THE PENROSE TEAM PRIVACY POLICY

1. OVERVIEW OF THIS POLICY

This Privacy Policy (this “Policy”) relates to the personal information that you submit when you access and use our website and other information we automatically collect when you access the website. This Policy explains all activities regarding your information, including but not limited to how we collect, use, disclose, and secure it and the rights available to you.

You are required to read, understand, and agree to how we process (collection, use, disclosure, security, etc.) your information in this Policy. You are also required to read our Terms and Conditions and print a copy each for future reference. By using the website and submitting the requested personal information, you agree to how we process your information as described in this Policy. If you disagree, you should not submit information.

2. WHAT INFORMATION DOES THE PENROSE TEAM COLLECT FROM YOU?

2.1 We collect information from and about users of our website:

  • Directly from you when you provide it to us.
  • Automatically, when you use the website. 

2.2 We do not collect special categories of personal data such as information relating to or about the below or criminal records.

  • Health 
  • Racial or ethnic origin
  • Political opinions
  • Membership in a political association, 
  • Membership in a trade union
  • Religious beliefs or affiliations
  • Philosophical beliefs
  • Sexual orientation or practices
  • Biometric information 

2.3 Information that you provide to us (“personal information”) when you register or join our website may include: 

Information we collect during user registration:

  • Name;
  • Contact Address;
  • Phone Number;

2.4 This information may also include:

  • Information you provide by registering on the website, such as first name, last name, e-mail address, telephone number and address (“Contact Information”). This includes information provided when registering for the website and requesting further services. 
  • Information you provide us when you complete user surveys or surveys for research purposes, such as your Contact Information.
  • Information you provide us when you report a problem with the website, such as your first name, last name and e-mail address.
  • Records and copies of your correspondence (including e-mail addresses and phone numbers) if you contact us.
  • Details of transactions you carry out through the website when you make payment to The Penrose Team. 
  • Your correspondence within the website with other users.

​​​​​​​3. WHAT DOES THE PENROSE TEAM USE THE INFORMATION COLLECTED FOR?

Any information collected by us is for a purpose in relation to your use of our website, including for providing the services. 

  • Provide Services to you: We collect information to send you an e-mail about your registration, perform tasks required to complete your registration, provide customer support, or provide other types of user relationship management. We may also use your information to optimize e our Services and operations, for example, training and quality assurance.
  • Fulfilling legal and compliance obligations: We collect information to fulfil our legal obligations. Examples may include satisfying regulatory screening requirements concerning entity formations, responding to subpoenas and other legal requests for information, and maintaining records as required. We may also collect information to detect fraud or other suspicious activity.
  • Analytics: We collect information for use in performing various types of analytics. For example, we use the information to analyze how visitors interact with our website, where visitors arrive from and exit, pages visited, links clicked, text entered and mouse movements to understand site usage, detect fraud and potential threats and improve our services.
  • To communicate with you: We collect your e-mail address and phone number to (i) contact you regarding your use of our website, (ii) respond to your questions, complaints, and queries, and (iii) send you updates regarding our services or this Policy and other agreements;
  • For other purposes through your consent: We may also process your information for other reasons for which your consent will be sought before we process such information. You may also withdraw your consent at any time.

4. HOW PERSONAL INFORMATION COLLECTED.

4.1 Automatic Information Collection and Tracking.   

When you access and use the website, it may use technology to collect automatically:

  • Usage Details. When you access and use the website, we may automatically collect certain details of your access to and use, including traffic data, location data, logs and other communication data and the resources you access and use on or through the website.

4.2 If you do not want us to collect this information, please do not register with us. 

4.3 We may also use these technologies to collect information about your activities over time and across third-party websites, Websites or other online services (behavioral tracking). 

4.4 Information Collection and Tracking Technologies.

The technologies we use for automatic information collection may include the following:

  • Cookies (or mobile cookies). A cookie is a small file placed on your smartphone or device. It may be possible to refuse to accept mobile cookies by activating the setting on your browser. However, if you select this setting, you may be unable to access certain parts of our website.

The cookies we use include “analytical” cookies. They allow us to recognize and count the number of visitors and see how they move around the website. This helps us improve how our website works, for example, by ensuring that users find what they are looking for easily.

These cookies are used to collect information about how visitors use our website. We use the information to compile reports on general user traffic and conversion statistics and to help us improve the site. The cookies collect information anonymously.

Please note that our advertisers may also use cookies, over which we have no control.

  • Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
  • Third-Party Cookies. The website may link to other websites owned and operated by certain trusted third parties (for example, Facebook) who, for example, collect data that helps us to track conversions from Facebook ads. These other third-party websites may also use cookies or similar technologies in accordance with their separate policies. Please note that our advertisers may also use cookies, over which we have no control. For privacy information relating to these other third-party websites, please consult their policies as Appropriate.

5. HOW DO WE USE PERSONAL DATA AND LAWFUL BASES FOR PROCESSING

5.1 Lawful Bases for Processing under the GDPR

What are the lawful bases for processing personal data? The lawful grounds for processing are set out in Article 6 of the GDPR.   At least one of these must apply whenever we process personal data. We mainly use consent, contract, legal obligations and legitimate interests as the bases to process your data in accordance with this privacy policy.

  • Consent: the individual has given explicit consent for us to process their data for a specific purpose. 
  • Contract: the processing is necessary for a contract we have with the individual or because they have asked us to take specific steps before entering into a contract. 
  • Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations). 
  • Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is an excellent reason to protect the individual’s data, which overrides those legitimate interests.

5.2 We use information that we collect about you or that you provide to us, including any personal information, to:

  • To create an account (such processing is necessary for the performance of our contract with you).
  • To verify your identity and carry out security checks in order to set up your account (such processing is necessary for the performance of our contract with you and essential for us to comply with a legal obligation).
  • Provide you with the website and its contents and any other information, products or services you request from us (such processing is necessary to perform our contract with you).
  • Give you notices about your account and the account you create (such processing is necessary for the performance of our contract with you and for us to comply with a legal obligation).
  • Ensure that content from our website is presented most effectively for you and your computer or device for accessing the website (such processing is necessary for the performance of our contract with you).
  • Carry out our obligations and enforce our rights arising from any contracts between you and us, including billing and collection (such processing is necessary for our legitimate interests).

5.3 The usage information we collect helps us to improve our website and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns (such processing is necessary for our legitimate interests (running our services and studying how users use our website).
  • Store information about your preferences, allowing us to customize our website according to your interests (such processing is necessary for our legitimate interests (in running our services).
  • Speed up your searches (such processing is necessary for our legitimate interests (in running our services).
  • Recognize you when you use the website (such processing is necessary for the performance of our contract).
  • To provide us with information about how the website is running or whether there are any faults or issues with our products and services (such processing is necessary for our legitimate interests (for us to deliver a better service to you).

5.4 We may also use your information to contact you about news, offers, notifications, surveys, information that we think may be of interest to you (such processing is done with your consent and is necessary for our legitimate interests (to develop our products/services and grow our business)). We allow you to consent to such e-mails when you sign up for the website. If you do not want us to use your information this way, please do not consent. You may adjust your user preferences in your account profile.

5.5 We have implemented reasonable measures to secure your personal information from accidental loss and unauthorized access, use, alteration and disclosure.

5.6 The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the website, like message boards. Any website user may view the information you share in public areas.

5.7 Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your information transmitted through our website. Any transmission of personal information is at your own risk. We are not responsible for circumventing any privacy settings or security measures we provide. 

5.8 If you suspect that there has been a breach of the security of your data, you should contact us at: jason@thepenroseteam.com and include details of: 

  • the nature of the breach; 
  • the date of the breach; and
  • the full circumstances of the breach. 

6. INTERNATIONAL USE OF THE WEBSITE 

This Privacy Policy is intended to cover the collection of information on our website from residents of the United States. If you are using the website from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where our servers are located, and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to protect your privacy. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this privacy policy.

7. TECHNICAL DATA

You acknowledge that The Penrose Team may collect and use technical data, including but not limited to information about your mobile device and system, Internet connection or your use of the The Penrose Team website. Collecting technical data ensures quality, increases comfort, and further analyses and develops The Penrose Team and related services.

Technical data is anonymous and stored separately from Personal Data; therefore, it cannot be linked back to you in any way in order to identify you.

8. HOW PERSONAL DATA IS SHARED AND WITH WHOM

The Penrose Team does not sell or share your personal information with third parties but may share your information if the need arises, such as the following: 

  • 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 the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
  • For any other purpose disclosed by us when you provide the information.
  • For academic research.
  • For any other purpose with your consent. 
  • To comply with any court order, law or legal process, including responding to any government or regulatory request.
  • To enforce our rights arising from any contracts between you and us.

