Privacy Policy – Pearl-Plaza

PRIVACY POLICY

Your privacy is important to you and to us, and we are committed to protecting your privacy.  This Privacy Policy discloses the information practices of Pearl-Plaza, Inc. and its wholly owned affiliates, MaritzCX Holdings LLC, MaritzCX Limited, Pearl-Plaza GmbH, MaritzCX Australia PTY LTD, Empathica Inc., Empathica UK LTD and Pearl-Plaza PTY LTD (collectively “Pearl-Plaza”, “we”, or “us”) relating to our web sites (collectively the “Sites”).

Table of Contents

Compliance with European Union Regulations (GDPR) 

Cookies and IP Addresses

Privacy in Specific Circumstances

How to Contact Us

Compliance with European Union Regulations (in particular the GDPR)

We Adhere to European data protection requirements 

pearl-plaza.ruplies with European data protection requirements and we value these regulations as an important date privacy rights framework.  While the below terms are required to be offered to data subjects under EU laws and regulations, we offer these terms to data subjects globally. The controller within the meaning of data protection laws, in particular the EU General Data Protection Regulation (GDPR) is Pearl-Plaza, Inc.:

Pearl-Plaza, Inc., 10355 South Jordan Gateway, Suite 600, South Jordan, UT 84095 USA.

Email: privacy@pearl-plaza.ru

Your rights under the GDPR

You can exercise the following rights at any time using the contact details provided below:

• The right of access (Article 15 GDPR) – You have the right to be informed about your personal data processed by us.

• The right to rectification Article 16 GDPR) – You are entitled to have your personal data rectified if it is inaccurate or incomplete.

• The right to erasure – Also known as ‘the right to be forgotten’ (Article 17 GDPR) –  you have the right to have your personal data erased. This is, however, only possible if the data concerning you are no longer necessary, if they have been unlawfully processed, or a corresponding consent has been withdrawn.

• The right to restrict processing (Article 18 GDPR) – You have the right to obtain restriction of processing of your personal data.

• The right to data portability (Article 20 GDPR) – you have the right to retain your personal data in a commonly used, machine-readability format in order to have them, if required, transferred to another controller.

• The right to object (Article 21 GDPR)  – You are entitled to object to the processing of your personal data.

• Right to lodge a complaint with a supervisory authority (Article 77 GDPR) – you can contact a supervisory authority with a complaint at any time. A list of the national Data Protection Authorities of the EU Member States can be retrieved here: https://edpb.europa.eu/about-edpb/board/members_en.

Collection of general information when visiting our website

Nature and purpose of the processing:

When you access our website, i.e., when you do not register or otherwise submit information, information of a general nature is automatically collected. This information (server log files) includes, for example, the type of web browser, the operating system used, the domain name of your Internet service provider, your IP address and the like.

In particular, they are processed for the following purposes:

  • Ensuring a smooth connection setup of the website;
  • Ensuring a smooth use of our website;
  • Evaluation of system security and stability; and
  • Optimizing our website

We do not use your data to draw conclusions about your person. Information of this kind is statistically evaluated anonymously by us, if necessary, in order to optimize our Internet presence, confirm the status of our IT security, and the technology behind it.

Legal basis and legitimate interest:

The processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in improving the stability and functionality of our website.

Recipients:

Recipients of the data may be technical service providers who act as order processors for the operation and maintenance of our website.

Transfer to a third country:

The collected data may be transferred to the following third countries: United States of America.

The following data protection guarantees are in place: Please find further information in section EU-U.S. Privacy Shield  and Swiss-U.S. Privacy Shield Frameworks

Storage Duration:

The data is deleted as soon as it is no longer required for the purpose for which it was collected. This is generally the case for data used to provide the website when the respective session has ended.

In the case of storage of data in log files, deletion takes place after 14 days at the latest. Storage beyond this period is possible. In this case, the IP addresses of the users are anonymized, so that an assignment of the calling client is no longer possible.

Provision prescribed or required:

The provision of the aforementioned personal data is neither legally nor contractually required. However, without the IP address, the service and functionality of our website is not guaranteed. In addition, individual services and services may not be available or may be limited.

Right to object

You have the right to object to the processing of your data. Information on how to object is provided here. 

Newsletter

Nature and purpose of the processing:

For the delivery of our newsletter, we collect personal data that is transmitted to us via a relevant web form on the Sites.

