Privacy policy

Last updated September 8, 2018

Pointr Talent, LLC (“ Pointr ,” “us,our” or “ we ”) is committed to protecting your privacy. Our privacy policy, which applies to all users of our Website, App and Service, is designed to explain the information we collect and how we use it to provide our services and give Users a better experience (“ Privacy Policy ”). Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use. This Privacy Policy is part of, and incorporated into, the Terms of Use.

By accessing and using the Website, App and/or Service, you consent to our collection, storage, use and disclosure of your personal information and other information as described in this Privacy Policy.

We are a data controller and therefore we are responsible for, and control the processing of, your personal data (defined below) in accordance with applicable law.

1. Types of Information We Collect

We collect both " Personal Information" and " Anonymous Information" about our users. Personal Information or “Personal Data” (collectively, “Personal Information”) is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Anonymous Information is information that cannot be used to contact or identify you and is not linked to information that can be used to do so. We passively collect certain information from your devices, such as your IP address, browser information, unique device identifier (“ UDID ”) and/or your mobile operating system.

  1. Voluntarily submitted information

  2. We collect information that you voluntarily provide to us during your use of the Website, App and/or Service, including without limitation, when you create an Account, upload information to a profile and contact us for support services.

  3. Information collected via technology

    • We also collect information from your use of the Website, App and Service, including your hardware model, browser type, operating system, Internet Protocol (“IP”) address and domain name. If you are using a mobile device, Pointr may also receive your UDID, or another unique identifier, and mobile operating system. We may correlate this information with other Personal Information we have about you. We may also use technological tools such as cookies and tags to gather information.
  • Pointr may access, collect, monitor and/or remotely store your geolocation data, in part by utilizing Google Maps API.
  • We may obtain information when you login or register with us through a third party social network, such as Facebook, Google or LinkedIn. These services will authenticate your identity and provide you the option to share certain Personal Information with us.
  • When you interact with us through a social media site or third party service, such as when you like, follow or share Pointr content on any third party social network, we may receive certain information from the social network. The data we receive from these third party sites is dependent upon the third party’s policies and your privacy settings on that site.
  • We use third party services, such as Google Analytics, Google Marketing Platform, Google Ad Manager and Google Ads, to track and analyze online behavior data of Users. We do this to better understand how you use the Website, App and Service, with a view to offering improvements for all Users.
  • If you would like to opt out of Google Analytics, please download and install the browser plugin at http://tools.google.com/dlpage/gaoptout?hl=en .
2. How We Use Your Information
  1. Personal Information

  2. We may use and process your Personal Information for a variety of business purposes including but not limited to:

    • Help you create an Account
    • Send communications and administrative emails
    • Personalize and tailor the features, performance and support of the Website, App and Service
    • Send you promotional/marketing information, newsletters, offers or other information from us or on behalf of our sponsors or partners
    • Investigate, respond to and resolve complaints, as well as perform internal operations, including fraud detection
    • Analyze, benchmark and conduct research on user data and interactions with the Service
    • Consider applications and recruitment information if you apply to work for Pointr

    Where you have allowed for Pointr’s processing of your Personal Information, subject to applicable legal and ethical obligations that may apply and our lawful ability to enforce our rights or your obligations to us, you may withdraw that consent at any time and opt out.


  3. Anonymous Information

  4. We may use and process Anonymous Information for the following representative purposes:

    • Perform internal operations on the Website, App and Service
    • Improve the Website, App and Service and customize the user experience
    • Aggregate the information collected via cookies and tags to use in statistical analysis to help us track trends and analyze patterns
  1. Advertising

  2. We may target (and measure the performance of) ads to Users, visitors and others both on and off our Services directly or through a variety of partners, using the following data, whether separately or combined:

    • Data from advertising technologies on and off our Website, App and Services, like tags and cookies, and device identifiers
    • User-provided information (e.g., contact information, title and industry)
    • Data from your use of our Website, App and Services (e.g., connections, page visits, videos watched, ads clicked, etc.)
    • Information from advertising partners and publishers
    • Information inferred from data described above

    We may show you ads which look similar to non-sponsored content, except that they are labeled “ads” or “sponsored.” If you take an action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the advertiser. Subject to your settings, if you take a social action, that action may be mentioned with related ads.

Where you have allowed for Pointr’s processing of your Personal Information, subject to applicable legal and ethical obligations that may apply and our lawful ability to enforce our rights or your obligations to us, you may withdraw that consent at any time and opt out.

3. How We Share and Disclose Information

We know how important it is to keep your information confidential. We will not rent, sell or share your Personal Information with third parties except as specifically approved by you at the time of disclosure or under the circumstances described in this Privacy Policy. If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Privacy Policy, you may choose not to use the Website or Service, download the App, or provide your Personal Information at any time.

