Paminga Privacy Policy

Effective Date: May 16, 2024

Paminga is a marketing automation platform that provides marketers with tools to work productively at scale.

By definition,  the Paminga platform collects, stores, and processes data related to your customers and prospective customers, as well as data about our own customers and potential customers.

The Big Picture

Paminga processes two broad categories of personal information when you use our products and services:

• Your personal information as a customer (or potential customer) of Paminga – information that we refer to as Account Data, and
• If you are a customer of Paminga, we will process information related to your customers and prospects that may come from your integrated CRM platform, persons who may visit your website or interact with marketing messages you’ve built on Paminga or by other means, each of which is under your control. We call this Customer Data.

Paminga processes these categories of personal information differently because the direct relationship we have with you, our customer, is different than the indirect relationship we have with your customers and prospects.

How Paminga Processes Your Personal Information

We, Paminga, collect and process your personal information:

• When you visit a Paminga public-facing website like Paminga.com, sign up for a Paminga event, or make a request to receive information about Paminga or our products, like a Paminga whitepaper or a newsletter;
• When you contact Paminga's Sales Team or Customer Success Team; and
• When you sign up for a Paminga account and use our products and services.

We refer to this personal information as Account Data.

Data protection (or privacy) laws in certain jurisdictions, like the European Economic Area (EEA), differentiate between “controllers” and “processors” of personal information. A controller decides why and how to process personal information.

A processor processes personal information on behalf of a controller based on the controller’s instructions. When Paminga processes your Account Data, the Paminga entity with whom you are contracting is acting as a controller.

Broadly speaking, we use Account Data to further our legitimate interests to:

• understand who our customers and potential customers are and their interests in Paminga's product and services,
• manage our relationship with you and other customers,
• carry out core business operations such as accounting and filing taxes, and
• help detect, prevent, or investigate security incidents, fraud and other abuse and/or misuse of our products and services.

What Account Data Paminga Processes When You Visit Our Website, Sign Up for a Paminga Event, or Make a Request for Information About Paminga and Why

When you visit our website, sign up for a Paminga event or request more information about Paminga, we collect information automatically using tracking technologies, like cookies, and through web forms where you type in your information. We collect this information to provide you with what you request through the web form, to learn more about who is interested in our products and services, and to improve navigation experience on our pages.

Information You Share Directly: In some places on Paminga's public-facing websites, you can fill out web forms to ask to be contacted by our Sales Team, sign up for a newsletter, subscribe to our blog, download content, register for a Paminga event, or take a survey. The specific personal information requested on these forms will vary based on the purpose of the form. We will ask you for information necessary for us to provide you with what you request through the form (for example, we will ask you for your email address if you want to sign up for an email newsletter and for your phone number if you want a member of our Sales Team to call you). We may also ask you for additional information to help us understand you better as a customer like your Paminga use case, your company name, or your role at your company. If you sign up to receive ongoing marketing communications from Paminga, like a newsletter, you can always choose to opt-out of further communications through a preferences page which will be linked from any marketing email you receive from Paminga. Or, you can contact our Customer Success Team to communicate your choice to opt-out.

Information We Collect Automatically: When you visit Paminga websites, including our web forms, we and our service providers acting on our behalf automatically collect certain information using tracking technologies like cookies, web beacons, and similar technologies. We use this information to understand how visitors to our websites are using them and which pages and features of the websites are most popular. This helps us understand how we can improve our websites and track performance of our advertisements. In addition, we using tracking technologies to help improve the navigation experience on Paminga websites. For more details on our use of cookies and tracking technologies, please see our Cookie Notice.

What Account Data Paminga Processes When You Communicate with Our Sales or Customer Success Teams and Why

You may share personal information, like your contact information, with a member of our Sales or Customer Success Team when you communicate with them. We keep a record of this interaction.

If you contact our Sales or Customer Success Teams, those teams keep a record of that communication, including your contact details and other information you share during the course of the communication. We store this information to help us keep track of the inquiries we receive from you and from customers generally so we can improve our products and services and provide training to team members. This information also helps our teams manage our ongoing relationships with our customers. Because we store a record of these communications, please be thoughtful about what information you share with our Sales and Customer Success Teams. While we will take appropriate measures to protect any sensitive information you share with us, it is best to avoid sharing any personal or other sensitive information in these communications not necessary for these teams to assist you.

