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Last updated: January 2020
Ping Identity Corporation (“Ping Identity,” “we,” “us,” “our”) values privacy, and we want you (“user,” “you”) to have the information you need to make your own decisions about your privacy.
This Privacy Notice (“Notice”) describes how we collect, use, share, and protect information about you, as well as the choices you may make about how we use this information. This Notice only applies to information that can be used to identify an individual (“Personal Information”) and which we collect through various channels, both online and offline, in the context of our sales and marketing activities, our hiring activities, and our service offerings “(Service Offerings”). This Notice also tells you how we can verify the accuracy of your Personal Information and how you can request that we delete or update it.
Please note that the website, https://www.pingidentity.com (referred to herein as the “site”), contains links to other sites. Unless specifically stated otherwise, the collection and use of your Personal Information at other sites, linked to https://www.pingidentity.com, are not governed by this Notice. In addition, the site is not intended for children under the age of 16, and Ping Identity does not knowingly collect or use Personal Information from children under the age of 16.
Please read the following to learn more about our privacy practices before providing us with any Personal Information. If you have questions about this Notice, please e-mail us at email@example.com.
1. Ping Identity Website
There are three manners in which we collect your Personal Information for uses related to our marketing activities.
Information You Provide
When you access, use and/or interact with us through a channel (detailed below), including in connection with activities that require sign-in or subscription, we collect business information and Personal Information you voluntarily provide us. This includes but is not limited to:
Providing this information is completely voluntary. Though you will still have access, for example, to the site without providing requested information, you may not be able to use certain services or features that require such information to function.
Interactions through channels include, but are not limited to:
Automatically Collected Information
Collecting this information enables us to better understand the visitors who come to our site, where they come from, and what content on our site is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our site to our visitors.
Information Collected Through Third Party Sources
We also obtain Personal Information about you from third party sources as permitted by applicable law, such as:
2. Ping Identity Hiring Activities
As part of our hiring activities, we collect and maintain different types of Personal information about you in accordance with applicable law. Some examples include:
Generally, we collect employee-related Personal Information directly from you in circumstances where you provide us with such information (e.g., during the onboarding process, signing up for direct deposit, enrolling in benefits or services). However, in some instances, we supplement your Personal Information with other information you provide us, or that we obtain through your interactions with us or from third parties. When we collect your Personal Information from third parties it is either because you have given us express permission to do so, your permission was implied by your actions (e.g., your use of a third-party employee service made available to you by us), or because you provided explicit or implicit permission to the third party to provide the Personal Information to us.
We reserve the right to monitor the use of our premises, equipment, devices, computers, network, applications, software, and similar assets and resources. In the event such monitoring occurs, it may result in the collection of Personal Information about you.
3. Ping Identity Service Offerings
Ping Identity facilitates the transfer of information for our customers in connection with our Service Offerings. Ping Identity has no direct relationship with the individual users/employees of our customers, and the type of information that is processed by Ping Identity’s Service Offering is at the sole discretion of our customers. Such information may include Personal Information of users/employees.
We will only use and share your Personal Information as described in this Notice. The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the time of request.
1. The Basis On Which We Collect Personal Information
If you are a website visitor, candidate, employee or customer 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 and use it.
We collect Personal Information from you only (i) where we need the Personal Information to perform a contract with you (to provide the marketing products and services you use, as part of our employment relationship, etc.), (ii) where the processing is in our legitimate interests and not overridden by your rights (when we fulfill your inquiry, for example), or (iii) 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.
If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).
If we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicate with you as necessary to provide our marketing products and services and for our legitimate commercial interest - for example, to respond to your queries, improve our platform, undertake marketing, or for the purpose of detecting or preventing illegal activities. We may have other legitimate interests and, if appropriate, we will make clear to you at the relevant time what those legitimate interests are.
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 via firstname.lastname@example.org.
2. Purposes of Processing
We use and process Personal Information for the following business purposes:
3. Sharing Your Personal Information
We rely on service providers to perform a variety of services on our behalf. In so doing, we may need to share your Personal Information with them. Please note that we only provide our service providers with the Personal Information they need to perform their services and we require that they protect this information and not use it for any other purpose. These service providers are also not permitted to use your Personal Information for their own promotional or business purposes.
We may share your business contact information with our trusted business partners with whom we have a strategic partnership, or our investors. We do not otherwise sell or rent information about you or your use of this site to other companies.
Please also note that our sponsors, co-sponsors and/or exhibitors may directly request your information at their conference booths or presentations. You should review their privacy policies to learn how they use Personal Information.
Your information may also be transferred to another company in connection with a corporate transaction, such as a divestiture, merger, acquisition, consolidation, or asset sale (or the negotiation thereof) of a substantial amount or all of the assets of Ping Identity, or in the unlikely event of bankruptcy. We may assign or transfer your information as part of the transaction.
In addition, Ping Identity may use or disclose any information available to it, if required to do so by law, or if necessary to conform with the requirements of the law or to comply with legal process served upon us, to protect or defend our legal rights, or to investigate, prevent, or take legal action regarding suspected fraud, threats to physical safety, or other illegal activity.
Finally, with respect to Personal Information we collect as part of our hiring activities, we disclose your Personal Information to our private equity sponsor, Vista Equity Partners, and its affiliates, including Vista Consulting Group (collectively, “Vista”), for administration, research, database development and business operation purposes, in line with the terms of this Notice. Vista processes your Personal Information on the basis of its legitimate interests in overseeing the recruitment process and, if applicable, your employment relationship with Ping Identity. If you have consented to us doing so, we also share your Personal Information with other Vista portfolio companies for the purpose of being considered for other job opportunities in the pooling system, both inside and outside the EEA. Please find a full list of all Vista portfolio companies at: https://www.vistaequitypartners.com/companies/.