You give us permission to use your name, profile picture and other Personal Information in connection with commercial, sponsored or related content both on and off the Website, App and Service. This means, for example, that you permit a third party to pay us to display your name and/or profile picture and/or other Personal Information, without any compensation to you.

Your Personal Information may be shared with the following third parties and/or for the following purposes:

  1. Other Users and Visitors

  2. Sharing information is at the very core of our mission. As such, your profile is visible to all Users of our Service. Subject to your settings, it can also be visible to others on or off of our Service.


  3. Service Providers

  4. We share Personal Information with vendors, consultants and other third party service providers who perform services on behalf of - and at the request of - Pointr, including without limitation, companies that provide email services and host the Website, App and Service. Pointr has selected companies who maintain high standards with respect to privacy and agree to use the Personal Information only to perform specific services on behalf of Pointr and in accordance with the terms and conditions of this Privacy Policy.

  5. Compliance with Laws, Law Enforcement and Safety

  6. We may disclose information we have collected about you if required to do so by law or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement, or any legal process (whether or not such disclosure is required by applicable law), or to protect or defend Pointr's, or a third party's, rights or property.

  1. Aggregated Anonymous information

  2. Aggregated Anonymous Information is the combination of your Anonymous Information with the Anonymous Information of other Users (“ Aggregated Anonymous Information ”). Aggregated Anonymous Information does not allow you to be identified or contacted. We may share such Aggregated Anonymous Information with third parties.

  3. Business transactions

  4. We may share all or some of your Personal Information with any of our subsidiaries, joint venturers, or other companies under common control, in which case we will require them to honor this Privacy Policy. Additionally, in the event we undergo a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Privacy Policy, and that any entity that acquires us, is merged with us or that acquires our assets may continue to process your Personal Information as set forth in this Privacy Policy.

  5. Online advertising networks

  6. We may share, or we may permit third party online advertising networks to collect, information about your use of our Website, Service and App over time so that they may place or display ads on our Website, Service and App, on other devices you may use, and on other websites, apps or services. We and our third party partners use this information to make the advertisements you see online more relevant to your interests. Depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technologies by actively managing your settings. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).

4. Your Choices

By submitting Personal Information, you consent to receive certain communications from us. You may modify or opt out of receiving messages sent for marketing purposes, or certain other communications, by following the unsubscribe instructions in such messages. Please note that despite any indicated marketing preferences, we may send you administrative emails regarding the Website, App or Service, including, for example, notices of updates to our Privacy Policy.

5. Children

We do not knowingly collect or solicit information from anyone under the age of 13 through the Website, App or Service. In the event that we learn that we have inadvertently collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at privacy@pointr.co so that we may delete and remove such information from our system.

6. Security and Data Retention

We are concerned with safeguarding your information. We employ reasonable and appropriate administrative, physical and electronic measures designed to protect your information from unauthorized access. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data (as defined in applicable state statutes on security breach notification) to you via email and/or conspicuous posting on the Website in the most expedient time possible and without unreasonable delay, insofar as it is consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system. Although guaranteed security does not exist either on or off the Internet, we make commercially reasonable efforts to make the collection and security of such information consistent with this Privacy Policy and all applicable laws and regulations. Your consent to such purpose remains valid after termination of our relationship with you.

7. Changes to Our Privacy Policy

We reserve the right to change, modify, add or remove portions of this Privacy Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. However, we will not use your Personal Information in a way that is adverse and materially different from the uses described in this Privacy Policy without giving you an opportunity to opt out. If you object to any changes we implement, you may close your account. Your continued use of the Website, App and Service after this Privacy Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Privacy Policy, as amended. We encourage you to bookmark this webpage and review this Privacy Policy regularly.

8. EU Resident Privacy Rights

To the extent required by law, we provide EU residents with reasonable access to the Personal Information they provide to us, a portable copy of the information and the ability to review, correct, delete, restrict or object to the processing of such information. Although we make good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information would compromise others’ privacy or legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where the information is commercially proprietary. If we determine that access should be restricted in any particular instance, we will endeavor to provide you with an explanation of why that determination has been made and a contact point for further inquiries. To protect your privacy, Pointr will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information. If you would like to review or update your Personal Information or preferences, or have your information removed from our mailing lists, please let us know by emailing us at privacy@pointr.co or by writing to us at Pointr Talent, LLC, of 156 W 56th St, New York, NY 10019. EU residents may also report privacy complaints directly to their local data protection authorities. You may contact us to be directed to the relevant authorities, as well.

9. California Privacy Rights

Under California’s “Shine the Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. To request the above information, California residents can email us at privacy@pointr.co.


10. Contact Us

If you have any questions regarding our Privacy Policy, you can contact us via email at privacy@pointr.co or write to us at Pointr Talent, LLC, of 156 W. 56th St., New York, NY 10019.

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