What Account Data Paminga Processes When You Request and Log Into a Paminga Account and Why

When you request a Paminga account we ask for certain information like your contact details and billing information so we can communicate with you and so you can pay for our products and services. We also collect some information automatically, like your IP address, when you log in to your account or when your software application built on Paminga makes requests to our APIs. We use this to understand who is using our services and how, and to detect, prevent and investigate fraud, abuse, or security incidents.

When you sign up for a Paminga account, we ask for certain information like your contact details and billing information so we can communicate with you and so you can pay for our products and services. We also collect some information automatically, like your IP address, when you log in to your account or when your software application built on Paminga makes requests to our APIs. We use this to understand who is using our services and how, and to detect, prevent and investigate fraud, abuse, or security incidents.

Information You Share Directly: When you request a Paminga account, you’ll be asked to give us your name, email address, your company name, and your company’s address (if we can’t easily locate your address on your website). We collect this information so we know who you are, we can communicate with you about your account(s), and we can recognize you when you communicate with us.

We also use your email address to send you information about other Paminga products, services or events in which we think you may be interested. You can opt out of further marketing communications through your marketing preferences page linked from any marketing email you receive from Paminga or you can contact our Customer Success Team to communicate your choice to opt-out.

When you first request an account, we also ask you for a telephone number. This allows Paminga's team members to contact you at this number to help you with onboarding.

When you upgrade your trial account, we may ask you to provide our payment processor with a credit card and your billing address. Our payment processor, acting on our behalf, gathers this so we can bill you for your use of our products and services. Our payment processor will share your billing address with Paminga. Your billing address may also be used by Paminga for tax calculation and audit purposes.

Information We Generate or Collect Automatically. When you request an account with Paminga, we collect your IP address and other data through tracking technologies like cookies, web beacons, and similar technologies. We use this information to understand how customers are using our platform, who those customers are (if they are a company and the IP address is associated with that company), what country they are logging in from (for analytics and export control purposes), and to help improve the navigation experience. For more details on our use of cookies and tracking technologies, please see our Cookie Notice.

Note that we also collect the IP address of your devices or servers when you make requests to our APIs. When you use our APIs, we also collect and process the information contained in those interactions. For more information about how personal information is processed in that context, see the section below on “How Paminga Processes End Users’ Personal Information” and our API Docs.

All information we collect when you request a Paminga account and interact with the Paminga platform may be used to detect, prevent, or investigate security incidents, fraud, or abuse and misuse of our platform and services.

Other Account Data We Collect and Why

We may collect information about you, as our customer, from publicly-available sources so we can understand our customer base better.

We may use publicly-available information about you through services like LinkedIn, or we may obtain information about your company from third party providers to help us understand our customer base better, such as your industry, the size of your company, and your company’s website URL.

How Long We Store Your Account Data

Paminga will store your Account Data as long as needed to provide you with our services and to operate our business. If you ask Paminga to delete specific personal information from your Account Data (see ‘How To Make Choices About Your Account Data’ below), we will honor this request unless deleting that information prevents us from carrying out necessary business functions, like billing for our services, calculating taxes, or conducting required audits.

Here is an overview of how long we hold on to Account Data in a form that can be used to identify you, unless there is a specific need or obligation to retain your information longer (like in the case of an open investigation, audit or other legal matter):

• Account Data stored in our customer relationship management system(s) is generally stored up to 7 years following closure of your account. Invoice records, including their digital equivalent, may be retained in identifying form by Paminga for longer periods for accounting, tax, and audit purposes depending on and in accordance with applicable tax law.
• Your communications with Paminga's Customer Success Teams is generally stored for up to 3 years after your account is closed.
• Apart from the above, following closure of your account, Account Data is generally deleted within 120 days of account termination.

How To Make Choices About Your Account Data

You can make various choices about your Account Data through the marketing preferences center, a link to which is available in marketing emails you may receive from us from time to time. Any other requests about your data can be submitted by emailing privacy@Paminga.com or contacting Customer Success.

Promotional Communications. You can choose not to receive promotional emails from Paminga by following the unsubscribe/opt-out instructions in those emails. You can also opt-out by contacting Customer Success. Please note that even if you opt out of promotional communications, we may still send you non-promotional messages relating to things like updates to our terms of service or privacy notices, security alerts, and other notices relating to your access to or use of our products and services.

