Pivot Point International, Inc. (“Pivot Point,” “we,” “us,” or “our”) provides this Privacy Policy to explain how information is collected, used, and shared when you access or use the Pivot Point Pro website at pro.pivot-point.com, its subdomains, and the related online learning and continuing education platform (together, the “Platform”).

Scope of this Policy
This Privacy Policy applies only to the Pivot Point Pro website and Platform. It does not apply to any other websites, mobile applications, or online services owned or operated by Pivot Point, including the general Pivot Point International website, found at pivot-point.com , which maintains its own separate privacy policy. This Privacy Policy also does not apply to third party websites or services unless expressly stated.

By accessing or using the Platform, you acknowledge the collection, use, and disclosure of information as described below. If you do not agree, please do not access or use the Platform.

Pivot Point may update or modify this Privacy Policy at any time. Changes are effective immediately upon posting to the Platform. If we make material changes, we will post a clear notice on the Platform or otherwise communicate changes to you. Your continued use of the Platform after changes are posted constitutes acceptance of the revised Privacy Policy.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE SEE THE SECTION BELOW TITLED “CALIFORNIA RESIDENT PRIVACY RIGHTS” FOR ADDITIONAL TERMS THAT MAY APPLY TO YOU.
1. Information We Collect
We may collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“Personal Information”) when you use the Platform.

Information You Provide to Us
We collect information you voluntarily provide directly to us, such as when you create an account, enroll in courses, purchase services, or communicate with us.

Platform Accounts. When you create an account to use the Platform, you will be required to provide certain information such as your name, email address, mailing address, phone number, and professional or license related information. We will also maintain records related to your course enrollments and completions.

Order & Payment Data. When you make a purchase on the Platform, payment is processed by a PCI compliant third party payment processor. We contract with this processor to help ensure your Personal Information is protected and used only as necessary to complete your transaction. Pivot Point does not receive your credit card, debit card, or other financial account information; such information is provided directly to the payment processor. Pivot Point does receive information about your purchase and basic contact information (e.g., name, email address, mailing address, phone number) associated with the order, and we maintain records of your purchases.

Communications. If you make a purchase, create an account, or otherwise provide us with your contact information, including signing up for our mailing list, we may use that information to send you updates, newsletters, promotional messages, and other marketing communications. We may use third parties or service providers to deliver these communications for us. You may opt out of marketing emails, including our newsletter mailing list, at any time by using the “unsubscribe” link in any marketing email or by contacting us at [email protected] with “Unsubscribe” in the subject line. Opting out of marketing communications will not affect your receipt of non-marketing messages such as emails about your account, transactions, or required service notifications.

Feedback. When you provide comments or feedback about our Platform, the content on the Platform, or our products and services (“Feedback”), we will not treat that Feedback as confidential, and we may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you. Feedback will be used without attribution or compensation to you.

Data Automatically Collected
We may use cookies, web beacons, pixel tags, and other tracking technologies (collectively, “Tracking Technologies”) on the Platform.

Tracking Technologies may be “session” or “persistent.” Session Tracking Technologies exist only while you are visiting the Platform and are typically deleted when you close your browser. Persistent Tracking Technologies remain on your device for a set period of time, which may range from several months to several years. Each time you visit a site that uses a persistent Tracking Technology, it may be renewed until it reaches its predetermined expiration date. Certain persistent Tracking Technologies can be manually deleted through your browser settings. Tracking Technologies may also be “first party” or “third party.” First party Tracking Technologies allow your browser to communicate with the Platform. Third party Tracking Technologies allow your browser to communicate with third party websites or services, such as advertising networks or analytics providers. We may not control how third parties use information collected through their Tracking Technologies.

Most browsers automatically accept Tracking Technologies, but you can adjust your browser settings to disable certain types. Disabling Tracking Technologies may impact your experience on the Platform. Some features or functions may not work correctly if you disable them. Certain Tracking Technologies that are essential to the operation of the Platform cannot be disabled.

Tracking Technologies used on the Platform may collect information such as:
  • IP addresses associated with your devices
  • Your internet service provider
  • Device identification numbers
  • Approximate geographic location
  • Browser type
  • Pages visited on the Platform
  • Websites visited before or after the Platform
  • Information about how and when you use the Platform


Video Players and Embedded Content. The Platform may include embedded videos and other media hosted by third party providers. When you play or interact with embedded content, those providers may collect information about you, such as your device information, IP address, and how you engage with the video. This data is collected directly by the third party provider, and their use of the data is governed by their own privacy policies.

We may receive limited analytics from these providers, such as the number of views, whether you watched a webinar to completion, and general information about engagement with our content. Blocking or disabling certain tracking technologies through your browser may affect the ability to view or use embedded videos.

DO-NOT-TRACK. WE CURRENTLY DO NOT RESPOND TO “DO NOT TRACK” REQUESTS.
2. How We Use Your Information.

We use Personal Information that we collect for the following purposes:

As Stated or Agreed to at the Point of Collection. We may use Personal Information for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use Personal Information to respond to your questions, comments, or complaints. We may also use Personal Information as requested or consented to by you.

