Effective Date: December 29, 2021

PGM of Texas LLC and all associated companies and subsidiaries (“PGM”) have created this privacy policy (“Privacy Policy”) in compliance with applicable laws and in order to demonstrate our firm commitment to privacy. This Privacy Policy describes how PGM collects, uses, discloses, transfers, stores, retains or otherwise processes your information when you (whether in your individual or business capacity) access or use, in any manner, any content, products, services or related activities (collectively “Services”), including through the Internet domains and mobile applications owned or operated by PGM, which include, but are not limited to:

Website(s): Application(s):
https://pgmoftexas.com/ PGM of Texas Mobile Application (Android)
PGM of Texas Mobile Application (iOS)

We refer to the above websites and all related websites as “sites” and to each of them as a “site.” We will also refer to our web and mobile applications as “applications.” When we refer to “we,” “us,” or “our,” we mean PGM, or the specific division, subsidiary or affiliate that operates a site, provides its content, or processes information received through it, each as appropriate and applicable. When we refer to “you” or “your,” we mean the person accessing the site or application. If the person accessing the site or application does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization.

This Privacy Policy applies to your use of our Services, and covers information collected in connection with your access to and use of our Services, including those Services provided through our sites, applications or in-person. Please read this Privacy Policy carefully. By continuing to use our sites and applications, you agree to have your personal information handled in the manner described in this Policy.

I. OUR PRIVACY POLICY INCLUDES:

II. GENERAL DISCLOSURES

Each of the sites and applications are hosted in the United States. If you are visiting the sites or using the applications from outside of the United States, please note that by providing your information it is being transferred to, stored or processed in the United States. This section sets forth the general Privacy Policy for the United States and other jurisdictions not otherwise specifically covered by the below jurisdiction-specific policies. Depending on your state or country of residence, applicable privacy laws may provide you right to additional disclosures as well as special consumer rights. If you are outside of the United States, please see the provisions in our International Privacy Policy. If you are outside of the United States and do not wish to allow the transfer of your personal information to the United States, you should not use these sites, our applications or our Services, and you should opt-out of the collection of cookies by following the guidelines in our section titled How To Restrict Cookies. For more information about how we utilize cookies, view our Cookie Policy.

We take your privacy and the protection of your personal information seriously. We will only store, process and disclose your personal information in accordance with applicable law. We will make it clear when we collect personal information and will explain what we intend to do with it. We do our best to protect your privacy through the appropriate use of information security measures.

III. WHAT INFORMATION WE COLLECT

PGM may collect personal information about you either directly from you, your Connected Device and from select external sources.

  1. CATEGORIES OF PERSONAL INFORMATION THAT WE COLLECT

The following categories of personal information are provided to help you better understand the information we may collect directly from you, either through your use of the sites (including from your mobile and/or other Internet connected devices (“Connected Device”)) or in the course of us providing our Services to you.

We may collect, use, store and process different kinds of personal information about you, which we have grouped into the following categories:

Category of Information Examples Purpose of Collection
Identity Information (personal)

 

 

 

 

·         first and last name

·         e-mail address

·         phone number

·         address

·         internet protocol (IP) address

·         we collect this information in order to provide you our Services

·         we collect this information in order to respond to your questions or concerns

·         we also collect this information to send you information we think you may find useful or which you have requested from us

·         we also collect this information to communicate with you about opportunities, products and services offered by us

·         we also collect this information in order to provide you our Services and to comply with local, state and federal law

Identity Information (vehicle)

 

·         driver’s license, including the information listed on your driver’s license

·         license plate number

·         images or physical descriptions of your vehicle

·         vehicle identification number (VIN)

·         we are required to collect this information by local, state and federal law
Identity Information (log-in)

 

·         user name

·         password

·         we collect this information in order to provide you with access to our applications
Visual Information ·         video recording ·         we are required to collect this information by local, state and federal law

·         we also collect this information to maintain the security of our physical locations

Geolocation Information ·         physical location ·         we collect this information in order to enforce any applicable terms of use for our applications as well as other applicable agreements or policies
Financial Information ·         bank account information