Cookies and Tracking Technologies. How you make choices about cookies and other tracking technologies depends on the type of cookie or tracking technology being used. For details on how to manage your preferences for cookies and tracking technologies, please check out our Cookie Notice.

Other Choices About Your Account Data. In addition, you can express other choices about your Account Data (i.e., accessing it, deleting it, restricting its use, porting it, or withdrawing consent for its use) by contacting privacy@Paminga.com.

How Paminga Processes Your Customer Data

As noted above, data protection (or privacy) laws in certain jurisdictions, like the EEA, differentiate between “controllers” and “processors” of personal information. When Paminga processes Customer Data, we act as a processor while you, our customer, act as a data controller.

What Customer Data Paminga Processes and Why

We process Customer Data in the course of providing the Paminga services to you. We do not sell your Customer Data and we do not share your Customer Data with third parties for those third parties’ own business interests.

The particular Customer Data Paminga processes when you, our customer, use our products and services and the reason Paminga processes it depends on how you use our products and services.

In addition, records containing Customer Data may, from time to time, also be used in debugging or troubleshooting or in connection with investigations of platform performance issues or security incidents, as well as for the purposes of detecting and preventing spam or fraudulent activity, and detecting and preventing system exploits and abuse.

How Long Do We Store Customer Data and Exercising Choices About Customer Data

As a active Paminga customer, we will retain your Customer Data for as long you instruct. You may choose to delete Customer Data at your convenience within the Paminga services. Normally, deleted Customer Data is retained in the event that you ask us to restore that data (as our customers do occasionally delete records by mistake)

You may also choose to delete Customer Data permanently. Customer Data deleted in this manner is non-recoverable and is referred to within the services as “GDPR Delete”. Please refer to the Paminga documentation for more information on various methods you can use to “GDPR Delete” Customer Data.

Sometimes legal matters arise that also require us to preserve records, including those containing personal information. These matters include litigation, law enforcement requests, or government investigations. If we have to do this, we will delete the impacted records when no longer legally obligated to retain them. We may, however, retain Customer Data transformed such that your end user cannot be identified.

When and Why We Share Your Personal Information Or Your Customer Data

We do not sell or allow your Account Data to be used by third parties for their own marketing purposes, unless you ask us to do this or give us your consent to do this. Further, we do not sell your Customer Data or access to your Customer Data, and we do not share it with third parties for their own marketing or other purposes.

Below are the different scenarios under which we may share your data with third parties.

• Third-party service providers or consultants. Paminga engages certain third-party service providers to carry out certain data processing functions on our behalf. These providers are limited to only accessing or using this data to provide services to us and must provide reasonable assurances they will appropriately safeguard the data.
• Sub-processors. We may share Customer Data with sub-processors who assist in providing the Paminga services, like our infrastructure providers, or as necessary to provide functionality like email delivery. An up-to-date list of our sub-processors is located at https://www.paminga.com/legal/sub-processor-list/.
• Compliance with Legal Obligations. We may disclose your Account Data or Customer Data to a third party if we reasonably believe that disclosure is compelled by applicable law, regulation, legal process or a government request (including to meet national security or law enforcement requirements). If Paminga is required by law to disclose any personal information of you or your end user, we will notify you of the disclosure requirement, unless prohibited by law. Further, we object to requests we do not believe were issued properly.
• Affiliates. We may share your Account Data or your Customer Data with an affiliate company, like a subsidiary of Paminga. We and our subsidiaries will only use the information as described in this notice.
• Business transfers. If we go through a corporate sale, merger, reorganization, dissolution or similar event, data we gather from you may be part of the assets transferred or shared in connection with the due diligence for any such transaction. Any acquirer or successor of Paminga may continue to process data consistent with this notice.
• Aggregated or de-identified data. We might also share data with third parties if the data has been de-identified or aggregated in a way so it cannot be used to identify you or your Customer Data.

Transfers of Personal Information Out of the EEA

When you use our account portal, or our other products and services, Account Data and Customer Data processed by Paminga may be transferred to the United States, where our primary processing facilities are located.