For an effective registration we need a valid e-mail address. In order to verify that a registration is actually made by the owner of an email address, we use the “double opt-in” procedure. For this purpose, we log the registration for the newsletter, the sending of a confirmation email and the receipt of the response requested herewith. We track whether a newsletter has been opened by the recipient and when the recipient has clicked on a link within the newsletter. Further data is not collected.

Legal basis:

Based on your explicit consent (Art. 6 para. 1 lit. a GDPR), we will regularly send you our newsletter or similar information by e-mail to your specified email address.

Withdrawal of consent:

You can revoke your consent to the storage of your personal data and its use for the newsletter dispatch at any time with effect for the future. You will find a corresponding link in each newsletter. In addition, you can also unsubscribe directly on this website (https://mkt.pearl-plaza.ru/hs/manage-preferences/unsubscribe-simple) at any time or inform us of your revocation using the contact option provided at the end of this privacy policy.

Recipients:

If applicable, recipients of the data are processors.

Transfer to a third country:

The collected data may be transferred to the following third countries: United States of America.

The following data protection guarantees are in place: Please find further information in section EU-U.S. Privacy Shield  and Swiss-U.S. Privacy Shield Frameworks.

Storage Duration:

Your data will only be processed as long as the corresponding consent is given. Afterwards they will be deleted.

Provision prescribed or required:

The provision of your personal data is voluntary, based solely on your consent. Without existing consent, we can unfortunately not send you our newsletter.

Contact Form

Nature and purpose of the processing:

The data you enter will be stored for the purpose of individual communication with you. For this purpose, it is necessary to provide a valid e-mail address, phone number and your name. This serves the assignment of the request and the subsequent response to the same. The specification of further personal data is optional.

Legal basis:

The processing of the data entered in the contact form is based on a legitimate interest (Art. 6 para. 1 lit. f GDPR).

By providing the contact form, we would like to enable you to contact us easily. The information you provide will be stored for the purpose of processing the request and for possible follow-up questions.

If you contact us to request a quote, the data entered in the contact form will be processed to carry out pre-contractual measures (Art. 6 para. 1 lit. b GDPR).

Recipients:

If applicable, recipients of the data are processors.

Transfer to a third country:

The collected data may be transferred to the following third countries: United States of America.

The following data protection guarantees are in place: Please find further information in section EU-U.S. Privacy Shield  and Swiss-U.S. Privacy Shield Frameworks.

Storage Duration:

Your data will be deleted no later than 6 months after processing the request unless there are other legal retention periods.

Provision prescribed or required:

The provision of your personal data is voluntary. However, we can only process your request if you provide us with your name, phone number and e-mail address.

Right to object:

You have the right to object to the processing of your data. Information on how to object is provided here. 

Information about your right to object according to Art. 21 GDPR

Right to object on a case-by-case basis:

You have the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data which is carried out on the basis of Art. 6 para. 1 lit. f GDPR (data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Art. 4 para. 4 GDPR.

If you object, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.

Recipient of an objection:

• By Email: privacy@pearl-plaza.ru

• By postal mail:  Pearl-Plaza, Attn: Privacy Team/Legal, 10355 South Jordan Gateway, Suite 600, South Jordan, UT 84095 USA.  

Access to your Information: Correction, Deletion, Portability and other Actions.

We want to make sure that your questions are answered and that your personal information is accurate and up to date. You may ask questions, request a copy of the information that we hold about you, request correction or deletion of the same or pursue any of the other above listed rights by submitting a request at /pii-request/.

EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Frameworks 

Pearl-Plaza is aware that the European Court of Justice declared the EU-U.S. Privacy Shield as invalid in its ruling from 16 July 2020. Consequently, the EU-U.S. Privacy Shield Framework is no longer a valid mechanism for the transfer of personal data from European Economic Area (EEA) to the Unites States of America. Pearl-Plaza is also aware that the Swiss Federal Data Protection and Information Commissioner on 08 September 2020 declared that the Swiss-U-S- Privacy Shield does not provide an adequate level of protection for the transfer of personal data from Switzerland to the US. 

However, in accordance with the relevant advice and request by the US Federal Trade Commission (FTC), Pearl-Plaza continues to      comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the      EEA and Switzerland to the United States.  Pearl-Plaza has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Pearl-Plaza would oppose and aggressively defend against government law enforcement requests to disclose any personal data collected on this website. To the extent possible, Pearl-Plaza will without undue delay inform the affected data subject about such government law enforcement requests and support the data subject in defending its rights under the GDPR.  Pearl-Plaza concludes Standard Data Protection Clauses (also known as Standard Contractual Clauses) with all data processors outside the EU/EEA. To ensure that the level of data protection is maintained, Pearl-Plaza maintains safeguards in its systems and processes to ensure an adequate level of data protection.