·         bank wire information

·         we collect this information in order to pay you
Device Information ·         browser plug-in types and versions

·         operating system and platform and other technology on the Connected Devices that you use to access the sites or applications

·         diagnostic information relating to your Connected Devices

·         we collect this information in order to measure, track and analyze trends and usage in connection with your use of our sites and application as well as the performance of our Services

·         we also collect this information in order to see how we can better optimize our Services, including our sites and applications, to make them easier to use

·         we also collect this information to maintain and improve our Services, sites and applications, including improving safety and quality controls, as well as to develop new products and services

Internet and Electronic Network Activity Information ·         webpages viewed

·         search history

·         events and page loads

·         time zone setting and location (geocodes)

·         user content

·         time spent on sites

·         cookie data

·         we collect this information in order to measure, track and analyze trends and usage in connection with your use of our sites and application as well as the performance of our Services

·         we also collect this information to see how customers are finding and accessing our sites and applications in order to gauge the effectiveness of our marketing campaigns

·         we also collect this information in order to enforce any applicable terms of use or other applicable agreements or policies

·         we also collect this information to maintain and improve our Services, sites and applications, including improving safety and quality controls, as well as to develop new products and services

  1. INFORMATION THAT WE RECEIVE from select external PARTNERS

We may receive information about you when you access our sites through external platforms, including social media websites such as Facebook. If you use our sites on or through an external platform, including via your Connected Device, or click on external links, the collection, use, and disclosure of your information and your use of the sites will also be subject to the privacy policies and other terms of such external parties and platforms. You should review such privacy policies, terms and other agreements.

  1. COLLECTION OF Internet and Electronic Network ACTIVITY Information

The Internet and Electronic Network Information that we collect is collected through the use of server logs and tracking technologies, including: (i) cookies, which are small pieces of code that websites and applications send to your Connected Device to uniquely identify your browser or Connected Device or to store information in your browser setting; and (ii) web beacons, which are small objects that allow us to measure the actions of visitors using the PGM’s sites. For more detailed information regarding how we use cookies and other technology, please review the additional information in our Cookie Policy.

  1. BUSINESS CONTACT INFORMATION 

We may collect your business contact information, such as your full name and your business name, email address, telephone number, address and other work-related information you provide to us in the course of providing our Services.

IV. WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION

  1. WE DO NOT SELL YOUR INFORMATION

We do not sell your personal information.

  1. WHEN AND HOW WE MAY SHARE/DISCLOSE YOUR INFORMATION WITH OUR SERVICE PROVIDERS AND CUSTOMERS

In the course of our business we may share your personal information with select and trusted entities that are engaged by PGM to provide services that are deemed necessary for the function, operation or management of our business. We will share your information with the following service providers or other external entities under the circumstances described below or as otherwise described in this Policy:

Category of Information External Entities Purpose of Disclosure
Identity Information (personal)

 

·         U.S. state, local and federal governments

·         our regulators

·         in certain cases, we are required by state, local and federal law to disclose this information to our regulators for anti-theft purposes
Identity Information (vehicle)

 

·         U.S. state, local and federal governments

·         our regulators

·         in certain cases, we are required by state, local and federal law to disclose this information to our regulators for anti-theft purposes
Visual Information ·         U.S. state, local and federal governments

·         our regulators

·         in certain cases, we are required by state, local and federal law to disclose this information to our regulators for anti-theft purposes
Financial Information ·         our point-of-sale vendor

·         banking institutions

·         in the course of providing our Services, we may need to disclose your information to our vendors who process payments for us

·         we may also need to disclose your information to our bank or to your banking institution to process and deliver payments

Internet and Electronic Network Activity Information ·         our data analytics providers ·         we use external analytics such as Google Analytics to help understand your usage of our sites and applications

 

  1. DATABASE HOSTING VENDOR

Like many other businesses, we utilize cloud databases to host our business data, including your personal information, so that we can effectively and safely operate our business.

