Privacy Policy

PennyPilot Privacy Policy

Last Revised March 1, 2021

Please read this Privacy Policy carefully before using our website, mobile applications or apps, online content, online services, or other outlets (together, the “Service”) owned and controlled by PennyPilot LLC (“PennyPilot”, “we,” “us,” and “our”).  The terms “you” and “your” means you, your agents and affiliates if any, and any other person accessing your PennyPilot Account.

Thank you for using PennyPilot.  We are strongly committed to safeguarding your privacy and have established this Privacy Policy to inform you how we treat the information you provide to us through our website or in the applications as part the services we offer to you.  We also want to tell you about the other information that we collect on our website and in our applications, and how we treat this information.  We follow this Privacy Policy in accordance with local law in the places where we operate.

If you choose to use our Service, then you agree to the collection and use of information in relation to this Privacy Policy.  The information that we collect is used for providing and improving the Service.  We will not use or share your information with anyone except as described in this Privacy Policy.

This Privacy Policy is incorporated into and subject to the Terms of Use of this Service (“Terms of Use”).  Each time that you access or use the Service, you acknowledge that you have read, understand and agree to be bound by the Terms of Use and this Privacy Policy.  If you do not agree to the Terms of Use and this Privacy Policy, you must discontinue using our Service.

1.       Important Definitions

Personal Information.  We consider some, but not all, of the information you provide us to be your “Personal Information.” We define Personal Information as information about you that is personally identifiable to you, such as your contact information (e.g., name, address, email address, or telephone number) and any other non-public information that is associated with such information (collectively, “Personal Information”).  It does not include information where your identity had been removed, deidentified, or made anonymous.

Financial Information.  Any information that you provide that corresponds to a financial account that we use to process payments.

2.       Types of Information We Collect

The only information we obtain and store about you is information required to properly use the Service.  This includes:

        Information you provide when you register for or modify your PennyPilot account, which may include your first name and surname, email address, username, password, and account membership dates;

        Financial Information that you provide us.  Although you may submit Financial Information for payment in order to use the Services, we do not store or process your Financial information.  All Financial Information is collected and stored through our payment processor, Stripe Inc., and is governed by the terms of their privacy policy. 

        If you submit a request for support, we may collect name, telephone number, e-mail address, and other information that you choose to give us to respond to the support request.  This information will only be used for this purpose.

        Information you provide to us when you use our Service and application, or, if available as an option, link your profile on a third-party Service or platform with your registration account;

        Location information when you visit our Service or use our applications, including location information either provided by a mobile device interacting with one of our Service or applications, or associated with your IP address, where we are permitted by law to process this information; and

        Technical data, including your device identifier or IP address, when you visit our Service, use our applications or open emails we send.

        Any other information you input into the site or related Services.

Our Service and application may provide you with hyperlinks to other sites not owned or controlled by us and we are not responsible for the privacy practices of any site that is not owned or controlled by us. We encourage you to be aware when you leave our site or applications and to read the privacy policies of these other sites.

We process payments to PennyPilot using a secure third-party credit card processing service. PennyPilot does not store or process your payment information.  Your payment information is submitted directly to and stored by our payment’s processor.  We chose our current payment processor in part because of its ability to secure your payment information in compliance with the Payment Card Industry Data Security Standard (“PCI DSS”).  You should familiarize yourself with their privacy and security policies if you have concerns about your payment information.

3.       Use of Cookies

This Service may use cookies to track information for routine administration and maintenance purposes, as well as to improve our website/application and our user experience.  A cookie is a small text file that is generated by a website/application and is stored on your device.  When you access our Service, the next time you visit our site, this information is used to recognize and remember your device.  Cookies

Strictly Necessary Cookies:  The Service uses these cookies for the website to function and cannot be switched off in our systems.  They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.  These cookies do not store any personally identifiable information.

Analytics and Performance Cookies:  The Service may use analytic and performance cookies (through platforms such as Google Analytics) to allow us to optimize performance by collecting information about how you use our Service, such as which pages you visited and which links you accessed, as well as other analytical data.  All of this information is aggregated and therefore anonymous, therefore, none of this information can be used to identify you.  The sole purpose is to improve the website and understand how users interact with the website.

Functional Cookies: The Service may use functional cookies which are essential for our website and Service to perform enhanced functions and personalization.  These include those required to allow registered users to authenticate and perform account-related functions, store information about your preferences such as account name, language and location, and history in order to better serve you.

Advertising Cookies:  The Service may use advertising or marketing cookies to track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad.  They may be used to collect information about your online activities over time and across different websites predict your preferences and to display more relevant advertisements to you.  These cookies also allow a profile to be built about you and your interests and enable personalized ads to be shown to you based on your profile.

Controlling Cookies:  You will see a “cookie banner” on the website or application requesting your consent for many of the cookies and tracking technologies we use.  You may either accept all cookies or customize which cookies you will allow.  Additionally, you can always change your browser settings to control cookie behavior or disable cookies if you have privacy concerns.  Be aware that disabling cookies for websites/applications may interfere with your use of some websites/applications.  For EU residents, you must consent first to the use of cookies before being allowed access to our Service.

