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Privacy Policy

Last Updated February 13, 2025

PeopleGrove Privacy Policy

Effective Date: February 13, 2025

PeopleGrove Inc. company, ( “PEOPLEGROVE”, “us”, “we”, or “our”), respects your privacy.  It is our policy to comply with all applicable privacy and data protection laws, including in the choices we offer with respect to your Personal Information (as defined below). This Privacy Policy (“Privacy Policy”) will provide you with information regarding how PEOPLEGROVE collects, uses, and discloses Personal Information about you, including the choices we offer with respect to that data. The purpose of this Privacy Policy is to inform you about the types of Personal Information that we may collect and process when you visit our website (the “Site”) or transact with us. By using our Site, you agree to the collection and use of information under this Privacy Policy and with our Terms of Service, which govern your use of the Site, available here https://www.peoplegrove.com/terms-of-service/.

1.                       Objective and Scope

This Privacy Policy explains how we use and protect the Personal Information of the individuals who visit our Site or otherwise transact with us. This Privacy Policy does not apply to our job applicants, current employees, former employees, or independent contractors.

When we refer to “Personal Information”, we mean any information that is related to an identified or identifiable natural person. This may include direct identifiers such as your name, postal address, email address, and mobile number, and also may include all other information which is linked or linkable to that information.

2.                       Collection of Personal Information
        a.                      Information that You Provide

PEOPLEGROVE and its Service Providers (defined below) may collect Personal Information that you provide directly to PEOPLEGROVE and/or its Service Providers via the Site or when you interact with us. For example, PEOPLEGROVE collects Personal Information when you use our Site, subscribe to notifications, participate in promotional activities, including at conferences and events, communicate or transact with us through the Site, contact us via any of our Contact Us forms, request support, or request a demo. In addition, when you interact with Third-Party Services (defined below), you may be able to provide Personal Information to those third parties and such Personal Information may be disclosed to PEOPLEGROVE.

We may ask for and you may choose to provide the below information, which may include Personal Information, when you use the Site or when you contact us directly:

  • First and last name
  • Email address
  • Phone number
  • University or company name
  • Position at your university or company
  • Academic program
  • PEOPLEGROVE services of interest to you, your organization, or employer
  • PEOPLEGROVE service for which you are requesting support
  • Any additional comments that you may provide
       b.                      Information Collected Automatically

We may also collect information automatically about you and your use of our Site, your interactions with our Site, as well as information regarding your computer or other smart/mobile device used to access our Site. The information may be collected using certain tracking technologies, as described in Section 11, such as Cookies, pixels, tags, application programming interfaces (“APIs”), and Web beacons, etc. and may include:

  • Your interactions with our Site, emails, communications, and messages
  • Your interactions with our customer support such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings
  • Device and software information such as:
    • Device ID
    • Device model
    • Platform
    • Operating system, including type and installed version
    • Time zone setting
    • Mobile carrier
    • Screen resolution
    • Internet Protocol address (“IP Address”)
    • Your interactions with the Site
    • Other unique device identifiers
  • We capture information related to the performance of the Site, such as crash logs, analytics, and other performance statistics generated when you use the Site
        c.                      Information We Collect from Other Sources

PEOPLEGROVE may also obtain information about you from other sources, including Service Providers and Third-Party Services (as defined below). We are not responsible or liable for the accuracy of the information provided to us by third parties or for third-party policies or practices.

3.                       How We Use Your Information

Our primary purpose in collecting your Personal Information, is to provide the Site and its various features and to market our products and services. PEOPLEGROVE may use your Personal Information for any purpose not inconsistent with our statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including without limitation, to:

  • Fulfill or meet the reason you provided the information, including to: (1) provide you services or carry out transactions you have requested; (2) provide you a more consistent experience in interacting with us, including by learning more about you and how you use and interact with the Site, products, and services; (4) plan, manage, and perform under our contractual relationships with our customers; and (5) provide you with customer or technical support including addressing support queries, or to diagnose any problems with our servers/systems, etc.
  • Communicate with you about our Site or provide you with information, including marketing and promotional materials that may be of interest to you and provide information about relevant PEOPLEGROVE products, services, and transactions, including, for example, pricing information, technical data, invoice, or information about product or service improvements
  • Send you transactional or relationship messages, such as customer service responses, messages regarding billing and accounts receivable, and other administrative messages
  • Administer our systems and monitor the use of our Site, including enforcing our terms (such as determining free trial eligibility)
  • Confirm your identity if you are exercising legal rights
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us
  • Disclose to third parties for the performance of services provided by us, including third-party providers of services related to the operation and management of the Site, or in connection with the administration and support of the activities noted above
  • Addressing legal issues, including: (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal process; (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of the Site, products or services; and (v) protecting the Company’s rights or property, or yours or others’ health, safety, welfare, rights, or property.
  • Any other purpose disclosed by us when you provide the information or with your consent
4.                       Information Disclosure

Generally, we may disclose information about you for any purpose not inconsistent with our statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, as follows:

       a.                      Service Providers and Affiliates

We may provide Personal Information, to affiliated entities and to our contracted vendors and other trusted businesses or persons to process it for us who are involved in the direct delivery of services to you (“Service Providers”) (such as email service providers), based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

       b.                      Promotional Partners

We may disclose your Personal Information to third parties who partner with us to provide products or services to our customers (“Promotional Partners”).

       c.                      Advertising Networks

We may provide Personal Information, to certain third parties who use this Personal Information to as part of their advertising efforts, which may include communications and offers for products and services (“Advertising Networks”).

       d.                      Legal

In the event of any requirement by court order, government, or quasi-government agency to disclose your Personal Information, we will disclose information as may be legally required. We may also disclose your Personal Information if we, in good faith, believe that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal processes. In the event PEOPLEGROVE is merged with or acquired by another company or in case of reorganization or restructuring of the business, we and our affiliates may share your Personal Information, wholly or in part, with another business entity by virtue of such transaction.

5.                       Your Choices for Promotional Content

You may opt out of receiving promotional emails from us by following the instructions in those emails.  If you opt out, we may still send you non-promotional emails, such as those about our ongoing business relations.

6.                       Third-Party Services

Please also note that our Site may contain integrations, tracking technologies, and links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those technologies and sites. Some examples of such third-party services include those websites, platforms, and services operated by our business partners, suppliers, advertisers, sponsors, licensors, and other third parties (collectively, “Third-Party Services”). The inclusion of these Third-Party Services on the Site does not imply any endorsement of the activities or content of the related websites, apps, or platforms, nor any association with their operators. To learn about the information collected by these third-party websites, apps, and plugins, please visit their privacy policies. We encourage you to review the privacy policies for the websites, apps, and social media platforms you visit before using them or providing Personal Information.

7.                       Children’s Privacy

We do not knowingly permit any person who is under 13 years of age to register or to provide any other Personal Information. If we become aware that any Personal Information of persons less than 13 years of age has been collected on the Site, we will take appropriate steps to delete any such information. If you become aware that a person less than 13 years of age is using our Site, please contact us via the methods in Section 14 “Contact Us”.

We do not, to the best of our knowledge, disclose the Personal Information of persons under the age of 16.

8.                       California Privacy Notice

This California Privacy Notice (“California Notice”) applies to “Consumers” as defined under the California Consumer Privacy Act, including as amended by the California Privacy Rights Act (together, the “CCPA”). In California, the term “Consumer” is not limited to data subjects acting as individuals in an individual or household goods and services context and includes individuals acting in a business-to-business. Capitalized terms used but not defined in this California Notice shall have the meanings given to them under the CCPA. This California Notice is designed to meet our obligations under the CCPA. In the event of a conflict between any other PEOPLEGROVE policy, notice, or statement, this California Notice will prevail as to Consumers unless stated otherwise.

       a.                      Notice of Data Practices

The description of our data practices in this California Notice covers our Site, over the twelve (12) months prior to the Effective Date (“Reporting Period”). This California Notice serves as our notice at Collection.

This California Notice describes our data practices, including our collection, use, disclosure, and Sale of Consumers’ Personal Information as defined by the CCPA.

Generally, we may retain, use, and disclose your Personal Information to provide you our Site as otherwise related to the operation of our business, including for the one or more of the “Business Purposes” described in Section 3 of this Privacy Policy entitled “How We Use Your Information”, and for any other Business Purpose permitted by the CCPA.