  1. AUDITORS

Like many other businesses, we are subject to audits from a number of entities, such as our regulators, enterprise customers and service providers, as well as due to our own internal auditing policies. In order to accomplish an effective audit, we must provide information, which may include your personal information, to external auditors. We always ensure that your information is safely disclosed and stored and that auditors can only use your information for the purposes of completing an audit.

  1. CORPORATE TRANSACTIONS

We may share all or part of your personal information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of PGM’s business or assets to such business entity (including due to a sale in connection with a bankruptcy). We will require any such purchaser, assignee or other successor business entity to honor the terms of this Privacy Policy.

  1. DISCLOSURE OF INFORMATION FOR LEGAL PURPOSES

PGM may disclose all or part of your personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating any agreement with PGM, or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users of our sites, or anyone else that could be harmed by such activities. We may disclose information in response to a subpoena, search warrant, in connection with judicial proceedings, or pursuant to court orders, legal process or other law enforcement measures. PGM may disclose or access personal information when we believe in good faith that the law requires it, to establish our legal rights or to defend against legal claims, and for administrative and other purposes that we deem necessary to maintain, service and improve our Services.

  1. AGGREGATED, ANONYMIZED OR DE-IDENTIFIED INFORMATION

We may disclose or use aggregated, anonymized or de-identified information for any purpose. Aggregated, anonymized or de-identified information is information that can no longer reasonably identify a specific individual. Although such information may be derived from your personal information, it can no longer directly or indirectly reveal your identity.

V. COOKIES POLICY

Like many online platforms, PGM and its analytics vendors use server logs and automated data collection tools, such as browser cookies, pixel tags, scripts and web beacons. These tools are used for analytics purposes to enable PGM to understand how users interact with the sites and applications. PGM and its analytics vendors may tie the information gathered by these means to the identity of users.

Cookies are small text files placed on a computer or device while browsing the Internet. Cookies are used to collect, store and share bits of information about user activities. PGM uses both session cookies and persistent cookies.

Session cookies are used to identify a particular visit to PGM’s sites and collect information about your interaction with the sites. These cookies expire after a short time or when the user closes their web browser after using the sites. PGM uses these cookies to identify a user during a single browsing session, such as when you log into the sites. This helps PGM improve the sites, application and Services as well as improve the users’ browsing experience.

A persistent cookie will remain on a user’s device for a set period of time specified in the cookie. PGM uses these cookies to identify and recognize a specific user over a longer period of time. They allow PGM to:

  • analyze the usage of the sites (e.g. what links users click on) in order to improve our offering;
  • test different versions of the sites to see which particular features or content users prefer to optimize the sites;
  • provide a more personalized experience to users with more relevant content and course recommendations; and
  • allow users to more easily log in to use the sites and Services.

Examples of persistent cookies include: (i) preferences cookies to remember information about a user’s browser and settings preferences, such as preferred language – preference cookies make a user’s experience more functional and customized; (ii) authentication and security cookies to enable a user to log in or stay logged in to access the sites and Services, to protect user accounts against fraudulent log-ins by others and to help detect and protect against abuse or unauthorized usage of user accounts; and (iii) functional cookies to make the experience of using the sites and Services better, like remembering the sound volume level selected by the user.

PGM uses tracking technology to: (i) determine if a certain page was visited or whether an email sent by PGM was opened or clicked on by a user; and (ii) to customize the experience of individual users by recommending specific content.

We also use clear gifs in HTML-based emails sent to our users to track which emails are opened and clicked on by recipients. We may use the information we obtain from the cookie in the administration of the sites, to improve the usability of the sites and for marketing purposes. We may also use that information to recognize your computer when you visit our sites and to personalize our sites for you.

Cookies and information captured through our sites are stored for a certain retention period, however you can eliminate these cookies any time before the expiration date. Below is our table of cookies that is current as of the effective date of this Privacy Policy.