Paminga employs appropriate safeguards for cross-border transfers of personal data, as required by applicable local law, including the EU-U.S. Privacy Shield Framework.

Paminga employs appropriate safeguards for cross-border transfers of personal data, as required by applicable local law.

EU-U.S. Privacy Shield. Paminga complies with the EU-U.S. Privacy Shield Framework regarding the collection, use, and retention of Personal Information from European Union member countries. Paminga has certified that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability. To learn more about the Privacy Shield program, and to view Paminga's certification, please visit http://www.privacyshield.gov/ or see our Privacy Shield Notice at https://www.paminga.com/privacy-shield.

In compliance with the Privacy Shield Principles, Paminga commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at: privacy@paminga.com.

Paminga has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit http://go.adr.org/privacyshield.html for more information or to file a complaint. The services of American Arbitration Association are provided at no cost to you.

In matters related to privacy, Paminga is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Paminga remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless Paminga proves that it is not responsible for the event giving rise to the damage.

European Union Model Clauses. Paminga also offers EU Model clauses, also known as Standard Contractual Clauses, to provide appropriate safeguards for Customers that transfer personal information to use from the EEA. Our Data Protection Addendum goes into more detail and can be requested here.

Automated Decision Making

Paminga may use automated decision making using a variety of signals derived from account activity to help identify and suspend accounts sending spam or engaged in other abusive or fraudulent activity. Holders of accounts suspended under these circumstances are notified of the suspension and given an opportunity to request human review of the suspension decision.

Handling Disputes Relating To Our Data Protection Practices

We hope we can resolve any disputes relating to our data protection practices between us. You can raise your concern or dispute by emailing our Privacy Team at privacy@Paminga.com or by writing to us at:

Paminga
6698 S. Iris St. #621149
Littleton, CO 80127

For individuals in the EEA, you have additional rights to make a complaint to a competent data protection authority or commence proceedings in a court of competent jurisdiction in accordance with applicable data protection laws.

Unless you are in EEA or Switzerland, if you have a dispute with us relating to our data protection practices, please contact us by email us at privacy@Paminga.com.

For those in the EEA or Switzerland, if you have a dispute with us relating to our data protection practices or are not satisfied with how we’ve addressed your concerns or questions, you may complain to an independent dispute resolution provider, at no cost to you, as outlined in our Privacy Shield Statement.

If you are a resident of the EEA, you also have the right to lodge a complaint with your local data protection authority.

How We Secure Personal Information

We use appropriate security measures to protect the security of your personal information both online and offline. These measures vary based on the sensitivity of the personal information we collect, process and store and the current state of technology. We also take measures to ensure service providers that process personal data on our behalf also have appropriate security controls in place.

Please note that no service is completely secure. While we strive to protect your data, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will never occur.

To protect the confidentiality of your account and protect from unauthorized use of your account, you must keep your account passwords confidential and not disclose them publicly or to unauthorized individuals – this includes accidentally distributing them in a binary or checking them into source control. Please let us know right away if you think your password or Auth Token was compromised or misused.

Other Information You May Find Useful

Here’s some other information about our privacy practices, such as how we handle certain types of data like children’s data or protected health information, how we handle do-not-track signals, what to expect if we make changes to our notice, and the legal bases for processing personal information.

Information from Children

We do not knowingly permit children (under the age of 13 in the US or 16, if you live in the EEA) to sign up for a Paminga account. If we discover someone who is underage has signed up for a Paminga account, we will take reasonable steps to promptly remove that person’s personal information from our records. If you believe a person who is underage has signed up for a Paminga account, please contact us at privacy@Paminga.com.

Do-Not-Track Signals

Paminga does not currently respond to web browser’s Do-Not-Track signals.

Changes to Our Privacy Statement

We may change our Privacy Statement from time to time. If we make changes we’ll revise the “Effective” date at the top of this statement, and we may provide additional notice such as on the Paminga website homepage, account sign-in page, or via the email address we have on file for you. We will comply with applicable law with respect to any changes we make to this notice and seek your consent to any material changes if this is required by applicable law.

Legal Basis for Processing Personal Information (EEA only)

If you are from the EEA, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person such as in the case where we request personal information from you in the context of a government audit or in response to a request from law enforcement.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact information provided in the introduction section of this privacy statement.