4. International Data Transfers
Your Personal Information might be transferred to, and processed in, countries other than the country in which you are resident.
Ping Identity shares data with other entities within the Ping Identity group. We have implemented the European Commission’s Standard Contractual Clauses for transfers of Personal Information between our group companies, which require all group companies to protect Personal Information they process from the EEA in accordance with European Union data protection law. In connection with our recruitment processes, we transfer your Personal Information outside of the EEA to Hirebridge, LLC and Criteria Corp., which provide applicant tracking services. Hirebridge, LLC and CriteriaCorp. both comply with the EU-U.S. Privacy Shield Framework and ensure that your Personal Information is adequately protected while outside of the EEA.
We have taken appropriate safeguards to require that your Personal Information will remain protected in accordance with this Notice when we share your Personal Information with third parties (as detailed above under “Sharing Your Personal Information”). These safeguards include transferring your Personal Information to third parties who are located in a country which the European Commission has determined has data protection laws that are at least as protective as those in Europe, and transferring your Personal Information to third parties who have entered into Standard Contractual Clauses or equivalent (according to EU Commission Decision 87/2010/EC or any future replacement) with us, in order to contractually ensure that your Personal Information is subject to a level of data protection which applies in Europe. For more information about these safeguards, please contact us at email@example.com.
5. Notice to California Residents
The California Consumer Privacy Act of 2018, as amended (Cal. Civ. Code § 1798.100 to 1798.199), and related regulations (“CCPA”), requires that we describe our handling of California consumer Personal Information by reference to the categories of Personal Information defined in the statute. This section outlines the categories of personal information that we collect, the sources of the information, and with whom we share the information.
In the past twelve (12) months, we have collected, used, and disclosed the following categories of personal information:
|Category of Personal Information||Category of Source||Business or commercial purpose(s) for collection||Categories of third parties with whom we share|
|Identifiers||Directly from you; from your employer; from third parties or public sources||Ping Identity Website and Marketing; Ping Hiring Activities; Ping Service Offerings||Service Providers; we may share your contact information with our trusted business partners but only when you direct us to do so|
|Categories of personal information described in subdivision (e) of Section 1798.80, including but not limited to government issued ID, education and employment history, financial account information, and health, medical and benefits information||Directly from you||Ping Hiring Activities||Service Providers|
|Protected classification characteristics under California or federal law||Directly from you||Ping Hiring Activities||Service Providers|
|Professional or employment-related information||Directly from you; from your employer||Ping Identity, Website, and Marketing; Ping Hiring Activities; Ping Service Offerings||Service Providers|
|Internet or other electronic network activity||Indirectly from you (from your device or browser)||Ping Identity, Website, and Marketing; Ping Hiring Activities; Ping Service Offerings||Service Providers|
YOUR DATA RIGHTS
We take steps to make sure your Personal Information is accurately maintained. You may view the Personal Information you provide to us to make corrections or modify your information at any time, subject to the final paragraph of this section.
If you are a resident of California, you have the following rights:
In addition, if you are a resident of the EEA, you have the following data protection rights:
If you would like to exercise your rights under this Notice, you may contact us at firstname.lastname@example.org or 1001 17th Street, Suite 100, Denver, Colorado 80202, USA, attn: Privacy Department. We will respond to reasonable requests as soon as reasonably practicable.
Finally, with respect to Personal Information processed by Ping Identity on behalf of our customers as part of our Service Offerings, an individual who seeks to exercise their rights under this heading should direct their query to their employer or service provider, as appropriate. If the employer or service provider requests that Ping Identity remove the data, we will respond to their request within 30 business days.
If you have concerns about this Notice, its implementation, or other related inquiries or concerns, please contact us at email@example.com. Any improper collection or misuse of information in violation of this Notice should be reported by e-mail to firstname.lastname@example.org. Ping Identity takes seriously any reported violations, and will investigate such violations and correct any misinformation.
If you are a resident of the EEA, you have the right to complain to a relevant data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA and certain non-European countries (including the US and Canada) are available here.
We reserve the right to modify this Notice at any time, so please review it frequently. If we decide to change our Notice, we will post the changes to the Notice here and other places we deem appropriate. We will obtain your consent to any material changes if required by applicable law.
Ping Identity will use appropriate technical and organizational measures to secure the Personal Information users provide to us. We have implemented reasonable information security policies, rules and technical measures to protect the Personal Information we have under our control from unauthorized access, improper use or disclosure, unauthorized modification, and unlawful destruction or accidental loss.
All our employees, contractors and data processors who have access to, and are associated with, the processing of your Personal Information are obligated to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for us.
We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it, 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.
With regard to Personal Information processed as part of our Service Offerings, Ping Identity will retain any information we process on behalf of our customers for as long as needed to provide services to our customer or as otherwise required by law, or until you object to Ping Identity’s use of your Personal Information (if our use of your Personal Information is based on a legitimate interest) or you withdraw your consent (if our use of your Personal Information is based on your consent). Ping Identity will retain and use this information solely as necessary to provide our services, comply with our legal obligations, resolve disputes, and enforce our agreements.
Unless it is in respect of Ping Identity’s Service Offerings, the controller of your personal information is Ping Identity Corporation. In light of our GDPR obligations, we have appointed a Data Protection Officer (DPO) who can be contacted using the contact details listed below.
If you have questions specifically about this Notice, or to legal issues pertaining to the practices of the site or your use of the site, please contact us using the following details:
E-mail Address: email@example.com
Mailing Address: 1001 17th Street, Suite 100, Denver, CO 80202