Last Updated: February 2022
In the normal course of providing our products and services, Peridot Global Holdings Limited and our subsidiaries and affiliates (“Peridot Affiliates”) (collectively, the “Company, We, Us, or Our”) may collect, use, store, and/or share your Personally Identifiable Information (“PII”). This Privacy Notice (“Notice”) is intended to provide you with an explanation of the type of PII we may process, how we may process it, and the rights that may be available to you under law.
The Scope of this Notice
This notice applies to Peridot’s websites or social media pages (collectively “Sites”). This notice also applies to Our direct marketing activities as well as all customer interactions, including but not limited to the establishment of a customer relationship with Peridot. This Notice applies only where Peridot may collect, use, store, share, or otherwise process PII.
The term “Personally Identifiable Information” or “PII” as used throughout this Privacy Notice applies to any information that is used by or on behalf of Peridot that specifically and uniquely identifies you as an individual.
Please note that information which cannot reasonably be related to you is not considered PII and is not subject to this Notice. Only information which can be connected to you is subject to this Notice.
THE PERSONALLY IDENTIFIABLE INFORMATION WE MAY COLLECT AND WHEN WE COLLECT IT
We may collect and process your PII when:
- You visit our Sites.
- Information that you provide by filling in forms on Our websites. This includes information provided when subscribing to Our services (for example to receive information from us,) requesting further information.
- Technical details of your visits to our site. For more information on our use of “Cookies” see the “Information We Collect Automatically” section below.
- You have engaged Us to provide you services or products.
- We need to have sufficient information to provide you those services, as well as fulfill legal requirements associated with such services or products (e.g., payment and financial details, “Know Your Customer” requirements, etc.)
- You contact Us.
- If you contact us, We may keep a record of your contact details and the correspondence.
The PII we collect and process may consist of one or more of the following categories:
- Contact Details and Information About You
- First and last name
- Phone Number
- National Origin
- Employer/Employment-Related Information
- Employer’s Name
- Position or Title
- Employer Credit Details
- Tax Identifiers
- Government Identifiers (used for the purpose of confirming identity and complying with various fraud, anti-money laundering, and other relevant legal requirements)
- Social Security Number or National ID
- Government Identification Card Number
- Driver’s License Number
- Background Check Information (pursuant to Peridot’s “Know Your Customer” requirements)
- Site Browsing Details
- Geo-location Information
- Information we May Infer Based on the PII You Provide
- Fraud and Other Risk Assessments
- Audio and Visual Information
- Voice recordings when you contact Us
- Copies of photo IDs
HOW WE MAY COLLECT YOUR PERSONAL INFORMATION
We may collect your PII:
- Directly from you
- From third parties (e.g., third party fraud monitoring, credit services or Know Your Customer diligence services)
Why We Collect Your Personal Information and How We Use It
We collect your PII to deliver Our products and services, We use your information to send you email marketing communications about Peridot products and services, invite you to participate in our events, to onboard you as a customer, to validate your identity, to perform required “Know Your Customer” and other related fraud and anti-money laundering preventative measures. We may also use your personal information to comply with various legal reporting and retention requirements, and to otherwise communicate with you in accordance with applicable law.
If at any time you would like to unsubscribe from receiving promotional or commercial emails from us, you can click the unsubscribe link at the bottom of the email or send us an email at email@example.com.
Additionally, we may use your PII for the following purposes:
- To ensure that content from Our site is presented in the most effective manner for you and for your computer.
- To provide you with the information, products, and services that you request from Us or which We feel may interest you.
- To allow you to participate in interactive features of Our sites.
- To notify you about changes to what We do.
- To improve the products and services we offer the marketplace.
- To protect the integrity of Our website, Our services, and Our reputation.
- To prosecute or defend legal claims.
- To protect other users of Our websites, and to ensure no unlawful or unethical activity occurs through Our systems.
- To engage in business transactions where some of Our assets may be transferred to another entity.
- To meet legal, security, processing, and regulatory requirements.
- To respond to inquiries by legal, regulatory, or law enforcement authorities.
Note, at times, we may employ automated means to process your information.
How and With Whom We Share Your Information
We may disclose your PII with the following entities:
- With our vendors: We share your information with vendors that provide services on our behalf, such as enterprise software providers, customer service, audit and accounting firms, law firms, security vendors, marketing and events services, travel services, fraud and anti-money laundering prevention firms, and physical or electronic information storage services. We authorize vendors to use or disclose PII only as necessary to perform services on our behalf or comply with legal requirements. We require our vendors to contractually commit to protect the security and confidentiality of data they process on our behalf.
- With our Affiliates: We share Personal Information with our Affiliates to effectively deliver our products and services as well as for internal administrative purposes.
- With our unaffiliated strategic partners: We may share Personal Information with other select unaffiliated entities to carry out joint development, marketing, or management of our products or services.
- With our advertising partners: We share Personal Information with our advertising agencies in support of our marketing campaigns. We authorize these vendors to use or disclose Personal Information only as necessary to perform services on our behalf or comply with legal requirements.
- With governmental authorities and regulatory agencies (as necessary): We share information with law enforcement agencies, courts, other government authorities or other entities, where we believe it is necessary: (i) to comply with a legal or regulatory obligation; (ii) to protect the rights, safety, and property of Peridot, you, or others; and (iii) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities.
- With third parties during a merger, acquisition, joint venture, or divestiture: We may share Personal Information in connection with the consideration, negotiation, or completion of a corporate transaction, such as a merger or acquisition or a sale or transfer of all or a portion of our assets or business, including during any due diligence process.
Rights of Individuals Located in the European Union or United Kingdom
If you reside in the European Union (“EU”) or the UK, you have certain rights with respect to your Personal Information. We will rely on the following legal bases for processing your Personal Information, depending on our purpose for such processing.
