PRIVACY NOTICE
Last updated June 27, 2022
This privacy notice for
Palla Capital Corporation
( ”
Company
,”
“we,” “us,” or
“our”
), describes how and why we might collect, store, use, and/or
share (
“process”
) your information
when you use our services (
“Services”
), such as when
you:
-
Visit our website
at http://www.pallacapital.com , or any website of ours that links to this privacy notice
-
Engage with us in other related ways, including any sales,
marketing, or events
Questions or concerns? Reading this privacy
notice will help you understand your privacy rights and choices.
If you do not agree with our policies and practices, please do
not use our Services. If you still have any questions or
concerns, please contact us at
srikanth.palla@pallacapital.com .
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but
you can find out more details about any of these topics by
clicking the link following each key point or by using our
table of contents below to find the section you are looking
for. You can also click
here to go directly to our table of contents.
What personal information do we process? When
you visit, use, or navigate our Services, we may process personal
information depending on how you interact with
Palla Capital Corporation
and the Services,
the choices you make, and the products and features you use. Click
here to learn more.
Do we process any sensitive personal information?
We do not process sensitive
personal information.
Do we receive any information from third parties?
We do not receive any
information from third parties.
How do we process your information? We process
your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to
comply with law. We may also process your information for other
purposes with your consent. We process your information only when
we have a valid legal reason to do so. Click
here to learn more.
In what situations and with which
parties do we share personal
information?
We may share information in specific situations and with specific
third parties. Click
here to learn more.
How do we keep your information safe? We have
organizational
and technical
processes and procedures in place to protect your personal
information. However, no electronic transmission over the internet
or information storage technology can be guaranteed to be 100%
secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other
unauthorized
third parties will
not be able to defeat our security and improperly collect, access,
steal, or modify your information. Click
here
to learn more.
What are your rights? Depending on where you are
located geographically, the applicable privacy law may mean you
have certain rights regarding your personal information. Click
here to learn more.
How do you exercise your rights? The easiest way
to exercise your rights is by filling out our data subject request
form available here:
https://www.pallacapital.com/contact/
, or by contacting us. We will
consider and act upon any request in accordance with applicable
data protection laws.
Want to learn more about what
Palla Capital Corporation
does with any
information we collect? Click
here to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to
us.
We collect personal information that you voluntarily provide to
us when you
express an interest in obtaining information about us or our
products and Services, when you participate in activities on the
Services, or otherwise when you contact us.
Personal Information Provided by You. The
personal information that we collect depends on the context of
your interactions with us and the Services, the choices you
make, and the products and features you use. The personal
information we collect may include the following:
-
names
-
phone numbers
-
email addresses
Sensitive Information.
We do not process sensitive
information.
All personal information that you provide to us must be true,
complete, and accurate, and you must notify us of any changes to
such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol
(IP) address and/or browser and device characteristics
— is collected automatically when you visit our
Services.
We automatically collect certain information when you visit,
use, or navigate the Services. This information does not reveal
your specific identity (like your name or contact information)
but may include device and usage information, such as your IP
address, browser and device characteristics, operating system,
language preferences, referring URLs, device name, country,
location, information about how and when you use our Services,
and other technical information. This information is primarily
needed to maintain the security and operation of our Services,
and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through
cookies and similar technologies.
The information we collect includes:
-
Log and Usage Data. Log and usage data is
service-related, diagnostic, usage, and performance
information our servers automatically collect when you access
or use our Services and which we record in log files.
Depending on how you interact with us, this log data may
include your IP address, device information, browser type, and
settings and information about your activity in the
Services (such as the
date/time stamps associated with your usage, pages and files
viewed, searches, and other actions you take such as which
features you use), device event information (such as system
activity, error reports (sometimes called
“crash dumps” ), and hardware settings).
-
Device Data. We collect device data such as
information about your computer, phone, tablet, or other
device you use to access the Services. Depending on the device
used, this device data may include information such as your IP
address (or proxy server), device and application
identification numbers, location, browser type, hardware
model, Internet service provider and/or mobile carrier,
operating system, and system configuration information.
