Privacy Policy

 

Pembrooke & Ives, Inc., a New York corporation (the “Company”, “Pembrooke, “we”, “our” or “us”), is committed to protecting your privacy through compliance with this policy. This Privacy Policy tells you about our online collection and use of data.

 

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies immediately discontinue use of the website under the domain name www.pembrookeandives.com and related subdomains (the “Website”). By accessing or using the Website, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

 

This Website is owned by the Company and may be accessed in the United States and abroad. Information collected may be retained, and may be stored, processed, accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction.

 

WHAT INFORMATION DO WE COLLECT?

 

We will collect personal information that you voluntarily provide to us. Our collection of your personal information commences when you (i) submit a request or inquiry through the Website; (ii) contract us for our services; and (iii) when you contact us through any other mediums.

 

The personal information that we collect depends on the context of your interactions with us and the services that you request. Please be advised that all personal information that you provide with us must be true, complete and accurate, and you must notify us of any changes to such personal information.

 

In general, we may collect the following personal information from you:

• Personal Information. We collect names; email addresses; contact or authentication data; and other similar information if you choose to provide them to us.
• Information Collected Automatically

 

We may automatically collect certain information from you when you visit our Website. The information that we automatically collect does not reveal your specific identity (such as your name or contact information) but may include certain technical information, such as your IP address, device name, country, location, browser and device characteristics, language preferences, referring URLs, operating system, information about how and when you visit our Website and other technical information. In general, we collect such information to (i) maintain the security and operation of our Website and (ii) conduct internal analytics review. The information that is automatically collected includes:

 

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information that our Website automatically collect when you visit or use our Website. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity when using our Website, such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take and other relevant technical information.
• Device Data. We collect certain device data, such as information about your laptop, phone, tablet or other device you use to visit or use our Website. While the information collected under this category would vary based on the type of device, such information would commonly include your IP address (or proxy server), device and application identification browser type, numbers, location, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
• Location Data. We may collect certain location data, such as information about your device’s location, and such data can be either precise or imprecise. The extent to which we collect such information would depend on the type and settings of the device that you use to access our Website. In general, you can opt out of allowing us to collect such location-related information by (i) refusing access to such information or (ii) disabling your location setting on your device.

 

HOW DO WE USE YOUR INFORMATION?

 

We use personal information collected through our Website for a variety of legitimate purposes described below, such as: (i) to meet our reasonable and legitimate business interests, (ii) to provide you with the services that you request, (iii) to use the collected information with your consent, and/or (iv) to comply with our legal obligations. We do not sell your personal information.

 

In general, we use the information we collect or receive:

 

• To request feedback. We may use your information to request feedback on our Website or the services that we provide with you.
• To send administrative information to you. We may use your personal information to send you certain administrative information, such as an update on our services, and/or information about changes to our terms, conditions, and policies.
• To protect our Website and services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud prevention purposes).
• To enforce our terms, conditions and policies, to comply with legal and regulatory requirements or other obligations that arise in connection with our contract. We may use your personal information to enforce the contractual terms, policies or purposes legitimately related to our rendering of services or to facilitate our compliance with legal, regulatory or contractual requirements.
• To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the information we hold to determine how to respond to such request.
• To deliver and facilitate delivery of services. We may use your information to provide you with the requested service.
• To respond to user inquiries/offer support. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Website.
• To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes as long as such communications are consistent with your marketing preferences. For example, when expressing an interest in obtaining information about us or our services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time.
• To deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

 

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

 

We may process or share your personal information that we possess based on the following legal basis:

 

• Consent: We may process your personal information if you have given us your specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may process your personal information when it is reasonably necessary to achieve our legitimate business interests, including maintaining the security of our Website and protecting our rights and properties.
• Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to perform the obligations or exercise the rights stipulated in our contract.
• Legal Obligations: We may disclose your personal information when we are legally required to do so in accordance with applicable law, governmental requests, a judicial proceeding, court order, or legal process. Examples of such legal obligations include (but are not limited to) a court order or a subpoena seeking to obtain certain information.
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies or applicable law, or to act in response to situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

 

Additionally, we may need to process or share your personal information when one or more of the following situations occur:

 

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Vendors, Consultants and Other Third-Party Service Providers. We may share your personal information with third-party vendors, service providers, contractors or agents who perform certain services for us or on our behalf and require access to the described information. Examples of such third party services include but are not limited to payment processing, hosting services, data analysis, email delivery, customer service and marketing efforts. Additionally, we may allow selected third parties to use tracking technology on our Website, which will enable such third parties to collect data on our behalf about how you interact with our Website. This information may be used for several purposes, such as analyzing and tracking data, determining the popularity of certain content, pages or features, and assessing online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional or commercial purposes, meaning that such third party service providers may not use, process or transfer your information unless otherwise instructed.

 

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

 

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out below.

 

This cookie notice applies to our Website and explains how we use cookies and similar technologies to recognize you when you use or access our Services.

 

What Are Cookies?

 

Cookies are small files placed on your device when you visit a website. They are commonly used for maintaining a website or to improve the efficiency thereof. Website owner also use cookies to provide reporting information. In addition, cookies may be used for supplementary purposes, meaning that such cookies are not used in a way that is necessary for the functioning of a website. We will seek your consent to place supplementary cookies on your device whenever using such cookies are required by laws. Where required by applicable law, we will obtain your consent before we place any cookies on your device that are not strictly necessary for the functioning of our Website.

 

How First Party Cookies Are Different from Third Party Cookies?

 

First party cookies means the cookies that we set and place on your device for using or accessing our Website. As to third party cookies, those are the cookies that enable third party features or functionality to be provided on or through our Website, including, without limitations, cookies placed for advertising purposes.

 

Why Cookies are Used for Our Services?

 

We use first party cookies to ensure the operation, efficiency and availability of our Website. Therefore, such first party cookies as the necessary component for our Website. Separately, other first and third party cookies allow us to understand the interests of the users and help us improve the Website. Below you can find details of the cookies that we use in connection with the operation and maintenance of the Website.

 

• “Strictly necessary” cookies are the cookies that are required for our Website. In most cases such cookies are set to respond to your actions. For example, such cookies will respond when you subscribe for our updates through the Website.
• “Performance” cookies are first party cookies that help us to collect information about how visitors use our Website. We use the collected information to improve the efficiency and operation of the Website. While performance cookies will remain on your device after you close your browser, we only use the information collected by these cookies in an aggregated for so that any information relating to you or your device will NOT be identified or used separately or independently. When permitted by applicable law, we may deploy first party performance cookies automatically when you use our Website.
•  “Targeting” cookies means the third party cookies that are used to make advertising communications more relevant to you. The targeting cookies do not store personal information, but they are capable to identify your browser and internet device. Please note that advertisement would still be displayed in the event you denied the targeting cookies to be placed.
• “Functionality” cookies means the cookies that help our Website to recognize and your information. Examples of the use of such cookies are automatic fill-ins for online forms. The functionality cookies do not track your activity when you are using other websites. In general, if you do not allow these functionality cookies to be placed, some features or functions of the Website might not work properly.

 

What About Other Tracking Technologies (e.g., Web Beacons)?

 

Certain tools other than cookies might also be used to recognize or track visitors to a website. Technologies like web beacons (also called “tracking pixels” or “clear gifs”, which are tiny graphics files that contain a unique identifier, by which a website can ascertain its visitors when the visitors use the website or open an e-mail sent by the website) are often used for such tracking purposes. The tracking technologies are mostly used for following purposes: (i) to monitor the traffic patterns, (ii) to ascertain whether an user comes from an online advertisement which is shown on a third-party website, (iii) to deliver or communicate with cookies, (iv) to assess e-mail marketing activities, or (v) to improve website performance. These technologies generally require cookies in order to function properly, so any rejection or blocking of cookies might impair the functionality of such technologies.

 

How do We Use Google Analytics for Our Services?

 

We use Google Analytics to assess how our Website is used by our users. In general, Google Analytics places first party performance and targeting cookies through our Website so that it can recognize such cookies when you visit or access other websites or applications. Google Analytics’ first party performance and targeting cookies will generate your activities or personal information (such as your IP address), and such information, once generated, will be transmitted to and stored by Google on its servers located in the United States. Google will compile the information collected through those cookies and provide a report to us describing your use of our Website or other activities associated with such use.

 

How Can I Control Cookies?

 

In general, you can find out what cookies are placed on your device and delete or block them with the control features provided by browsers. If you choose to delete or block some or all of the cookies placed on your device, you may still visit our Website, but certain features might not function properly due to such rejection or blocking. Additionally, your preference will be lost when cookies are deleted or rejected, and such loss of saved preference would include your preference to opt-out from cookies because opting out would require an opt-out cookies to function properly. For more information on how to delete or block cookies, please visit your browser’s help menu.

 

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

 

We may transfer, store, and process your information in countries other than your own. We are based in the United States, but please note that if you are accessing our Website from outside the United States, your information might be transferred to, stored, and processed in other countries.

