Who We Are
What This Policy Covers
How This Policy Applies
How We Collect Your Personal Information
Types of Personal Information We Collect
How We Use Your Personal Information
Lawful Basis For Processing (for users in the European Economic Area “EEA”)
Retaining Personal Information
Who We Are
The Pendolino Group is an international strategic, business-centric HR consultancy – committed to increasing human resourcefulness, inspired performance, real business results, and positive workplace culture.
This Policy gives effect to our commitment to protect your personal information. References to “Pendolino Group”, “we” “us” and “our” throughout this Policy, depending upon the context, collectively refer to our legal entity.
What This Policy Covers
This Policy applies to personal information that we obtain about our customers and the other individuals with whom we do business and to the use of that personal information in any form – whether oral, electronic or written, all in accordance with applicable global data privacy laws. The term “personal information” in this Policy refers to information that does identify or is capable of identifying you as an individual. This Policy applies to all the products, services, websites and apps offered by The Pendolino Group (“Services”).
How This Policy Applies
This Policy describes the information we collect from you, how we use that information and our legal basis for doing so. It also covers whether and how that information may be shared and your rights and choices regarding the information you provide to us. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you.
If you do not agree with this Policy, do not access or use our services or interact with any other aspect of our business.
As one of our customers with whom we do business, you understand and agree that we collect, store, use, transfer and disclose your personal information in accordance with this Policy.
How We Collect Your Personal Information
Your personal information may be collected by us in a number of ways, including:
- when you provide us with information in relation to your attendance at any of our webinars, workshops, seminars or other hosted events and services;
- when you provide information to us by filling in forms on any of our websites;
- when you complete surveys that we use for research purposes; and
when you contact us, for example, to inquire about our services.
Types of Personal Information We Collect
In order for you to use our Services, we collect and process certain information, including personal information.
Depending on your use of the Services, the types of personal information that we collect and process (which may vary by jurisdiction based on applicable law) include:
Registration data. When you sign up for our Services you are asked to provide us with information about yourself and to give us more detailed insights into who you are. For example: your email, name, title, company, address, phone number, or other personal information. Such personal information will not be posted in areas of the Site viewable by the public or Authorized Users of the Site.
Payment Information. We collect certain payment and billing information when you register for certain paid Services in order to facilitate payment of those Services. We do not store payment details nor do we share your payment information with third parties for any purpose other than the provision of the requested Service.
Special Requests. We may collect any information necessary to fulfil special requests.
Communications. We collect information from you if you contact us for any purpose. The scope of the information that we collect will be based on your particular inquiry.
Surveys. We may collect demographic data or other personal information in customer surveys, the results are anonymized or aggregated for analysis.
Security. We may use security measures on our website or webinars that may capture or record images and sound of customers and guests in public areas where permitted by law.
Analytics. We collect information about the ways people visit and interact with our websites, in the form of cookies and traffic analytics.
Sensitive Personal Information. There may be instances in which the personal information that you provide to us or that we collect is considered Sensitive Personal Information under the privacy laws of some countries. Those laws generally define “Sensitive Personal Information” to mean personal information from which we can determine or infer an individual’s, racial or ethnic origin, political opinions, religious beliefs or other beliefs of a similar nature, philosophical beliefs, membership in a trade union or professional association, physical or mental health or condition, medical treatment, genetic data, sexual life, sexual orientation, biometric data or judicial data (including information concerning the commission or alleged commission of a criminal offence). In some very rare instances, financial records may form part of Sensitive Personal Information where you are located. We only process Sensitive Personal Information in your jurisdiction if and to the extent permitted or required by applicable law and will obtain your explicit consent to do so.
How We Use Your Personal Information
We use the information we collect from you to provide you the extraordinary level of service you request and expect from The Pendolino Group brand. Our primary goal in collecting your information, including your personal information, is to provide you with a smooth, efficient, and customized experience. As part of that undertaking, we are committed to safeguarding the privacy of the personal information that we gather and never selling your data.
