Penguin Strategies Privacy Statement

Current version published: May 24th, 2018

Penguin Strategies strives to be completely transparent with how we collect and use information we gather about you on this site. Your privacy is important to us and we respect your preferences.

This Privacy Statement (“Privacy Statement”) explains how Penguin Strategies Ltd, (“Penguin Strategies”) uses personal information (“Personal Information”) and applies to all users (“users”) who access, view, visit, download, or otherwise interact with https://www.penguinstrategies.com/ (the “Site”). By visiting the Site, you are accepting the practices described in this Privacy Statement. If you do not agree to the Penguin Strategies practices, do not access, view, visit, download, or otherwise interact with the Site. If you have any questions or comments concerning Penguin Strategies’s Privacy Statement, please contact us by sending an email to contact (at) info@PenguinStrategies.com. You can also contact Penguin Strategies via postal mail at: 14 Hahorest Street, Raanana, Israel.

Our Privacy Statement is organized as follows:

Personal Information Penguin Strategies gathers
How Penguin Strategies Collects Personal Information
How Penguin Strategies Uses Personal Information
When and Why Penguin Strategies Discloses Personal Information
Personal Information Retention
Tracking Technologies
Choice and Control
Security of Personal Information
EU Data Subject Rights
Withdrawing Consent
Privacy Practices of Third Parties
Notice to Residents of Countries outside the United States of America
Penguin Strategies Blog
Changes to this Privacy Statement

1) Personal Information Penguin Strategies gathers

“Personal Information” is information that can be used to identify, locate, or contact an individual. Penguin Strategies collects the following types of Personal Information:

Contact Information. Contact Information allows Penguin Strategies to communicate with you. Examples of Contact Information include, but are not limited to, your name, accurate postal addresses, valid email address, or other addresses at which you receive communications from or on behalf of Penguin Strategies. Penguin Strategies may also request demographic contact information including, but not limited to, your job title, job function, and corporate title.

Transaction Information. Penguin Strategies automatically receives and records some information from your browser when you visit the site, such as your IP address, cookies and data about which pages you visit on the site through the use of log files provided by our third-party tracking-utility partners. This information helps Penguin Strategies analyze and understand how the site works for users. Information that is gathered includes, but is not limited to, information about how you interact with Penguin Strategies, information about how you use Penguin Strategies’s Sites, email, other communications, and applications, and how you interact with other users and Penguin Strategies business partners.

Mobile Location Information. If you have permitted your mobile or other location-aware device to transmit location data, Penguin Strategies collects Mobile Location.

Posted Information. If you chose to post a comment on Penguin Strategies’s blog, Penguin Strategies may collect information regarding your name and the content of your post. It is important to note that any content you post on the blog is publicly displayed and will be seen by other users of the Site.

2) How Penguin Strategies Collects Personal Information

Penguin Strategies gathers Personal Information in the following ways:

If and when you are prompted and to provide Personal Information (including Contact Information) when you use Penguin Strategies or otherwise interact with the Site or contact Penguin Strategies.

When you use the Site. For example, Penguin Strategies may track the pages you view, the methods of communication that may be offered on or through the Site from time to time. Penguin Strategies uses cookies and related technologies to collect information about your computer and your interaction with the Site and our partner websites.

If and when you contact Penguin Strategies via telephone, email, or other methods of communication.

Lawful basis for Penguin Strategies’s processing of your Personal Information:

As applicable, the following is the lawful basis Penguin Strategies relies on to process your Personal Information:

Legitimate Interest means the interest of Penguin Strategies in conducting and managing its business to enable it to give you best service/product and the most optimized and secure interaction. Penguin Strategies makes sure to weigh any potential Penguin Strategies on you (both positive and negative) and your rights before Penguin Strategies processes your Personal Information for its legitimate interest. Unless Penguin Strategies has your consent or is otherwise required or permitted to by law, it will not use your Personal Information for activities where the Penguin Strategies on your overrides Penguin Strategies’s interests.

3) How Penguin Strategies Uses Personal Information

Penguin Strategies may use Personal Information to enhance to enhance your user experience, to help Penguin Strategies better understand you, to help Penguin Strategies customize offers, blog topics, or posts that may be of interest to you, and to help Penguin Strategies otherwise enhance the Site.

