Privacy Policy

Effective October 27, 2020

Pinnacle Building Maintenance, Inc. (“Pinnacle”, “we”, or “us”) is a commercial cleaning company serving the Commercial Real Estate industry in the New York area.  Our services are offered to contractors, developers, building owners and managers in the New York area and our website https://www.pinnacle-nyc.com/ (our “Website”) is directed to and intended for our commercial customers and potential commercial customers.

This Privacy Policy explains how Pinnacle treats your personal information.  By using or accessing our Website, you acknowledge your acceptance of the policies and practices outlined in this Privacy Policy.  Your use of the Website is your consent to Pinnacle to collect, use, and share your information in the manner below.  In addition, your use of our Website is subject to our Terms of Use which are also available on our Website.  If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Website. Any terms we use in this Privacy Policy without defining them have the definitions given to them in our Terms of Use.

Where we need to collect Personal Data, defined below, by law, or under the Terms of Use or another agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you, for example allowing you to utilize the Website.

Contact Information

You may contact us at anytime with questions and comments about our collection and use of Personal Data and your rights and choices regarding Personal Data by email or post at:

Email Address [email protected]

Telephone (718) 892-0100

Postal Address Pinnacle Building Maintenance, Inc.

Attn: Pinnacle Website Privacy

2050 Eastchester Road

Bronx, New York 10461 USA

Where this Privacy Policy directs or allows you to email us, you may do so at the email address above and your inquiry will be forwarded to the relevant Data Protection Officer, Data Privacy Officer, or other appropriate personnel based on the nature of your inquiry and your location.

What this Privacy Policy Covers  

This Privacy Policy covers how we treat Personal Data that we gather when you access or use the Website. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Sources of Personal Data

We collect Personal Data about you from you when (i) you provide such information directly to us including when you submit a contact form or send us an email and (ii) when Personal Data about you is automatically collected in connection with your use of the Website.  When you purchase products or services from Pinnacle we require billing and payment information and certain additional Personal Data including A. Personal Identifiers as defined below.

We may also collect Personal Data about you from third parties (“Third Parties”). Third Parties that share your Personal Data with us may include:

• Service providers. We may use analytics service providers to analyze how you interact and engage with the Website, or third parties may help us provide you with customer support.
• Advertising partners. We may receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements, or communications.

Categories of Personal Data We Collect

The following chart details the categories of Personal Data that we may collect or have collected over the past twelve (12) months. Throughout this Privacy Policy, we will refer back to the categories of Personal Data listed in this chart (for example, Category A. “Personal identifiers”).

Customer records identified by state law (including the California Customer Records statute (Cal. Civ. Code § 1798.80(e)))

Information Collected Automatically

Logs  

We may track the data you see when using the Website and how you interact with our Website by automatically collecting certain information such as “Internet or other similar network activity information”. To obtain such information, we may use web logs or applications that recognize your device and gather information about its online activity. We treat this information as Personal Data if we combine it with or link it to any of your information that otherwise is categorized as Personal Data. Otherwise, it is used in aggregate form only.

Cookies

The Website and emails we send you may use cookies and similar technologies such as pixel tags, web beacons, clear GIFs, and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser and tell us how and when you visit and use the Website, to analyze trends, learn about our user base and operate and improve the Website.  A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information. For example, it allows an email sender to determine whether a user has opened a particular email.  Generally, Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone, or similar device when you use that device to visit our Website. We may also supplement the information we collect from you with information received from third-parties, including third-parties that have placed their own Cookies on your device(s). Pinnacle uses or may use the following types of cookies:

• Performance/Analytical Cookies. Performance/Analytical Cookies are used to help us understand how visitors use the Website by collecting information about the number of visitors to the Website and users of the Website, what pages are viewed, and how long visitors are viewing pages or features of the Website. These types of Cookies help measure the performance of advertising campaigns and our content. For example, Google, Inc. (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to our Website is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some of the Website functionalities may not work.  Because of our use of Cookies, the Website may not support “Do Not Track” requests sent from your browser, which means that we may collect information about your online activity both while you are using our Website and after you leave our Website.

How you manage your cookie settings, including deletion, may differ per browser. Please use the “Help” function in your browser and look in the “preferences” or “options” section of your browser’s menu. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://www.allaboutcookies.org/. If you want to disable cookies from specific parties, you can do so via www.youronlinechoices.com

Pinnacle keeps Personal Data contained in your cookies and obtained through the other tracking technologies confidential.  We do not set any cookies outside of our Website domain.  Pinnacle also may partner with certain third parties to collect, analyze, and use some of the Personal Data described in this section.  For example, we may allow third parties to set cookies or use web beacons on the Website or in email communications from Pinnacle. This information may be used for a variety of purposes, including analytics and online behavioral advertising.