Your rights under the Privacy Shield Framework:

• Pearl-Plaza is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) in regards to your data privacy.

• Pearl-Plaza may have liability in cases of onward transfers of you data to third parties.

• Under certain conditions there is the possibility for you to invoke binding arbitration (see Privacy Policy FAQs).

For additional details about the Privacy Shield program, our certification therein and the suitable safeguards we use to protect your data visit: /wp-content/uploads/2021/07/Privacy-Shield-Statement-180925.pdf.

3rd Party Dispute Resolution

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Australian Privacy Act

pearl-plaza.ruplies with the Australian Privacy Act 1988 (Privacy Act) and the Office of the Australian Information Commissioner’s (OAIC) APP guidelines. For information about the APP and the text of the act, you may visit this link. https://www.oaic.gov.au/privacy-law/privacy-act/.

If you have any complaints, send them to us at the contact information contained in “How to Contact Us” section below.

1. Disclosures for residents of the USA

If you are a resident of California, Colorado, Connecticut, Delaware, Iowa, Maryland, Utah, or Virginia, you have certain rights and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. This supplemental section, together with other relevant sections of the Policy, provides information about your rights and how to exercise them under the California Consumer Privacy Act and the California Privacy Rights Act (collectively, “CCPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CDPA”), the Delaware Online Privacy and Protection Act (“DOPPA”), the Iowa Consumer Data Protection Act (“ICDPA”), the Maryland Personal Information Protection Act (“PIPA”), the Utah Consumer Privacy Act (“UCPA”), the Virginia Consumer Data Protection Act (“VCDPA”), and any and all regulations arising therefrom. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in the related state laws.

In addition to the rights as explained in this Policy, if you provide Personal Information as defined in the statute to obtain Services for personal, family, or household use, you have the right to submit requests related to your Personal Information once a calendar year. Note that there are circumstances when we may not be able to comply with your request such as when we are not able to verify your request or find that providing a full response conflicts with other legal obligations or regulatory requirements. You will be notified if it’s the case.

(a) Right to know and right to access: You have the right to request certain information we have collected about you. Once we receive and confirm a verifiable request from you, we will disclose to you, to the extent permitted by law: the specific pieces of Personal Information we hold about you, the categories of sources from which Information about you is collected, the purposes for collecting, selling, or sharing your Personal Information.

You have the right to request that the Personal Information is delivered in a format that is both portable and easily usable, as long as it is technically possible to do so.

(b) Right to correct: You have the right to request that we correct your inaccurate Personal Information taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information.

(c) Right to delete: You have the right to request deletion of your Personal Information.

(d) Right to opt-out of the sale and sharing: You have the right to opt-out of the sale of your Personal Information which may include selling, disclosing, or transferring Personal Information to another business or a third party for monetary or other valuable consideration.

(e) Right to consent to or limit the use of your sensitive personal information: You have the right to consent to the use of your Sensitive Personal information and to direct us to restrict its use and disclosure solely to what is essential for carrying out or delivering the Services in a manner reasonably anticipated by an average user, or for certain business objectives as specified by law. However, we do not use Sensitive Personal Information for any purposes other than those legally permitted or beyond the scope of your consent.

(f) Right to non-discrimination: You have the right to not be discriminated against in the Services or quality of Services you receive from us for exercising your rights. We may not, and will not, treat you differently because of your data subject request activity, and we may not and will not deny goods or Services to you, charge different rates for goods or Services, provide a different level quality of goods or Services, or suggest that we would treat you differently because of your data subject request activity.

(g) Shine the Light: California residents that have an established business relationship with us have the right to know how their personal information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law, or the right to opt out of such practices.

To exercise any of your rights, simply contact us using the details below. After we receive and verify your request, we will process it to the extent possible within our capabilities.

How to exercise your rights

Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorized representative of such a person. If we receive your request from an authorized representative, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf.

You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

2. Pearl-Plaza and CCPA

2.1 California Consumer Privacy Act (CCPA) Activities

In this section, “business,” “business purpose,” “consumer,” “commercial purpose,” “personal information,” “sale” or “selling,” and “service provider” refer to the definitions in the CCPA.