During the Reporting Period, we collected, retained, disclosed, and otherwise process Personal Information about Consumers as follows:

Category of Personal Information

Examples of Personal Information Collected and Retained

Categories of Recipients

Identifiers

First and last name, IP Address, email address, and device ID.

Disclosures for Business Purposes:

·        Service Providers (e.g., cloud providers, IT service providers, payment processors, analytics companies, marketing service providers);

·        Affiliates;

·        Governmental entities (making requests pursuant to legal or regulatory process); and/or

·        Other parties (e.g., litigants).

Sale/Share: Promotional Partners; Advertising Networks.

Personal Records

First and last name, address, telephone number, passport number, driver’s license or state identification card number, education or employment information, bank account number, credit card number, or debit card number (note: some Personal Information included in this category may overlap with other categories).

Disclosures for Business Purposes:

·        Service Providers (e.g., cloud providers, IT service providers, payment processors, marketing service providers);

·        Affiliates;

·        Governmental entities (making requests pursuant to legal or regulatory process); and/or

·        Other parties (e.g., litigants).

Sale/Share: N/A

Customer Account Details / Commercial Information

PEOPLEGROVE services of interest to you, your organization or employer, PEOPLEGROVE services for which you are requesting support, your interactions with our communications including customer support, and records of products or services purchased.

Disclosures for Business Purposes:

·        Service Providers (e.g., cloud providers, IT service providers, analytics companies, marketing service providers);

·        Affiliates;

·        Governmental entities (making requests pursuant to legal or regulatory process); and/or

·        Other parties (e.g., litigants).

Sale/Share: Promotional Partners; Advertising Networks.

Internet or Other Electronic Network Activity Information

Browsing and search history and information regarding the Consumer’s interaction with our Site.

Disclosures for Business Purposes:

·        Service Providers (e.g., cloud providers, IT service providers, analytics companies, marketing service providers);

·        Affiliates;

·        Other parties (e.g., litigants).

Sale/Share: Promotional Partners; Advertising Networks.

Geolocation Data

If you interact with us online, we may gain access to the approximate location of the device you are using.

Disclosures for Business Purposes:

·        Service Providers (e.g., cloud providers, IT service providers, analytics companies, marketing service providers);

·        Affiliates;

·        Governmental entities (making requests pursuant to legal or regulatory process); and/or

·        Other parties (e.g., litigants).

Sale/Share: Promotional Partners; Advertising Networks.

Professional and Employment Information

Professional, educational, or employment-related information.

Disclosures for Business Purposes:

·        Service Providers (e.g., cloud providers, IT service providers, analytics companies, marketing service providers);

·        Affiliates;

·        Governmental entities (making requests pursuant to legal or regulatory process); and/or

·        Other parties (e.g., litigants).

Sale/Share: Promotional Partners; Advertising Networks.

Inferences from Personal Information Collected

Inferences drawn from Personal Information to create a profile about a Consumer reflecting their preferences.

Disclosures for Business Purposes:

·        Service Providers (e.g., cloud providers, IT service providers, analytics companies, marketing service providers);

·        Affiliates;

·        Other parties (e.g., litigants).

Sale/Share: Promotional Partners; Advertising Networks.

Sensitive Personal Information

Financial data (e.g., financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account).

Disclosures for Business Purposes:

·        Service Providers (e.g., cloud providers, IT service providers, payment processors);

·        Affiliates;

·        Other parties (e.g., litigants).

Sale/Share: N/A

Because there are numerous types of Personal Information in each category, and various uses for each Personal Information type, actual retention periods vary. Because there are so many different types of personal data in certain categories, and so many purposes and use cases for different data, we are unable to provide retention ranges based on categories of personal data in a way that would be meaningful and transparent to you. Actual retention periods for all personal data will depend upon how long we have a legitimate purpose for the retention, consistent with the collection purposes and applicable law. For instance, we may maintain business records for as long as relevant to our business and may have a legal obligation to hold personal data for as long as potentially relevant to prospective or actual litigation or government investigation.

b.                      California Privacy Rights:
       i.                         Rights to Know, Delete, Correct, Opt Out of Sensitive Personal             Information Disclosures, and Opt Out of Automated Decisionmaking

If you are a California resident, you may have certain rights with respect to your Personal Information under the CCPA, including the following:

  • The right to know whether PEOPLEGROVE collected, sold, shared, or disclosed for a business purpose your Personal Information;
  • The right to delete Personal Information;
  • The right to correct inaccurate Personal Information;
  • The right to request specific pieces of Personal Information PEOPLEGROVE collected in a clear and portable manner; and
  • The right to make such requests without discrimination.

