and industry);
  • Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, group participation, page visits, clicking on an ad, etc.), including as described in Section 1.3;
  • Information from advertising partners and publishers
  • Information inferred from data described above (e.g., using job titles from a profile to infer industry, seniority, and compensation bracket; using graduation dates to infer age or using first names or pronoun usage to infer gender).

We will show you ads called “sponsored” which look similar to non-sponsored content, except that they are labeled “ads” or “sponsored.” If you take an action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser. Subject to your account settings if you take a social action on the Pangian Services, that action may be mentioned with related ads.

2.3.1 Ad Choices

We adhere to self-regulatory principles for interest-based advertising and participate in industry opt-outs from such ads. This does not opt you out of receiving advertising; you will continue to get other ads by advertisers not listed with these self regulatory tools. You can also opt-out specifically from our uses of certain categories of data to show you more relevant ads. For Visitors, the setting is here.

2.4 Info to Ad Providers

We do not share your personal data with any third-party advertisers or ad networks for their advertising except for: (i) hashed or device identifiers (to the extent they are personal data in some countries); (ii) with your separate permission (e.g., lead generation form) or (iii) data already visible to any users of the Services (e.g. profile). However, if you view or click on an ad on or off our site or apps, the ad provider will get a signal that someone visited the page that displayed the ad, and they may through the use of mechanisms such as cookies determine it is you. Advertising partners can associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertising partners to obtain your explicit, opt-in consent before doing so.

2.5 Marketing

We promote our Services to you and others.

We use data and content about Members for invitations and communications promoting membership and network growth, engagement and our Services.

2.6 Developing Services and Research

We develop our Services and conduct research.

2.6.1 Service Development

We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect professionals to each other and to economic opportunity.

2.6.2 Other Research

We seek to create economic opportunity for Members of the global workforce and to help them be more productive and successful. We use the personal data available to us to research social, economic and workplace trends such as jobs availability and skills needed for these jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

2.6.3 Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.

2.7 Customer Support

We use data to help you and fix problems.

We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).

2.8 Aggregate Insights

We use data to generate aggregate insights.

We use your data to produce and share aggregated insights that do not identify you. For example, we may use your data to generate statistics about our members, their profession or industry, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or demographic workforce insights.

2.9 Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Members or Visitors.

3. How We Share Information

3.1 Our Services

Any data that you include on your profile and any content you post or social action (e.g. likes, follows, comments, shares) you take on our Services will be seen by others.

3.2 Profile

Your profile is fully visible to all Members and customers of our Services. Subject to your settings, it can also be visible to others on or off of our Services (e.g., Visitors to our Services or users of third- party search engines). Your settings, degree of connection with the viewing Member, the subscriptions they may have, their usage of our Services, access channels and search types (e.g., by name or by keyword) impact the availability of your profile and whether they can view certain fields in your profile.

3.3 Related Services

We share your data across our different Services and Pangian-affiliated entities.

We will share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, Pangian will recommend better content to you based on your Pangian profile or the articles you read on the Pangian Services, and we can personalize your feed or job recommendations based on your learning video history, because we are able to identify you across different Services using cookies or similar technologies.

3.4 Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

3.5 Legal Disclosures

We may need to share your data when we believe it’s required by law or to help protect the rights and safety of you, us or others.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Pangian, our Members, personnel, or others. We attempt to notify Members 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. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

3.6 Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

 

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.

4. Your Choices & Obligations

4.1 Data Retention

We keep most of your personal data for as long as your account is open.

We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when looking for a new job every few years, we will retain your information and keep your profile open until you decide to close your account. In some cases we choose to retain certain information in a depersonalized or aggregated form.

4.2 Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile. We offer you settings to control and manage the personal data we have about you. Contact us at compliance@pangian.com with any questions.

For personal data that we have about you:

  • 4.2.1 Delete Data
    • You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
  • 4.2.2 Change or Correct Data
    • You can edit some of your personal data PII through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
  • 4.2.3 Object to, or Limit or Restrict, Use of Data
    • You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
  • 4.2.4 Right to Access and/or Take Your Data
    • You can ask us for a copy of your personal data and can ask for a copy of the personal data you provided in machine readable form.

You may also contact us at compliance@pangian.com using the contact information below, and we will consider your request in accordance with applicable laws.

4.3 Account Closure

We keep some of your data even after you close your account.

 

If you choose to close your Pangian account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

 

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

 

Information you have shared with others  will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

5 Where Your Data Is Transferred

Pangian Inc. is headquartered in the United States of America (USA). The information that you provide or that we collect as a result of your interaction with the Website and/or your use of our services on the Website is transferred to the USA and/or to another country where we have a subsidiary or where we have engaged service providers. Some countries that are not located within the EU may be recognized by the European Commission as providing an adequate level of data protection.

