Privacy Policy

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Privacy Policy) refers to PROVINITI LLC, 501 Madison Avenue, 5th Floor, New York, NY 10022.
• Consent Tool means the cookie banner and “Cookie Settings” panel on the Website that lets You accept, reject, or change Your choices about non-essential Cookies and tracking technologies.
• Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
• Country refers to: New York, United States.
• Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
• Personal Data (also called “personal information”) is any information that relates to an identified or identifiable individual.
• Service refers to the Website.
• Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
• Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
• Visitor Identification Partner means a third-party vendor that, with Your consent, uses Cookies and similar technologies to associate Your visit to the Website with information that it or others already hold about You, such as Your name, email address, employer, job title, or professional profile.
• Website refers to Proviniti, accessible from https://proviniti.com.
• You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data You Provide to Us

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. When You submit our Contact Us form, request information, register for an event, or otherwise contact Us, this may include:

• First and last name
• Work email address
• Phone number
• Company name
• Job title
• The content of Your message or request

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, the page that referred You to the Website, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Visitor Identification Partners

Only if You accept Marketing Cookies, We use a Visitor Identification Partner (RB2B, which works with its data partner Retention.com) to help Us understand which businesses and professionals visit the Website. When You consent, this partner may match Your visit with information it or others already have about You and provide Us with information such as:

• Your name and business email address
• Your employer, job title, and professional (e.g. LinkedIn) profile URL
• Your general location (city/state)
• The pages of the Website You visited and when

We use this information for business-to-business marketing and sales outreach, as described in “Use of Your Personal Data” below. If You reject or do not accept Marketing Cookies, this technology does not load and We do not receive this information from Your visit.

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email. We (or service providers on our behalf) may then send communications and marketing to these email addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout.

Social Media Links

The Website contains links to Our pages on third-party social media services such as LinkedIn, X (Twitter), and Instagram. The Website does not offer account registration or login through these services. If You click one of these links, You leave the Website and that service’s own privacy policy applies.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies (such as tags, scripts, and pixels) to operate the Service and, only with Your consent, to analyze how the Service is used and to support Our marketing.

Your consent comes first. When You first visit the Website, We ask You through Our Consent Tool which categories of non-essential Cookies You want to allow. Analytics and Marketing technologies do not load until You choose to accept them. You can reject them just as easily as accepting them, and You can change Your choice at any time by clicking “Cookie Settings” in the footer of any page.

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use the following categories of Cookies and similar technologies:

Strictly Necessary Cookies (always active)

• Type: Session and Persistent Cookies
• Administered by: Us
• Purpose: These Cookies are essential to provide You with the Website, keep it secure, prevent spam and fraudulent form submissions, and remember Your cookie choices. Without these Cookies, the services that You have asked for cannot be provided. They do not require consent and cannot be turned off in the Consent Tool.

Functional Cookies (only with Your consent)

• Type: Persistent Cookies
• Administered by: Us
• Purpose: These Cookies allow Us to remember choices You make when You use the Website, such as display preferences, to provide You with a more personal experience.

Analytics Cookies (only with Your consent)

• Type: Persistent Cookies and scripts
• Administered by: Google LLC (Google Analytics) and Zoho Corporation (Zoho PageSense)
• Purpose: These technologies help Us understand how visitors use the Website — for example, which pages are visited, how visitors arrived at the Website, how far they scroll, where they click, and how they interact with pages and forms — so We can improve the Website’s content and design.
• Google Analytics collects information such as pages viewed, time on page, referring website, device and browser type, and approximate location derived from Your IP address. Google Analytics does not log or store IP addresses. We do not use Google Analytics for advertising, and We do not allow Google to use this data for its own advertising. Learn how Google uses this information at https://policies.google.com/technologies/partner-sites, or opt out of Google Analytics on all websites with Google’s browser add-on at https://tools.google.com/dlpage/gaoptout.
• Zoho PageSense may also create heatmaps and recordings of on-page interactions. Form fields are not intended to be captured.

Marketing Cookies (only with Your consent)

• Type: Persistent Cookies and scripts
• Administered by: RB2B and its data partner Retention.com
• Purpose: These technologies allow Our Visitor Identification Partner to associate Your visit with information it or others hold about You (including by association with Your email address), so that We can identify businesses and professionals interested in Our services and follow up with relevant communications. See “Information from Visitor Identification Partners” above.

A current, detailed list of the specific Cookies used on the Website, including their names, providers, purposes and durations, is available in the Consent Tool under “Cookie Settings” in the footer of any page.

Content delivery. To display fonts and icons, the Website loads resources from third-party content delivery networks (Google Fonts and Font Awesome). These providers receive Your IP address and basic browser information as part of delivering that content, but they are not used by Us for analytics or marketing.

Global Privacy Control and Do Not Track

If Your browser sends a Global Privacy Control (GPC) signal, We treat it as a request to opt out of Analytics and Marketing Cookies and of any “sale” or “sharing” of Your personal information, and those technologies will not load on Your browser.