Administration. We use Personal Information for administrative purposes, such as managing accounts, facilitating transactions, to inform our business strategies, and to understand demographics and user preferences.

Platform Management. We use Personal Information for Platform management, such as allowing you access to content, troubleshooting problems, improving content and functionality, conducting statistical and other analyses, and to customize the Platform to you and our users.

Business Analytics. We may use Personal Information for business analytics purposes, including consumer and operations research, to assess the effectiveness of our sales, online services, marketing, advertising, and to analyze market trends and future customer demand.

Advertising and Communications. We may use Personal Information to send you promotions, to notify you of new services, products, or programs, to notify you of new features of the Platform, to notify you of changes to this Policy, and for other communications.

To Protect Our Rights. We may use Personal Information to protect our legal rights or interests, or those of other parties, including to bring a legal action against you or anyone who may be causing harm to us, our Platform, or to other users of the Platform. We may also use Personal Information to seek business, financial or legal advice, and to respond to other legal requests. We may also use Personal Information to address any copyright claims or counterclaims.

How We Use Data Collected by Tracking Technologies.
We use Tracking Technologies to: (i) make our Platform function properly; (ii) provide personalized experiences; (iii) tailor our interactions with you; (iv) help with our marketing efforts; (v) provide us with valuable data and statistics about the usage and effectiveness of our Platform; and (vii) help us improve our Platform.

Google Analytics. We use Google Analytics to collect and process information about your use of the Platform. Google sets cookies on your browser or device, and then your web browser will automatically send information to Google. Google uses this information to provide us with reports that we use to better understand and measure how users interact with our Platform.

To learn more about how Google uses data, visit Google’s Privacy Policy and Google’s page on "How Google uses data when you use our partners’ sites or apps." You may download the Google Analytics Opt-out Browser Add-on for each web browser you use, but this does not prevent the use of other analytics tools. To learn more about Google Analytics cookies, visit the "How Google Uses Cookies" page.
3. Retention of Personal Information
We will keep Personal Information for the period necessary to fulfil the purposes described in this Policy, unless a longer retention period is permitted or required by law.

4. Disclosure of Personal Information
We may disclose Personal Information with the following categories of third parties, in compliance with this Policy and applicable laws:

Vendors and Service Providers. We may disclose Personal Information to third party vendors and service providers that provide services for us. For example, we may disclose Personal Information with vendors to help us host and manage the Platform, provide marketing services, improve the content and functionality of the Platform, perform data analysis and statistical analysis; troubleshoot problems with the Platform, provide payment processing services and online storefronts, and support or provide the security of the Platform.

Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose Personal Information: (i) if we believe in good faith we are legally required to disclose that Personal Information, (ii) if we are advised to disclose Personal Information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of Pivot Point or any other party.

Professional Advisors. We may disclose Personal Information to our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Pivot Point.

Change in Ownership. In the event Pivot Point is the subject of a change of control or in the event the Platform changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Information to the subsequent owner(s).

Other Users. By submitting a copyright infringement notice, counter-notice or other similar notification, you consent to having that communication forwarded to any person or entity to whom the notice or counter-notice relates to, in order to facilitate a prompt resolution of the copyright infringement claim.

Other. We may disclose Personal Information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure). This may include other companies and organizations that we partner with to host or sponsor events, services, or courses.

5. Use and Disclosure of Non-Personal Information.
Pivot Point may collect, use, disclose, transfer and otherwise process anonymized, de-identified and aggregated information that it receives or creates for any purposes in its sole discretion and such information is not subject to this Policy. Pivot Point is the sole and exclusive owner of such de-identified and aggregated information, including if Pivot Point de-identifies Personal Information so that it no longer considered Personal Information under applicable laws.

6. Children's Information.
The Platform is not directed at children under 18 years of age. We do not knowingly collect, sell, use, or share Personal Information from children under 18. If we obtain actual knowledge that Personal Information collected has been provided by someone under the age of 18, we will promptly delete that information. If a parent or legal guardian learns that their child provided us with Personal Information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Information.

7. Data Security
We use commercially reasonable technical and organizational measures to help secure Personal Information against loss, misuse, and alteration appropriate to the type of Personal Information processed. YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR ELECTRONIC DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.

8. Social Media
We are active on social media, including Meta and LinkedIn (“Social Media”). Anything you post on Social Media is public information and will not be treated confidentially. We may post (or re-post) on the Platform and our Social Media pages any comments or content that you post on Social Media.

The Platform allows you to connect and share data with Social Media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such Social Media platforms to facilitate those communications and features. The Platform may use advertising networks and services offered by Social Media platforms to deliver advertising content. Use of these services requires Social Media platforms to implement cookies or pixel tags to deliver ads to you while you access the Platform.

Your use of Social Media is governed by the privacy policies and terms of the providers that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

9. Access from Outside the United States
If you access the Platform from outside the United States, please be aware that Personal Information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Information in the United States to be equivalent to that required by the in other jurisdictions.

