Lawful Basis for Processing Data
In certain jurisdictions, the processing of your Personal Data (as defined below) is lawful only if it is permitted under data protection legislation. In this case, we have a lawful basis for each of our processing activities (unless an exemption applies) as outlined below:
How We Collect and Use Personal and Anonymous Data
When you access the Site, register for any associated products and/or services made available to you through the Site, or opt-in to receive newsletters and other communications from us, we may collect Personal Data and Anonymous Data from you. We may also collect Personal Data and Anonymous Data when you directly contact us.
“Personal Data” means data that allows someone to identify or contact you, including, for example, and without limitation:
Personal Data may be used for the purposes of recording the transaction when you access the Site, or when you use any of the associated products and/or services being made available to you through the Site. Pilothouse does not knowingly collect any sensitive personal data or any data defined under special categories of the applicable law(s). We do not (knowingly) collect personal information from persons under the age of (18) eighteen.
We may also use Personal Data for the following purposes:
If and when we use a third-party technical support provider or third-party hosting provider, we ensure that the same privacy criteria as defined herein with respect to Personal Data are in place with such providers.
“Anonymous Data” refers to data about you that is not associated with or linked to your Personal Data. Anonymous Data does not permit the identification of individual persons. If and when we use a third-party technical support provider or third-party hosting provider, we ensure that the same privacy criteria as defined herein with respect to Anonymous Data are in place with such providers. We do not (knowingly) collect Personal Data from persons under the age of (18) eighteen.
How We Collect and Use Site Data
“Site Data” refers to data about how you use the Site. We may collect certain information from you including, but not limited to, User IP addresses, OS version, OS localization, device type, etc. We obtain this information from third-party traffic monitoring service providers. Other than User IP address, the Site does not, and will not, collect any other Personal Data from you without your prior approval. The Site Data we collect is primarily used to report Site usage and statistics, to improve the Site, and to track the performance of various marketing initiatives. Site Data may also be used by Pilothouse to answer questions about the general use of the Site and/or any associated product(s) or service(s).
Sharing of Personal Data
We will never sell, trade, or rent any Personal Data, Site Data, or any Anonymous Data that may contain Personal Data, to any third party without your explicit consent.
In certain special cases, we may disclose Personal Data when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action against someone who may be causing injury to you, or is otherwise injuring or interfering with our rights, property or operations, other users of the Site or any associated product(s) and/or service(s), or anyone who could be harmed by such activities. We may also disclose your Personal Data and any Site Data when we believe the law requires it or in response to any demand by law enforcement authorities in connection with criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation.
If we determine, in our sole discretion, that you have engaged in conduct that might be considered unlawful, fraudulent, or might harm or damage the reputation or standing of Pilothouse with either the general public or with a business partner or potential business partner of Pilothouse, we reserve the right to release your Personal Data to such persons or third parties, as we consider necessary, to prevent you from causing injury to, or otherwise injuring or interfering, now or in the future, with our rights, property or operations or otherwise the rights, property or operations of anyone which could be harmed by such conduct.
Your Rights with Respect to Your Personal Data
This section applies if you are located in the European Union (EU) or European Economic Area (EEA). In accordance with applicable privacy law, you have the following rights in respect of any Personal Data that we may hold about you:
California Residents: Your California Privacy Rights
California Consumer Protection Act
Without being discriminated against for exercising these rights, California law gives its residents the right to request that we disclose what Personal Data we collect from you, to delete such Personal Data, and to opt-out of the sale of your Personal Data (if we sell such information), subject to certain restrictions. For security purposes, we will verify your identity – in part by requesting certain information from you -- when you request to exercise your California privacy rights. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.
Right to Know
If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:
• The specific pieces of Personal Data we have about you;
• The categories of Personal Data we collected, sold, or disclosed for a business purpose about you within the last twelve (12) months;
• The categories of sources from which the Personal Data was collected;
• The purposes for which the Personal Data was collected or sold; and
• The categories of third parties to whom the Personal Data was sold, disclosed for a business purpose, or otherwise shared.
If possible, we will provide this information to you in a readily usable format that allows transmission to another entity. The easiest way to submit a request and receive your report is to contact Pilothouse.
Right to Delete
If you are a California resident, you may submit a verifiable request for us to delete the Personal Data we have collected about you. The easiest way to submit a request for deletion is to contact Pilothouse.
Right to Opt-Out
California residents may opt out of the “sale” of their Personal Data, as defined by the CCPA. This does not include when:
• You direct us to disclose your Personal Data or use us to interact with a third party and the third party does not sell the personal information;
• We use or share an identifier solely to alert a third party you have opted out of the sale of your Personal Data;
• Your Personal Data is transferred as an asset as part of a transaction in which the third party assumes control of all or part of our business, in which case the third party would have to tell you in writing if it materially changes how the information is used or shared; and
• We use or share your Personal Data under a written contract with a service provider necessary to perform a business purpose. Here, the service(s) that the service provider performs is on our behalf, and our written contract prohibits it from keeping, using or disclosing your Personal Data for any purpose other than for the specific purpose identified in the contract.
Right to be Free from Discrimination
We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our owned and/or operated websites.
If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request.
Cookies and Similar Technologies
Do Not Track
If you opt-out of having your information collected through cookies and other web technologies, your existing display advertising cookie(s) will be deleted and a new cookie will attempt to be placed that instructs third-party service providers not to track your future activities when that cookie is detected (a “do-not-track” cookie). If your browsers are configured to reject cookies when you visit our opt-out page, a “do-not-track” cookie cannot be set on your computer. Also, if you subsequently erase “do-not-track” cookies, use a different computer or change web browsers, you will need to opt-out again. We currently do not respond to browser "do-not-track" signals.
Third-party Links. The Site, our newsletters, and our product(s) and/or service(s) may contain links to other third-party owned and/or operated websites and, where you request information from third-party providers, we may transfer you directly to the websites of such third-party providers. Pilothouse is not responsible for the privacy practices or the content of such third-party websites. In some cases, you may be required to provide certain information to register or complete a transaction at such website. These third-party websites have separate privacy and data collection practices and Pilothouse has no responsibility or liability relating to them. We do not endorse, nor are we responsible for the accuracy of, the privacy policies and/or terms and conditions of such third-party website. These third-party entities are independent third parties and are not affiliated with Pilothouse.
Pilothouse may provide you with the opportunity to receive special offers, products and/or services from third parties. Where you indicate the desire to receive certain offers, products or services from a third party during the applicable information collection process, your Personal Data that was provided during that information collection process will be shared with the applicable third party so that such third party may provide their products and/or services to you without the need for you to complete another information collection form in order to purchase or receive that product or service. Clicking on any third party offers may add and place cookies on your computer prior to directing you to the applicable third party’s site. These third parties have separate cookie polices and Pilothouse has no responsibility or liability relating to them. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You are not required to accept cookies, however, if your browser rejects our cookies you may not be able to use all of the Site functionality.
Third-party Technology/Software/Service/Solutions Providers
The Site, and any product(s) and or service(s) being made available through the Site, may contain certain software technologies and services licensed from third-party providers. Pilothouse may engage with certain third-party services and solutions providers such as data hosting service providers, payment processing service providers, and email marketing service providers. These third-party providers have separate privacy and data collection practices and policies, and Pilothouse has no responsibility or liability relating to them. We do not endorse, nor are we responsible for the accuracy of the terms and conditions of any third-party privacy policies. These third-party entities are independent third parties and are not affiliated with Pilothouse.
Pilothouse may be using or sharing your Personal Data for Legitimate Interest purposes with third parties service providers, which may include, without limitation:
Security of Data
Pilothouse is committed to protecting the security of any Personal Data that it collects and stores. We use a variety of industry-standard security technologies and procedures to help protect any Personal Data from unauthorized access, use, or disclosure. Despite these measures, no method of transmission over the Internet, or method of electronic storage is 100% secure. Pilothouse cannot fully eliminate security risks associated with the collection and storage of any Personal Data, including without limitation, any mistakes and security breaches that may happen. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. In the unlikely event of a data breach where your Personal Data has been compromised, Pilothouse will promptly notify you, the applicable authorities and supervisory authorities or data protection authorities.
Data Retention Period
Any Personal Data that is collected and stored by Pilothouse will be retained only for as long as required in order to provide certain products and/or services to you, or as required by applicable law. Any Personal Data that is no longer required by Pilothouse will be destroyed.
Pilothouse Digital Ltd.
1011 Government St.
Victoria, BC V8W 1X6
We reserve the right to limit or deny your request to view, update, or remove your Personal Data if you have failed to provide us with sufficient information to verify your identity.