If we believe disclosure is necessary or appropriate to protect the Company’s rights, property, or safety, our customers or others. This includes exchanging information for fraud protection and credit risk reduction with other companies and organizations. 

9. OPTING OUT OF E-MAIL MARKETING

In accordance with applicable data protection laws, you have the right to unsubscribe from our marketing email list at any time. To do so, you may either click on the unsubscribe link provided in our marketing emails or contact us using the details provided below.

Once you have unsubscribed from our marketing email list, we will promptly remove your email address from our marketing list. Please note, however, that we may still need to send you service-related emails that are necessary for the administration and use of your account, as well as any other communications that are required by law.

We are committed to protecting your privacy and ensuring that your personal information is processed in accordance with applicable data protection laws. As such, we will only use your personal information for the purposes for which it was collected and will not share it with any third parties without your explicit consent, except as required by law or as necessary to provide our services to you.

10. YOUR RIGHTS WITH RESPECT TO PERSONAL DATA.

  • You can review and change your personal information by logging into the website and visiting your account settings page. 
  • You may also send us an e-mail at jason@thepenroseteam.com to request access to, correct or delete any personal information free of charge that you have provided to us. We cannot delete your personal information except by deleting your user account. 
  • We will respond to a request to access, correct or delete any data within 30 days of the date we receive the request. 
  • We may not accommodate a request to change information if we believe the change would violate or breach any law or legal requirement or cause the information to be incorrect. 
  • If, on your request, we refuse to amend, correct or delete your personal information, we will set out our reasons for not doing so and provide you with details of how you may complain about our refusal.
  • Suppose you delete your User Contributions from the website. In that case, copies of your User Contributions may remain viewable in cached and archived pages or have been copied or stored by other Website users. Our Terms and Conditions govern the proper access and use of information provided on the website, including User Contributions.

11. CHILDREN’S PRIVACY

The Children’s Online Privacy Protection Act was created to protect children under 13 from unsuspecting acts or practices in conjunction with collecting, using, and disclosing information about them. Our Services are not intended for anyone under the age of 13. If you are under 13, do not use or provide any information on or through our Services. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you are a parent or guardian or believe we might have any information from or about a child under 13, please contact us so we can delete the child’s information. The Services will never knowingly accept, collect, maintain or use any information from a child under 13. If a child whom we know to be under the age of 13 sends personal information to us online, we will only use that information to respond directly to that child or notify parents

12. HOW LONG IS PERSONAL DATA KEPT?

We will only retain personal data for as long as is reasonably necessary. Upon deletion of an account, all personal data will be removed as soon as possible, and always within 90 days of the deletion.

13. LEGAL BASIS FOR THE PROCESSING OF PERSONAL INFORMATION

13.1 We rely upon consent and legitimate business interests to process personal information. For example, we may process personal information with a user’s consent when they agree to place cookies on their devices or process information, they enter into a form on one of our sites.

13.2 It is in our interest as a business to enhance the services that we provide, which may include processing your information to enable us to:

  • Respond to User enquiries and fulfil User requests
  • Send Customers or Potential Customers relevant marketing information and offers
  • Complete transactions
  • Provide customer service
  • Send administrative information
  • Personalize Users’ experiences with our sites
  • Do so where we are required to by law

13.3 We may also process personal information when it is in our or a User’s legitimate interests to do so and when an individual’s data protection rights do not override these interests. 

14. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing using the contact information provided below.

If you are under 18, reside in California, and have a registered account with the Services or Websites, you have the right to request the removal of unwanted data that you publicly post on the Services or Websites. To request the removal of such data, please contact us using the contact information below. Include the e-mail address associated with your account and a statement that you reside in California. We will ensure the data is not publicly displayed on the Services or Websites, but please be aware that the data may not be completely or comprehensively removed from our systems.

15. NEVADA RESIDENT RIGHTS

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. You can exercise this right by contacting us at jason@thepenroseteam.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the e-mail address associated with your account. We will not sell your Personal Data.

16. DATA SECURITY

We have implemented multiple security measures to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. All information you provide is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

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 information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for circumventing any privacy settings or security measures on the website.

17. CHANGES TO OUR PRIVACY POLICY

Our Policy is to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. Suppose we change how we treat our users’ personal information. In that case, we will notify you by e-mail to the primary e-mail address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you and for periodically visiting our website and this privacy policy to check for any changes.

18. CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy, how we collect and use your Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

The Penrose Team

6991 E. Camelback Rd. STE D-300

Scottsdale, Arizona, 85251

United States

jason@thepenroseteam.com