We may use your information as set forth below:
Service Administration. We use your personal information to create and administer your account, keep your account secure, contact you, complete a purchase or provide the services you have requested, customize your experience, to carry out services we have agreed to provide you and to protect our Services (including to verify the identities of creators and prevent fraud and abuse), to improve the content and methods of delivery of our website and provide, manage and improve our services.
Communication. We use your information to send communications about the Services, including confirming your purchases, sending invoices, responding to your comments, questions and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We will contact you through email, phone calls, notices posted on our websites, and other ways, including text messages.
Payment Information. We collect certain payment and billing information when you register for certain paid Services. For example, you might provide payment information, such as payment card details, which we collect via secure payment processing services. We do not store payment details nor do we share your payment information with third parties for any purpose other than the provision of the requested Service.
Marketing. Information you submit, such as your name, email, other contact information, may be collected by The Pendolino Group for internal marketing and development purposes as well as to respond to your inquiries. With your permission we may use your personal information to provide or offer you promotions and featured specials, as well as other marketing messages in accordance with any communication preferences you have expressed, to send you marketing messages; and to conduct surveys. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), and other means.
Meeting and Event Planning. We may use your personal information to provide you with a better or more personalized level of service, including responding to your requests for information and services from a third party (such as travel, accommodation or transportation arrangements).
Other. In addition, The Pendolino Group may disclose personal information in order to: (i) comply with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of The Pendolino Group, site visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain, (vi) enforce our websites’ terms and conditions, and (vii) respond to an emergency.
Lawful Basis For Processing (for users in the European Economic Area “EEA”) Only:
Lawful basis for processing. If you are an individual in the European Union (EU), we collect and process information about you only where we have a lawful basis for doing so under applicable EU laws, including, but not limited to, The EU General Data Protection Regulation (“GDPR”). The lawful basis depends on the Services you use and how you use them. Our lawful basis include:
Consent. Under certain circumstances, personal information may be processed on the basis that you have consented to such processing. If you have consented to our use of information about you for a specific purpose, you have the right to change your mind and withdraw your consent at any time, but this will not affect any processing that has already taken place.
Contractual Necessity. Personal information may be processed on the basis that such processing is necessary in order to enter into or perform a contract with you. In certain circumstances, we need your personal data to comply with our contractual obligation to deliver the Services we provide to you.
Compliance With Legal Obligations. Personal information may be processed on the basis that we have a legal obligation to perform such processing. For example, tax laws may require us to retain records of payments you made through our Services.
Legitimate Interests. This is a technical term in data protection law which essentially means we have a good and fair reason to use your personal information and we do so in ways which do not interfere with your interests, freedoms and fundamental rights. We sometimes require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business.
Retaining Personal Information
International Transfers of Personal Information
As a global company, The Pendolino Group endeavors to provide you with the same level of service that you have come to expect. To provide this service, The Pendolino Group may share your personal information among our service providers, and other third parties working with The Pendolino Group who we need to operate our business, which may be located in countries outside of your own. Although the data protection laws of these various countries may differ from those in your own country, we will take appropriate steps to ensure that your personal information is handled as described in this Policy.
Disclosure of Your Personal Information To Third Parties
The Pendolino Group does not sell or rent your personal information to third parties for their own marketing purposes. We may disclose the information that we collect about you, including your personal information, as follows:
Affiliates. We also may share your personal information with our affiliates to assist us in providing services to you, and, where applicable, to notify you about products and services that may be relevant to you.
Business Transfers. If The Pendolino Group, its affiliates, joint ventures or any combination of such, is acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information that we have collected about you, including your personal information, to the other company.
Credit Card Information. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use billing information except for the sole purpose of credit card processing on The Pendolino Group’s behalf.
Your Use of Other Users Information
Certain features of our Site enable you to have access to other users of our Site. For example, you may interact with other users through seminars and various forums. You are prohibited from disclosing personally identifiable information about another user, including Authorized Users, that you learn through these or other portions of our Site or otherwise, to any third party without our consent and the informed consent of such other user. Our users do not tolerate spam. Therefore, without limiting the foregoing, you are not licensed to add any user to your mail list (email or physical mail) without their express written informed consent.