 

5.1. Cross-Border Data Transfers

We store and use your data outside your country.

We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders.

6 Your Data Subject Access Rights (for data subjects in the EEA)

Data subjects in the EEA have the following rights with respect to their Personal Data:

YOUR RIGHTS WHAT YOU CAN REQUEST
Right to Information The right to know what Personal Data we hold about you and how we use it.
Right to Access The right to be provided with a copy of your Personal Data (subject to certain restrictions).
Right of Rectification The right to require us to correct any incomplete or inaccurate Personal Data we hold about you, though we may need to verify the accuracy of the new data you provide to us. If you have a user account with us, you also have the option of correcting your information directly in your account.
Right to erasure/be forgotten This enables you to ask us to delete or remove Personal Data where there is no good reason for us to continue to process it. Note, however, that we may not always be able to comply with your request for erasure and in such circumstances, will notify our reasons to you.
Right to restrict processing The right to require us to restrict processing of your Personal Data, i.e., you can request that we suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to request data portability In certain circumstances, you have the right to request the transfer of your Personal Data to you or to a third party in a commonly used machine-readable format. Note, however, that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to object to processing You have the right to object to the processing of your Personal Data in the following circumstances: (i) at any time to your Personal Data being processed for direct marketing (including profiling); or (ii) in certain other situations, to our continued processing of your Personal Data, e.g., our processing of your Personal Data when such processing is based on our legitimate interests. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to withdraw consent at any time You have the right to withdraw your consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Right not to be subject to a decision based solely on automated decision-making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. However, your right does not apply if: (i) you gave us your explicit consent to use your personal data to make our decision; (ii) we are allowed by law to make our decision; or (iii) our automated decision was necessary to enable us to enter into a contract with you.

California residents may have additional personal information rights and choices. Please see section 7 California Privacy Rights for more information.

 

6.1 Method for Requesting Information Pursuant to Your Rights

Upon request, Pangian will provide you with information about whether we hold any of your personal information. If you would like to exercise any of the data subject access rights in the table above (each, an “Access Request”) please send an email to compliance@pangian.com, and we will send you a Data Subject Access Request Form. We will respond to your request within a reasonable time frame.

 

6.2 No Fee Usually Required

You will not usually be required to pay a fee to access your Personal Data (or to exercise any of the other rights).  However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

6.3 What We May Need from You

Once we receive your Access Request, we may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

If we are not clear as to what you are requesting, we may also need to contact you for clarification so we can more fully respond to your request.

If we cannot locate any records about you, we may also ask you for additional information to assist us in locating records, if they exist.

 

6.4 Time Limit to Respond

We try to respond to all legitimate requests within one month.  Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

7 California Privacy Rights

California residents have the right to request certain information regarding our disclosure of personal information (as defined by the California Shine the Light Act) STL to third parties for their direct marketing purposes unless we provide them with an ability to exercise choice regarding such disclosures. We comply with this law by providing California residents with the ability to opt-out of, or prospectively withdraw their consent, if they have previously opted-in to, the disclosure of personal information to third parties for their direct marketing purposes.  If you are a California resident, to receive confirmation of how we comply with this law, or to make a request or to opt out at any time, please contact us at compliance@pangian.com or mail us at the address provided in Section 5.5 Contact Information.  Any request must include “California Privacy Rights Request” in the first line of the description and must include the requestor’s name, street address, city, state, and ZIP code.

8 Minors and Children

Our Services and the Website are not intended for use by persons under the age of 18 years.  Pangian does not knowingly collect or solicit Personal Data from anyone under the age of 13 or knowingly allow such persons to register to use our Website.  In the event that we learn that we have collected Personal Data of a child under the age of 13, we will delete that data to the extent required by applicable law as quickly as possible. If you believe that we might have any Personal Data from or about a child under 13, please contact us at compliance@pangian.com.

 

9. Other Important Information

9.1 Security

We use appropriate technical and organizational measures to protect Personal Data we process about you.

 

However, no transmission of information via the Internet or wireless network can be guaranteed to be 100% secure.  As a result, while we strive to protect your Personal Data, you acknowledge that there are security and privacy limitations of the Internet which are beyond our control and accordingly, the security, integrity and privacy of data exchanged between you and us through the Website cannot be guaranteed.