Pearl-Plaza has two areas of activity that are related to the CCPA:

  • First, Pearl-Plaza collects data from consumers in the course of its marketing and recruiting efforts. This includes information we collect voluntarily from forms on our website and event registrations, information we collect automatically when you visit our website, apply for a position, and information we obtain from third party sources. In this activity, Pearl-Plaza acts as a “business” under the CCPA.
  • Second, Pearl-Plaza collects data from consumers in the course of providing Pearl-Plaza products and services to its clients. In this activity, Pearl-Plaza acts strictly as a “service provider” to our clients under the CCPA, and our clients are “businesses”.  In the Pearl-Plaza products and services, Pearl-Plaza collects customer data based on our clients’ instructions. For example, our clients specify what consumers we should contact to provide feedback, when we should contact them (e.g., after completing a purchase at a client’s retail store), how we should contact them (e.g., email or SMS), how often we should send them reminders to provide a response, and what questions are asked. Pearl-Plaza’s clients also decide how to use or respond to feedback that is collected.

2.2 Handling Personal Information Under CCPA

Regardless of which area of activity applies to you, Pearl-Plaza does not sell your personal information.

To be clear, in the previous 12 months we have not sold, rented, released, disclosed, disseminated, made available, transferred, or otherwise communicated a consumer’s personal information to another business or third party for monetary or other valuable consideration. If that changes, we will update this Privacy Policy.

Further, when we provide the Pearl-Plaza products and services to our clients, we do not:

  • process personal information for any commercial purpose other than providing our clients the products and services they have purchased; or
  • retain, use or disclose personal information outside of the scope of the agreements we have with our clients.

2.3 Personal Information Collected and Disclosures for Business Purposes

The CCPA requires that we disclose the categories of personal information we collect about consumers, and the categories of personal information we disclose for a business purpose.

The chart below details where you find information about the categories of personal information that Pearl-Plaza has collected in the previous 12 months for each activity related to the CCPA.

ActivityWhere you can find information
Providing the Pearl-Plaza products and services to Pearl-Plaza clients as a “service provider”The categories of personal information Pearl-Plaza collects about consumers vary depending on our clients’ implementation and use of our software. For a generalized description of these categories, please see the Pearl-Plaza Customer DPA located here.

For more information on the types of data collected by a particular Pearl-Plaza client, refer to the privacy policy or communications of the Pearl-Plaza client.

Our clients’ privacy policies are commonly located in the Pearl-Plaza survey invitation email (for web-based surveys) or on the client’s web site or mobile application (for in-the-moment surveys).
Carrying out Pearl-Plaza’s marketing and recruiting efforts as a “business”See section 2 (Types of Information Collected) of this Privacy Policy.

The chart below details where you can find information about the categories of information we disclose for a business purpose in the previous 12 months.

ActivityWhere you can find information
Providing the Pearl-Plaza products and services to Pearl-Plaza clients as a “service provider”The categories of personal information Pearl-Plaza discloses for a business purpose vary depending on the features of our software our clients use, and the servicing and support they have purchased. For a generalized description of these disclosures, please see the Pearl-Plaza Customer DPA located here.

For more information on the disclosures made to a particular Pearl-Plaza client, refer to the privacy policy or communications from the Pearl-Plaza client.

Our clients’ privacy policies are commonly located in the Pearl-Plaza survey invitation email (for web-based surveys) or on the client’s web site or mobile application (for in-the-moment surveys).
Carrying out Pearl-Plaza’s marketing and recruiting efforts as a “business”See section 5 (Disclosure of Information) of this Privacy Policy.

2.4 Consumer Rights Under the CCPA

Your rights under the CCPA include the right to request a copy of the specific personal information collected about you in the 12 months prior to the request, and a business’s data collection practices (including categories of information collected, how information is used, and who it is disclosed to). We will generally refer to these as “access requests”.

In addition, with some exceptions, you can request deletion of the personal information that is collected about you. We will generally refer to these as “deletion requests”.

You have a right not to receive discriminatory treatment for exercising their CCPA rights.

With respect to personal data of consumers collected in Pearl-Plaza products and services, Pearl-Plaza’s clients are responsible for fulfilling access and deletion requests. Pearl-Plaza supports these requests by offering our clients product features, processes and assistance in exporting personal information about individuals. These product features and processes complete the data deletion within 30 days of receiving the request from our client.

