Privacy Policy
By using or accessing the Site in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Statement, and you hereby consent that we will collect, use, and share your information in the following ways.
If you have a disability, you may access this Privacy Statement in an alternative format by contacting privacy@getplenum.io
Please remember that your use of Plenum’s Site is subject to the Plenum Terms of Service posted at https://www.getplenum.io/terms
What this Privacy Statement Covers
The Plenum Privacy Statement covers how we treat Personal Data that we gather when you:
• Visit our Site or other sites or applications that display or link to this Privacy Statement;
• Visit our branded social media pages;
• Visit our offices;
• Receive communications from us or otherwise communicate with us, including but not limited to emails, phone calls, texts or faxes; or
• Register for, attend or take part in our events, webinars, programs, or trainings.
“Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations.
This Privacy Statement does not apply to the extent we process Personal Data in the role of a processor or service provider on behalf of our clients, including where we offer to our clients various products and services through which our clients (or their affiliates) collect, use, share or process Personal Data via our products and services.
For detailed privacy information related to a Plenum client or a client affiliate who uses Plenum products and services as the controller, please contact our client directly. We are not responsible for the privacy or data security practices of our clients, which may differ from those explained in this Privacy Statement.
This Privacy Statement does not cover the practices of companies we don’t own or control or people we don’t manage.
If you are a Plenum client, please remember that your use of Plenum’s Services is subject to the agreement between you and Plenum governing your use of such Services, and not this Privacy Statement.
Personal Data of Children
We do not knowingly collect or solicit Personal Data about children under 18 years of age; if you are a child under the age of 18, please do not attempt to use the Site or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided Personal Data to us, please contact us at privacy@getplenum.io
Categories of Personal Data
The categories of Personal Data that we collect and have collected over the past 12 months is detailed in the chart below:
Category of Personal Data
Personal Data We Collect
Third Parties With Whom We Share Personal Data:
Profile or Contact Data
• First and last name
• Service Providers
• Advertising Partners
• Analytics Partners
• Business Partners
Device/IP Data
• IP address
• Device ID
• Domain server
• Type of device/operating system/browser used to access the Site
• Service Providers
• Advertising Partners
• Analytics Partners
• Business Partners
Web Analytics
• Web page interactions
• Referring webpage/source through which you accessed the Site
• Non-identifiable request IDs
• Statistics associated with the interaction between device or browser and the Site
• Service Providers
• Advertising Partners
• Analytics Partners
• Business Partners
Inferences Drawn From Other Personal Data Collected
• Profiles reflecting user attributes
• Profiles reflecting user behavior
• Service Providers
• Advertising Partners
• Analytics Partners
• Business Partners
Other Identifying Information that You Voluntarily Choose to Provide
• Identifying information in emails or letters you send us
• Service Providers
• Advertising Partners
• Analytics Partners
• Business Partners
[Other]
• Service Providers
• Advertising Partners
• Analytics Partners
• Business Partners
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
Categories of Sources from which Personal Data is Collected
We collect Personal Data about you from the following sources:
• You
• When you provide such information directly to us.
• When you use our interactive tools on the Site.
• When you voluntarily provide information in free-form text boxes through the Site or through responses to surveys or questionnaires.
• When you send us an email or otherwise contact us.
• When you use the Site and information is collected automatically through cookies as further described in the tracking tools and opt out section below.
• Third Party Vendors and Advertising Partners
• We may use analytics providers to analyze how you interact and engage with the Site, or third parties may help us provide you with client support.
• We may use vendors to obtain information to generate leads.
• We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our Site, applications, advertisements or communications.
When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by emailing info@getplenum.io.
Business or Commercial Purposes for Collecting Personal Data:
• Providing you with the information you request.
• Meeting or fulfilling the reason you provided the information to us.
• Providing support and assistance for the Site.
• Improving the Site, including testing, research internal analytics and product development.
• Personalizing the Site, website content and communications based on your preferences.
• Doing fraud protection, security and debugging.
• Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).
• Marketing the Site
• Marketing and selling our products and services.
• Showing you advertisements, including interest-based or online behavioral advertising.
• Corresponding with You
• Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about our products and services.
• Sending emails and other communications according to your preferences or that display content that we think will interest you.
• Meeting Legal Requirements and Enforcing Legal Terms
• Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
• Protecting the rights, property or safety of you, Plenum or another party.
• Responding to claims that any posting or other content violates third-party rights.
• Resolving disputes.
Categories of Third Parties with whom we share Personal Data
We disclose your Personal Data to the third parties listed in this section.
