Pinwheel Terms & Policies

Contents

Website Privacy PolicyEnd User Privacy PolicyTerms of ServiceResponsible Disclosure PolicyDeveloper PolicyWhistleblower Policy

Pinwheel Website Privacy Policy

Last Updated: April 20, 2020.

Welcome to the website (the “Site”) of Underdog Technologies, Inc., d/b/a Pinwheel (“Pinwheel,” “we,” “us,” or “our”). This Privacy Policy explains what Personal Data (defined below) we collect in connection with your use of our Site and access to our products and services (collectively, “the Service”), how we use and share that data, and your choices concerning our data practices. [This Privacy Policy is incorporated into and forms part of our website Terms of Service.]

If you are an individual who has used Pinwheel to connect payroll accounts to our third-party customers such as financial institutions, please note that our End User Privacy Policy governs our processing of your information.

Before using the Service or submitting any Personal Data to Pinwheel, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.

Personal Data We Collect

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:

Identification Data

We will collect your name, email address, phone number, employer name, and the number of employees at your company.

Communication Data

We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback.  Providing this information is optional to you.

Social Media Data

We have pages on social media sites like Facebook, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.

Internet Activity Data

When you visit, use, and interact with the Site, we may automatically receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Site, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Site (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:

Cookies

We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners.

Online Tracking and Do Not Track Signals

We and our third party service providers, including Facebook, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.

Your Choices. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.

Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.

If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.

How We Use Personal Data

We may use Personal Data for the following purposes:

Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.

Marketing. We may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email or telephone number, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. To the extent you create an account, you can also control the marketing emails and/or text messages you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.

Sharing and Disclosure of Personal Data

In certain circumstances we may share your Personal Data with third parties without further notice to you, unless required by the law, as set forth below:

Update your Information

Please contact us if you need to change or correct your Personal Data.

California Privacy Rights Disclosures

Collection, Disclosure, and Use of Personal Data

The categories of Personal Data we have collected in the preceding twelve months are described above in the “Personal Data We Collect” section. In the preceding twelve months, we have disclosed for business purposes each of the categories identified in that section to the categories of third parties identified in the “How We Share and Disclose Personal Data” section. The business and commercial purposes for collecting Personal Data are described in the “How We Use Personal Data” section. We collect Personal Data directly from you and from the financial institutions at which you maintain accounts you link through the Service.

Privacy Rights

Where provided for by law and subject to any applicable exceptions, California residents may have the following rights under the California Consumer Privacy Act of 2018 (“CCPA”):

Pinwheel does not sell your Personal Data.

If you would like to exercise any or all of these rights, you may do so by contacting us. Your authorized agent may submit requests in the same manner. Once we receive your request, we will verify your identity by sending an email to the email address you provide to us.

Please contact us if you have questions about your rights or our disclosures under the CCPA, or to request access to an alternative format of this Privacy Policy.

Children

Our Service is not directed to children who are under the age of 16. Pinwheel does not knowingly collect Personal Data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Data to Pinwheel through the Service please contact us and we will endeavor to delete that information from our databases.

Links to Other Websites

The Service may contain links to other websites not operated or controlled by Pinwheel, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

Security

You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Pinwheel via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.

International Users

By using our Service, you understand and acknowledge that your Personal Data will be transferred from your location to our facilities and servers in the United States.

Your Choices

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data.

Changes to the Privacy Policy

The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.

Contact Us

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address: privacy@getpinwheel.com.