Cookie Name Purpose of Collection
_ga, _gid, _gat and _gali we use these cookies to collect data from visitors to our sites, including tracking the number of visitors to the sites, where visitors have come to the website from, the websites they have visited and to help distinguish between individual site visitors
AMP_TOKEN we use this cookie to identify if the same user is accessing our site from different origins, e.g., via a Google search or whether by navigating to our site directly
_gac_ we use these cookies to determine how you navigated to our sites and understand how our sites are interacting with third-party websites and our online ads


VI. HOW TO RESTRICT COOKIES

You can adjust the settings in your browser in order to restrict or block cookies that are set by the sites (or any other website on the Internet). Your browser may include information on how to adjust your settings. Alternatively, you may visit www.allaboutcookies.org to obtain comprehensive general information about cookies and how to adjust the cookie settings on various browsers. This site also explains how to delete cookies from your computer.

You can control and delete these cookies through your browser settings through the following:

Or you can also use the following cookie management and disposal tool from Google Analytics by downloading and installing the browser plug-in from the following link: http://tools.google.com/dlpage/gaoptout.

Please be aware that restricting cookies may impact the functionality of our Services. Most browsers allow you to refuse to accept cookies. Additional general information about cookies, including how to be notified about the placement of new cookies and how to disable cookies, can be found at www.allaboutcookies.org.

VII. EXTERNAL PARTNER ADVERTISING AND ANALYTICS

We may use service providers to provide site metrics and other analytics services. These service providers may use cookies, web beacons and other technologies to collect information, such as your IP address, identifiers associated with your device, other applications on your device, the browsers you use to access our sites and Services, webpages viewed, time spent on webpages, links clicked and conversion information (e.g., transactions entered into). This information may be used by PGM and service providers on behalf of PGM to analyze and track usage of our sites and Services, to determine the popularity of certain content and to better understand how you use our sites and Services. The service providers that we engage are bound by confidentiality obligations and other restrictions with respect to their use and collection of your information.

This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons or other tracking technologies, which are covered by such third-parties’ privacy policies. For more information, we encourage you to check the privacy policies of these third-parties to learn about their privacy practices. For more information about targeted advertising specifically, please visit http://www.aboutads.info/choices.

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking across websites. Most modern web browsers give you the option to send a DNT signal to the websites you visit, indicating that you do not wish to be tracked. However, there is no accepted standard for how a website should respond to this signal, so we do not take any action in response to this signal. PGM does not have a mechanism in place to respond to DNT signals. Instead, in addition to publicly available external tools, we offer you the choices described in this Privacy Policy to manage the collection and use of information about you.

PGM does track some activity across websites (including your search terms, the website you visited before you visited or used the Services and other clickstream data), and we may continue to collect information in the manner described in this Privacy Policy from web browsers that have enabled DNT signals or similar mechanisms.

VIII. LINKING SITES

The sites contain links to other websites. PGM is not responsible for the privacy practices or the content of such websites, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships). We do not share information we gather with other websites or any other entities or individuals unless such sharing is disclosed to you in advance through this Privacy Policy. Other linked websites, however, may collect personal information from you that is not subject to our control. To ensure protection of your privacy, always review the privacy policy of the websites you may visit by linking from the sites. Please note that this Privacy Policy applies only to our sites and not to other companies’ or organizations’ websites to which we link.

For instance, information collected through Google Analytics is shared with Google and its partners who may combine it with other information you provided to them or they collected from your use of their services. This information is stored in Google’s servers according to their privacy practices.

IX. SOCIAL MEDIA

We may collect information from other sources, such as social media platforms that may share information about how you interact with our social media content. We do not control how your personal information is collected, stored or used by third-party websites or to whom those websites disclose your information. You should review the privacy policies and settings on any social media website that you subscribe to so that you understand the information they collect and may be sharing. If you do not want your social media websites to share information about you, you must contact that website and determine whether it gives you the opportunity to opt-out of sharing such information. PGM is not responsible for how these third-party websites may use information collected from or about you.

Further, our sites may include social media features, such as the Facebook Like button. Our integration of these features may allow external social media to collect certain information, such as your IP address and which page(s) you are visiting when using our sites and Services, and to set a cookie to enable that feature to function properly. Your interactions with these features are governed by the privacy policy of the company providing it.

X. HOW LONG WE RETAIN YOUR INFORMATION

We retain your information as long as necessary to provide you the Services, comply with applicable law, or as otherwise allowed by our data retention policy. We may retain copies of information about you and any transactions or Services you have used for a period of time that is consistent with applicable law, applicable statute of limitations and our data retention policy or as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.

XI. MARKETING AND PROMOTIONAL COMMUNICATIONS

You may opt-out of receiving marketing and promotional messages from PGM, if those messages are powered by PGM, by following the instructions in those messages. If you decide to opt-out, you will still receive non-promotional communications relevant to your use of our Services.

XII. CHILDREN’S ONLINE PRIVACY PROTECTION ACT (COPPA) COMPLIANCE AND RELATED INFORMATION

The Children’s Online Privacy and Protection Act (COPPA) regulates online collection of information from persons under the age of 13. It is our policy to refrain from knowingly collecting or maintaining personal information relating to any person under the age of 18. If you are under the age of 18, please do not supply any personal information through the sites or application. If you are under the age of 18 and have already provided personal information through the sites or application, please have your parent or guardian contact us immediately by using the information provided under Contact Us so that we can remove such information from our files.

XIII. SECURITY

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold information about you both at our own premises and with the assistance of service providers. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please feel free to contact us directly using the information provided under Contact Us .

XIV. CALIFORNIA CONSUMERS

The California Consumer Privacy Act (“CCPA”) permits residents of California to have the following additional rights. For more information, or if you have questions, you can contact us using the information provided under Contact Us . For your protection, before PGM can respond to your request, PGM may be required to collect certain information from you to verify your identity. This may include asking for your full name, aliases, current home addresses or alternative e-mail address. The information you provide to verify your identity will only be used for verification purposes, and a record of your request, including certain information contained within it, will be maintained by PGM for its files.

  1. CALIFORNIA RESIDENTS HAVE THE RIGHT TO REQUEST PGM DISCLOSE WHAT INFORMATION IT COLLECTS, USES AND DISCLOSES

California residents have the right to request that PGM disclose what personal information PGM collects, uses and discloses about them. The general categories of personal information PGM collects about California residents are listed above under What Information We Collect. If you are a California resident and would like to request the specific personal information that PGM collects, uses and discloses about you, please complete this Request Form or contact PGM at the toll-free number provided in this Policy.

  1. CALIFORNIA RESIDENTS HAVE THE RIGHT TO REQUEST THE DELETION OF THEIR PERSONAL INFORMATION MAINTAINED BY PGM

California residents have the right to request that PGM delete the personal information PGM maintains about them. PGM will make every effort to comply with California residents’ requests to delete their personal information, however, certain laws or other legal requirements might prevent some personal information from being deleted. If you are a California resident and would like to request the deletion of your personal information, please complete this Request Form or contact PGM at the toll-free number provided in this Policy under Contact Us. To verify any request to delete personal information, you will be required to provide the information contained in the request form. Failure to do so could result in PGM’s inability to comply with your request.

  1. CALIFORNIA RESIDENTS HAVE THE RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF THEIR PRIVACY RIGHTS UNDER THE CCPA

Under the CCPA, California residents have the right not to receive discriminatory treatment by PGM for the exercise of their privacy rights. However, the exercise of certain privacy rights by California residents will make it so that PGM is no longer able to provide those residents with certain services. For example, if, at the request of a California resident, PGM deletes all of the California resident’s personal information that it maintains, PGM will no longer be able to send marketing communications to that resident.

  1. CALIFORNIA RESIDENTS HAVE THE RIGHT TO OPT-OUT OF THE SALE OF THE PERSONAL INFORMATION.

 

Under the CCPA, California residents can request that a company stop selling their personal information. However, as described above, PGM does not sell your personal information.

 

  1. CALIFORNIA RESIDENTS CAN DESIGNATE AN AUTHORIZED AGENT TO MAKE A REQUEST UNDER THE CCPA ON THEIR BEHALF

California residents can designate an authorized agent to make requests under the CCPA related to the residents’ personal information. PGM can deny any request made by an agent who does not submit proof that he or she has been authorized by the California resident to act on the California resident’s behalf. For more information on submitting a request on behalf of a California resident as an authorized agent, you can contact us using the information provided under Contact Us.