Local storage

Pinnacle may also collect and store information (including Personal Data) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

How We Use Your Personal Data 

We process Personal Data to operate, improve, and understand use of the Website and in conjunction with any agreements with you to provide cleaning services. We use Personal Data for the following purposes:

• To meet or fulfill the reason you provided the information to us;
• To communicate with you about Pinnacle, including announcements, updates, offers, confirmations, security alerts, support and administrative messages, and other communications necessary to facilitate your use of and our operation of the Website and our business;
• To provide support and assistance for the Website;
• To process orders or other transactions;
• To post testimonials about or services with your consent;
• To respond to user inquiries and fulfill user requests including opt-outs, data requests, deletions, and other interactions described in this Privacy Policy;
• To improve and develop our Website and services including testing, research, analysis and product development;
• To protect against or deter fraudulent, illegal or harmful actions and maintain the safety, security and integrity of the Website;
• To comply with our legal or contractual obligations, resolve disputes, and enforce our Terms of Use;
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• For any other purposes for which the information was collected as indicated above; and
• For any other business purpose stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.

As noted in the list above, we may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers or email you about your use of the Website. Also, we may receive a confirmation when you open an email from us, which helps us improve our communications. If you do not want to receive communications from us, please indicate your preference by emailing us.

How We Share Your Personal Data

We disclose your Personal Data only for business purposes.  We may disclose your Personal Data to service providers and other parties for the following business purposes:

• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Performing services on our behalf or in connection with providing you services, including maintaining or servicing accounts, providing customer service, providing relevant recommendations, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that we own, manufacture, was manufactured for us, or control;; and
• Other parties authorized by you.

We may disclose your Personal Data to the following categories of service providers and other parties:

• Payment processors;
• Companies who send emails on our behalf;
• Advertising networks;
• Security and fraud prevention consultants;
• Hosting and other technology and communications providers;
• Internal and external auditors;
• Analytics providers;
• Other parties authorized by you; and
• Staff augmentation, our affiliates, and contract personnel who are subject to Pinnacle’s obligations under this Privacy Policy.

We may also disclose your Personal Data to parties who acquire your Personal Data through an acquisition or other change of control of Pinnacle. Personal Data may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business, in whole or in part.

Over the past twelve months, we have disclosed the following categories of your Personal Data to service providers or other parties for the business purposes listed above, or may do so in the future:

• A. Personal identifiers;
• B. Contact information;
• C. Profile and usage information;
• D. Customer records identified by state law;
• E. Transaction data;
• F. Internet or other similar network activity information;
• G. Geolocation data;
• H. Professional or employment-related information;
• I. Non-public education information;
• J. Business Information

Pinnacle has not and will not sell your Personal Data.

We may also disclose your Personal Data if required to do so by law or when we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants or court orders.  We may also disclose your Personal Data when we believe that disclosure is necessary to protect our rights or the rights, property or safety of others, to enforce or apply this Privacy Policy, our Terms of Use or our other policies or agreements.

We may also share aggregated data such as statistical or demographic data for any purpose.  Aggregated data could be derived from your Personal Data but is not considered Personal Data under applicable law as it will not directly or indirectly reveal your identity or Personal Data.  We do not link this aggregate user data with Personal Data.  Our Privacy Policy does not restrict or limit our collection and use of aggregated data.

No Personal Data of Children

Our Website is a commercial, business to business website.  By using the Website, you represent that you are at least 18 or that you are the parent or guardian of a minor utilizing the Website and consent to your dependent minor’s use of the Website.  As indicated in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 18.  If you are a child under 18 years of age, please do not attempt to use our Website or send us any Personal Data. If we learn we have collected Personal Data from a child under 18 years of age, we will delete that information as quickly as possible. If you believe that a child under 18 years of age may have provided us Personal Data, please contact us.

Data Security and Retention

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your own passwords and sign-on mechanisms and limiting access to your computer or device and browser. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the Internet or storing data is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.

We retain Personal Data about you for as long as necessary to provide you with our services.  Website data is generally only maintained in aggregate form, but Personal Data may be retained, particularly for Website users that are or become customers of Pinnacle through the duration of our relationship. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

Telephone Consumer Protection Act

By providing us with your wireless number by email or a contact form submission, you confirm that you want Pinnacle to send you information regarding our services or employment opportunities that we think may be of interest to you, which may include Pinnacle using automated dialing technology to text you at the wireless number you provided, you agree to receive communications from Pinnacle, and represent and warrant that each person for whom you provide a wireless phone number has consented to receive these communications. You agree to indemnify and hold harmless Pinnacle, its affiliates, vendors, contractors, and personnel from and against any and all claims, liabilities, damages (actual and consequential), losses and expenses (including attorneys’ fees) arising from or in any way related to your breach of this representation and warranty.

Third-Party Websites

Our Website and content provided therein may contain links to other sites and applications, for example our LinkedIn page.  Any Personal Data you provide on the linked pages is provided directly to that third-party and is subject to that third- party’s privacy policy. Our Privacy Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these sites or any other sites that are linked to from our Website.

Procedure to Exercise Your Privacy Rights

This section explains how to exercise the rights provided by applicable laws and under this Privacy Policy.  This procedure applies to the rights afforded in the following jurisdictions which are more fully explained and defined below:

• Nevada – right to opt-out of Personal Data sales;
• California – rights to access, deletion, and to opt-out of Personal Data sales;
• European Union – right to access, rectification, erasure, withdrawal of consent, portability, objection and restriction of processing, each defined below;

To exercise these rights you must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate, and respond to it including the right you are exercising.  The request may be submitted by email or post at the number and addresses set forth above under “Contact Information”.  Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify you and complete your request. You do not need an account to submit a Valid Request.  

We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, and charging a fee is permitted by applicable law, we will notify you of the fee and explain that decision before completing your request.

Changes to this Privacy Policy

Pinnacle may need to change this Privacy Policy from time to time and will alert you to changes by placing a notice on our Website.  We do not require account registration nor generally collect email addresses so this will be the only form of notice we can provide to users.  The current version of this Privacy Policy and the Terms of Use on our Website will govern your use of the Website after any changes have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

Nevada Resident Rights & Disclosures

Our Website is not intended for use by consumers rather it is targeted for business to business use in the New York area only.  Nonetheless, as the Website does not currently have the technology to discriminate based on users’ locations, we are providing this notice.

If you are a Nevada consumer, you have the rights under the Nevada Revised Statutes Chapter 603A (“NRS 603A”) outlined in this section in addition to those set forth above, where there are conflicts, the portion that is more protective of your Personal Data shall control.

Personal Information Defined

The definition of “Personal Data” used throughout this Privacy Policy includes “personal information” as that term is defined by NRS 603A.040.  NRS 603A.040 defines “personal information” to mean a natural person’s first name or first initial and last name in combination with any one or more of the following data elements, when the name and data elements are not encrypted: 

• Social security number.
• Driver’s license number, driver authorization card number or identification card number.
• Account number, credit card number or debit card number, in combination with any required security code, access code or password that would permit access to the person’s financial account.
• A medical identification number or a health insurance identification number.
• A user name, unique identifier or electronic mail address in combination with a password, access code or security question and answer that would permit access to an online account.

Required Disclosures

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

The “How We Share Your Personal Data” section above details the categories of third parties with whom your Personal Data is shared.

The “Sources of Personal Data” and “Information Collected Automatically” sections above detail how we and third parties collect your information through our Website and different websites including by the use of Cookies.

Pinnacle has not and will not sell the Personal Data of Nevada consumers.

The “Changes to this Privacy Policy” section above describes the process by which we will let you know of any changes to this Privacy Policy.

The Effective Date of this Privacy Policy is set forth at the beginning of the Privacy Policy, immediately below the title.

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data.

If you are a resident of Nevada, you have the right to review and request changes to your Personal Data.

Exercising Your Rights

To exercise your right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.”

To exercise your right to review your Personal Data, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.” In response to a Valid Request we will provide you with the specific pieces of Personal Data that we have collected about you.

To exercise your right to request changes to your Personal Data, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.”  Such Valid Request must include the specific items of Personal Data you are requesting us to change, that is the information we have collected and the change to it you are requesting.

We will work to respond to your Valid Request opt-out, review, or change within 60 days of receipt. If we are not able to respond to your request within 60 days, we will let you know that we may need additional time to respond, up to 30 additional days. 

California Resident Rights under California Consumer Protection Act

Our Website is not intended for use by consumers rather it is targeted for business to business use in the New York area only.  Nonetheless, as the Website does not currently have the technology to discriminate based on users’ locations, we are providing this notice.

This section applies only to California residents.  If you are a California resident, you have the rights under the CCPA outlined in this section in addition to those set forth above, where there are conflicts, the portion that is more protective of your Personal Data shall control.  Please contact us by post or email if you have any questions about this section or whether any of the following applies to you.  Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes, any such request shall be made by sending a Valid Request following the procedure set forth below under “Exercising Your Rights.”