10. Third-Party Websites The Services may link to, or be linked from, websites not controlled by us. We are not responsible for third parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

11. Contact Us If you have questions or concerns regarding this Policy, contact us at:
Pivot Point International, Inc.
8725 W. Higgins Rd
Suite 700
Chicago, IL 60631
[email protected]

CALIFORNIA RESIDENTS’ PRIVACY RIGHTS

This section provides additional terms that apply to residents of California. In the event of a conflict between this section and the remainder of this Policy, this section shall take precedence for California residents. In this section only, any capitalized terms not defined in this Policy have the meanings set forth in the California Consumer Privacy Act of 2018, as amended, and including its implementing regulations (the “CCPA”).

The Collection, Source, Purposes, and Sharing of Your Personal Information.

Categories of Personal Information. In the last twelve (12) months, we have collected the following categories of Personal Information:

  • Identifiers consisting of real name, alias, postal address, unique personal identifier, online identifier, internet protocol address (“IP Address”), email address, account name, and other similar identifiers.
  • Consumer information under Cal. Civ. Code 1798.80(e) consisting of: credit card number, debit card number, and telephone number.
  • Commercial Information consisting of: records of personal property, customer billing information, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Internet Activity consisting of: browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
  • Geolocation Data consisting of: IP address, and other data from sensors on or around your device, depending in part on your device and account.


Categories of Sources From Which Personal Information is Collected. The categories of sources from which your Personal Information is collected is described in Section 1 (Information We Collect).

Purposes for Collecting Personal Information. Our purposes for collecting your Personal Information are described in Section 2 (How We Use Your Information).

Categories of Third Parties / Service Providers with Whom Personal Information is Disclosed for a Business Purpose. In the last 12 months we disclosed the categories of Personal Information listed above for our business purposes. The categories of third parties and/or service providers with whom we disclose Personal Information in the last 12 months are described above in Section 4 (Disclosure of Personal Information).

We do not collect Sensitive Personal Information.

Categories of Personal Information Sold or Shared for a Commercial Purpose.

In the last 12 months we have not Sold or Shared Personal Information of any individual for compensation or cross-contextual behavioral advertising and we currently do not Sell or Share Personal Information. You have the right to opt-out of the Sale or Sharing of your Personal Information.

We do not have any actual knowledge that we have Sold or Shared information of any individual under the age of 16 for monetary compensation or for cross-context behavioral advertising.

California Privacy Rights.

California residents may exercise the following rights regarding their Personal Information:

  • Right to Know and Access. You have the right to request that we disclose the following information to you regarding our collection and use of your Personal Information:
    • The categories of Personal Information we have collected about you;
    • The categories of sources from which we collect the Personal Information about you;
    • The business or commercial purpose(s) for which the Personal Information was collected, sold, or shared;
    • The categories of third parties with whom we disclose that Personal Information for a business purpose;
    • The specific pieces of Personal Information we collected about you in a format easily understandable to the average consumer; and
    • The categories of Personal Information that we sold or shared, and the categories of third-party recipients to whom it was sold or shared.
  • Right to Delete. You have the right to request that we delete any of your Personal Information that we collected from you and retained.
  • Right to Opt-out of “Sale” and Certain “Sharing” Practices. You have the right to opt-out of the “sale” and “sharing” of your Personal Information with third parties, as those terms are defined under CCPA. “Sell” in this case does not mean providing data in exchange for money – we don’t do that.
  • Right to Correct. You have the right to request that we correct inaccurate Personal Information that we maintain about you that you can prove is inaccurate.
  • Right to Non-Discrimination. We will not discriminate against you for exercising any of your rights under the CCPA.

How to Exercise Your Rights. To exercise your California rights described in this section, you may submit your request to us by contacting us at [email protected].

Verifiable Consumer Request. In order to verify your request, you must provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information, and you must describe your request with sufficient detail to allow us to properly understand, evaluate, and respond to your request. This information may vary depending on the Personal Information we already have.

We will only use Personal Information we collect during the verification process for the purpose of verifying your identity. If you maintain an account with us, we may use that account to respond to your request and/or verify your identity. If we are unable to verify your identity as required by applicable laws and regulations, we will decline to comply with your request and let you know why.

Authorized Agents. You may only make a request to exercise your rights on behalf of yourself, or a parent or legal guardian may make a request on behalf of their minor child. You also have a right to submit requests to exercise your rights under the CCPA through an authorized agent. If an authorized agent contacts us to exercise the above rights, we will need to verify their identity as well as your identity. We will also require proof of your written authorization to the agent to be your agent and to make the specific request submitted, unless the agent is subject to a Power of Attorney under California probate laws. If the agent is a Power of Attorney under California probate laws, we may require evidence of that status.

When We Will Respond. We will confirm receipt of your request within 10 business days. We will try to respond to your request within 45 days. If we require additional time, we will inform you of the reason and extension period. Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. We may charge a fee to process or respond to your request if it is excessive, repetitive, or manifestly unfounded.