Last updated: 23 July 2021
I. Who we are and who this applies to
II. What is Pangle
III. What personal data we process
III.1 The types of personal data that we process depend on the circumstances of collection and on the nature of the services requested or transaction undertaken for our Partners.
III.2 When you create an Account with Pangle, we process certain information about you. This information may be collected directly from you or your authorised representatives, or when you interact with Pangle (for example, in the course of obtaining services from Pangle).
III.3 To register as an Account Holder, we require certain personal data from you. If you choose not to provide such data, you may not be able to utilize the services provided by us.
III.4 The information that we process about you may include some or all of the following categories:
a. Identity and contact information: We may process identity information that you provide to us when registering for an Account or using our services, such as your name, email address, contact number and address and bank account details. If you are an individual, we may also process your government-issued tax identification number in accordance with applicable laws.
b. Account information: We may process information about you which is associated with your Account, such as your username and password and IP address.
c. Newsletter details: If you sign up to receive our newsletter, we may process certain personal data about you which you provide to us when signing up for the newsletter. This includes your name, email address, company name and job title.
d. Information we collect automatically: We automatically collect certain information from you when you visit the Pangle website. Such information includes:
i. Identifiers and device information. We automatically log your IP address and collect information regarding the device you are using to visit the Pangle website such as the model of your device, your browser information, system language setting, your screen resolution and operating system.
ii. Usage data. We automatically log your activity on the Pangle website, including the content you view on the Pangle website, how long you spent viewing such content, the URL of the website from which you came to our site, and other details about your use of and actions on the Pangle website.
iii. Location data. We collect information about your location based on your IP address.
e. Cookies: We use strictly necessary Cookies that are required for the operation of the Pangle website. They include, for example, Cookies that enable you to log into secure areas of the Pangle website. We also use analytical/performance Cookies. They allow us to recognize and count the number of visitors and to see how visitors move around the Pangle website when they are using it. This helps us to improve the way the Pangle website works, for example, by ensuring that visitors are finding what they are looking for easily.
You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you.
IV. How we use personal data
IV.1 We process personal data of our Account Holders for the following purposes:
a. To manage your Account: To register you or the company you work with as a Partner, to manage your Account (including managing payments) and your relationship with us.
b. To provide you with our services: To perform our obligations in relation to Pangle and the services we provide to the Partner you represent.
c. To send you promotional material: To send you information about our events, announcements, promotions or other marketing campaigns. If required by law this will be subject to your permission.
d. To verify or maintain the quality of Pangle and improve, upgrade or enhance Pangle: For example, (i) for audit, research, and analysis of the information in order to maintain, improve, upgrade or enhance our advertising services, and to ensure that our technologies function properly; and (ii) other internal operations, such as debugging, support, and security.
e. To provide you with our newsletter: If you have signed up to receive our newsletter, we will only use the details you provide to us when signing up for the newsletter for the purposes of providing you with the newsletter.
f. For compliance with legal obligations: To comply with legal obligations that apply to us, for example to respond to law enforcement requests.
g. For any other purpose to which you consent: To use your personal data for any other purpose to which you have provided consent.
h. To contact you: To contact you in relation to any of the above.
i. For archiving purposes in the public interest, scientific or historical research purposes.
V. Who we share your personal data with
a. Our affiliates and third party services providers: We share personal data with our affiliates and other companies who to help operate Pangle, perform functions on our behalf or provide services to us, including data processing services to us (for example, to support, provide functionality on, or help to enhance the accuracy, safety and security of our services, or to provide analytics or attribution services to us, as well as service providers who provide technical, customer, hosting, data hygiene and enhancement or operational support), as well as other professional advisors.
b. Any competent law enforcement body, regulatory, government agency, court or other third party: We may share personal data with these parties where we believe disclosure is necessary (i) as a matter of applicable law or regulation; (ii) to exercise, establish or defend our legal rights; (iii) to detect and protect against fraud or other security or technical vulnerabilities; (iv) to respond to an emergency; or (v) to otherwise protect your vital interests or those of any other person where permitted by applicable law.
c. Any other person: We will only share personal data with any other person with your consent to the disclosure or as otherwise permitted or required under applicable data protection law.
VI. How we keep your personal data secure
VI.1 We use reasonable technical and organisational measures to protect the personal data that we process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.
VII. International data transfers
VII.1 Your personal data may be transferred to, and processed in, countries other than the country in which you are located or in which your personal data was collected. However, we will not transfer or permit any of your personal data to be transferred outside of such country unless we have taken measures necessary to ensure the transfer is in compliance with applicable laws, and in any case to a recipient that has comparable privacy protections in place.
VIII. Data retention
VIII.1 We retain your personal data for as long as it is necessary to provide you with services so that we can fulfil our contractual obligations and exercise our rights in relation to the information involved. Where we do not need your information in order to provide services to you, we retain it only for so long as we have a legitimate business purpose in keeping such data or as necessary to comply with the law.
VIII.2 When we have no ongoing legitimate business or legal need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives or the law requires otherwise), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
IX. Your data protection rights
IX.1 Pangle supports the exercise of your data protection rights which may be available in your country in accordance with applicable data protection laws. Specifically:
IX.2 You can request to access, correct or delete your personal data by contacting us using the contact details provided under the "How to contact us" section below, and we will fulfil your request if these rights are available under applicable data protection laws in your country.
XI. How to contact us
XI.1 If you have any questions or concerns about our use of your personal data, please contact us using the details below.
- For Account Holders and Site Visitors located in the European Economic Area, United Kingdom or Switzerland: email@example.com
- For Account Holders and Site Visitors located in any other part of the world: firstname.lastname@example.org.
- For Account Holders and Site Visitors located in Brazil: email@example.com
For individuals located in Israel:
The following paragraph shall be added to the end of section III. What personal data we process:
III.5 You are under no legal obligation to provide us any personal data.
The following paragraph shall be added to the end of section VII. International Data Transfers:
VII.3 You hereby consent to the transfer of your personal data as set out in this Section VII.
The following paragraph shall be added to the end of section IX. Your data protection rights:
IX.3 You have the right to appeal the refusal of Pangle to comply with your request to exercise your rights in a court of competent jurisdiction.
For Account Holders and Site Visitors located in Brazil
g. For any other purpose in compliance with the applicable data protection law: To use your personal data for any other purpose in compliance with the applicable data protection law.
b. Any other person: We will only share personal data with any other person in compliance with the applicable data protection law.
Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.
We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:
I. confirmation of whether your data are being processed;
II. access to your data;
III. correction of incomplete, inaccurate or outdated data;
IV. anonymization, blocking or erasure of data;
V. portability of personal data to a third party;
VI. object to the processing of personal data;
VII. information of public and private entities with which we shared data;
VIII. information about the possibility to refuse providing personal data and the respective consequences, when applicable;
IX. withdrawal of your consent.
Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.
Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.
DPO: If you wish to reach the Pangle's Data Protection Officer, contact us at: firstname.lastname@example.org
Access Logs. We keep your application access logs, under confidentiality, in a controlled and safe environment, for, at least, 6 (six) months, in order to comply with legal obligations.
For Account Holders and Site Visitors located in the European Economic Area, United Kingdom or Switzerland:
The following paragraph shall be added under section VII. International Data Transfers:
7.3 Where you are located in the European Economic Area, United Kingdom or Switzerland and we transfer your personal data outside of these regions, we do so on the basis that either the recipient country’s data protection laws have been deemed adequate by the European Commission or through the use of safeguards such as the European Commission’s model contracts for the transfer of personal data to third countries, or in line with any other legally approved mechanism approved. For further details contact us using the details in the “How to contact us” section below.
9.1 Pangle supports the exercise of your data protection rights which may be available in your country in accordance with applicable data protection laws. Specifically:
a. Access Your Data: You can ask us, free of charge, to confirm we process your personal data and for a copy of your personal data.
b. Delete Your Data: You can ask us to delete all or some of your personal data.
c. Change or Correct Data: You can ask us to change or fix your data.
d. Portability: You can ask for a copy of personal data you provided in a machine-readable form.
e. Object or Restrict Use of Data and Withdraw Consent: You can ask us to stop using some or all of your data, e.g. if we have no legal right to keep using it. You can ask us to stop processing your personal data for direct marketing purposes; withdraw your consent or ask us to stop making any automatic individual decisions, including profiling. If you object to such processing, we ask you to share the reason for your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing.
f. Complain: The right to lodge complaints before the competent data protection regulator.
9.2 For further information, contact us using the contact details provided under the "How to contact us" section below, and we will fulfil your request if these rights are available under applicable data protection laws in your country. If you have made a specific request to us, and do not provide personal data that we can use to identify you we will be unable to fulfil your request.
XII. Legal basis
XII.1 In the European Economic Area and the United Kingdom we must have a legal basis to process your personal data. For users located in these regions, we will make the platform available to you on the basis of our legitimate interests. The legal basis for other processing of your personal data will depend on the personal data concerned and the specific context in which we process it. If we process your personal data in our legitimate interests, such as for security and product improvement purposes, this interest will normally be to provide an effective, secure and dynamic platform.
XII.2 In some cases, we process your data to comply with our legal obligations, with your consent or where it is in the vital interests of you or another person.
XII.3 If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “How to contact us” heading below.