PRIVACY CENTER

Privacy Policy


1. About This Privacy Policy

Pipl, Inc.’s (“Pipl”, “we”, “our” or “us”) privacy policy was built with both its usefulness and your privacy in mind. This privacy policy applies when you visit or use our website and/or our Services. This privacy policy may be updated and will be posted on Pipl’s website (www.pipl.com).

 

2. Information We Collect

Pipl collects the following types of data:

Website Visitors: Individuals who visit our website and who may volunteer certain contact data (such as their name, email address) to receive communications from Pipl. For the purposes of this Policy, “Website” shall refer to pipl.com as well as any other websites Pipl owns and that link to this Policy.

Customers: Those who register on their own or on behalf of an entity or organization to use any of the Pipl Services (as defined below), including administrators on a Customer account may provide personal information (such as customer account and payment information). For the purposes of this Policy, “Services” shall refer to all products or service offerings made available by Pipl.

Services: We collect information about you from (a) reliable third parties; (b) the Internet; (c) other publicly available sources; and/or (d) our Customers who chose to allow such collection.   The categories of public and private data collected are set forth below.

  • Name, alias, username, account name, social media handle
  • Postal address
  • Phone numbers
  • Gender
  • Associates
  • Email addresses
  • Education and degrees
  • Employment history
  • Languages
  • Trade affiliations, interest groups
  • Licenses
  • Social media account and profile
  • Social media images
  • Deceased data
  • Vehicle ownership
  • Home ownership
  • Date of Birth, age
  • Associated web pages
  • IP Address
  • Device ID
  • (Brazil) CPF, Taxpayer ID number
  • Profiling information

We obtain the categories of personal information listed above from the following categories of sources:

  • Public sources – online publicly available information, such as public databases and web pages.
  • Third Party sources – information licensed from providers of publicly available information, such as public record aggregators and other information, such as device id or Ip address.
  • Customer queries – when Customers have consented, information submitted by our customers in the form of query or feedback data.
  • Consumer provided – information directly provided on our website or other systems.

3. How We Use Personal Information

Under the GDPR, Pipl may be considered a controller and/or a processor depending on the nature of the transaction. Please note that our basis for collecting and using your personal information will depend on the personal information collected and the specific context in which we collect it.

We normally collect personal information from you only where: (a) we have your consent to do so, (b) where we need your personal information to perform a contract with you (e.g. to deliver the Pipl Services you have requested), (c) where the processing is in our legitimate interests; or (d) where we are required to collect, retain or share such information under applicable laws.

 

In some cases, we may need the personal information to protect your vital interests or those of another person.

Where we rely on your consent to process your personal information, you have the right to withdraw or decline consent at any time. Where we rely on our legitimate interests to process your personal information, you have the right to object.

 

4. How We Share Personal Information

Depending on the service provided, we share personal information with:

  • Our affiliates of Pipl, Inc.; or
  • Our service providers, suppliers, agents and representatives, including but not limited to, payment processors, customer support, IT service providers; or
  • Our customers.

In addition, please note the Pipl, Inc. may be required to disclose an individuals's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Purpose

Legal Basis

Provision of our Services; Support. We use your personal information, such as but not limited to your name and email address, for customer services purposes. This includes, for example, responding to your inquiries

The legal bases for processing this data are the performance of our contract with you; compliance with our legal obligations; and our legitimate interests. Our legitimate interests in this case are enforcing our policies, protection against fraud and misuse of our Services.

Payments. We collect from our third-party payment processors certain information about your payment instruments for the purpose of connecting your payment instrument to your account on our Services, and sending statements, invoices, and payment reminders.

The legal bases for processing this data are the performance of our contractual obligations; the protection of our legitimate interests, in this case provision of our Services; and compliance with legal obligations to which we are subject.

Improve our Services. We collect and analyze information about you and your usage of our Services to improve the usability and effectiveness of our Services

The legal basis for processing this data is our legitimate interests, in this case providing and improving our Services.

Marketing and Advertising. We may use tracking technologies (which may collect personal information) in order to provide you with personalized advertisements when you visit our Services.

The legal bases for processing this data are your consent (when required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored services, content and advertisements that better correspond with your interests.

Integrity. We may process certain information about you and your usage of the Service in order to keep the integrity and security of the Services, prevent fraud, identify your identity and enforce our policies

The legal bases for processing this data are your consent (when required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored services, content and advertisements that better correspond with your interests.

Services. We provide or sell information collected to the users of our Services. Our Services are used primarily for identity verification, compliance, fraud prevention, content enrichment and investigations.

The legal basis for processing this data is our legitimate interests and for the purposes for preventing fraud.

Compliance with applicable laws.

We may be required to collect, retain, or share your personal information, under applicable laws.

 

For information received under the EU-US Data Privacy Framework (EU-U.S. DPF), Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) or the UK-US Data Privacy Framework (UK-U.S. DPF), Pipl will require third parties to whom we disclose personal information to safeguard that personal information consistent with this Policy by contract, obligating those third parties to provide at least the same level of protection as is required by the Data Privacy Framework Principles. EU, UK and/or Swiss residents may choose to opt-out of such disclosures. Pipl may have liability to individuals in case of failure to comply with the law or this Policy in handling onward transfer of such individuals’ information to third parties.

 

5. Commitment to Children’s Privacy

We are committed to protecting the privacy of minors. To comply with various privacy regulations, at this time, Pipl is not directed or otherwise intended to be used by users under the age of 18. Therefore, our Services are only available to users who are at least 18 years old and should only be used by users in that condition, in accordance with our terms of service. If you are under 18, please do not use Pipl’s Service.

Furthermore, Pipl never knowingly sells or publicly discloses personal information that is associated with a minor individual.

6. Cookies

Pipl may use cookies, pixels, beacons, local storage and similar technologies (“Tracking Technologies”) in an effort to improve the quality of our Services. A Cookie is a small data file that is sent to your computer when you first visit a website. Cookies usually include an identification number that is unique to the computer you are using. Such identifiers can help us better understand our users and how they are using the website and the Services. Cookies can improve the quality of service e.g. recognizing a user when he visits the site, displaying the site according to the user’s chose user settings for language, and maintaining the security of the user’s account; and help us provide relevant information and offers to our customers and prospects. If you prefer, you can reset your browser so that it refuses all cookies or notifies you when a cookie is being sent. In such case, your browser will send us a special signal to stop tracking your activity. You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third-party webpages:


 

7. Third Party Websites

Pipl Services contain links to third party websites and embedded elements from third party web services such as Google Maps; likewise, your query information might be relayed to third party data feeds for additional results. If you use Pipl’s Services or follow a link to a third-party website, some information about you and your query will be visible to subsequent services. Even if the third-party website or service is affiliated with us, we have no control over linked sites, services or data feeds, each of which has a separate privacy and data collection practices independent of Pipl. As such, we are not responsible for, nor have any control over, the content or privacy policies of those third-party websites or services, and encourage all users to read the privacy policies of each and every website linked from or embedded in pipl.com.

8. Data Subject Rights

Pipl, Inc. acknowledges the rights of access afforded to EU, UK and/or Swiss individuals. If the European Union’s General Data Protection Regulation, UK Data Privacy Act, California Consumer Privacy Act, or other countries’ privacy regulation is applicable to you, you may have the following rights in respect of your personal data that we hold:

  • Right of Access. You have the right to know about the specific pieces of personal data we have about you.
  • Right to Delete. You have the right to request the erasure of your personal data.
  • Right to Rectification. You have the right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
  • Right to Restrict. You have the right to restrict the processing of your personal data.
  • Right to Object. You have the right to object to the processing of personal information by us.
  • Right to Portability. You have the right to move, copy or transfer personal data easily from one organization to another.
  • Right to Opt-Out of the Sale of Data (CCPA). You have the right to opt out of the sale of your personal data.
  • Right to Opt-Out of Automated Decision Making. You have the right to opt out of automated decision making based on your personal data.

9. Exercising Your Rights

California, EU, Swiss and/or UK residents have the choice to exercise their rights under the CCPA, the GDPR, or the UK-GDPR in the following ways:

For California residents under CCPA, to “Opt-Out” of the sale or sharing of your information with third parties, visit:

DO NOT SELL OR SHARE MY PERSONAL INFORMATION LINK  

For California residents, under CCPA, to make a deletion or disclosure request, visit: https://pipl.com/ccpa-disclosure-form

EU, Swiss and/or UK residents may exercise your right to access, delete, rectification, or object to processing as described above you may also submit a request to us via the following methods:

  • Calling us at (877) 616-1115 (phone requests typically require additional steps and take longer to process);
  • Initiate a request for disclosure/deletion using the following link (identity verification required); or
  • Email: privacy@pipl.com

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Pipl will provide you with a date when the information will be provided. If for some reason access is denied, Pipl will provide an explanation as to why access has been denied.

For questions or complaints about the processing of your personal data, you can email Pipl’s privacy team at privacy@pipl.com. Alternatively, if you are located in the European Union, you can also have recourse to the European Data Protection Supervisor or with your nation’s data protection authority.

10. International Transfers

Information collected by Pipl may be stored in the United States or any other country in which Pipl or its agents maintain facilities. By using Pipl, you consent to any such transfer outside of your country. With respect to personal information that Pipl receives from its EU based customers, Pipl complies with applicable transfer mechanism(s) in place at such time.  

Pipl, Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Pipl, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Pipl, Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

11. Data Retention

We will retain your personal information for as long as necessary to operate our website or provide services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods shall be determined taking into account the type of information that is collected and the purpose for which it is collected for, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

 

12. Data Security

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use or disclosure of your personal information.

While we seek to protect your information to ensure that it is kept confidential, we cannot guarantee the security of any information. You should be aware that there is always some risk involved in transmitting information over the internet and there is also some risk that others could find a way to thwart our security systems. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security and privacy of your personal information or other content you transmit using the Services or Websites, and you do so at your own risk. Thus, we encourage you to exercise discretion regarding the personal information you choose to disclose.

13. California Consumer Privacy Act (“CCPA”) and Related Regulations

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods and services;
  • Charge you a different price or rates for goods or services, including through granting discounts or other benefits or imposing penalties;
  • Provide you a different level or quality of goods or services; nor
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Annual Report on request to access, delete and opt-out for the calendar year 2023:

Requests

Total Number of Requests

Number of Requests Complied with in Full

Number of Requests Complied with in Part

Number of Requests Denied

Mean Number of Days to Respond*

Disclose

23

19

4

0

15.08

Delete

3

3

0

0

2.54

Opt-Out

3161

1739

1422

0

8.29

14. How to Contact Us

If you have any questions, concerns or complaints, or would like to exercise your rights, please contact us at:

In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), Pipl, Inc. commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact Pipl, Inc. at privacy@pipl.com.

Pipl, Inc. has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf  

The Federal Trade Commission has investigatory and enforcement authority regarding Pipl’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and SW-US DPF.

Effective Date: October 1, 2023