-
Location Data. We collect location data such as
information about your device’s location, which can be either
precise or imprecise. How much information we collect depends
on the type and settings of the device you use to access the
Services. For example, we may use GPS and other technologies
to collect geolocation data that tells us your current
location (based on your IP address). You can opt out of
allowing us to collect this information either by refusing
access to the information or by disabling your Location
setting on your device. However, if you choose to opt out, you
may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and
administer our Services, communicate with you, for
security and fraud prevention, and to comply with law.
We may also process your information for other
purposes with your consent.
We process your personal information for a variety of
reasons, depending on how you interact with our Services,
including:
Palla
Capital
Corporation
320
Boston
Post
Road,
Suite
180-122
Darien
,
CT
06820
United
States
-
To request feedback. We
may process your information when
necessary to request feedback and to
contact you about your use of our
Services.
-
To send you marketing and promotional
communications. We may process the personal information
you send to us for our marketing purposes,
if this is in accordance with your
marketing preferences. You can opt out of
our marketing emails at any time. For more
information, see
” WHAT ARE YOUR PRIVACY RIGHTS? ” below).
-
To determine the
effectiveness of our
marketing and
promotional
campaigns.
We may process your
information to better
understand how to
provide marketing and
promotional campaigns
that are most relevant
to you.
-
To save or protect
an individual’s
vital
interest.
We may process your
information when
necessary to save or
protect an
individual’s vital
interest, such as to
prevent harm.
3. WHAT LEGAL BASES
DO WE RELY ON TO
PROCESS YOUR
INFORMATION?
In Short: We only process your
personal information
when we believe it is
necessary and we have
a valid legal reason
(i.e.
,
legal basis) to do so
under applicable law,
like with your
consent, to comply
with laws, to provide
you with services to
enter into or
fulfill
our contractual
obligations, to
protect your rights,
or to
fulfill
our legitimate
business
interests.
If you are
located in the EU
or UK, this
section applies to
you.
The General Data
Protection Regulation
(GDPR) and UK GDPR
require us to explain
the valid legal bases we
rely on in order to
process your personal
information. As such, we
may rely on the
following legal bases to
process your personal
information:
-
Consent. We may process your
information if you
have given us
permission (i.e.
, consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
-
Send users
information about
special offers and
discounts on our
products and
services
-
Support our
marketing
activities
-
Understand
how our users
use our
products and
services so we
can improve
user
experience
-
Legal
Obligations.
We may process
your
information
where we
believe it is
necessary for
compliance
with our legal
obligations,
such as to
cooperate with
a law
enforcement
body or
regulatory
agency,
exercise or
defend our
legal rights,
or disclose
your
information as
evidence in
litigation in
which we are
involved.
-
Vital
Interests.
We may process
your
information
where we
believe it is
necessary to
protect your
vital
interests or
the vital
interests of a
third party,
such as
situations
involving
potential
threats to the
safety of any
person.
If you
are
located in
Canada,
this
section
applies to
you.
We may process
your information
if you have
given us
specific
permission (i.e.
,
express consent)
to use your
personal
information for
a specific
purpose, or in
situations where
your permission
can be inferred
(i.e.
,
implied
consent). You
can withdraw
your consent at
any time. Click
here
to learn
more.
In some
exceptional
cases, we may be
legally
permitted under
applicable law
to process your
information
without your
consent,
including, for
example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
-
For
investigations
and fraud
detection and
prevention
-
For business
transactions
provided
certain
conditions are
met
-
If it is
contained in a
witness
statement and
the collection
is necessary
to assess,
process, or
settle an
insurance
claim
-
For
identifying
injured, ill,
or deceased
persons and
communicating
with next of
kin
-
If we have
reasonable
grounds to
believe an
individual has
been, is, or
may be victim
of financial
abuse
-
If it is
reasonable to
expect
collection and
use with
consent would
compromise the
availability
or the
accuracy of
the
information
and the
collection is
reasonable for
purposes
related to
investigating
a breach of an
agreement or a
contravention
of the laws of
Canada or a
province
-
If disclosure
is required to
comply with a
subpoena,
warrant, court
order, or
rules of the
court relating
to the
production of
records
-
If it was
produced by an
individual in
the course of
their
employment,
business, or
profession and
the collection
is consistent
with the
purposes for
which the
information
was produced
-
If the
collection is
solely for
journalistic,
artistic, or
literary
purposes
-
If the
information is
publicly
available and
is specified
by the
regulations
In
Short:
We may share
information
in specific
situations
described in
this section
and/or with
the
following
third
parties.
We
may need to
share your
personal
information in
the following
situations:
- Business Transfers. We may share or transfer your 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.
-
Affiliates. We may
share your
information
with our
affiliates,
in which
case we will
require
those
affiliates
to
honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
-
Business
Partners.
We may share
your
information
with our
business
partners to
offer you
certain
products,
services, or
promotions.
In
Short:
We may
use
cookies
and
other
tracking
technologies
to
collect
and
store
your
information.
We may
use
cookies
and
similar
tracking
technologies
(like
web
beacons
and
pixels)
to
access
or store
information.
Specific
information
about
how we
use such
technologies
and how
you can
refuse
certain
cookies
is set
out in
our
Cookie
Notice
.
6.
IS
YOUR
INFORMATION
TRANSFERRED
INTERNATIONALLY?
In
Short:
We
may
transfer,
store,
and
process
your
information
in
countries
other
than
your
own.
Our
servers
are
located
in
the
United
States
. If
you are
accessing
our
Services
from
outside
the
United
States
, please be
aware that
your
information
may be
transferred
to, stored,
and
processed by
us in our
facilities
and by those
third
parties with
whom we may
share your
personal
information
(see
”
WHEN
AND WITH
WHOM DO
WE SHARE
YOUR
PERSONAL
INFORMATION?
”
above),
in
n/a,
and
other
countries.
If you
are a
resident
in the
European
Economic
Area
(EEA) or
United
Kingdom
(UK),
then
these
countries
may not
necessarily
have
data
protection
laws or
other
similar
laws as
comprehensive
as those
in your
country.
However,
we will
take all
necessary
measures
to
protect
your
personal
information
in
accordance
with
this
privacy
notice
and
applicable
law.
European
Commission’s
Standard
Contractual
Clauses:
We have
implemented
measures
to
protect
your
personal
information,
including
by using
the
European
Commission’s
Standard
Contractual
Clauses
for
transfers
of
personal
information
between
our
group
companies
and
between
us and
our
third-party
providers.
These
clauses
require
all
recipients
to
protect
all
personal
information
that
they
process
originating
from the
EEA or
UK in
accordance
with
European
data
protection
laws and
regulations.
Our
Standard
Contractual
Clauses
can be
provided
upon
request.
We have
implemented
similar
appropriate
safeguards
with our
third-party
service
providers
and
partners
and
further
details
can be
provided
upon
request.
7.
HOW
LONG
DO
WE
KEEP
YOUR
INFORMATION?
In
Short:
We
keep
your
information
for as
long
as
necessary
to
fulfill
the
purposes
outlined
in
this
privacy
notice
unless
otherwise
required
by
law.
We will
only
keep
your
personal
information
for as
long as
it is
necessary
for the
purposes
set out
in this
privacy
notice,
unless a
longer
retention
period
is
required
or
permitted
by law
(such as
tax,
accounting,
or other
legal
requirements).
No
purpose
in this
notice
will
require
us
keeping
your
personal
information
for
longer
than
2
years
.
When we
have no
ongoing
legitimate
business
need to
process
your
personal
information,
we will
either
delete
or
anonymize
such
information,
or, if
this is
not
possible
(for
example,
because
your
personal
information
has been
stored
in
backup
archives),
then we
will
securely
store
your
personal
information
and
isolate
it from
any
further
processing
until
deletion
is
possible.
8.