With respect to the personal data of consumers collected in Pearl-Plaza’s marketing and recruiting efforts, we are responsible for fulfilling access and deletion requests.

The chart below details how you can exercise your rights under the CCPA.

ActivityHow to exercise your access and deletion rights
Providing the Pearl-Plaza products and services to Pearl-Plaza clients as a “service provider”Please contact the Pearl-Plaza client identified in the communication you received.
Contact information is commonly located within the communication or in a privacy policy linked from the communication.
Carrying out Pearl-Plaza’s marketing and recruiting efforts as a “business”Please submit a request to our Marketing team here.  
In the request, please be as specific as possible in relation to the personal information you wish to access or delete. Once we receive the request, we will review it, and process the request accordingly. If we need additional information to verify your identity, we will let you know.
Any identifying information in such requests will be used solely for verification, and to communicate with you. We will respond to the request within 45 days of receipt, or notify you if we require additional time.

Cookies and IP Addresses

Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. This information is used to track visitor use of the website and to compile statistical reports on website activity.

For further generalized information about cookies visit www.allaboutcookies.org.

You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our website features may not function as a result.

We use your IP address obtained through cookies to help diagnose problems with our servers and to administer the Sites. Your IP address is also used to gather broad demographic information. Our Sites may use cookies to make sure you don’t access the same survey repeatedly and to determine the browser the visitor uses so the Sites can be designed to work properly with the most common versions of different browsers. If used, these cookies are not linked to any Personal Information. If you reject cookies, you may still use the Sites; however, you may not be able to access all areas or features.

Privacy in Specific Circumstances

Children’s Information

Pearl-Plaza does not knowingly collect or solicit Personal information from anyone under the age of 16 or knowingly allow such persons to participate in any survey, contest or other offering from us. If you are under 16, please do not send us your Personal Information. In the event that we learn that we have collected personal information from a child under 16 without verification of parental consent, we will delete that information as quickly as possible. However, we have no obligation to search for, confirm, or identify such information. If you believe that we might have any information from or about a child under the age of 16 please contact us by email at privacy@pearl-plaza.ru and provide particulars of the situation.

Using and Sharing Personal Information

The following paragraphs describe in more detail how Pearl-Plaza may use your personal information in specific circumstances. Depending on the specific interaction you have with Pearl-Plaza, one or more of the following may apply.

Assistance to Complete a Survey

In certain circumstances you may require assistance from Pearl-Plaza to complete a survey. If the survey is being administered by telephone, you may be required to leave a voice message. If the survey is being administered online or by other text media, you may be asked to post a message to Pearl-Plaza using an e-form or e-mail. Personal Information may be required. In this case, the Personal Information will only be used to contact you for the intent of resolving their difficulty in accessing and completing a Survey.

Promotional and Incentive Contests

Pearl-Plaza or its clients may offer various promotions, incentives, or sweepstakes from time to time. When entering a promotional contest, we, our client, or our client’s fulfillment vendor may ask for your name, date of birth, address (e-mail and/or residential), financial information (such as income level), or phone number so that we may communicate with you in the event you are a winner.

Telephone ANI Visibility

When you dial a toll-free number in the United States, the party you are calling pays for the call. The called party is able to identify your telephone number using a telephone network technology called Automatic Number Identification (ANI). FCC rules limit parties that own toll-free numbers from distributing the telephone numbers identified through ANI and require telephone companies to inform customers that their telephone numbers are being transmitted to toll-free numbers in this way. If you take a Pearl-Plaza telephone survey, both Pearl-Plaza and its clients may have access to your ANI, but, per FCC rules, will not distribute that telephone number further.

Opt-In

For certain surveys and other opt-in services, Pearl-Plaza may collect profile (e.g. personal interests) and demographic information (e.g. household income, etc). This information will be used to communicate specific information to you based on the profile and demographic information you provide. Some surveys and opt-in services offer visitors the option of participating in additional surveys or receiving information from Pearl-Plaza or from a Pearl-Plaza client or business partner. Visitors must opt-in if they wish to participate or receive such information, and if they do, their Personal Information may be used by Pearl-Plaza and/or shared with a client of Pearl-Plaza or business partner for that purpose.

