Ping Website Privacy Notice

Last updated: June 2021

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 privacy@pingidentity.com.

TYPES OF PERSONAL INFORMATION WE COLLECT

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:

• information about you in the context of your professional activities, such as your name, professional email address, and professional telephone number;
• information about your company such as the name, size and location, as well as your role within the company; and
• your login credentials for the site.

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:

• our site;
• completion and submission of online (registration) forms (such as events, webinars, webinar recordings, asset downloads) as part of joint marketing activities with business partners;
• completion of lead sheets or other similar forms at events (either in paper format or electronically); handing over your business card or badge attendance at a Ping Identity hosted event; or visiting a Ping Identity booth at a trade show or industry or association event;
• sales inquiries which you initiate (online chat, or dedicated online “contact-us” form);
• tele-sales (cold or warm calls) and information you provide during phone calls with sales representatives and tele-sales representatives;
• subscription to marketing communications and/or submission of marketing preference in the Ping Identity Preference Center;
• completion of questionnaires and surveys;
• participation in sweepstakes and contests; and
• other conversation data triggered by the above direct interactions (such as follow-up calls and emails, thank-you emails, confirmation emails and the like).

Automatically Collected Information

We may use cookies and other technologies to collect information about you when you visit our site or use our website-based services. This may include information such as your IP address, device type, unique device identification numbers, browser-type, broad geographic location and other technical information. In some jurisdictions, including the state of California and countries in the European Economic Area (“EEA”), this information may be considered Personal Information under applicable data protection laws.

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.

For more information about cookies and other technologies we may use to collect information about you, please see the separate Cookie Policy. This Notice does not cover the use of cookies by other sites, of which we do not have access or control.

Information Collected Through Third Party Sources

We also obtain Personal Information about you from third party sources as permitted by applicable law, such as:

• information collected by our marketing service providers on our behalf, which are a variety of marketing lead generation and content syndication service providers, marketing opt-out lists and/or professional event organizers;
• information shared with us by our business partners as part of their referral activities; and
• public databases or other data you may have made publicly available, such as social media posts on professional networks and social media platforms.

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:

• Name, gender, home address and telephone number, date of birth, marital status, and employee identification number.
• Residency and work permit status, military status, nationality and passport information.
• Social security or other taxpayer/government identification number.
• Payroll information, banking details.
• Wage and benefit information.
• Retirement account information.
• Sick pay, Paid Time Off (“ PTO”), retirement accounts, pensions, insurance and other benefits information (including the gender, age, nationality and passport information for any spouse, minor children or other eligible dependents and beneficiaries).
• Information from interviews and phone-screenings you may have had, if any.
• Date of hire, date(s) of promotions(s), work history, technical skills, educational background, professional certifications and registrations, language capabilities, and training records.
• Beneficiary and emergency contact information.
• Results of credit and criminal background checks, drug and alcohol testing, health certifications, driver’s license number, vehicle registration and driving history.
• Information required for us to comply with the requests and directions of law enforcement authorities or court orders (e.g., child support and debt payment information).
• Acknowledgements regarding our policies, including employee handbooks, ethics and/or conflicts of interest policies and computer and other corporate resource usage policies.
• Information captured on security systems, including Closed Circuit Television (“CCTV”) and key card entry systems.
• Voicemails, e-mails, correspondence, documents, and other work product and communications created, stored or transmitted using our networks, applications, devices, computers or communications equipment.
• Letters of offer and acceptance of employment.
• Resume or CV, cover letter, previous and/or relevant work experience or other experience, education, transcripts, or other information you provide to us in support of the application and/or recruitment process.

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.

Our customers are the controller of your Personal Information when collected or used in connection with our products. They are solely in control of what Personal Information about you they submit, or ask you to submit, to or through our Products. This Personal Information may include contact information (such as your first and last name, email address, and phone number), government issued identification information, professional information (such as the department you work for at your place of employment), protected health information, biometric data (such as facial recognition), or other types of personal information our customer selects to submit to us for processing. We require our customers to obtain all necessary consents and authorizations as may be required under applicable data privacy laws in order for us to process special categories of Personal Information.

Ping Identity’s Service Offerings may use cookies and other technologies (for more information please see our Cookie Policy.) Furthermore, our Service Offerings may also collect certain Personal Information such as your IP address, device type, unique device identification numbers, browser-type, broad geographic location and other technical information to allow functionality defined by our customers. In some jurisdictions, including the state of California and countries in the EEA, this information may be considered Personal Information. Lastly, in the event a customer contacts our support organization, we may collect certain Personal Information in connection with troubleshooting activities.

