Privacy Policy

PARDINGTON COLLECTIVE PRIVACY POLICY

Please read this privacy policy carefully as it contains important information about Claire Elizabeth Pardington, LLC (“Pardington Collective”) and how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities if you have a complaint.

This privacy policy incorporates by this reference our Terms of Service and any updates and new rules, new polices, and new codes of conduct. Except as otherwise indicated, any reference to the “privacy policy” shall include the Terms of Service.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to various laws in the United States and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom), and we are responsible as “controller” of that personal information for the purposes of those laws.

By creating an account, providing information to us (by any means, whether in correspondence, via our websites, or otherwise), signing this privacy policy, or continuing to use or products or services, you acknowledge that you have read, understood, and agree to be bound by this privacy policy. You “sign” and accept this privacy policy by clicking “I agree” on the account creation screen.

This privacy policy may change from time to time and your continued use of our products or services constitutes your acceptance of those changes. We encourage you to review this privacy policy periodically.

If you do not agree with this privacy policy or our practices, you may not use our products or services.

IN THE EVENT OF ANY INCONSISTENCY OR CONFLICT BETWEEN THIS PRIVACY POLICY AND THE TERMS OF SERVICE, THE FOLLOWING ORDER OF PRECEDENCE SHALL CONTROL: (A) THE TERMS OF USE; AND (B) THE PRIVACY POLICY.

Compliance Page Links:

GDPR - General Data Protection Regulation
CCPA - California Consumer Privacy Act
APPI - Act on the Protection of Personal Information

1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

We, us, our

Claire Elizabeth Pardington, LLC, dba Pardington Collective

Email addresses:

General questions: contact@pardingtoncollective.com

Legal: inquiries@pardingtoncollective.com

Personal information

Any information relating to an identified or identifiable individual

2. Personal Information We Collect About You. We may collect and use the following personal information that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Categories of Personal Information	Specific Types of Personal Information We May Collect
Identifiers (examples include: a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers)	first name, last name, email address, title, date of birth, telephone number, address, credit card or other payment information, username and password. You may voluntarily provide us with additional information to help us identify and contact you, such as your middle name, preferred name, secondary phone number, text number, state or province, and areas of interest or expertise.
Characteristics of protected classifications under California or federal law.	We may collect demographic information about you, such as gender and ethnic origin. We usually collect and use this information on an anonymized basis. If you provide demographic information to us, you do so voluntarily and we will collect, store and use your demographic information in accordance with this Privacy Policy.
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement)	IP address, the URL/domain name of any referring website, the time and date of your visit to the Site and certain information known as “clickstream data”
Geolocation data	IP Address, city, or province

This personal information is required to provide products and services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing products and services to you.

3. How Your Personal Information is Collected. We collect most of this personal information directly from you— online, email, text, our websites, and telephone. However, we may also collect information:

From publicly accessible sources (e.g., property records);
Directly from a third party (e.g., sanctions screening providers, credit reporting agencies, or customer due diligence providers);
From a third party with your consent (e.g., your bank);
From you, in person;
From cookies on our website; and
Via our IT systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems.

4. How and Why We Use Your Personal Information. Under data protection law, we can only use your personal information if we have a proper reason for doing so, for example:

To comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party; or
Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide products or services to you	For the performance of our contract with you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or Pardington Collective	For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, inquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best products and services to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best products and services for you at the best price
Preventing unauthorized access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products and services
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best products and services to you
Marketing our services and those of selected third parties to: existing and former customers; third parties who have previously expressed an interest in our services; third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, such as a member of the Pardington Collective, i.e. to promote our or their business to existing and former customers
Credit reference checks via external credit reference agencies	For our legitimate interests or those of a third party, i.e. to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

5. Promotional Communications. We may use your personal information to send you updates (by email, text message, telephone, via our website) about our products and services, including exclusive offers, promotions or new products and services.

We have a legitimate interest in processing your personal information for promotional purposes (see above “How and why we use your personal information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We do not sell your personal information to other organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

Contacting us as described in the “Contact Us” section below; or
Using the “unsubscribe” link in emails.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With. We routinely share personal information with:

Our affiliates, including companies within Pardington Collective’s group;
Service providers we use to help deliver our products and/or services to you, such as payment service providers and other third party companies;
Other third parties we use to help us run our business, such as marketing agencies or website hosts;
Other third parties whose websites you visit through our website; and
Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

7. Personal Information We Sold or Disclosed for a Business Purpose. In the preceding 12 months, we have sold or disclosed to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers);
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;
Characteristics of protected classifications under California or federal law;
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);
Geolocation data;
Audio, electronic, visual, thermal, olfactory, or similar information;
Professional or employment-related information; and
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

8. Where Your Personal Information is Held. Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see above: “Who We Share Your Personal Information with”).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

9. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing products and/or services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf;
To show that we treated you fairly; or
To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

10. Transferring Your Personal Information Out of the EEA. To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

With our offices outside the EEA;
With your and our service providers located outside the EEA;
If you are based outside the EEA; or
Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

The following countries to which we may transfer personal information have been assessed by the European Commission as providing an adequate level of protection for personal information: at this time, we are not transferring information outside the EEA.

If you would like further information, please contact us (see “How To Contact Us” below).

11. Your Rights Under the GDPR.

Right to Access	The right to be provided with a copy of your personal information (the right of access)
Right to Rectification	The right to require us to correct any mistakes in your personal information
Right to be Forgotten	The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Right to Data Portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object	The right to object: at any time to your personal information being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

12. Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You	You have the right to know: The categories of personal information we have collected about you; The categories of sources from which the personal information is collected; Our business or commercial purpose for collecting or selling personal information; The categories of third parties with whom we share personal information, if any; and The specific pieces of personal information we have collected about you. Please note that we are not required to: Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained; Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose	In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage and click on the Do Not Sell My Personal Information link here:https://pardingtoncollective.com/pages/ccpa-compliance
Right to Deletion	Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; and Direct any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; Debug to identify and repair errors that impair existing intended functionality; Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law; Comply with the California Electronic Communications Privacy Act; Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; Comply with an existing legal obligation; or Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination	You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you; Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; Provide a different level or quality of goods or services to you; or Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information.

13. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

14. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

Complete a data subject request form available on our website at https://pardingtoncollective.com/pages/ccpa-compliance;
Call us, toll-free, at +1 917-426-1968; or
Email us at inquires@pardingtoncollective.com.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact directly by website/email/phone, you will need to provide us with:

Enough information to identify you (e.g., your full name, address);
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

15. How to File a GDPR Complaint. We hope that we can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. We are not currently sharing information outside the United States.

16. Children. We are committed to protecting the privacy of children. Our products and services are not intended for use by children under the age of 18. We do not knowingly collect personal information from children under the age of 18. If you are under 18 do not use our products or services or provide any information about yourself including, without limitation, your name, address, email address or any screen name or user name you may use. If we learn that we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe that we may have any information from or about a child under 18, please contact us as provided in Section 18 below. Please visit the FTC's website at www.ftc.gov for tips on protecting children's privacy online.

17. Changes to This Privacy Notice. This privacy notice was last updated and published on April 26, 2022.

We may change this privacy notice from time to time–when we do, we will inform you via email, SMS, and/or notice through our website.

18. How to Contact Us. Please contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you. Our contact details are shown below:

Pardington Collective
Attn: Customer Service
201 S. Division, Suite 400

Ann Arbor, Michigan 48104 USA

Email for general inquires: contact@pardingtoncollective.com

Email for legal inquires: inquiries@pardingtoncollective.com

Telephone: +1 917-426-1968

Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

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