PLEASE BE AWARE that our website currently does not recognize or respond to “Do Not Track” signals.

4.       How We Collect Your Information

        We collect all of the information you provide to us through the activities described above.

        We may collect information through technology, such as cookies, including when you visit our site and application or use our applications.

5.       How We Use Your Information

We may use your information to:

        Provide you with the products and services you request;

        Communicate with you about your Account or transactions;

        Improve our products, services and operations;

        Personalize your experience on our site and application;

        Send you information about new PennyPilot features, changes to our policies, or your use of our Service;

        Detect, investigate and prevent activities that may violate our policies or be illegal; and

        Review whether it is responsive to a subpoena or other legal request we have received.

6.       When We Share Your Information

We share Personal Information about you in limited circumstances and with appropriate safeguards on your privacy.  The instances of when we may share your information with other companies include:

        When you direct us to share your Personal Information with third-party sites or platforms;

        To our service providers who provide services such as Web site hosting, maintenance, data analysis, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services and other similar services, but only to the extent necessary or useful to provide such services, and only pursuant to contractual obligations requiring such third parties to maintain the privacy and security of your Personal Information.

        To our third-party vendors when we work with them to market and promote our Service.

        When we identify other companies that offer products or services that we believe will be of interest to PennyPilot users, or when we identify companies that can connect PennyPilot users to products or services that may be of interest to the users, provided that you have opted-in to receive such offers or information; or

        When we share Personal Information with third parties in connection with the sale of a business, to enforce our Terms of Use or rules, to ensure the safety and security of our guests and third parties, to protect our rights and property and the rights and property of our guests and third parties, to comply with legal process or in other cases if we believe in good faith that disclosure is required by law;

        And as otherwise required or permitted by applicable law;

Please note that once we share your Personal Information with another company, the other company’s privacy practices will govern their use of the information.

7.       How Long We Will Store Your Information

We will continue to store and process your information until the earlier of (i) your request that we delete your Personal Information in accordance with the procedures set forth in this privacy policy, (ii) your Personal Information is no longer required to fulfill the identified purpose for which it was collected, or (iii) we decide to delete your Personal Information for reasons such as because your failure to use our Service for a prolonged period of time (as determined in our sole discretion) or another business reason makes it desirable for us to delete your information.

The length of time for which we will retain your Personal Information will depend on the purposes for which we need to retain it.  We may continue to retain your Personal Information to meet any legal requirements or to defend or exercise our legal rights.

8.       How We Secure Your Data

The security of your Personal Information is important to us because we know that the security of your information is important to you. We have implemented reasonable security procedures that are intended to protect your information. From time to time, we review and update our procedures to consider appropriate new security technology and methods.

Please be aware though that no security measures are perfect or impenetrable. If, despite our security measures, your Personal Information has been compromised, we will notify you in accordance with our legal obligations in your jurisdiction.

We operate globally and may transfer your Personal Information to locations around the world. Wherever we control the transfer, storage, or processing of your personal information, we will take reasonable steps to safeguard the privacy of your Personal Information.

You need to help protect the privacy of your own information, including maintaining the confidentiality of any account information or access credentials.  You must take precautions to protect the security of any personally identifiable information that you may transmit over any public or untrusted network by using encryption and other techniques to prevent unauthorized persons from intercepting or receiving any personally identifiable information.  You are responsible for the security of your information when using unencrypted, open access, public or otherwise unsecured networks.

In the event you disclose any of your Personal Information in a public forum, the information in that disclosure will be treated as public, we will not take any steps to protect, secure, or delete that disclosure, and you should not have any expectation of privacy or confidentiality with regards to that disclosure.

9.       How You Control Your Information

You may modify, change, or correct your Personal Information in the same manner in which you originally provided it to us.

If you want to delete your PennyPilot account, we are sorry to lose your business, and we hope that you will give us the opportunity to discuss any issues or concerns that you have had regarding our service. To delete your account, please contact us at admin@pennypilot.com. Once we receive your request, we will then take steps to delete your Personal Information within a commercially reasonable time. We may retain some information for our own backup, archival, record or audit purposes and as otherwise required by law, however, we will only retain the information for those purposes. Please note that we will only be able to delete your Personal Information that is within our control, and we will not be able delete your Personal Information that we had previously shared with others in accordance with this privacy policy.

10.   How We Protect Children’s Privacy

We do not knowingly allow children under the age of 13 to register for PennyPilot, and therefore we do not knowingly collect personal information from children under the age of 13. 

If you believe that we have inadvertently collected personal information from a child under 13, please contact us at admin@pennypilot.com so we can take appropriate steps to delete the child’s personal information. 

We define “personal information from a child under 13” to include (1) a first and last name; (2) a home or other  physical address including street name and name of a city or town; (3) online contact information such as an email address or instant messaging user identifier; (4) a screen or user name; (5) a telephone number; (6) a persistent identifier that can be used to recognize a user over time and across different online services, including an IP address or a unique device identifier; (7) a photograph including the child’s image; or (8) geolocation information sufficient to identify street name and name of a city or town.

11.   Third Party Sites

Our Service may provide you with hyperlinks to other sites not owned or controlled by us and we are not responsible for the privacy practices of any site that is not owned or controlled by us. We do not share Personal Information with those other sites, unless specifically authorized by you. We aim to work with trusted partners and organizations which are also bound by state and federal laws governing privacy and security; however, we encourage users to be aware when you leave our site or mobile application and to review any privacy policy of any third-party site.

12.   How Our Privacy Policy May Be Changed

From time to time, in response to new technologies, industry practices, regulatory requirements, changes in our services, or other circumstances, we may change this Privacy Policy. If these changes are material, we will provide notice to you, and, if we are required by applicable law, we will obtain your consent.  If you choose not to accept the new Privacy Policy, your account may be terminated.

13.   Notice to Non-U.S. Users

This Service is operated in the United States and is intended for users located in the United States and internationally.  If you are located anywhere outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, processed, and stored in the United States.  The data protection laws in the United States may differ from those of the country in which you are located, and your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States.  By using the Service or providing us with any information, you consent to the transfer, processing and storage of your information in the United States.  You are also consenting to the application of United States federal and Illinois state law in all matters concerning the Service and this Policy.

14.   Special Policies for Canadian Resident

In accordance with the obligations under the Personal Information Protection and Electronic Documents Act (“PIPEDA”), we set forth the following additional notices and polices with respect to the residents of Canada who use the Service.

            Your Rights to Your Personal Information

        The right to withdraw your consent (where our processing activity is based on your consent);

        The right to be provided with details about what personal data we hold about you and whether your personal data has been transferred to a third-party, and to be provided with a copy of your personal data;

        The right to stop receiving marketing communication; and

        The right to require us to update any inaccuracies in the personal data we hold.  In order to assist us with this, please keep your account information up to date;

To exercise any of your rights set forth in this section, please contact us at admin@pennypilot.com.  Subject to our authentication of your identity, we will act on your request promptly.  If PennyPilot denies your request, we will advise you of the reason for the refusal.

If you are not satisfied with how we have addressed your complaint or concerns, you can also contact your appropriate data privacy regulator.  If you are located in Canada, your appropriate data privacy regulator may be the Office of the Privacy Commissioner of Canada or a local provincial privacy regulator.

Note: Publicly available information is defined under SOR/2001-7.  This includes information such as any personal information including the name, title, address and telephone number of an individual that appears in a professional or business directory, listing or notice, that is available to the public, where the collection, use and disclosure of the personal information relate directly to the purpose for which the information appears in the directory, listing or notice.  (For full definition see SOR/2001-7).

An organization may collect, use and disclose publicly available Personal Information without the knowledge or consent of the individual.

15.   Special Policies for EU Residents

In accordance with its obligations under the EU General Data Protection Regulation, we set forth the following additional notices and policies with respect to the residents of the EU who use the Service.

            Purposes For Collecting Personal Information

PennyPilot only collects and uses your Personal Information where it has a legal basis to do so, including:

        PennyPilot needs it to provide you the Service, including to provide customer support;

        PennyPilot needs it to satisfy a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our Service and to protect PennyPilot’ legal rights and interests;

        PennyPilot has obtained your specific consent to do so for a specific purpose; or

        PennyPilot needs to process your Personal Information to comply with a legal obligation.

Your Rights To Control Your Information To exercise any of your rights set forth in this section, please contact us at admin@pennypilot.com. Subject to our authentication of your identity, we will act on your request promptly.

Right to Withdraw Consent and Stop Our Use of Your Personal Information If you have consented for PennyPilot to use your Personal Information for a specific purpose or purposes, you may contact us to instruct us that you withdraw your consent that we use your Personal Information for that purpose or those purposes.  Note however, this will not affect any processing or use of your Personal Information that took place before you withdraw your consent.

Right to Access and Port Your Personal Information You may contact us to receive a copy of your Personal Information, which you may then port elsewhere for your purposes.

Right to Correct or Change Your Personal Information If your Personal Information has changed or you discover our records of your Personal Information is otherwise incorrect, you may contact us to change your Personal Information accordingly.

Right to Be Forgotten If you do not wish for PennyPilot to have your Personal Information anymore, you may contact us to instruct us to delete your Personal Information from our records.  We will delete your Personal Information from our database.  Note, however, if you have communicated to us through email or other channels, we may incidentally have portions of your Personal Information within our internal archives of such communications, however, we will not use such Personal Information for any purpose inconsistent with your right to be forgotten or the record-keeping purposes of the archive.  We may also preserve your Personal Information if we are required to do so by law, however, we will not use such Personal Information for any purpose inconsistent with your right to be forgotten or such legal obligation.

Right to Review Decision-Making If you question why you have received a communication or other material from PennyPilot, you may contact us to learn what about your Personal Information led us to send you the communication or other material

16.   Choice of Law

The laws of the State of Illinois shall govern any dispute, including those disputes arising from PennyPilot’s use of Personal Information or otherwise relating to privacy, as specified in the Terms of Use.  This Policy does not create rights enforceable by third-parties.

17.   How You May Contact Us Regarding Your Privacy And This Policy

 

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us at admin@pennypilot.com.