- Consent. We will obtain your consent before using or sharing your data for advertising that is targeted based on your browsing history, online behavior, or other Personal Information that we or others may have collected about you. If you consent to our use of your Personal Information for any purpose, you have the right to withdraw consent at any time by contacting us at firstname.lastname@example.org.
- Legitimate Interests. Peridot has a legitimate interest in processing your Personal Information for certain business and safety purposes such as product adverse event reporting; fraud detection and prevention; network and system security; and non‐targeted marketing and advertising. Peridot also has a legitimate interest in processing your Personal Information for compliance with applicable law.
- In Performance of a Contract. We will process your Personal Information where necessary for the performance of a contract to which you and Peridot are a party. We may also process your Personal Information prior to entering that contract at your direction.
- Compliance with EU and UK Legal Obligations. We will process your Personal Information where necessary to comply with our obligations under UK, EU or EU Member State law. If we intend to use your Personal Information that we have collected for a different purpose other than the purpose disclosed to you, we will provide you with information about the secondary purpose and with any other information necessary to ensure fair and transparent processing prior to such use.
You have the following rights regarding the Personal Information we control about you, subject to applicable exceptions, under the GDPR (General Data Protection Regulation) and UK data protection laws:
- The right to request confirmation of whether Peridot processes Personal Information relating to you, and if so, to request a copy of that Personal Information;
- The right to request that Peridot corrects or updates your Personal Information that is inaccurate, incomplete or outdated;
- The right to request that Peridot delete your Personal Information in certain circumstances provided by law;
- The right to request that Peridot restrict the use of your Personal Information in certain circumstances, such as while Peridot considers another request that you have submitted (including a request that Peridot make an update to your Personal Information);
- The right to request that we export your Personal Information in a usable electronic format to another company, where technically feasible;
- The right to object to processing of your Personal Information based on Peridot’s legitimate interests at any time, upon which Peridot will no longer process the data, unless there are compelling legitimate grounds for our processing that override the interests, rights, and freedoms of the data subject, or the processing serves the purpose of asserting, exercising, or defending legal claims; and
- The right to withdraw consent at any time, where Peridot is processing your Personal Information based on your consent.
- You have the right to make a complaint with your local data protection authority if you believe that the processing of your Personal Information infringes your rights under the GDPR. Contact details for data protection authorities are available here.
To exercise your data protection rights, you may contact Peridot by emailing us at email@example.com. To verify your identity, we may require you to provide us with Personal Information prior to accessing any records containing Personal Information about you.
Rights of California Residents
Residents of the State of California have the right to request information from Peridot regarding other companies to whom the company has disclosed certain categories of information during the preceding year for the other companies’ direct marketing purposes. If you are a California resident and would like to make such a request, please email us at firstname.lastname@example.org write to us at: Attn: Legal Department 230 Park Avenue, Suite 1525 New York, NY 10169
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” to mean “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act. To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below:
- Right to Access Information. You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request.
- Right to Request Deletion of Information. You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identity before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
- Peridot’s Statement Concerning its Sale of Personal Information to Third Parties. Peridot does not sell nor receive any form of remuneration for the transmission of your Personal Information. Where Peridot does disclose your Personal Information to third parties, the disclosure is made for specified purposes directly related to the delivery of a needed service. Our third‐party partners are not permitted to use your Personal Information in any manner other than what is necessary to fulfill the services requested.
How to Submit a Request. You may submit a request to exercise your rights through any one of two means: You may email us at email@example.com or you may write to us at: Attn: Legal Department (Privacy Office) 230 Park Avenue, Suite 1525 New York, NY 10169
DISCLOSURE OF YOUR INFORMATION
We do not sell or share your PII with third parties for their own marketing purposes. We may disclose your PII to any affiliated company directly or indirectly owned by Peridot Global Holdings Limited for the purposes described in this Notice. Third parties to whom we generally disclose information are required by law or a contract with us, to keep your PII confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances and generally for purposes as follows:
- To provide the information and services you have requested from us;
- To notify you or allow our Affiliated companies to notify you of certain products or services offered by our affiliated companies;
- To process transactions through data processing service providers.
We are a global business. As a result, the data that We collect from you may be transferred to, processed, and stored at, any of Our locations or the locations of Our cloud service providers, which may be inside or outside the European Economic Area. Data may also be processed by staff around the world working for Us, or for one of Our service providers. These staff may be engaged in, among other things, the fulfillment of your information requests, or the provision of support services. We will store PII we collect about you as long as necessary to fulfill the purposes for which we collected it or where there are laws or regulations that may set a minimum period for which we must keep your PII. Your information may be transferred to, stored, and processed in a country that does not provide the same level of protection for Personal Information as the laws of your home country and may be available to the government of those countries under a lawful court order made in those countries. Where Peridot transfers personal data outside the EU, we do so in accordance with the terms of this Privacy Notice and applicable data protection law.
We have in place reasonable safeguards appropriate to the sensitivity of the information we maintain. Note that due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of PII disclosed over the Internet, and the Company expressly disclaims any such obligation.
UPDATES TO OUR PRIVACY NOTICE
This Privacy Notice may be updated periodically to reflect changes to our PII practices or the law. Please visit this page regularly for any updates to the Privacy Notice.
QUESTIONS AND COMPLAINTS
Please note that any changes We make to this Privacy Notice in the future will be posted on this page. Please visit this page regularly to make sure you are comfortable with the current Privacy Notice. Questions, comments, and requests regarding this Notice are welcomed and should be addressed to firstname.lastname@example.org. If you are unhappy with the way in which we have handled your PII, you can also contact Us at that email address. In some countries, should you continue to have unanswered concerns, you may also contact the relevant data protection authority with your concerns. You can find your data protection authority by going to https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm