Palmetto Technology Group, Inc.

Website Privacy Policy

Effective Date: 8/15/2024

Last Reviewed on: 8/15/2024

Section 1. Scope

Section 2. Children’s Privacy

Section 3. Information Collection

          3.1       Information We Collect and How We Collect It

          3.2       Cookies and Other Tracking Technologies

          3.3       How We Use Information We Collect or Obtain

          3.4       Information Sharing

Section 4. Third-Party Services/Content, Social Features, Advertising, and Analytics

Section 5. Choices About How We Use and Disclose Your Information

Section 6. Access, Change, and Delete Information

Section 7. State Specific Privacy Rights

Section 8. Data Security

Section 9. International Transfer

Section 10. Your Consent

Section 11. Changes to Our Privacy Policy

Section 12. Contact Information

PALMETTO TECHNOLOGY GROUP, INC.

WEBSITE PRIVACY POLICY

 

Section 1. Scope

 

Thank you for visiting Palmetto Technology Group, Inc. ("PTG" or "We") website ("Website"). Your privacy is important to us. To better protect your privacy, we provide this notice, which explains our online information practices and the choices you can make about the way your information is collected and used.

 

This notice applies to all information we may collect from you, or that you may provide when you visit the Website. To make this notice easy to find, we make it available on our Website homepage and at every point where personally identifiable information may be requested. This Privacy Policy will provide you with information as to how PTG collects, uses, maintains, protects, and shares information about you, including the choices PTG offers concerning that information, and applies to your use of any Website, regardless of how you access or use it. It does not apply to PTG's data collection activities offline or otherwise outside of the Website (unless otherwise stated below or at the time of collection). The policy also does not apply to information collected by any third party, including affiliates and subsidiaries, including through any application or content (including advertising) that may link to or be accessible from or through the Website.

 

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By visiting or otherwise using our Website, you consent to PTG's data collection, use, disclosure practices, and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Website. If you do not agree and consent, please discontinue use of the Website. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

 

Section 2. Children's Privacy

     The Website is intended for an adult audience and is not directed to, or intended for, children under sixteen (16) years of age. PTG does not knowingly or intentionally collect personal information, as defined by the U.S. Children's Privacy Protection Act ("COPPA") ("Children's Personal Information"), in a manner that is not permitted by COPPA. If you are under sixteen (16) years of age, do not use or provide any information on this Website, including your name, address, phone number, email address, or any screen name or user name you may use. If we learn that we have collected Children's Personal Information in a manner not permitted by COPPA, we will delete such data. If you believe we might have any information from or about a child under sixteen (16), please contact us at privacy@GoPTG.com.

Section 3. Information Collection

   3.1 Information We Collect and How We Collect It

You provide most of the information that PTG, and/or its agents, vendors, consultants, and other service providers ("Service Providers") collects. PTG and/or its Service Providers may collect information you provide directly to PTG and/or its Service Providers via the Website.

For example, PTG collects information when you use the Website, purchase services or products, or communicate through the Website. In addition, when you interact with third-party services (e.g., websites, locations, platforms, applications, or services operated by Service Providers) ("Third-Party Services"), you may be able to provide information to those Service Providers.

Information PTG, its Service Providers and/or Third-Party Services may collect may include personally identifiable information ("Personal Information"), which is information that identifies you personally, such as:

  • First and last name;

  • Mailing and/or billing address;

  • Phone number;

  • Email address;

  • Personal information you provide to us when you contact our customer service team; and

  • Financial payment information (e.g., credit card information).

We collect this information:

  • Directly from you when you provide it to us.

  • Automatically, as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies web beacons, and other tracking technologies.

  • From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling in forms on our Website. This includes information provided at the time you contact us through our website. We may also ask you for information when you report a problem with our Website.
  • Your search queries on the Website.
  • Pages or links you click on through our website.
  • Information you provide when you purchase products or register for services.

Information Collected Automatically

PTG, its Service Providers, and/or Third-Party Services may also automatically collect certain information about you when you access or use the Website ("Usage Information") including IP address, device identifier, browser type, operating system, information about your use of the Website, and data regarding network connected hardware (e.g., computer or mobile device). Subject to applicable state, federal, or international law, PTG does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information.

The methods that may be used on the Website to collect Usage Information include:

  • Log Information: Log information is data about your use of the Website, such as IP address, browser type, internet Website provider, referring/exit pages, operating system, date/time stamps, and related data, and may be stored in log files.
  • Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as "tracking pixels"), embedded scripts, unique identifiers location-identifying technologies, and other tracking technologies now and hereafter developed ("Tracking Technologies") may be used to collect information about interactions with the Website or emails, including information about your browsing behavior.