XV. NEVADA CONSUMERS

If a business engages in the sale of personal information, Nevada law provides Nevada residents the ability to opt-out of the sale of their personal information. However, PGM has not and does not sell your personal information.

XVI. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy may be revised from time to time as we add new features and Services, as laws change and as industry privacy and security best practices evolve. We display an effective date at the top of this Privacy Policy so that it will be easier for you to know when there has been a change. If we make any material change to this Privacy Policy regarding use or disclosure of personal information, we will provide notice on our sites and within our applications. Changes will apply to information collected after the change is effective. Please check this Privacy Policy periodically for changes. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice. Your use of the sites and applications constitutes acceptance of the provisions of this Privacy Policy and your continued usage after such changes are posted constitutes acceptance of each revised Privacy Policy. If you do not agree to the terms of this Privacy Policy or any revised Privacy Policy, please exit the sites immediately and do not use our applications. If you have any questions about this Privacy Policy, the practices of the sites or your dealings with the sites, you can contact us by using the information provided below.

XVII. CONTACT US

Please contact PGM with any questions or concerns regarding this Privacy Policy.

Email: privacy@pgmoftexas.com

Toll Free: 844-271-9198

If you have any questions or concerns regarding our Privacy Policy, or if you believe our Privacy Policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with PGM using the contact information listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.

XVIII. INTERNATIONAL PRIVACY POLICY

This International Privacy Policy (the “International Privacy Policy”) applies to individuals residing in countries other than in the U.S. Residents of non-U.S. jurisdictions may be entitled to additional disclosures and notification of consumer rights. These disclosures and rights will be explained below on a per-country basis. If you reside in a country other than the U.S., please review the general Privacy Policy above as those disclosures also apply to you, other than where we specifically stated otherwise. If you find that there is an inconsistently between the disclosures of the general Privacy Policy and this International Privacy Policy, then please note that this International Privacy Policy will control.

If you reside in a non-U.S. country that does not have associated privacy disclosure below, PGM does not knowingly process your personal information and the sites, application and Services are not meant for you. You should leave the site or application and delete all of your cookies associated with the site or application. We provide some guidance regarding cookie management in our Cookie Policy and How to Restrict Cookies sections above.

THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL DATA ABOUT YOU THAT WE COLLECT, HOLD, USE AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E. WHETHER THROUGH A SITE OR OTHERWISE).

A. CANADA

The Canadian Personal Information Protection and Electronic Documents Act (“PIPEDA”) imposes requirements regarding the collection, use, and disclosure of personal data in relation to our commercial activities, as does private-sector privacy legislation in local jurisdictions, provinces and territories.

  1. PERSONAL DATA

For the purposes of this section of the International Privacy Policy, personal data is as defined by applicable Canadian law. It generally means any factual or subjective information, recorded or not, about an identifiable individual.

  1. COLLECTION OF PERSONAL DATA

We collect the following categories of personal data from you:

  • Identity Information (such as personal, vehicle and log-in),
  • Video Information
  • Geolocation Information,
  • Financial Information,
  • Device Information, and
  • Internet and Electronic Network Activity Information.

You can find more specific details about the personal data that we collect from you in the section titled What Information We Collect of our general Privacy Policy.

  1. HOW WE USE PERSONAL DATA

We collect your personal data for the following reasons:

  • to provide you our Services;
  • to respond to your questions or concerns;
  • to send you information we think you may find useful or which you have requested from us;
  • to communicate with you about opportunities, products and services offered by us;
  • to comply with U.S. and Canadian local, state, provincial and federal law;
  • to provide you with access to our applications;
  • to enforce any applicable terms of use for our applications as well as other applicable agreements or policies;
  • to pay you;
  • to measure, track and analyze trends and usage in connection with your use of our sites and application as well as the performance of our Services;
  • to see how we can better optimize our Services, including our sites and applications, to make them easier to use;
  • to maintain and improve our Services, sites and applications, including improving safety and quality controls, as well as to develop new products and services; and
  • we also collect this information to see how customers are finding and accessing our sites and applications in order to gauge the effectiveness of our marketing campaigns.