We only Process Sensitive Personal Information for purposes that are exempt from choice under the CCPA. For example, we may process your Personal Information to perform the services that you requested.

We do not engage in automated decision making or profiling, as defined by the CCPA.

       ii.                       Submitting Requests to Know, Delete, and Correct

To make such a request, you may contact us via email at [email protected]. As permitted or required by California law, any request you submit to us must be a Verifiable Consumer Request, meaning when you make a request, we may ask you to provide verifying information, such as your name, email, phone number, account and/or transaction information. We will review the information provided and may request additional information (e.g., transaction history) via email or other means to ensure we are interacting with the correct individual. We will not fulfill your right to know (categories), right to know (specific pieces), right to delete, or right to correct request(s) unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we collected Personal Information. We do not verify opt-outs of sale/sharing unless we suspect fraud.

You may use an authorized agent to make a request for you, subject to our verification of the agent, the agent’s authority to submit requests on your behalf, and of you. Once your agent’s authority is confirmed, they may exercise rights on your behalf subject to the agency requirements of applicable laws.

       iii.                     Opt Out of Sale or Sharing

We permit Consumers to opt-out of Personal Information “Sales” and “Sharing” of Personal Information for cross-context behavioral advertising (i.e., the use of Personal Information derived from different businesses or services to target advertisements).

Advertising, Analytics, and other similar Third-Party Services may associate Cookies and other tracking technologies that collect Personal Information about you on our services, or otherwise collect and process Personal Information that we make available about you, including digital activity information. We understand that giving access to Personal Information on our services or otherwise, to Third-Party Services could be deemed a Sale/Sharing under State Privacy Laws and as such, we will treat such Personal Information (e.g., Cookie ID, IP address, and other online IDs and internet or other electronic activity information) collected by Third-Party Services, where not limited to acting as our service provider, as a Sale/Sharing that is subject to a Do Not Sell/Share opt out request.

       iv.                     Opt-out for Non-Cookie Personal Information

If you would like to opt-out of the sale/sharing of your non-Cookie Personal Information (e.g., your email address), you must submit an opt-out request via email to [email protected].

       v.                       Opt-out for Cookie Personal Information

If you would like to limit our processing of your Cookie-related Personal Information for targeted advertising or opt-out of the sale/sharing of such data, you must exercise a separate opt-out request via our consent management tool here https://www.peoplegrove.com/. This is because we must use different technologies to apply your opt-out of Cookie Personal Information and opt-out of non-Cookie Personal Information. Our Cookie management tool enables you to exercise such an opt-out request and enable certain Cookie preferences on your device. You must exercise your preferences on each of our websites you visit, from each browser you use, and on each device you use. Since your browser opt-out is designated by a Cookie, if you clear or block Cookies, your preferences will no longer be effective, and you will need to enable them again via our Cookie management tool. Note that if you use ad blocking software, our Cookie banner may not appear when you visit our services, and you may have to use the link above to access the tool.

       vi.                     Global privacy control or “GPC”

The CCPA requires businesses to process GPC signals, also referred to as opt-out preference signals, which are signals sent by a platform, technology, or mechanism, enabled by individuals on their devices or browsers, that communicate the individual’s choice to opt-out of the sale or sharing of Personal Information. To use a GPC, you can download an internet browser or a plugin to use on your current internet browser and follow the settings to enable the GPC. We have configured the settings of our consent management platform to receive and process GPC signals on our Site, which is explained by our consent management tool here https://www.peoplegrove.com/ . We process GPC with respect to sales and sharing that may occur in the context of collection of Cookie Personal Information, discussed above, and apply it to the specific browser on which you enable GPC. We do not: (1) charge a fee for use of our service if you have enabled GPC; (2) change your experience with any product or service if you use GPC; or (3) display a notification, pop-up, text, graphic, animation, sound, video, or any interstitial in response to the GPC.