For information on how you can opt out of behavioral tracking on this website you can contact us at privacy@GoPTG.com.

The information we collect automatically does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

 

Information Collected Through Third Parties.

PTG's Service Providers and/or Third-Party Services may collect Personal Information, such as your first and last name, email address, phone number, and address, social media account, and image. Additionally, Service Providers and/or Third-Party Services may collect demographic information, such as your age, gender, interests, education, and employment information ("Demographic Information").

The following Service Providers or Third Party Services may collect the above mentioned personal information on behalf of PTG:

  1. Hubspot, Inc

If you have any questions about what Personal Information or Demographic Information is collected, you should contact the responsible provider directly.

Except to the extent required by applicable law, Demographic Information is "non-Personal Information" (i.e., data that is not Personal Information under this Privacy Policy).

Further, Personal Information once "De-identified" (i.e., the removal or modification of the personally identifiable elements, or the extraction non-personally identifiable elements including through anonymization, and/or hashing) is also non-Personal Information and may be used and shared without obligation to you, except as prohibited by applicable law. We do not attempt to re-identify the de-identified data and implement reasonable administrative and technical controls to prevent the data from being associated with an individual.

   3.2 Cookies and Other Tracking Technologies

The technologies we use for automatic data collection may include:

  1. HubSpot, Inc.
  2. ZoomInfo,
  3. LinkedIn,
  4. Google Analytics,
  5. Google Ads,
  6. Meta Pixel

 

  1. Cookies
    Cookies are small text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit the Website, we may collect information from you automatically through cookies or similar technology.
     
    How We Use Cookies. 
    PTG uses cookies in a range of ways to ensure the Website works correctly, improve your experience with the Website, and understanding how you use the Website. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. 

    The Types of Cookies We Use.
    There are several different types of cookies; however, the Website uses:
  • Functional Cookies. These cookies are essential for accessing and using the Website. These cookies do not gather information about you that could be used for marketing purposes and do not remember where you have been on the Internet. These cookies cannot be disabled because they are essential to ensure the Website operates correctly.
  • Analytics and Customization Cookies. PTG uses Service Providers and Third-Party Websites cookies to collect information about how visitors use the Website. These cookies collect information in the aggregate to give us insight into how the Website is being used.

    Other Tracking Technologies.
  • Web Beacons ("Tracking Pixels")

The Website may also contain electronic images known as Web Beacons (sometimes referred to as "clear gifs"). Web Beacons collect only limited information that includes a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides. We may also carry Web Beacons placed by third-party advertisers. These Web Beacons do not carry any Personal Information and are only used to track usage of the Website and activities associated with the Website.

  • Unique Identifiers

PTG may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information you see on the Website and some of the electronic communications you receive from us.

  • Embedded Scripts

An embedded script is programming code designed to collect information about your interactions with the Website. It is temporarily downloaded onto your computer from PTG's web server, or from a Service Provider with which PTG works, and is active only while you are connected to the Website, and deleted or deactivated after that.

  • Location Identifying Technologies

Global positioning systems (“GPS”) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you, or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you enabled GPS or use other location-based features on the Website, it may track your device location.

3.3 How We Use Information We Collect or Obtain

PTG may use information about you, including other Personal Information, for any purposes consistent with PTG's 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, the following:

  • To present our Website and its contents to you.
  • To diagnose problems with our equipment or software.
  • To customize your experience.
  • To manage your account.
  • To provide you with information, products, or websites that you request from us.
  • To respond to your customer service inquiries or requests.
  • To fulfill any other purpose for which you provide it.
  • To market toward you and provide us with information to improve the performance of the Website.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or Websites we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • In any other way that we may describe when you provide the information.
  • For any other purpose with your consent.

 

3.4 Information Sharing

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

 

We may disclose Personal Information that we collect, or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates.
  • To our agents, representatives, trusted service providers, contractors, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and secure, and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of PTG's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by PTG about our Website users is among the assets PTG transfers.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

 

We may also disclose your Personal Information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use or other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PTG, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

 

We do not sell, lease, or rent your personal information to third parties without your consent.

 

Section 4. Third-Party Services/Content, Social Features, Advertising, and Analytics

Some content or applications, including advertisements, on the Website that Service Providers and Third-Party Services serve, including advertisers, ad networks and servers, content providers, and application providers, could include advertisements. These Service Providers and Third-Party Services may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your Personal Information, or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control the tracking technologies used by or how the Service Providers and Third-Party Services use the tracking technologies. If you have any questions about an advertisement or other targeted content, you should contact the responsible Service Providers and or Third-Party Service directly.