 

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

The safety and security of your Personal Data also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential.  We ask you not to share your login or account credentials with anyone and keep your account information secure. We urge you to be careful about giving out information in public areas of the Website like message boards, where information will be available to other users of the Website.  If you believe that your access credentials or Personal Data have been compromised, please contact us immediately.

 

9.2 Lawful Bases for Processing

We have lawful bases to collect, use and share data about you. You have choices about our use of your data.

 

At any time, you can withdraw consent you have provided by going to settings.

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Pangian Services you have requested)) and “legitimate interests”.

 

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at compliance@pangian.com

9.3 Direct Marketing and Do Not Track Signals

Our statements regarding direct marketing and “do not track” signals.

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

9.4 Links to third party websites and social media features

Our Website may from time to time, contain links to third-party services such as websites, locations, platforms, applications or services operated by third parties. If you follow a link to or otherwise access any of these third-party services, these third-party services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit Personal Data from you.  Please note that these third-party services have their own privacy policies and we do not accept any responsibility or liability for these parties’ policies or practices. Please check these policies before you share any Personal Data with these third-party services.

 

We may offer you the opportunity to use your social media login when interacting with our Website. If you do so, please be aware that you may be sharing your profile information with us.  The personal data that is shared will depend on your social media platform settings. Please visit the relevant social media platform and review its privacy policy to understand how your personal data is shared and used in this context.

Social media features may also collect your IP address, which page you are visiting on our Website, and may set a cookie or other Tracking Technologies to enable the applicable social media feature to function properly.  Your interactions with these features are governed by the privacy policy of the company providing such features.

The Website may include tools provided by us or third-party services that enable you to send a message to another person.  If you use any such tools, please ensure that you only send messages to persons to whom you have permission to send messages.  Absent the recipient’s consent, we will only use their Personal Data that you provide us to facilitate such messages.

9.5 Public Forums

You should be aware that when you voluntarily disclose any Personal Data in a public forum on the Website, this information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control and this Privacy Policy does not apply to such information. You accept that you, and not Pangian, are responsible for providing such information in any public forum. Any submissions to public areas on the Website are accepted by you with the understanding that such forums are accessible to all third parties. If you do not want your comments or any content to be viewed by third parties, you are advised not to make any submissions. Please be careful and responsible whenever you’re online.

 

9.6 Invitation Service

If you choose to use our invitation service to invite a friend to our Services, we provide you with a link to copy and paste to share with your friends, or spread the word on Linkedin, Facebook or Twitter. We provide you with a unique link ID so that you earn credit for each friend that joins the site by following your link. Your friend may contact us to request that we remove this information from our database at compliance@pangian.com.

If you wish to invite a friend to view our blog posts, we will ask you for that person’s email address and automatically send an email invitation. Pangian stores this information to send this email, to register your friend if your invitation is accepted, and to track the success of our invitation service. Your friend may contact us to request that we remove this information from our database at compliance@pangian.com.

 

10 Questions or Complaints

10.1 Data Subjects Located Outside the European Economic Area and Switzerland

If you have a complaint, or if you have questions or requests regarding your Personal Data, please email us at compliance@pangian.com, and specify the country in which you are located.

10.2 Data Subjects Located within the European Economic Area & Switzerland

If you have a complaint, or if you have questions or requests regarding your Personal Data, please email us at compliance@pangian.com, and specify the country in which you are located. If we are not able to address your concern and you are a resident of the EU, you have the right to lodge a complaint with the Data Protection Authority where you are located or where the issue took place. For contact details of your local Data Protection Authority, please see www.ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm. Contact information for the Information Commissioner’s Office (ICO), which is the supervisory authority in the UK can be found at https://ico.org.uk/make-a-complaint.

11 Changes to this privacy policy

We reserve the right to change this Privacy Policy at any time. If we propose to make any material changes, we will notify you by posting notice on the Website or by issuing an email to the email address listed by registered users prior to the changes becoming effective. You acknowledge that it is your responsibility to maintain a valid email address as a registered user, and to review the Website and this Privacy Policy periodically in order to be aware of any modifications. If you object to any changes to the revised Privacy Policy, you can stop using our services and close your account with us. However, if you continue to use our services (including the Website) after we publish a new or updated Privacy Policy, you acknowledge that such continued use means that the treatment of your Personal Data will be subject to the new or updated Privacy Policy.

12 How to contact us

Data Privacy Questions. If you have any questions regarding our personal data practices, please contact us by using the communication means described below.

12.1 Contact Information

You can contact us or use other options to resolve any complaints.

If you have questions or complaints regarding this Policy, please first us at compliance@pangian.com or our physical address 101 S Garland Ave Ste#108, Orlando, FL 32824, USA.