When you open the Website, our servers automatically record information that your browser sends. This data may include information such as your device’s IP address, browser type and version, operating system type and version, language preferences, or the webpage you were visiting before you came to the Website and Services, pages of the Website and Services that you visit, the time spent on those pages, the information you search for on the Website, access times and dates, and other statistics. Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.

You can access and use the Website and Services without telling us who you are or revealing any information by which someone could identify you as a specific, identifiable individual. If, however, you wish to use some of the features offered on the Website, you may be asked to provide certain Personal Information (for example, your name and e-mail address). We receive and store any information you knowingly provide to us when you create an account, publish content, make a purchase, or fill out any online forms on the Website. When required, this information may include the following: Account details (such as user name, unique user ID, password, etc.) Contact information (such as email address, phone number, etc.) Basic personal information (such as name, country of residence, etc.) Payment information (such as credit card details, bank details, etc.) Geolocation data of your device (such as latitude and longitude)Any other materials you willingly submit to us (such as articles, images, feedback, etc.) Some of the information we collect is directly from you via the Website and Services. However, we may also collect Personal Information about you from other sources, such as public databases, social media platforms, third-party data providers, and our joint marketing partners. Personal Information we collect from other sources may include demographic information, such as age and gender; device information, such as IP addresses; location, such as city and state; and online behavioral data, such as information about your use of social media websites, page view information and search results and links. You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us.

We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services. If you have reason to believe that a child under 18 has provided Personal Information to us through the Website and Services, please contact us to request that we delete that child’s Personal Information from our Services.We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission. We also ask that all parents and legal guardians overseeing the care of children take the necessary precautions to ensure that their children are instructed never to give out Personal Information when online without their permission.

We act as a data controller and a data processor in terms of the GDPR when handling Personal Information unless we have entered into a data processing agreement with you, in which case you would be the data controller, and we would be the data processor. Our role may also differ depending on the specific situation involving Personal Information. We act as a data controller when we ask you to submit your Personal Information that is necessary to ensure your access and use of the Website and Services. In such instances, we are data controllers because we determine the purposes and means of processing Personal Information, and we comply with data controllers’ obligations set forth in the GDPR. We act in the capacity of a data processor in situations when you submit Personal Information through the Website and Services. We do not own, control, or make decisions about the submitted Personal Information, which is processed only per your instructions. In such instances, the User providing Personal Information acts as a data controller regarding the GDPR. To make the Website and Services available to you or to meet a legal obligation, we may need to collect and use certain Personal Information. If you do not provide the information we request, we may be unable to provide you with the requested products or services. 

Any of the information we collect from you may be used for the following purposes:

• Create and manage user accounts
  
• Fulfill and manage orders
  
• Deliver products or services
  
• Improve products and services
  
• Send administrative information
  
• Send marketing and promotional communications 
  
• Send product and service updates 
  
• Respond to inquiries and offer support
  
• Request user feedback
  
• Improve user experience
  
• Post customer testimonials
  
• Deliver targeted advertising
  
• Administer prize draws and competitions
  
• Enforce terms and conditions and policies
  
• Protect from abuse and malicious users
  
• Respond to legal requests and prevent harm
  
• Run and operate the Website and Services
  

Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies: 

(i) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to California Consumer Privacy Act or European data protection law; 

(ii) provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;

 (iii) processing is necessary for compliance with a legal obligation to which you are subject; 

(iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; 

(v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party. We may also combine or aggregate some of your Personal Information to better serve you and to improve and update our Website and Services. 

We rely on the following legal bases as defined in the GDPR upon which we collect and process your Personal Information: User’s consentPersonal Information is already publicly available note that under some legislations, we may be allowed to process information until you object to such processing by opting out, without having to rely on consent or any other of the legal bases above. In any case, we will be happy to clarify the specific legal basis that applies to the processing, particularly whether the provision of Personal Information is a statutory or contractual requirement or a requirement necessary to enter into a contract.

In case of Services requiring payment, you may need to provide your credit card details or other payment account information, which will be used solely for processing payments. We use third-party payment processors (“Payment Processors”) to assist us in processing your payment information securely. Payment Processors adhere to the latest security standards managed by the PCI Security Standards Council, a joint effort of brands like Visa, MasterCard, American Express, and Discover. Sensitive and private data exchange happens over an SSL-secured communication channel and is encrypted and protected with digital signatures. The Website and Services also comply with strict vulnerability standards to create as secure an environment as possible for Users. We will share payment data with the Payment Processors only to the extent necessary for the purposes of processing your payments, refunding such payments, and dealing with complaints and queries related to such payments and refunds. Please note that the Payment Processors may collect some Personal Information from you, which allows them to process your payments (e.g., your email address, address, credit card details, and bank account number) and handle all the steps in the payment process through their systems, including data collection and data processing. The Payment Processors’ use of your Personal Information is governed by their respective privacy policies, which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies.

