Effective date: June 2020
- Personal Data
- How We Share Your Personal Data
- Tracking Tools, Advertising and Opt-Out
- Data Security and Retention
- Personal Data of Children
- Privacy Shield
- California Resident Rights
- Other State Law Privacy Rights
- European Union Data Subject Rights
- Contact Information
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
|Category of Personal Data||Examples of Personal Data We Collect||Categories of Third Parties With Whom We Share this Personal Data:|
|Profile or Contact Data||
|Social Network Data||
|Professional or Employment-Related Data||
|Inferences Drawn From Other Personal Data Collected||
|Other Identifying Information that You Voluntarily Choose to Provide||
Categories of Sources of Personal Data
We collect Personal Data about you from the following sources:
- When you provide such information directly to us.
- When you create an account or use our interactive tools and Services.
- When you provide information in free-form text boxes or respond to surveys.
- When you contact us.
- When you use the Services and such information is collected automatically.
- Through Cookies (see “Tracking Tools, Advertising and Opt-Out” below).
- If you use a location-enabled browser, we may receive information about your location and device.
- If you access certain applications and software we make available, we may receive and collect information transmitted from your device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
- When you provide such information directly to us.
- Public Records
- Third Parties
- We may use analytics providers to analyze how you engage with the Services.
- Third parties may help us provide you with customer support.
- We may use vendors to obtain information to generate leads and create user profiles.
- Advertising Partners
- We receive information about you from vendors who assist us with marketing or promotional services including how you interact with our websites, applications, products, Services, advertisements or communications.
Our Commercial or Business Purposes for Collecting Personal Data
- Providing, Customizing and Improving the Services
- Creating and managing your account or other user profiles.
- Processing orders or other transactions; billing.
- Providing you with the products, services or information you request, including support and assistance for the Services.
- Improving the Services, including testing, research, internal analytics and product development.
- Personalizing the Services, website and communications based on your preferences.
- Performing fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
- Marketing the Services
- Marketing and selling the Services.
- Showing you advertisements, including interest-based or online behavioral advertising.
- Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Pendo or the Services.
- Sending emails and other communications according to your preferences or that display content that we think will interest you.
- Meeting Legal Requirements and Enforcing Legal Terms
- Fulfilling our legal obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
- Protecting the rights, property or safety of you, Pendo or another party.
- Enforcing agreements with you and resolving disputes.
- Responding to claims that any posting or other content violates third-party rights.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
- Service Providers who help us provide the Services or perform business functions:
- Hosting, technology and communication providers.
- Security and fraud prevention consultants and providers.
- Analytics providers.
- Support and customer service vendors.
- Product fulfillment and delivery providers.
- Employee and recruiting services providers.
- Payment processors.
- Advertising Partners who help us market our services:
- Ad networks.
- Data brokers.
- Marketing providers.
- Business Partners who partner with us in offering various services:
- Businesses that you have a relationship with.
- Companies that we partner with to offer joint promotional offers or opportunities.
- Parties You Authorize, Access or Authenticate
- Third parties you access through the services.
- Social media services.
- Other users.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
Tracking Tools, Advertising and Opt-Out
We use the following types of Cookies:
- Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
- Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Retargeting/Advertising Cookies. Retargeting/Advertising Cookies collect data about your online activity and identify your interests so that we can provide advertising that we believe is relevant to you. For more information about this, please see the section below titled “Information about Interest-Based Advertisements.”
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Information about Interest-Based Advertisements:
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users on the Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Services. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
To the extent applicable to Pendo, we or our third party providers comply with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based a consumer’s online behavior across different websites and properties. To make choices about Interest-Based Ads from participating third parties, including to opt-out of receiving behaviorally targeted advertisements from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website http://www.youronlinechoices.eu/.
Data Security and Retention
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you with our Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
Personal Data of Children
We do not knowingly collect or solicit Personal Data about children under 16; if you are under 16, please do not attempt to register for or use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided Personal Data to us, please contact us at [email protected]
Pendo remains responsible for any of your Personal Data that is shared under the onward transfer principle with third parties for external processing on our behalf, as described in the “How We Share Your Personal Data” section. In compliance with the Principles, Pendo commits to resolve complaints about our collection or use of your personal information. If you are a resident of the European Union or Switzerland with inquiries or complaints regarding your personal data within the scope of Privacy Shield, you should contact Pendo’s Data Protection/Compliance Officer at [email protected] Under Privacy Shield, organizations must respond to individuals within 45 days of receiving a complaint. Pendo will endeavor to respond to your inquiry promptly.
If we are unable to resolve any complaint related to Privacy Shield or if we fail to acknowledge your complaint in a timely fashion you may refer a complaint to your local data protection authority. Pendo has committed to cooperate with the panel established by the EU data protection authorities and the United States Council for International Business (USCIB) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU or Switzerland. We will work with them to address complaints and provide appropriate recourse free of charge to you. In certain circumstances, Privacy Shield provides the right to invoke binding arbitration to resolve complaints not resolved by other means, as described in Annex I to the Principles. Pendo has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
Pendo’s Privacy Shield compliance is subject to the investigatory and enforcement powers of the Federal Trade Commission. We may be required to disclose Personal Data that we handle under the Privacy Shield in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at [email protected]
Nevada Resident Rights
Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
- [email protected]
- 150 Fayetteville St., Raleigh, NC 27601, USA
If you are located in the European Union, you may use the following information to contact our Data Protection Officer and our European Union-Based Member Representative:
- Data Protection Officer: Kate Helin
- European Union-Based Member Representative: