Last updated August 7, 2018
Thank you for choosing to be a part of our community at Pillars of Wall Street, LLC, doing business as Pillars of Wall Street (“Pillars of Wall Street”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at email@example.com.
- What information Do We Collect?
Personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, limited payment information, and social media login data.
We collect personal information that you voluntarily provide to us when registering at the Sites or Apps, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or Apps (such as our eLearning platform) or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Sites or Apps, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and contact data: We collect your first and last name, email address, city of residence, and other similar contact data.
Credentials: We collect passwords, password hints, and similar security information used for authentication and account access.
Payment data: We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument where necessary. All payment data is processed and stored via our payment processor and you should review its privacy policies and contact the processor directly to respond to your questions.
Social Media Login Data: We provide you with the option to register using social media account details, such as your Facebook or LinkedIn login. If you choose to register in this way, we will collect the Information described in the section called “How Do We Handle Your Social Logins” below.
All personal information that you provide to us must be true, complete and accurate. You must notify us of any changes to your personal information
Information automatically collected
In Short: Some information, such as IP address and/or browser and device characteristics – is collected automatically when you visit our Sites or Apps.
We automatically collect certain information when you visit, use, or navigate the Sites or Apps. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Sites or Apps, and other technical information. This information is primarily needed to maintain the security and operation of our Sites or Apps, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
Information collected through our Apps
In Short: We may collect information regarding your mobile device, push notifications, and Facebook/LinkedIn permissions when you use our apps.
If you use our Apps, we may also collect the following information:
Mobile Device Data: We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information, and IP address.
Push Notifications: We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.
Facebook and LinkedIn Permissions: We by default access your Facebook and LinkedIn basic account information including your name, email, gender, birthday, current city, and profile picture URL, as well as other information that you choose to make public. We may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission. For more information regarding these third-party permissions, refer to the Facebook and LinkedIn Permission Reference page.
Information collected from other sources
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms (such as Facebook or LinkedIn), as well as from other third parties. Examples of the information we receive from other sources include: social media profile information (your name, gender, birthday, email, city, state, country, user identification numbers for your contacts, profile picture URL, and any other information that you choose to make public); marketing leads and search results and links, including paid listings (such as sponsored links).
- How Do We Use Your Information?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Sites or Apps for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To facilitate account creation and logon process with your Consent. If you choose to link your account with us to a third-party account (such as your Facebook or LinkedIn account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process. See the section below headed “How Do We Handle Your Social Logins” for further information.
To send you marketing and promotional communications for Business Purposes. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time (see the “What Are Your Privacy Rights” below).
To send administrative information to you for Business Purposes, Legal Reasons, and/or possibly for Contractual. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
Fulfill and manage your orders for Contractual reasons. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites or Apps.
Deliver targeting advertising to you for our Business Purposes. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
Request feedback for our Business Purposes. We may use your information to request feedback and to contact you about your use of our Sites or Apps.
To protect our Sites for Business Purposes and/or for Legal Reasons. We may use your information as part of our efforts to keep our Sites or Apps safe and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions and policies for Business Purposes, Legal Reasons, and/or possibly Contractual.
To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Sites or Apps, products, services, marketing and your experience.
- Will Your Information Be Shared with Anyone?
In Short: We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.
We only share and disclose your information in the following situations:
Compliance with laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or las enforcement requirements).
Vital Interests and legal rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Vendors, consultants, and other third-party service providers. We may share your data with third party vendors, service providers, contractors, or agents who perform services for us on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites or Apps, which will enable them to collect data about how you interact with the Sites or Apps over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. Unless described in this Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.
Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
With your consent. We may disclose your personal information for any other purpose with your consent.
- How Do We Handle Your Social Logins?
In Short: If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.
Our Sites or Apps offer you the ability to register and login using your third party social media account details (like your Facebook or LinkedIn logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture, as well as other information you choose to make public. If you login using Facebook, we may also request access to other permissions related to your account, such as friends, check-ins, and likes, and you may choose to grant or deny us access to each individual permission.
- How Long Do We Keep Your Information?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
- How Do We Keep Your Information Safe?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites or Apps is at your own risk. You should only access the services within a secure environment.
- Do We Collect Information From Minors?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites or Apps, you represent that you are at least 18, or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites or Apps. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at firstname.lastname@example.org
- What Are Your Privacy Rights?
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you would at any time like to review or change the information in your account or terminate your account, you can:
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites or Apps. To opt-out of interest-based advertising by advertisers on our Sites or Apps visit: http://www.aboutads.info/choices/.
Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out you may contact using the contact information below
- Do California Residents Have Specific Privacy Rights?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Sites or Apps, you have the right to request removal of unwanted data that you publicly post on the Sites or Apps. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites or Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.
- Do We Make Updates to This Policy?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
- How Can You Contact Us About This Policy?
If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Matthew Holaves, by email at email@example.com, or by pot to:
Pillars of Wall Street, LLC
c/o Matthew Holaves
100 Park Avenue
New York, NY 10017
If you have any further questions or comments about us or our policies, email us at firstname.lastname@example.org or by post to:
Pillars of Wall Street, LLC
c/o Technical Support
100 Park Avenue
New York, NY 10017