You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Website and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so on your account's settings page on the Website or by contacting us.

Depending on the requested Services or as necessary to complete any transaction or provide any Service you have requested, we may share your information with our trusted subsidiaries and joint venture partners, affiliates, contracted companies, and service providers (collectively, “Service Providers”) we rely upon to assist in the operation of the Website and Services available to you and whose privacy policies are consistent with ours or who agree to abide by our policies with respect to Personal Information. 

We will not share any information with unaffiliated third parties. Service Providers are not authorized to use or disclose your information except as necessary to perform services on our behalf or comply with legal requirements. Service Providers are only given the information they need to perform their designated functions. We do not authorize them to use or disclose any provided information for their marketing or other purposes. 

We will share and disclose your information only with the following categories of Service Providers: Advertising networks, Affiliate programs, Cloud computing services, Communication and collaboration services data, storage services financial services, government agencies Order fulfillment servicesPerformance monitoring servicesProduct engineering and design servicesSales and marketing servicesSocial networksUser authentication servicesWebsite hosting service providersWe may also disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.In the event, we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and your Personal Information will likely be among the assets transferred.

We will retain and use your Personal Information for the period necessary to comply with our legal obligations, enforce our agreements, resolve disputes, and unless a longer retention period is required or permitted by law, up to a maximum of 120 months. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own, including the USA. Transferring your Personal Information to countries outside the European Union will be made only if you have explicitly consented to it or in the cases provided for by the GDPR and will be processed in your interest. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer occurs, you can find out more by checking the relevant sections of this Policy or by contacting us using the information provided in the contact section.In certain instances, we may engage third-party service providers to assist us in delivering our digital products or to improve our offerings. These third-party service providers are contractually bound to handle your information with utmost confidentiality and are strictly prohibited from using your data for any purposes other than fulfilling their designated tasks.In the event of any legal obligation or compliance with regulatory authorities, we may disclose your information as required by law or to protect our rights and interests.Rest assured, your trust and confidence in our commitment to safeguarding your personal information are of paramount importance to us. If you have any concerns or questions regarding the sharing of information with third parties in India, please feel free to contact our dedicated customer support team. We value your privacy and will continue to uphold the highest standards in safeguarding your data.

If you are a resident of the European Economic Area (“EEA”), you have certain data protection rights, and we aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:

(i) You have the right to withdraw consent where you have previously given your consent to processing your Personal Information. To the extent that the legal basis for our processing of your Personal Information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. 

(ii) You have the right to learn if we are processing your Personal Information, obtain disclosure regarding certain aspects of the processing, and obtain a copy of your Personal Information undergoing processing.

 (iii) You have the right to verify the accuracy of your information and ask for it to be updated or corrected. You also have the right to request us to complete the Personal Information you believe is incomplete. 

(iv) You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent. Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.  You must know that, however, should your Personal Information be processed for direct marketing purposes, you can object to that processing at any time without providing any justification. To learn whether we are processing Personal Information for direct marketing purposes, refer to this Policy's relevant sections. 

(v) You have the right, under certain circumstances, to restrict the processing of your Personal Information. These circumstances include the following: the accuracy of your Personal Information is contested by you, and we must verify its accuracy; the processing is unlawful, but you oppose the erasure of your Personal Information and request the restriction of its use instead; we no longer need your Personal Information for the purposes of the processing, but you require it to establish, exercise or defend your legal claims; you have objected to processing pending the verification of whether our legitimate grounds override your legitimate grounds. Where processing has been restricted, such Personal Information will be marked accordingly and, with the exception of storage, will be processed only with your consent or for the establishment, to exercise or defense of legal claims, for the protection of the rights of another natural, or legal person or for reasons of important public interest. 

(vi) You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us. These circumstances include: the Personal Information is no longer necessary in relation to the purposes for which it was collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes, and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure, such as where processing is necessary: for exercising the right of freedom of expression and information; For compliance with a legal obligation; or for the establishment, exercise, or defense of legal claims. 

(vii) You have the right to receive your Personal Information that you have provided to us in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance from us, provided that such transmission does not adversely affect the rights and freedoms of others.

(viii) You have the right to complain to a data protection authority about our collection and use of your Personal Information. If you are not satisfied with the outcome of your complaint directly with us, you have the right to lodge a complaint with your local data protection authority. For more information, please get in touch with your local data protection authority in the EEA. This provision is applicable provided that your Personal Information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.

Consumers residing in California are afforded certain additional rights with respect to their Personal Information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, this section applies to you. In addition to the rights, as explained in this Policy, California residents who provide Personal Information as defined in the statute to obtain Services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the categories and specific pieces of Personal Information we have collected and disclosed. Furthermore, California residents have the right to request the deletion of their Personal Information or opt-out of the sale of their Personal Information, which may include selling, disclosing, or transferring Personal Information to another business or a third party for monetary or other valuable consideration. To do so, contact us. We will not discriminate against you if you exercise your rights under the CCPA.