As permitted by applicable law, PTG is not responsible for and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Website, and encourages you to familiarize yourself with and consult their privacy policies and terms of use.

 

Section 5. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Marketing Communications. You can opt-out of receiving email marketing communications from PTG at any time by following the instructions provided in emails (i.e., a link in the emails to unsubscribe from future emails). Please note that your opt-out is limited to the email address used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving marketing communications, PTG may, subject to applicable law, continue to send you non-marketing communications, such as those about your account, transactions, servicing, or PTG's ongoing business relations.

Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an email with your request to privacy@GoPTG.com.

Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by emailing us at privacy@GoPTG.com.

 

Section 6. Access, Change, and Delete Information

You may also send us an email at privacy@GoPTG.com to request access to, correct, or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We will not accommodate consumer requests to access, correct, or delete Personal Information that belongs to our clients, unless directed to do so by the client.

 

Section 7. State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) provide their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
  • Data portability.
  • Opt-out of personal data processing:
    • Targeted advertising (excluding Iowa).
    • Sales; or
    • Profiling in furtherance of decisions that produce legal or similarly significant side effects (excluding Iowa and Utah)

The exact scope of these rights may vary by state. To exercise any of these rights please email us at privacy@GoPTG.com. We will address your request within forty-five (45) days. To appeal a decision regarding a consumer rights request you may send an email to privacy@GoPTG.com stating the reasons for your appeal. We cannot guarantee specific outcomes regarding appeal requests. You will receive a response to your appeal request within forty-five (45) days.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request to: privacy@GoPTG.com. However, please know we do not currently sell data triggering that statute's opt-out requirements.

 

Section 8. Data Security

We restrict access to information about you to those PTG employees who need to know the information in order to perform their jobs, such as servicing your accounts, providing you with information you request, or notifying you of new products and services. To protect your personal information, we maintain physical, electronic, and procedural safeguards in keeping with industry standards and practices, and we review and adjust these safeguards regularly in response to advances in technology.

We have implemented measures designed to secure your Personal Information from accidental loss and unauthorized access, use, alteration, and disclosure such as encryption, regular software updates, audits, and security plugins. We secure information you provide on computer servers in a controlled, secure environment. We maintain reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Website. Any transmission of Personal Information is at your own risk. Further, 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 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.

 

Section 9. International Transfer and Storage

PTG is based in the U.S. and the information PTG and its Service Providers collect are governed by U.S. law. If you are accessing the Website from outside of the U.S., please be aware that information collected through the Website may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Website or provision of any information, therefore, constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personal Information, in the U.S., as outlined in this Privacy Policy.

 

Section 10. Your Consent

By using our Website, you consent to our Website’s privacy policy.

 

Section 11. Changes to Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page.

 

Section 12. Contact Information

If you have any questions about PTG's Privacy Policy, the data we hold on you, or if you would like to exercise one of your data protection rights, please do not hesitate to contact us. PTG can be reached at:

 

Email: privacy@GoPTG.com

Address:

Palmetto Technology Group

330A Pelham Rd., Suite 200,

Greenville, SC 29615

Acknowledgment of Consumer Request

 

[CONSUMER NAME]

[[POSTAL ADDRESS]/[EMAIL ADDRESS]]

 

[DATE]

 

RE: Response to Consumer Request Dated: [DATE]

 

Dear [[CONSUMER NAME]:

**Acknowledgement of Request to Delete, Correct, or Know**

Please allow this letter to serve as confirmation that we received your consumer request(s) to Delete, Correct, or Know your personal information collected by PTG on [date]. We will process the request as soon as possible, and certainly within forty-five (45) days of the day we received the request. Before processing your request, we must verify your identity and that the personal information identified in your request relates to you.

If you have any further questions, please contact our Privacy Officer at privacy@GoPTG.com.

Sincerely,

 

[POC]

For and on behalf of PTG.

 

Request to Know Response Letter

[CONSUMER NAME]

[[POSTAL ADDRESS]/[EMAIL ADDRESS]]

 

[DATE]

 

RE: Response to Request to Know Dated: [DATE]

 

Dear [CONSUMER NAME]:

We write in response to the above-referenced Request to Know. We recognize consumers’ the right to know what personal information a business collected, sold, or disclosed about them by submitting a verifiable consumer request, unless certain exceptions apply. For more information on the consumer's privacy rights, see PTG’s Privacy Notice available at: https://www.goptg.com/privacy.