Some browsers offer a “Do Not Track” (DNT) setting. Because there is no common industry standard for DNT, the Website does not respond to DNT signals separately; however, We honor GPC signals as described above, and You can always reject non-essential Cookies in the Consent Tool.

Third-Party Tracking Across Websites

With Your consent to Marketing Cookies, Our Visitor Identification Partner may collect information about Your online activities over time and across different websites, and combine it with information from other sources. Without that consent, We do not allow third parties to collect this information through the Website.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our Service and to keep it secure.
• To contact You: To contact You by email, telephone calls, or other equivalent forms of electronic communication regarding Your inquiries, the services You have requested, or events You have registered for.
• To provide You with news, special offers and general information about other services and events which we offer that are similar to those that you have already enquired about, unless You have opted not to receive such information.
• For business-to-business marketing and sales outreach: With Your consent to Marketing Cookies, to identify businesses and professionals who have shown interest in Our services and to contact them with relevant information. Every marketing email We send includes a way to unsubscribe.
• To manage Your requests: To attend and manage Your requests to Us.
• For the performance of a contract: the development, compliance and undertaking of any contract for services with Us.
• For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
• For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with Service Providers that help Us operate the Website and Our business, for example website hosting (Amazon Web Services), customer relationship management and form processing (Zoho CRM), and website analytics (Google Analytics and Zoho PageSense, only with Your consent).
• With Visitor Identification Partners: With Your consent to Marketing Cookies, information about Your visit is made available to RB2B and its data partner Retention.com as described above. Under some U.S. state privacy laws, this may be considered a “sale” or “sharing” of personal information. See “Your U.S. State Privacy Rights” below.
• For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
• With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
• With business partners: We may share Your information with Our business partners to offer You certain services or promotions.
• With Your consent: We may disclose Your personal information for any other purpose with Your consent.

We do not sell Your personal information for money.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Your cookie choices are stored in Your browser for up to 12 months, after which We will ask You again.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Your Choices and Rights

Access, Correction, and Deletion

You have the right to request access to, correction of, or deletion of the Personal Data that We have collected about You. To make a request, contact Us using the details in “Contact Us” below.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Cookie and Tracking Choices

• Consent Tool: Accept or reject Analytics and Marketing Cookies on Your first visit, and change Your choice at any time through “Cookie Settings” in the Website footer.
• Global Privacy Control: Enable GPC in Your browser, and We will treat it as an opt-out, as described above.
• Retention.com opt-out: Opt out of advertising based on visitor identification at https://app.retention.com/optout.
• Email unsubscribe: Use the unsubscribe link in any marketing email from Us, or contact Us.
• Browser settings: You can also block or delete Cookies through Your browser settings. Blocking Strictly Necessary Cookies may prevent some parts of the Website from working.

Your U.S. State Privacy Rights

Depending on where You live — including California, Colorado, Connecticut, Virginia, Texas, Oregon, and other states with consumer privacy laws — You may have some or all of the following rights, and We extend them to all U.S. visitors:

• Right to know / access: request the categories and specific pieces of personal information We have collected about You, the sources, the purposes, and the categories of third parties to whom We disclose it.
• Right to delete: request that We delete personal information We collected from You, subject to certain exceptions.
• Right to correct: request that We correct inaccurate personal information.
• Right to opt out of “sale,” “sharing,” or targeted advertising: You can opt out by clicking “Cookie Settings” in the Website footer and turning off Marketing (or clicking Deny), by enabling GPC in Your browser, by visiting https://app.retention.com/optout, or by contacting Us.
• Right to non-discrimination: We will not discriminate against You for exercising any of these rights.

Categories of personal information. In the past 12 months, We have collected the following categories of personal information:

We do not collect sensitive personal information for the purpose of inferring characteristics about You, and We do not knowingly sell or share the personal information of consumers under 16 years of age.

How to submit a request. Email info@proviniti.com with the subject line “Privacy Request”, or write to Us at the address below. We will verify Your request by matching the information You provide with the information We have, and We will respond within 45 days (or as otherwise required by law). You may use an authorized agent to submit a request on Your behalf; We may ask the agent for proof of authorization and ask You to verify Your identity directly. If We deny Your request, You may appeal by replying to Our response with the subject line “Privacy Request Appeal.”

California “Shine the Light.” California residents may request information about Our disclosure of personal information to third parties for their direct marketing purposes by contacting Us at the email address below.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

• Comply with a legal obligation
• Protect and defend the rights or property of the Company
• Prevent or investigate possible wrongdoing in connection with the Service
• Protect the personal safety of Users of the Service or the public
• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under the age of 16. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 16, We take steps to remove that information from Our servers.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the “Last updated” date at the top of this Privacy Policy. If We make material changes to how We use Cookies and tracking technologies, We will also ask for Your consent again through the Consent Tool.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, or want to exercise any of Your rights, You can contact us:

• By email: info@proviniti.com
• By mail: PROVINITI LLC, 501 Madison Avenue, 5th Floor, New York, NY 10022
• By visiting the Contact Us page on our Website: https://proviniti.com/contact-us/