We do not knowingly sell or share the Personal Information of Consumers under 16 years of age. If you think we may have unknowingly collected the Personal Information of a Consumer under 16 years old, please Contact Us as described in Section 14.

c.                      Additional Notice for California Residents

California’s “Shine the Light” law permits users of our Site who are California residents to request certain information regarding our disclosure of Personal Information to third parties for those third parties’ own direct marketing purposes. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us in the following ways: Postal Mail: PEOPLEGROVE Higher Education Group, 1 Coastway Blvd, Suite 101, Warwick, RI 02886; or by e-mail at [email protected]. Please note that the CCPA and Shine the Light are different laws offering different rights and requests must be made separately, however, a non-Cookie Do Not Sell request is broader and will function to opt you out of disclosures for third-party direct marketing purposes under Shine the Light.

9.                       Retention Period

We will retain your Personal Information for the period reasonably necessary to achieve the business and commercial purposes described in this Privacy Policy or any other notice provided at the time of collection. Your Personal Information may be retained longer if required or permitted by applicable law.

10.                  Security

The Site uses commercially reasonable security practices and procedures industry practices and procedures designed to help keep your Personal Information safe and secure. Unfortunately, the transmission of information over the Internet is not completely secure.  Although we strive to protect your Personal Information, we cannot guarantee the security of your data; any transmission is at your own risk.

11.                  Cookie Policy

This Cookie policy addresses how PEOPLEGROVE uses Cookies while you are on our Site. We collect certain information about you and your device as follows.

a.                      What are Cookies?

We use the term “Cookies” to refer to all tracking technologies we may deploy, including Cookies, pixels, tags, APIs, and web beacons, etc., which store and access information on the device that you use to access the Site, such as your computer, tablet, or mobile phone. We use Cookies to enhance the online experience of our visitors and to better understand how the Site is used. The types of Cookies that we may use include:

  • Cookies: A Cookie is a small text file that is stored on a user’s device, which may be session ID Cookies or tracking Cookies. Session Cookies make it easier for you to navigate the Service and expire when you close your browser. Tracking Cookies remain longer and help in understanding how you use the Service and enhance your user experience. Cookies may remain on your hard drive for an extended period. If you use your browser’s method of blocking or removing Cookies, some but not all types of Cookies may be deleted and/or blocked, and as a result, some features and functionalities of the Service may not work. Please note that you will not be able to opt out of receiving certain Cookies that are strictly necessary for the delivery of a service requested by you.

    The Site uses “session Cookies.” A session Cookie does not identify you personally and expires after you close your browser. The Site also uses “persistent Cookies.” These Cookies do not expire when you close your browser. Persistent Cookies stay on your computer until you delete them, or they expire. By assigning your computer a unique identifier, we can create a database of your previous choices and preferences which can be provided by us automatically, saving you time and effort on future visits.

  • Web Beacons: Web beacons are small graphic images, also known as “Internet tags”, “pixels”, or “clear gifs”, embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the Service, to monitor how users navigate the Service, and to count content views.
  • Embedded Scripts: An embedded script is programming code designed to collect information about your interactions with the Service. It is temporarily downloaded onto your computer from PEOPLEGROVE’s web server, or from a third party with which PEOPLEGROVE works and is active only while you are connected to the Service and deleted or deactivated thereafter.
  • Device Recognition Technologies: Device recognition technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household).
  • Device and Activity Monitoring and Session Replay: Device and activity monitoring and session replay technologies monitor, and may record, some of your interactions with the Service, and/or collect and analyze information from your device such as, for example, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving the Services and customizing or optimizing your experience on the Services.  This may also include technologies that monitor and record usage sessions to help us better understand, track, and improve the use of our Services.
b.                      How Does Our Site Use Cookies and Other Tracking Technologies?

PEOPLEGROVE uses Cookies to identify you and your interests, to remember your preferences, and to track your use of our Site. We also use Cookies to control access to certain content on the Site, protect the Site, and to process any requests that you make to us.

As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

Some information about your use of the Service and certain other online services may be collected using Cookies across time and services and used by PEOPLEGROVE and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain other online services.

c.                      How Can You Exercise Your Cookies Choices?

If you do not want the Site to collect information using Cookies, you can set your web browser to reject Cookies from the Site. Each browser is different, so you should check your browser's “Help”, “Tools” or “Edit” menu/facility to learn how to change your Cookie preferences (e.g., for “do-not-track-me” functions). For further information about Cookies, including how to see what Cookies have been set on your device and how to manage and delete them, please visit www.allaboutcookies.org. You may also exercise your Cookie choices through our Consent Management Platform, which can be found here [link]. Please note that we may continue to collect and share Personal Information about you with other third parties, including to continue providing services to you where sharing of your Personal Information is for purposes other than cross-context behavioral advertising and as permitted by law. Adjusting your settings using our Consent Management Platform will only opt you out of any sharing activity on the browser and device you are using for the Site once you tap the “confirm” button.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. PEOPLEGROVE currently does not alter its practices when PEOPLEGROVE receives a “Do Not Track” signal from a visitor’s browser. To learn more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but PEOPLEGROVE is not responsible for the completeness or accuracy of this third-party information.

We may also use Google Ad Services and Google Analytics. To learn more about the data Google collects and how your data is used by it and to opt out of certain Google browser Interest-Based Advertising, please visit here. You may exercise choices regarding the use of Cookies from Google Analytics by going here or downloading the Google Analytics Opt-out Browser Add-on.

If you reject Cookies, you may still use the Site, but the Site may not function as intended.

If you have any questions about our use of Cookies, please contact us via the methods provided in Section 14 “Contact Us”.

12.                  Canadian Privacy Rights

If you are located in Canada, the Personal Information Protection and Electronic Documents Act and applicable provincial privacy legislation (collectively, “Canadian Privacy Laws”) govern the collection, use, and disclosure of Personal Information by organizations in the course of commercial activities. If you are located in Canada, this Canadian Privacy Rights section applies to you. If you live in Canada and any part of our general Privacy Policy conflicts with this Canadian Privacy Rights section, this Canadian Privacy Rights section governs to the extent of the conflict.

       a.                      Consent

Your use of the Site signifies your consent to our collection, use, and disclosure of your Personal Information as described in this Privacy Policy, as it may be amended from time to time. Your continued use of the Site after having been informed of any amendment to this Privacy Policy will be deemed a consent by you to any such amendment; if you do not agree with this Privacy Policy or any amendment, do not access the Site.

If you provide Personal Information of a third party to us, you represent that you have complied with the requirements of Canadian Privacy Laws with regards to its collection before providing it to us and for us its use and disclosure as set out in this Privacy Policy.

       b.                      Online Behavioural Advertising

If you would like to limit our processing of your Cookie-related Personal Information for behavioural advertising, you may exercise an opt-out request via our consent management tool here https://www.peoplegrove.com/. Our Cookie management tool enables you to exercise such an opt-out request and enable certain Cookie preferences on your device. You must exercise your preferences on each of our websites you visit, from each browser you use, and on each device you use. Since your browser opt-out is designated by a Cookie, if you clear or block Cookies, your preferences will no longer be effective, and you will need to enable them again via our Cookie management tool. Note that if you use ad blocking software, our Cookie banner may not appear when you visit our services, and you may have to use the link above to access the tool. For more information regarding our use of Cookies, please see our Cookie Policy above.

       c.                      Your Rights
              i.                         Withdrawal of Consent

Under Canadian Privacy Laws, you may withdraw your consent to our collection, use, or disclosure of your Personal Information at any time, subject to reasonable prior notice and applicable legal and contractual restrictions.  Depending on the nature of the Personal Information for which you choose to withdraw your consent, if you do withdraw your consent we may not be able to provide our products and services to you; we will explain the implications of withdrawing consent to you when we receive your notice of withdrawal. If you withdraw your consent in respect of any Personal Information that has been provided to third parties, we will advise such third parties of your withdrawal to the extent required by Canadian Privacy Laws.

              ii.                       Right to be informed

You have the right to be information about the Personal Information that we collect, use, process, disclose, and retain about you.  You may request additional information regarding our Personal Information processing practices by contact us at [email protected].

              iii.                     Right to an Accounting

You have the right to receive an accounting of the categories of third parties to whom we have disclosed your Personal Information.

              iv.                     Rights of Access, Correction

You have the right to access the Personal Information we maintain about you and you have the right to correct or supplement your Personal Information if it is inaccurate or misleading and to have it completed if it is incomplete. Where appropriate, you have the right to have third parties to whom we have transmitted your Personal Information informed of the correction or supplemental information.