Fulfilling Your Transaction Request

If you request something from a Pearl-Plaza web site, for example, a product or service, a whitepaper, a callback, or specific marketing materials, we will use the information you provide to fulfill your request. To help us do this, we may share information, with others, for instance, other parts of Pearl-Plaza and business partners involved in the fulfillment. If you request information about our products or services, we may follow up with you in the future with additional information that we think may be of interest to you. You will always have an opportunity to opt out of receiving such communications. In connection with a transaction, we may also contact you for market research purposes.

When You Contact Us

Our Sites’ contact forms may request your name and contact information, potentially including telephone numbers. An email address is required to post a message to Pearl-Plaza using an e-form.

Public Forums

The Sites may make chat rooms, forums, message boards and/or news groups available to its visitors. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.

Subscription Registration

If you register for a subscription (e.g. to a newsletter or other communication) we will use the registration information that you submit to process your request. We will keep this information in a database. In addition, we may contact you about future publications and Pearl-Plaza services that may be of interest to you. You will always have an opportunity to opt out of receiving such communications.

Disclosure of Aggregate Information

Pearl-Plaza reserves the right to use non-personal customer and/or employee data in aggregate for the purposes of generating “norms” and industry benchmarks, etc.

Job Applications

If you submit a job application to Pearl-Plaza, we may use the Personal Information that you supply, such as your email address and phone number, to contact you about possible job openings. We may also contact previous employers and references, unless you instruct us not to.

Disclosures Required by Law

Be aware that in certain circumstances, it is possible that Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders. This includes the investigation of network abuse or a violation of our terms of use or other published guidelines, or as a part of any actual or threatened legal proceedings or alternative dispute resolution proceedings either initiated by or against us.

New Use of Personal Information

Should Pearl-Plaza wish to use your Personal Information for a purpose not contemplated at the time of initial collection, such as additional services, products, or promotional offers that may be of interest to you, we will use your contact information, including your email address, to ask for your consent to use your Personal Information for the new purpose.

Links to Third-Party Sites

The Sites contain links to third-party sites. Neither Pearl-Plaza nor any of its affiliates are responsible for the privacy practices or the content of such third-party Web sites. Pearl-Plaza co-branded sites and content partner sites have privacy policies independent of Pearl-Plaza. We do not control the privacy practices of those sites and therefore strongly encourage users to familiarize themselves with the privacy practices and customs of any web site controlled by a third party before disclosing any Personal Information on that site. Pearl-Plaza may share aggregate information with co-branded and other related sites, however this aggregated information does not contain personally identifiable information. This Privacy Policy extends only to data collected on pages hosted on the Pearl-Plaza servers.

Security, Storage, and Retention of Information

The Sites (including, but not limited to: websites, surveys, reporting applications, and data transfer applications), have commercially reasonable security measures consistent with industry standards in place to protect against the loss, misuse and interception of information by third parties. Pearl-Plaza holds its physical hosting facilities to these same standards. Nevertheless, Pearl-Plaza assumes no liability for interception, alteration or misuse of information transmitted over the Internet. Pearl-Plaza imposes strict internal controls over employees with access to Customer Information. Such access is granted only on a need-to-know basis. Pearl-Plaza will retain Personal Information only for as long as necessary to fulfill the purpose(s) for which it was collected and to comply with applicable laws, and your consent to such purposes(s) will remain valid after termination of our interaction with you.

Our Worldwide Practices

Pearl-Plaza conducts business globally, with people, processes, and systems that cross borders. Our privacy practices are designed to provide protection for your Personal Information, all over the world.

Pearl-Plaza uses data to train our artificial intelligence tools.

Pearl-Plaza may process your data using artificial intelligence (“AI”) technologies including generative AI, and Pearl-Plaza also may use this information for training our own machine learning models, natural language processing, large-language models, and other relevant AI use-cases. Pearl-Plaza will only process in these above environments the data that you provide to us. Any third-party AI processors will not store your data beyond the brief period needed to process it nor will such data be shared with any other persons, entities, or data models beyond those contracted with Pearl-Plaza and contractually obligated to process in the above manner.

Changes to this Privacy Policy

This Privacy Policy may be amended at any time, without prior notification.

How to Contact Us

Please contact us if you have any complaints, questions about the Privacy Policy, or for access to the information we hold about you:

• By Email: privacy@pearl-plaza.ru

• Or write us at:  Pearl-Plaza, Inc., Attn: Privacy Team/Legal, 10355 South Jordan Gateway, Suite 600, South Jordan, UT 84095 USA.

Version: This Privacy Policy has been updated on 7 July 2021

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