Before processing your request, we must verify both your identity and that the personal information you asked us to disclose relates to you.

 

**Unable to Verify Consumer Information**

 

After reviewing the information you provided to date, we are unable to verify your identity. We therefore cannot honor your deletion request at this time. To help us verify your request, please provide [ADDITIONAL VERIFICATION INFORMATION REQUIRED].

 

**Provide Consumer Information**

 

We are pleased to enclose the information you requested.

[INSERT INFORMATION].

 

If you have any further questions, please contact our Privacy Officer at [EMAIL ADDRESS].

Sincerely,

 

[POC]

For and on behalf of PTG.

 

 

 

Request to Delete Response Letter

 

[CONSUMER NAME]

[[POSTAL ADDRESS]/[EMAIL ADDRESS]]

 

[DATE]

 

RE: Response to Request to Delete Dated: [DATE]

 

Dear [CONSUMER NAME]:

We write in response to the above-referenced Deletion Request. PTG recognizes consumers’ the right to request deletion of certain personal information we hold by submitting a verifiable consumer request, unless certain exceptions apply. For more information on the consumer's privacy rights, see PTG’s Privacy Notice available at: https://www.goptg.com/privacy.

Before processing your request, we must verify both your identity and that the personal information you asked us to delete relates to you.

 

**No Records Found**

 

After conducting a diligent search of our records, we have not found any related data to delete pursuant to your request. This is likely because we do not process personal information about you or we previously destroyed, erased, aggregated, or de-identified the personal information in accordance with our record retention obligations and practices. We have also forwarded your request to our service providers and contractors, and confirmed they similarly have not found any related data to delete/directed them to delete the personal information described in your request unless it falls within one of the permitted exceptions.

 

**Records Found but retained because of an exception under the law**

 

After careful review of your request, we determined that the [applicable state] privacy laws allow us, along with our service providers and contractors, to retain some of the personal information described in your request, as follows:

 

Retained Personal Information

Deletion Exception

[PERSONAL INFORMATION DESCRIPTION]

Necessary to [STATE LAW EXCEPTION)]

[PERSONAL INFORMATION DESCRIPTION]

Necessary to [STATE LAW EXCEPTION]

You may not appeal or request a review of this decision.

 

**Confirm to Delete Records**

In response to the deletion request we have:

  • Deleted, de-identified, or aggregated all of the remaining personal information described in your request.
  • Directed our service providers and contractors to similarly delete the personal information described in your request unless an exception applies.

 

We will maintain a record of this request for at least 24 months.

If you have any further questions, please contact our Privacy Officer or privacy@GoPTG.com.

 

Sincerely,

 

[POC]

For and on behalf of PTG.

 

 

 

Request to Correct Response Letter

[CONSUMER NAME]

[[POSTAL ADDRESS]/[EMAIL ADDRESS]]

 

[DATE]

 

RE: Response to Request to Correct Dated: [DATE]

 

Dear [CONSUMER NAME]:

We write in response to the above-referenced Request to Correct. PTG recognizes consumers’ the right to request correct inaccurate personal information the business may hold about the consumer by submitting a verifiable consumer request, unless certain exceptions apply. For more information on the consumer's privacy rights, see PTG’s Privacy Notice available at: https://www.goptg.com/privacy .

 

Before processing your request, we must verify both your identity and that the personal information you asked us to correct relates to you.

 

**Unable to Verify Consumer Information**

 

After reviewing the information you provided to date, we are unable to verify your identity. We therefore cannot honor your deletion request at this time. To help us verify your request, please [ADDITIONAL VERIFICATION INFORMATION REQUIRED].

 

**Inaccurate Personal Information Corrected**

 

We were able to determine the accuracy of the contested personal information based on the totality of the circumstances. We are pleased to notify you that we have corrected the inaccurate personal information on our existing systems and have instructed our service providers and contractors to make the necessary corrections in their systems.

 

**Personal Information Not Corrected**

 

We were unable to determine the accuracy of the contested personal information based on the totality of the circumstances. We considered (i) the nature of the personal information, (ii) how PTG obtained the contested information, and (iii) documentation provided to us related to the accuracy of the personal information and we determined that the personal information is more likely than not accurate. Upon full or partial denial of a consumer request to correct inaccurate personal information, the consumer is entitled to request that we delete the personal information instead. Please submit a request to delete by emailing us at privacy@GoPTG.com.

 

If you have any further questions, please contact our Privacy Officer or privacy@GoPTG.com.

Sincerely,

 

[POC]

For and on behalf of PTG.

 

Palmetto Technology Group, Inc.

California Consumer Privacy Act