If we cannot provide you with access to your Personal Information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

If we refuse to rectify your Personal Information, we will attach a statement to the record that sets out the reason why we have refused to make the rectification.

We will also retain the Personal Information that has been the subject of an access request or a rectification request for as long as necessary to allow you to exhaust any recourse provided by law.

              v.                       Right to Lodge Complaints

You have the right to lodge a complaint about our collection, use or disclosure of your Personal Information with the Office of the Privacy Commissioner of Canada and any applicable provincial privacy commissioner’s office having jurisdiction.

       d.                      Additional Rights in Quebec

If you are in the province of Quebec, you have the following additional rights:

              i.                         Right of Deletion

Under certain circumstances, you may request the deletion of your Personal Information.

              ii.                       Right to Data Portability

You have the right to be provided a copy of your Personal Information in a structured, commonly used, and machine-readable format, or to have it transferred directly to another entity or person.

       e.                      Exercising Your Rights

To exercise the above rights, email us at [email protected].  We will consider and process your request within a reasonable period of time and in any event within thirty days of receipt of your request or such longer time as we may be permitted under Canadian Privacy Laws.  Please be aware that under certain circumstances, Canadian Privacy Laws may limit your exercise of these rights.

       f.                        International Transfers

Your Personal Information may be transferred to and stored at a location outside of your jurisdiction of residence. Please note that local data protection laws where your Personal Information is stored or processed may not provide the same privacy protections as the data protection laws in force in your jurisdiction of residence, and Personal Information transferred to another jurisdiction may be subject to access by the courts of that jurisdiction, law enforcement authorities, and national security agencies. In cases where we need to transfer personal data outside of Canada, we will ensure that adequate safeguards, as required under applicable law, are implemented.

       g.                       Business Transfers

Where we disclose your Personal Information in the event of a business transfer described in our Privacy Policy above, we will ensure that the information is treated confidentially by the parties to the transaction and that the information will be protected by security safeguards appropriate to its sensitivity. If the transfer is completed, we will require that the parties to the transaction continue to treat your Personal Information in accordance with Canadian Privacy Laws.

       h.                      Service providers and Affiliates

We may disclose your Personal Information to Service Providers and Affiliates as described in Section 4, Information Disclosure above. Where we disclose Personal Information to Service Providers and Affiliates, we ensure that they are bound by contractual obligations to:

  • Use Personal Information only for purposes specified in the agreement;
  • Implement security measures consistent with the nature of the Personal Information processed and the processing activities; and
  • Destroy Personal Information at the end of the contract or when such Personal Information is no longer required to provide the services under the agreement with the Service Provider.
       i.                         Electronic Marketing Messages

If you are located in Canada, we will only send electronic marketing messages to you if we have your prior opt-in consent, unless an exception or a specific form of implied consent applies.

       j.                         Information security and governance

As described in Section 10, Security, above, we implement commercially reasonable security measures to protect your Personal Information from unauthorized access disclosure, alteration, or destruction. Such security measures include physical, technical, and administrative security controls. Our retention practices are set forth in Section 9, Retention, above. Each employee who uses Personal Information is bound by confidentiality obligations and has received appropriate training. In addition, each employee may only access Personal Information that is necessary for the performance of his or her duties. While we implement industry-standard security measures, no method of transmission over the Internet is entirely secure.

13.                  Change in Privacy Policy

This Privacy Policy is subject to change from time to time. We reserve the right, at our sole discretion, to modify the terms of this Privacy Policy to ensure compliance with applicable laws or in response to changing regulatory or operational requirements. Such requirements under applicable law shall be effective immediately (unless we state otherwise) and shall supersede the terms of this Privacy Policy. Your continued use of the Site after any updates will mean you have accepted those changes. If you do not agree to the updates, you should stop using the Site immediately.

14.                  Contact Us

If you have any questions about this Privacy Policy or our Site, you can contact us at [email protected] or via the contact information provided at the bottom of the page, or you can write and send a letter to us at the below address:

PeopleGrove Inc.

Attn: Legal Department / 1101 Wilson Blvd 6th Floor,

Arlington, VA 22209 USA.

Please do not share any private information in your message to us, unless we request such information as necessary to verify your identity prior to undertaking any action to fulfill a legal request.