• Service Providers.
These parties help us provide the Site or perform business functions on our behalf. They include:
• Hosting, technology and communication providers.
• Security and fraud prevention consultants.
• Support and customer service vendors.
• Advertising Partners.These parties help us market our products and services and provide you with other offers that may be of interest to you. They include:
• Ad networks.
• Data brokers.
• Marketing providers.
• Social media services.
• Analytics Partners.These parties provide analytics on web traffic or usage of the Site. They include:
• Companies that track how users found or were referred to the Site.
• Companies that track how users interact with the Site.
• Business Partners.These parties partner with us in offering various services. They include:
• Businesses that you have a relationship with.
• Companies that we partner with to offer joint promotional offers or opportunities.
Legal Obligations
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
Business Transfers
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Site and promote our business, provided that we will not share such data in a manner that could identify you.
Tracking Tools and Opt-Out
The Site uses cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript to enable our servers to recognize your web browser, tell us how and when you visit and use our Site, analyze trends, learn about our user base and operate and improve our Site. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Site. If you use a location-enabled browser, we may receive information about your location. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). Please note that because of our use of Cookies, the Site does not support “Do Not Track” requests sent from a browser at this time.
We use the following types of Cookies:
• Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Site. Disabling these Cookies may make certain features and services unavailable.
• Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Site, maintain your preferences over time and recognize you when you return to our Site. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Site. They do this by collecting information about the number of visitors to the Site, what pages visitors view on our Site and how long visitors are viewing pages on the Site.
Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Site’ content for those who engage with our advertising. For example, Google Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Site is subject to the Google Analytics Terms of Use and the Google Privacy Statement. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Site and functionalities may not work.
To explore what Cookie settings are available to you, look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.
Data Security
We endeavor to protect the privacy of your Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
Data Retention
We retain Personal Data about you for as long as necessary to provide you with our Site. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, or as otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
California Resident Rights
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our clients’ end users or employees in connection with our provision of certain services to our clients. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Statement and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@getplenum.io
Access
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
• The categories of Personal Data that we have collected about you.
• The categories of sources from which that Personal Data was collected.
• The business or commercial purpose for collecting or selling your Personal Data.
• The categories of third parties with whom we have shared your Personal Data.
• The specific pieces of Personal Data that we have collected about you.
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient.
Deletion
You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Site or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
Exercising Your Rights
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request using the following methods:
• Email us at: privacy@getplenum.io
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
Personal Data Sales Opt-Out and Opt-In
We will not sell your Personal Data and have never done so.
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA.
Other State Law Privacy Rights
California Resident Rights
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@getplenum.io
Nevada Resident Rights
We do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
Privacy Notice for EU Residents
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.
Plenum may process Personal Data of our clients’ end users or employees in connection with our provision of services to clients, and we are the processor of any such Personal Data. Please contact your employer, the controller party. in the first instance to address your rights with respect to such data. Plenum may also be the controller of Personal Data processed in connection with the Site.
If there are any conflicts between this section and any other provision of this Privacy Statement, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@getplenum.io
Personal Data We Collect
The “Categories of Personal Data” section above details the Personal Data that we collect from you.
Personal Data use and Processing Grounds
The “Business or Commercial Purposes for Collecting Personal Data” section above explains how we use your Personal Data.
We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
• Legitimate Interest: We process Personal Data when we believe it furthers the legitimate interest of us or third parties. Examples of these legitimate interests include:
• Operation and improvement of our business, products and services
• Marketing of our products and services
• Protection from fraud or security threats
• Compliance with legal obligations
• Completion of corporate transactions
• Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
• Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.
Sharing Personal Data
The “Categories of Third Parties with whom we share Personal Data” section above details how we share your Personal Data with third parties.
EU Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email privacy@getplenum.io Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Site.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Plenum’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Transfers of Personal Data
The Site is hosted and operated in the United States (“U.S.”) through Plenum and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Site, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Plenum in the U.S. and will be hosted on U.S. servers, and you authorize Plenum to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to (i) a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission.
Changes to this Privacy Statement
We’re constantly trying to improve our Site, so we may need to change this Privacy Statement from time to time as well, but we will alert you to changes by placing a notice on www.getplenum.io or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Site, and you are still responsible for reading and understanding them. If you use the Site after any changes to the Privacy Statement have been posted, that means you agree to all of the changes. Use of information we collect now is subject to the Privacy Statement in effect at the time such information is collected.
Contact Information
If you have any questions or concerns regarding our privacy policies, please send us a detailed message to privacy@getplenum.io, and we will try to resolve your concerns.