Penguin Strategies uses Personal Information to:

Identify and authenticate users;
Facilitate transactions;
Operate and improve the Site;
Connect with you on social media (such as Facebook, LinkedIn, or Twitter);
Contact you by phone or email;
Personalize and continually improve users’ Penguin Strategies experience;
Provide you with suggested information based on variables such as stated preferences, interests, business activities, and/or location;
Send you technical notices, updates, alerts and support and administrative messages service bulletins, or marketing;
Evaluate additional services, items, or offerings that may be of interest to users;
Track transactions and perform other analytics;
Communicate and provide additional information that may be of interest to you about Penguin Strategies partners or third parties; and
Manage Penguin Strategies everyday business needs such as Site administration, communication management, analytics, fraud prevention, enforcement of our corporate reporting obligations, Terms of Use or to comply with the law.

4) When and Why Penguin Strategies Discloses Personal Information

Penguin Strategies will not disclose your Personal Information to third parties without your explicit consent, except as specified in this Privacy statement. Penguin Strategies will disclose your Personal Information when:

Working with companies and service providers (i.e. HubSpot, Salesforce.com, or other companies that process billing, website hosting, or analytics performance in furtherance of the purposes described in Section 3 (“How Penguin Strategies Uses Personal Information”) above.
Penguin Strategies employs other companies to perform tasks on Penguin Strategies’s behalf and therefore Penguin Strategies must share your Personal Information with these companies to provide services to you. Examples include but are not limited to processing payments, handling billing disputes and collections, analyzing data, providing marketing assistance and providing customer service. Penguin Strategies may partner with third-party services for fraud prevention and/or identity verification.
Enforcing Penguin Strategies’s rights or protect Penguin Strategies property and intellectual property;
Protecting the rights, property or safety of others, investigate fraud, respond to a government request.
Penguin Strategies believes in good faith that it must disclose such information to prevent imminent physical harm or financial loss.
Penguin Strategies believes in good faith that it must disclose such information to commence an investigation or take action regarding illegal activities or suspected fraud.
Penguin Strategies believes in good faith that it must disclose such information per auditing, compliance, and corporate governance functions.
Penguin Strategies believes in good faith that it must disclose such information to defend Penguin Strategies in litigation or a regulatory action.
Penguin Strategies believes in good faith that it must disclose such information, or advised to do so by law, such as in response to a subpoena, or similar legal process, including to law enforcement agencies, regulators, and courts in the United States and other countries where we operate.

Penguin Strategies will not sell your Personal Information to third parties unless Penguin Strategies is in the process of entering into a merger with another business, acquisition of another business, or the sale of all or a portion of Penguin Strategies’s assets and the information is needed to support the sale or transfer of business assets.

This Privacy Statement only governs when and why Penguin Strategies discloses Personal Information. This Privacy Statement does not apply to the practices of third parties that Penguin Strategies does not own or control, or individuals that Penguin Strategies does not employ or manage. The use of your Personal Information by third parties that you access through the Site is governed by the privacy policies of such parties and is not subject to Penguin Strategies’s control. Penguin Strategies is not responsible for the privacy or security practices of other websites on the Internet, even those linked to or from the Penguin Strategies Site. Penguin Strategies encourages you to ask questions before you disclose your personal information to others.

Penguin Strategies may disclose information about you that is not personally identifiable. For example, Penguin Strategies may provide our partners, (such as HubSpot or Salesforce.com), or other third parties with reports that contain aggregated and statistical data about Penguin Strategies users.

5) Personal Information Retention

To determine the appropriate retention period, Penguin Strategies considers the type and volume of the information, the negatives that can result from un-permitted access to such information, why Penguin Strategies gathers such information and the availability of achieving the goals of such gathering through alternative means.

6) Tracking Technologies - Indirect Data Collection

Penguin Strategies implements cookies to store user information and track user activities. User’s web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information. Cookies enable Penguin Strategies to monitor your activity across sessions of interaction between your device and the Site. Please see #7, Choice and Control, for information on how to refuse cookies.

7) Choice and Control

While Penguin Strategies does need to gather certain information to make your Penguin Strategies experience personalized and to conduct transactions for you, Penguin Strategies wants to give you the ability to control how your information is provided and shared.

Email Preferences. For various reasons, Penguin Strategies may contact you about our services or your activity.
Cookies and Tracking Devices. Upon visiting Penguin Strategies’s site for the first time (or after a clearing a browser’s cache) you will be shown a notification. You may click “accept” to clear the notification. However, we will, by default, use cookies when you visit our site.
The notification states: “This website uses cookies to remember you and improve your experience. To find out more see our Privacy Policy.”

If you would like to decline cooking tracking, you can manage how your browser handles cookies and other tracking devices by adjusting the privacy and security settings on your browser. If accessing Penguin Strategies by a mobile device, you may manage the information your mobile device shares, such as cookies, tracking technologies, and location information, by adjusting your mobile device privacy and security settings.

8) Security of Personal Information

Penguin Strategies strives to use commercially acceptable means to protect your Personal Information, however, no method of transmission over the Internet, or method of electronic storage, is 100% secure and therefore Penguin Strategies cannot guarantee absolute security of your personal information. Penguin Strategies strives to maintain a system that reasonably safeguards Personal Information and has put in place appropriate security measures to accomplish the foregoing.

9) EU Data Subject Rights

In certain circumstances, you have the following rights under data protection laws in relation to your Personal Information:

Request access to your Personal Information (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal Information Penguin Strategies holds about you and to check that Penguin Strategies is lawfully processing it.
Request correction of the Personal Information. This enables Penguin Strategies to have any incomplete or inaccurate data held about you corrected, though Penguin Strategies may need to verify the accuracy of the new data provided.
Request erasure of Personal Information. This enables you to ask Penguin Strategies to delete or remove Personal Information where there is no good reason for Penguin Strategies continuing to process it. You also have the right to ask Penguin Strategies to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where Penguin Strategies may have processed your information unlawfully or where Penguin Strategies is required to erase your personal data to comply with local law. Note, however, that Penguin Strategies may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to gathering of your Personal Information where Penguin Strategies is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to gathering on this ground as you feel it Penguin Strategiess on your fundamental rights and freedoms. You also have the right to object where Penguin Strategies is gathering your Personal Information for direct marketing purposes. In some cases, Penguin Strategies may demonstrate that it has compelling legitimate grounds to gather your information which override your rights and freedoms.
Request restriction of gathering of your Personal Information. This enables you to ask Penguin Strategies to suspend the gathering of your personal data in the following scenarios: (a) if you want Penguin Strategies to establish the data's accuracy; (b) where Penguin Strategies’s use of the data is unlawful but you do not want Penguin Strategies to erase it; (c) where you need Penguin Strategies to hold the data even if Penguin Strategies no longer requires it as you need it to establish, exercise or defend legal claims; or (d) you have objected to Penguin Strategies’s use of your data but Penguin Strategies needs to verify whether it has overriding legitimate grounds to use it.
Request the transfer of your Personal Information to you or to a third party. Penguin Strategies will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for Penguin Strategies to use or where Penguin Strategies used the information to perform a contract with you.
Withdraw consent at any time where Penguin Strategies is relying on consent to gather your Personal Information. However, this will not affect the lawfulness of any gathering carried out before you withdraw your consent. If you withdraw your consent, Penguin Strategies may not be able to provide certain products or services to you. Penguin Strategies will advise you if this is the case at the time you withdraw your consent.

10) Withdrawing Consent

If Penguin Strategies is relying on your consent for certain activities, you have the right to withdraw you sent at any time by contacting Penguin Strategies at info@.PenguinStrategies.com

11) Privacy Practices of Third Parties.

This Privacy Statement describes the collection, use, and disclosure of information by Penguin Strategies through the Site. Penguin Strategies utilizes third parties to provide services to users and also provides links from the Site to other websites. These third parties may have their own privacy policies and may collect, use, and distribute information differently than Penguin Strategies. Penguin Strategies encourages all users to read the privacy policies of all third parties.

12) Penguin Strategies Blog

Penguin Strategies contains a blog and other areas where users may publicly post information, communicate with other users, and submit content they deem relevant for discussion. Penguin Strategies strongly encourages you to read the Penguin Strategies Terms of Use carefully prior to posting or engaging in the blog. All the information you post will be accessible to anyone, at any time, with Internet access. Furthermore, Penguin Strategies strongly advises you to NOT post any personal or identifiable information about yourself or contact information, including address, email, phone numbers, or other means of communicating outside of the blog. Any information you post may be read, collected, and used by others.

13) Changes to this Privacy Statement

Penguin Strategies may, from time to time, in Penguin Strategies’s sole, absolute, and unfettered discretion, update this Privacy Statement to clarify its practices or to reflect new or different privacy practices. Penguin Strategies encourages all users to periodically review the Privacy Statement. You are bound by any changes to the Privacy Statement when you use the Site after such changes have been first posted.