Right to Access

You have the right, but no more than twice in a twelve-month period, to request certain information about our collection and use of your Personal Data over the past 12 months. We will provide you with the following information:

• The categories of Personal Data that we have collected about you;
• The categories of sources from which that Personal Data was collected;
• The business or commercial purpose for collecting or selling your Personal Data;
• The categories of third parties with whom we have shared your Personal Data;
• The specific pieces of Personal Data that we have collected about you; and
• If we have disclosed your Personal Data for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third-party recipient.

Right to Deletion 

You have the right to request that we delete the Personal Data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with our services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Personal Data Sales Opt-Out

You have the right to opt-out of the sale of your Personal Data. To do so send a Valid Request following the procedure set forth below under “Exercising Your Rights.” Once you have submitted an opt-out request, we will not ask you to reauthorize the sale of your Personal Data for at least 12 months. However, you may change your mind and opt back into Personal Data sales at any time by contacting us.    Please note we do not permit use of our Website by persons under 16 years of age.

Exercising Your Rights

To exercise the rights described above, please submit a Valid Request following the procedure set forth above in the section entitled “Procedure to Exercise Your Privacy Rights.”

We will work to respond to your Valid Request within 45 days of receipt. If we are not able to respond to your request within 45 days, we will let you know that we may need additional time to respond, up to 90 additional days. 

No Discrimination

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you the use of the Website or our services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may not be able to provide our cleaning services without adequate customer and billing information for your company.

European Union Data Subject Rights

Our Website is not intended for use by consumers rather it is targeted for business to business use in the New York area only. It is not intended for use non-US residents.  Nonetheless, as the Website does not currently have the technology to discriminate based on users’ locations, we are providing this notice.

If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.   Pinnacle’s Website, and the services advertised, are not currently targeted to or intended for use by persons subject to protection under the GDPR, nonetheless, Pinnacle will utilize reasonable efforts to comply with the requirements of the GDPR.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure.  Pinnacle will be the controller of your Personal Data processed in connection with the Website.  If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict.  If you have any questions about this section or whether any of the following applies to you, please contact us by email or post at the addresses set forth above under “Contact Information”.

Personal Data We Collect

The “Categories of Personal Data We Collect” section above details the Personal Data that we collect from you.

Personal Data Use and Processing Grounds 

The “How We Use Your Personal Data” section above explains how we use your Personal Data.  We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include (1) consent, 

(2) contractual necessity, (3) our “legitimate interests” or the legitimate interest of others, and (4) other processing grounds based on legal necessity, as further described below.

(1) Consent.  In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data.  When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

(2) Contractual Necessity. We process Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use and any other agreements with you, which enables us to provide you with our cleaning services.  When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of our services that require such data, for instance customer identification and billing information.  We process the following categories of Personal Data as a matter of “contractual necessity”:

• Personal identifiers;
• Customer records identified by state law;
• Internet or other similar network activity information;
• Geolocation data;
• Professional or employment-related information; and
• Non-public education information;

(3) Legitimate Interest.  We process each of the categories of Personal Data in the chart appearing above in the section titled “Categories of Personal Data We Collect” when we believe it furthers the legitimate interest of us or third parties.  Examples of these legitimate interests include:

• Operation and improvement of our business, products and services;
• Marketing of our products and services;
• Provision of customer support;
• Protection from fraud or security threats;
• Compliance with legal obligations; and

Completion of corporate transactions.

(4) Other Processing Grounds.  From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Sharing Personal Data

The “How We Share Your Personal Data” section above details how we share your Personal Data with third parties.

EU Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below.  For more information about these rights, or to submit a request, contact us by email or post at the addresses set forth above under “Contact Information.”  Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision.  In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request. Your rights include the following.

• Access.  You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by logging on to your account.
• Rectification.  If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can also correct some of this information directly by logging on to your account.
• Erasure.  You can request that we erase some or all of your Personal Data from our systems. 
• Withdrawal of Consent.  If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize the Website or our services.
• Portability. You can ask for a copy of your Personal Data in a machine-readable format.  You can also request that we transmit the data to another controller where technically feasible.
• Objection. You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
• Restriction of Processing.  You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint. You have the right to lodge a complaint about Pinnacle’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.  A list of Supervisory Authorities is available here:  https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data 

The Website is hosted and operated in the United States (“U.S.”) through Pinnacle and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using our Website, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Pinnacle in the U.S. and will be hosted on U.S. servers, and you authorize Pinnacle to transfer, store and process your information to and in the U.S., and possibly other countries.  You hereby consent to the transfer of your data to the U.S. pursuant to: (i) a data processing agreement incorporating standard data protection clauses promulgated by the European Commission, (ii) binding corporate rules for data protection that align with the GDPR’s requirements, or (iii) adherence to an industry- or technology-specific approved code of conduct blessed by the European Commission.