Any requests to exercise your rights can be directed to us through the contact details provided in this document. Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you claim to be or that you are the authorized representative of such a person. Suppose we receive your request from an authorized representative. In that case, we may request evidence that you have provided such an authorized representative with power of attorney or that the authorized representative otherwise has valid written authority to submit requests on your behalf. You must include sufficient details to allow us to understand the request and respond to it properly. We cannot respond to your request or provide you with Personal Information unless we verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

Our Website and Services use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. You may learn more about cookies and how they work in this guide. We may use cookies to collect, store, and track information for security, personalization, and statistical purposes. See our cookie policy for further information on the cookies we collect and their purpose. Please note that you have the ability to accept or decline cookies. Most web browsers automatically accept cookies by default, but you can modify your browser settings to decline cookies if you prefer.

Our Website and Services may use third-party analytics tools that use cookies, web beacons, or similar information-gathering technologies to collect standard internet activity and usage information. The information gathered is used to compile statistical reports on User activity, such as how often users visit our Website and Services, what pages they visit and for how long, etc. We use the information obtained from these analytics tools to monitor the performance and improve our Website and Services.

Some browsers incorporate a Do Not Track feature that signals to websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information about a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, the Website and Services are not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information.

We may display online advertisements and share aggregated and non-identifying information about our customers that our advertisers or we collect through your use of the Website and Services. We do not share personally identifiable information about individual customers with advertisers. Sometimes, we may use this aggregated and non-identifying information to deliver tailored advertisements to the intended audience. We may also permit certain third-party companies to help us tailor advertising that we think may interest users and to collect and use other data about User activities on the Website. These companies may deliver ads that might place cookies and otherwise track User behavior.

Our Website and Services may include social media features, such as the Facebook and Twitter buttons, Share This buttons, etc. (collectively, “Social Media Features”). These Social Media Features may collect your IP address and what page you are visiting on our Website and Services and may set a cookie to enable Social Media Features to function properly. Social Media Features are hosted either by their respective providers or directly on our Website and Services. Your interactions with these Social Media Features are governed by the privacy policy of their respective providers.

We offer electronic newsletters to which you may voluntarily subscribe at any time. We are committed to keeping your e-mail address confidential and will not disclose your email address to any third parties except as allowed in the information use and processing section or for the purposes of utilizing a third-party provider to send such emails. We will maintain the information sent via e-mail in accordance with applicable laws and regulations. In compliance with the CAN-SPAM Act, all e-mails sent from us will clearly state who the e-mail is from and provide clear information on contacting the sender. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us. However, you will continue to receive essential transactional emails.

We offer push notifications to which you may also voluntarily subscribe anytime. To ensure push notifications reach the correct devices, we use a third-party push notifications provider that relies on a token unique to your device, which is issued by the operating system of your device. While accessing a list of device tokens is possible, they will not reveal your identity, unique device ID, or contact information to our third-party push notifications provider or us. We will maintain the information sent via e-mail in accordance with applicable laws and regulations. If, at any time, you wish to stop receiving push notifications, adjust your device settings accordingly.

We may engage in affiliate marketing and have affiliate links on the Website and Services to offer you related or additional products and services. If you click on an affiliate link, a cookie will be placed on your browser to track any sales for purposes of commissions.

The Website and Services contain links to other resources not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy statements of each and every resource that may collect Personal Information.

We secure the information you provide on computer servers in a controlled, secure environment protected from unauthorized access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in our control and custody. However, no Internet or wireless network data transmission can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts. As the security of Personal Information depends in part on the security of the device you use to communicate with us and the security you use to protect your credentials, please take appropriate measures to protect this information.

In the event we become aware that the security of the Website and Services has been compromised or Users’ Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe there is a reasonable risk of harm to the User due to the breach or if notice is otherwise required by law. When we do, we will send you an email.

We reserve the right to modify this Policy or its terms related to the Website and Services at any time at our discretion. When we do, we will revise the updated date at the bottom of this page. We may also provide notice to you in other ways at our discretion, such as through the contact information you have provided. An updated version of this Policy will be effective immediately upon posting the revised policy unless otherwise specified. Your continued use of the Website and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different than what was stated at the time your Personal Information was collected.

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Website and Services and submitting your information, you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Website and Services.

If you have any questions, concerns, or complaints regarding this Policy or the information we hold about you, or if you wish to exercise your rights, we encourage you to contact us using the details below: https://attainpinnacle.com/contactconnect@attainpinnacle.comWe will attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. 

This document was last updated on 15th July 2023