 

If you are a resident in the European Economic Area, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

 

HOW LONG DO WE KEEP YOUR INFORMATION?

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as extension period permitted or mandated by tax, accounting or other legal requirements). When we have no ongoing legitimate business that needs to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

HOW DO WE KEEP YOUR INFORMATION SAFE?

 

We have implemented appropriate security measures designed to protect the security of any personal information we process. However, you should bear in mind that submission of information over the internet is never entirely secure. We cannot guarantee the security of information you submit through our Website as such submission is in transit over the Internet. Accordingly, any such submission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. It is advisable to close your browser when you have finished your user session to help ensure others do not access your personal information if you use a shared computer or a computer in a public place.

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DO WE COLLECT INFORMATION FROM MINORS?

 

We do not knowingly collect information from children under 18 years of age. By using this Website in any manner, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of our Website. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such information from our records. If you become aware of any information we may have collected from children under age 18, please contact us.

 

YOUR PRIVACY RIGHTS AND GDPR NOTICE

 

General Notice

 

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

 

• Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website.
• Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list, however, we may still communicate with you (for example, to send you service-related emails) to respond to service requests or for other non-marketing purposes. To otherwise opt-out, you con contact us.

 

GDPR Notice

 

This section is for people who are located in the European Economic Area (“EEA”). Our processing of personal data of people who are in the EEA is governed by the General Data Protection Regulation (the “GDPR”), and GDPR requires us to provide certain information to you about your personal data.

 

• Data Controller. We are the data controller for the Website.
• Purpose of Processing Your Information. We collect and process your personal information in accordance with the purposes that we enumerated in Section 2 of this Privacy Policy.
• Legal Basis for Processing Your Information. We process your personal information on the basis of consent, which you may withdraw anytime by contacting us. We may also process personal information on other bases permitted by the GDPR and applicable laws, such as when the processing is necessary for complying with certain legal or regulatory obligations.
• Categories of Personal Information. We will process the information that you voluntarily provide with us. The information may include, without limitations, your name, business title, name of employer, email address, country, and telephone number.  We will also collect and process information through cookies, but we will seek your consent when placing cookies that are not strictly necessary for our Website, and you can revoke your consent at any time by contacting us.
• Who Might Receive Your Personal Information. We work with third party service providers to operate, maintain or manage our Website. If you would like specific information about the third party service provider with whom we share your information, please contact us and we will provide that information to you.
• Transfers of Personal Information Outside of EEA. We are based in the United States of America. When you provide personal information to us, we request your consent to transfer that personal information to the USA. We will safeguard your personal information by treating it in accordance with this GDPR privacy notice. We will take adequate steps to protect your privacy and implement reasonable security measures to protect your personal information in storage.
• How Long We Retain Your Personal Information? As previous provided in this Privacy Policy, we will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law.
• What Are Your Rights. You have the rights (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. Your rights may be subject to certain limitations under the GDPR. If you wish to exercise the rights listed in this paragraph, or if you have any concerns about our processing of your personal data, please contact us. We will consider and act upon any request in accordance with applicable data protection laws.
• Filing a Complaint. If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm. If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
• No Obligations to Provide Personal Information. You are under no statutory or contractual obligations to provide personal information to us.

 

Controls for do-not-track features

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature that you can activate to signal your privacy preference that you do not wish to have data concerning your online browsing activities monitored and collected. Currently, because no uniform technology standard for recognizing and implementing DNT signals are available, we do not respond to DNT browser signals (or similar features) that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in an updated Privacy Policy.

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Do California residents have specific privacy rights?

 

Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

• Rights to Access Your Personal Information, Know What Personal Information We Collect and with Whom We Share

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about (i) what information we collected from you, and (ii) categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please contact us. We will respond to your request as promptly as we can.

• Right to Deletion

Unless certain exception exists, you have the right to request deletion of your personal information. Examples of exceptions include when the information is required for us to (i) meet legal obligations, (ii) detect fraud, (iii) investigate violation of the terms and conditions of our Website, or (iii) fix security issues, We will delete your personal information upon your request and within a reasonable period of time unless an exception applies. We will direct our service providers to delete your personal information if you so request.

• Non-Discrimination

Whenever you make an request to exercise your rights, we will not hold it against you.

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DO WE MAKE UPDATES TO THIS NOTICE?

 

Yes, we will update this notice from time to time so as to stay compliant with relevant laws. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

 

HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

 

If you have questions or comments about this notice, you may contact us.

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HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us. We will respond to your request within 30 days.