HOW
DO
WE
KEEP
YOUR
INFORMATION
SAFE?
In
Short:
We
aim to
protect
your
personal
information
through
a
system
of
organizational
and
technical
security
measures.
We have
implemented
appropriate
and
reasonable
technical
and
organizational
security
measures
designed
to
protect
the
security
of any
personal
information
we
process.
However,
despite
our
safeguards
and
efforts
to
secure
your
information,
no
electronic
transmission
over the
Internet
or
information
storage
technology
can be
guaranteed
to be
100%
secure,
so we
cannot
promise
or
guarantee
that
hackers,
cybercriminals,
or other
unauthorized
third
parties
will not
be able
to
defeat
our
security
and
improperly
collect,
access,
steal,
or
modify
your
information.
Although
we will
do our
best to
protect
your
personal
information,
transmission
of
personal
information
to and
from our
Services
is at
your own
risk.
You
should
only
access
the
Services
within a
secure
environment.
9.
DO
WE
COLLECT
INFORMATION
FROM
MINORS?
In
Short:
We do
not
knowingly
collect
data
from
or
market
to
children
under
18
years
of
age.
We do
not
knowingly
solicit
data
from or
market
to
children
under 18
years of
age. By
using
the
Services,
you
represent
that you
are at
least 18
or that
you are
the
parent
or
guardian
of such
a minor
and
consent
to such
minor
dependent’s
use of
the
Services.
If we
learn
that
personal
information
from
users
less
than 18
years of
age has
been
collected,
we will
deactivate
the
account
and take
reasonable
measures
to
promptly
delete
such
data
from our
records.
If you
become
aware of
any data
we may
have
collected
from
children
under
age 18,
please
contact
us at
PRESS@PALLACAPITAL.COM
.
10.
WHAT
ARE
YOUR
PRIVACY
RIGHTS?
In
Short:
In
some
regions,
such
as
the
European
Economic
Area
(EEA),
United
Kingdom
(UK),
and
Canada
, you
have
rights
that
allow
you
greater
access
to and
control
over
your
personal
information.
You
may
review,
change,
or
terminate
your
account
at any
time.
In some
regions
(like
the
EEA, UK,
and
Canada
), you
have
certain
rights
under
applicable
data
protection
laws.
These
may
include
the
right
(i) to
request
access
and
obtain a
copy of
your
personal
information,
(ii) to
request
rectification
or
erasure;
(iii) to
restrict
the
processing
of your
personal
information;
and (iv)
if
applicable,
to data
portability.
In
certain
circumstances,
you may
also
have the
right to
object
to the
processing
of your
personal
information.
You can
make
such a
request
by
contacting
us by
using
the
contact
details
provided
in the
section
”
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
”
below.
We will
consider
and act
upon any
request
in
accordance
with
applicable
data
protection
laws.
If you
are
located
in the
EEA or
UK and
you
believe
we are
unlawfully
processing
your
personal
information,
you also
have the
right to
complain
to your
local
data
protection
supervisory
authority.
You can
find
their
contact
details
here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you
are
located
in
Switzerland,
the
contact
details
for the
data
protection
authorities
are
available
here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing
your
consent:
If we
are
relying
on your
consent
to
process
your
personal
information,
which
may be
express
and/or
implied
consent
depending
on the
applicable
law,
you have
the
right to
withdraw
your
consent
at any
time.
You can
withdraw
your
consent
at any
time by
contacting
us by
using
the
contact
details
provided
in the
section
”
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
”
below
.
However,
please
note that
this will
not affect
the
lawfulness
of the
processing
before its
withdrawal,
nor
when
applicable
law
allows,
will it
affect the
processing
of your
personal
information
conducted
in
reliance
on lawful
processing
grounds
other than
consent.
Opting
out of
marketing
and
promotional
communications:
You can
unsubscribe
from our
marketing
and
promotional
communications
at any
time by
clicking
on the
unsubscribe
link in
the emails
that we
send,
or by
contacting
us using
the
details
provided
in the
section
”
HOW CAN
YOU
CONTACT
US ABOUT
THIS
NOTICE?