User Generated Content
Certain portions of our Site, such as comments on our blogs, permit user generated content. If you post content to our Site, all of the information that you post will be available to other persons visiting the Site. Your posting becomes public and we cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.
Device and Connection Information
We may collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We may also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We may use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services. You are able to prevent this information from being shared with us by blocking transmission at the local network level.
Cookies & Tracking Notice
If you do not want to accept cookies, you can block them by adjusting the settings on your Internet browser. However, if you block them, you will not be able to use all of the features of our websites, including the customization features associated with creating a user profile.
Further information about cookies and other similar technology and how they work is available at allaboutcookies.org.
Web Beacons, Pixel Tags and Other Technologies
We use web beacons, such as clear GIFs, web bugs or pixel tags, which are tiny graphics with a unique identifier similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our customers to help us track e-mail response rates, measure the success of our marketing campaigns, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
We work with third party service providers who use the technologies described in this section and other tracking means to conduct analytics to help us track and understand how visitors use our Site. For example, we use a variety of third party web analytics, including Google Analytics, to help us improve our Site’s performance and user experiences. We analyze how users interact with our websites so we can understand better what elements of the design are working well and which are not working so well. This allows us to improve and develop the quality of the online experience we offer all our customers.
The security of your personal information is important to us. We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us. If your browser is SSL enabled (which most are), your transmission of personal information to us online will be encrypted. You can verify whether your personal information is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of your browser window. You can also verify that your personal information will be encrypted using SSL encryption by making sure that the prefix for the web address listed for that page has changed from “http” to “https”. If you do not see the appropriate symbol and the “https” prefix, you should not assume that the personal information that you are being asked to provide will be encrypted prior to transmission.
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal information that may affect you so that you can take the appropriate actions for the due protection of your rights.
Our websites may also contain plug-ins and other features that integrate third party social media platforms into our website. You are able to click on such links. If you do so, the third parties who operate these platforms may be able to identify you, they may be able to determine how you use this website and they may link and store this information with your social media profile. Please consult the data protection policies of these social media platforms to understand what they will be doing with your personal data. If you activate these plug-ins and other features, you will be doing so at your own risk.
The Pendolino Group recognizes the privacy interests of minor children and we encourage parents and guardians to take an active role in their children’s activities and interests. Minor children are not permitted to provide any personal identifiable information on or through our websites.
How to Access and Control your Personal Information
You have certain choices available to you when it comes to your information. Below is a summary of those choices, how to exercise them and any limitations.
In some cases, you may request a copy of your information, to object to our use of your information (including for marketing purposes), to ask us to stop accessing, using, and storing your information where you believe we don’t have the appropriate rights to do so, to request the deletion of your information, to request the restriction of processing of your personal information, or to request your information in a structured, electronic format. You can exercise some of these choices by contacting us as provided in the Contact Us section below to request assistance.
Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep.
Where you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.
In some jurisdictions, in addition to agreeing to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. We may seek your consent expressly in accordance with applicable laws (e.g. where the information collected is regarded to be Sensitive Personal Information under local regulations).
We will comply with any request from you not to send you direct marketing materials. When such a request is received, your contact details will be “suppressed” rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it. If you opt out of receiving marketing communications from us, we will continue to send administrative notices and communications relevant to your use of the Services to you via email.
If you are dissatisfied with the way we process your information, you may lodge a complaint with the data protection authority (“DPA”) also referred to as the Supervisory Authority, in your jurisdiction.
Changes to this Policy
The Pendolino Group may modify this Policy from time to time. When we make material changes to this Statement we will post a link to the revised Statement on the homepage of our site, and to assist you, this Policy has an effective date set out at the end of this document.
Questions regarding this Policy or the information practices of our websites and Services should be directed to:
The Office of the Privacy Officer
The Pendolino Group
51 Monte Mar #201
Sausalito, CA 94965, USA
As stated above, we may modify this Policy from time to time. To help you track the most significant chnges, we will include a history of changes, below, so that you are aware of modifications to our Policy.
Last Update: June 18, 2018
Effective Date: May, 2018
In the event of any inconsistencies between the English version of this Policy and any version of this Policy in any other language, the English version shall prevail (to the fullest extent permitted under applicable law).