You can find more specific details about how we use your personal data as described above in the section titled What Information We Collect of our general Privacy Policy.

  1. THE BASIS ON WHICH WE PROCESS YOUR PERSONAL DATA

Where required by Canadian law, we will obtain your consent before processing your personal data. We will only collect, process and share your personal data appropriate to the type of consent that we have received from you. You may provide your consent impliedly through the continued use of our sites and application after being presented with this International Privacy Policy or through our customers and partners who have lawfully obtained your consent to process your personal information in the manner described in the general Privacy Policy and this International Privacy Policy.

You may provide explicitly consent orally, in writing, by electronic communication or any other means reasonably capable of conveying your consent. Except when otherwise permitted by law, we will only use the data for the purpose for which it was given.

  1. WITHDRAWING YOUR CONSENT

As a Canadian resident, you have the right to withdraw your consent to PGM processing your personal data, subject to certain limitations allowed by applicable law. You withdraw your consent through our Request Form. If you decide withdraw your consent, you may no longer receive any e-mails from us and may lose your access to our application as well as some functionality of our sites.

  1. SHARING OF PERSONAL DATA

We may disclose your personal information:

  • to U.S. and Canadian local, state, provincial and federal governments,
  • to our regulators,
  • to our point-of-sale vendor,
  • to yours or our banking institution,
  • to our data analytics providers,
  • to our data matching and analytics partners,
  • to database hosting vendors,
  • to our auditors,
  • to another entity if we are involved in a corporate transaction (for example, if we get purchased by another company), or
  • as otherwise required by law or court order.

You can find more specific details about who we disclosure your personal data to the section titled When and With Whom Do We Share Your Information of our general Privacy Policy.

  1. LIMITATIONS

We only collect the personal data necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes, or as required by law. We do not use or disclose your personal data, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.

We do not, as a condition of providing services to you, or as an administrative or management requirement, require consent to the collection, use or disclosure of personal data beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law.

  1. RETENTION OF PERSONAL DATA

We may retain your personal data for a period of time that is consistent with applicable law, applicable statute of data and our data retention policy. We may also retain your personal data as we believe is reasonably necessary to comply with applicable law, regulation, legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce other applicable agreements or policies or to take any other actions consistent with applicable law.

  1. ACCESS AND RIGHTS TO YOUR PERSONAL DATA

As a Canadian resident, Canadian law provides you with the right:

  • to access the personal data that we maintain about you,
  • to request that we rectify or correct incorrect personal data that we maintain about you, and
  • to withdraw your consent to PGM using your personal data.

To exercise these rights, please use the Request Form. We will have to collect additional personal data about you in order to process your request, but we will not use this data for any other purpose. We also may retain a record of your request, which will be linked to you, for as long as is required by applicable law.

  1. RESPONSE TIMES

We will make every reasonable effort to respond to each of your written requests. When applicable, we will advise you in writing if we cannot meet your requests within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority with respect to this time limit.

  1. COSTS

We expect to be able to respond to your request without charge as a general matter. However, we reserve the right to collect a reasonable charge when you request the transcription, reproduction or transmission of such information. We will notify you, following your request for transcription, reproduction or transmission of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.

  1. SAFEGUARDS

We use security safeguards appropriate to the sensitivity of personal data to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and publishing this policy to appropriate personnel with instructions to act in accordance with its principles (for example, limiting access on a “need to know” basis), and technological measures, such as the use of passwords and/or encryption.

Personal data is generally located at our corporate or divisional offices. A list of corporations, divisions, subsidiaries and affiliates to which this Privacy Policy and International Policy apply is available upon request. Personal data may also be stored with our trusted service providers who are necessary to provide our Services. We ensure that that all service providers who maintain or process personal data have security safeguards appropriate to the sensitivity of personal data in order to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

  1. CONTACT

If you have any questions or concerns regarding our International Privacy Policy, or if you believe our Privacy Policy or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with PGM using the contact information listed in the Contact Us section of our General Privacy Policy, and we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.