”
below. You
will then
be removed
from the
marketing
lists.
However,
we may
still
communicate
with you —
for
example,
to send
you
service-related
messages
that are
necessary
for the
administration
and use of
your
account,
to respond
to service
requests,
or for
other
non-marketing
purposes.
Cookies
and
similar
technologies:
Most Web
browsers
are set
to
accept
cookies
by
default.
If you
prefer,
you can
usually
choose
to set
your
browser
to
remove
cookies
and to
reject
cookies.
If you
choose
to
remove
cookies
or
reject
cookies,
this
could
affect
certain
features
or
services
of our
Services.
To opt
out of
interest-based
advertising
by
advertisers
on our
Services
visit
http://www.aboutads.info/choices/.
If you
have
questions
or
comments
about your
privacy
rights,
you may
email us
at
PRESS@PALLACAPITAL.COM .
11.
CONTROLS
FOR
DO-NOT-TRACK
FEATURES
Most
web
browsers
and some
mobile
operating
systems
and
mobile
applications
include
a
Do-Not-Track
(
“DNT”
)
feature
or
setting
you can
activate
to
signal
your
privacy
preference
not to
have
data
about
your
online
browsing
activities
monitored
and
collected.
At this
stage no
uniform
technology
standard
for
recognizing
and
implementing
DNT
signals
has been
finalized
. As
such, we
do not
currently
respond
to DNT
browser
signals
or any
other
mechanism
that
automatically
communicates
your
choice
not to
be
tracked
online.
If a
standard
for
online
tracking
is
adopted
that we
must
follow
in the
future,
we will
inform
you
about
that
practice
in a
revised
version
of this
privacy
notice.
12.
DO
CALIFORNIA
RESIDENTS
HAVE
SPECIFIC
PRIVACY
RIGHTS?
In
Short:
Yes,
if you
are a
resident
of
California,
you
are
granted
specific
rights
regarding
access
to
your
personal
information.
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
to us
using
the
contact
information
provided
below.
If you
are
under 18
years of
age,
reside
in
California,
and have
a
registered
account
with
Services,
you have
the
right to
request
removal
of
unwanted
data
that you
publicly
post on
the
Services.
To
request
removal
of such
data,
please
contact
us using
the
contact
information
provided
below
and
include
the
email
address
associated
with
your
account
and a
statement
that you
reside
in
California.
We will
make
sure the
data is
not
publicly
displayed
on the
Services,
but
please
be aware
that the
data may
not be
completely
or
comprehensively
removed
from all
our
systems
(e.g.
,
backups,
etc.).
13.
DO
WE
MAKE
UPDATES
TO
THIS
NOTICE?
In
Short: Yes,
we
will
update
this
notice
as
necessary
to
stay
compliant
with
relevant
laws.
We may
update
this
privacy
notice
from
time to
time.
The
updated
version
will be
indicated
by an
updated
“Revised”
date and
the
updated
version
will be
effective
as soon
as it is
accessible.
If we
make
material
changes
to this
privacy
notice,
we may
notify
you
either
by
prominently
posting
a notice
of such
changes
or by
directly
sending
you a
notification.
We
encourage
you to
review
this
privacy
notice
frequently
to be
informed
of how
we are
protecting
your
information.
14.
HOW
CAN
YOU
CONTACT
US
ABOUT
THIS
NOTICE?
If you
have
questions
or
comments
about
this
notice,
you may
email
us
at
PRESS@PALLACAPITAL.COM
or
by
post
to:
15.
HOW
CAN
YOU
REVIEW,
UPDATE,
OR
DELETE
THE
DATA
WE
COLLECT
FROM
YOU?
Based
on the
applicable
laws of
your
country,
you may
have the
right to
request
access
to the
personal
information
we
collect
from
you,
change
that
information,
or
delete
it. To
request
to
review,
update,
or
delete
your
personal
information,
please
visit:
https://www.pallacapital.com/contact/
.