An important exception is if you download or purchase one of our products or applications from an app store as an individual consumer (independent of a customer relationship between Ping Identity and your employer or service provider, in which case you would be an end user subject to the provisions above). An example of this is our Shocard application. In these situations we are still a Processor of your information (as discussed in this section above), however you are the controller of your data. We will only process the data that you select to provide us with in accordance with that product or application’s functionality and its terms of use. Types of personal information that we process in this situation may include contact information (such as your first and last name, email address, and phone number), government issued identification information, professional information (such as the department you work for at your place of employment), protected health information, biometric data (such as facial recognition), or other types of information. Our provision and your use of those products or applications, and any liability associated therewith, shall be governed by the terms of use that you agree to upon download or purchase of the product or application. We will obtain all necessary consents and authorizations as may be required under applicable data privacy laws for us to process special categories of Personal Information.
 

HOW WE USE PERSONAL INFORMATION

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 privacy@pingidentity.com.

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 privacy@pingidentity.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:
 

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:

 

• Right to Know. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

   

  • The categories of Personal Information we collected about you
  • The categories of sources for the Personal Information we collected about you;
  • Our business and commercial purpose for collecting or selling that Personal Information;
  • The categories of third parties with whom we share that Personal Information;
  • The specific pieces of Personal Information we collected about you.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

   

• Right to Delete. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. If so, we will notify you in our response that an exception applies and identify that exception.

   

• To exercise your rights, please submit a verifiable consumer request to us by emailing privacy@pingidentity.com or by visiting our website www.pingidentity.com. To verify your identity we may ask you for additional information, which may include asking you to confirm other Personal Information you have provided to us. We reserve the right to deny any requests for which identity cannot be reasonably verified. If you have authorized another person to make a request on your behalf, that person must provide to us your written authorization allowing them to make such a request on your behalf. We reserve the right to deny any request by an authorized agent if we are not reasonably able to confirm proper authorization.

   

• We will not discriminate against you for exercising any of your rights under California law. Unless permitted by California law, we will not:

   

  • Deny you goods or services;
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
  • Provide you a different level or quality of goods or services;
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

   

• The CCPA provides a right to opt-out of the sale of Personal Information as that sale is defined in the statute. However, we do not sell California consumer Personal Information for monetary or other valuable consideration. To the extent we share California consumer Personal Information with our trusted business partners or investors we do so only when you have directed us to do so. We do not sell the Personal Information of minors under 16 years of age.

In addition, if you are a resident of the EEA, you have the following data protection rights:

• If you wish to access, correct, update or request deletion of your Personal Information, you can do so at any time by contacting us using the contact details provided below. You can require Ping Identity to confirm at any time that we are processing your Personal Information, or to have access to the Personal Information we may have about you. You may also request information about: the purpose of the processing; the categories of Personal Information concerned; who else outside Ping Identity might have received your data from Ping Identity; what the source of the information was (if you did not provide it directly to us); and how long it will be stored. Reasonable access to your Personal Information will be provided at no cost to you upon request and subject to a reasonable proof of identity. If access cannot be provided within a reasonable time frame, Ping Identity will provide you with a date when the information will be provided. If for some reason access is denied, we will provide an explanation as to why that happened;

   

• In addition, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information, or request portability of your Personal Information. Again, you can exercise these rights by contacting us using the contact details provided below:
  
  
  • You can object to Ping Identity processing your Personal Information in cases where we rely on the ground of our legitimate interest to process it. Should you choose to exercise this right, we will cease using your Personal Information and remove it from our systems unless such Personal Information is permitted to be used by Ping Identity for another purpose set out in this Notice or we determine and demonstrate a compelling legitimate interest to continue processing your Personal Information;
  • You can exercise your right to restrict the processing of your Personal Information where, for example, you believe that the Personal Information we hold about you is not accurate or lawfully held; or where you object against the processing of your Personal Information by Ping Identity on the ground of legitimate interest - in such case you have a right to restrict processing of your Personal Information while we verify if we have a prevailing interest in processing your Personal Information; and
  • If you wish to request a copy of the Personal Information you provided us, you need to clearly state which Personal Information you require from Ping Identity, in which format, and whether the Personal Information shall be provided to you or another recipient. We will carefully review your request and discuss with you how it can be best implemented.

   

• In certain circumstances, you may also have a right to have your Personal Information erased. For example, if it is no longer necessary for the purposes for which it was originally collected (also called the “Right to Be Forgotten”).

   

• If we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. This means that we will not process the Personal Information subject to this consent any longer unless legally required to do so. In case we are required to retain your Personal Information for legal reasons, such data will be restricted from further processing and only retained for the term required by law. Furthermore, if your use of Ping Identity’s Service Offerings require your prior consent, we will not be (any longer) able to provide the relevant product or service to you after withdrawal of your consent.

If you would like to exercise your rights under this Notice, you may contact us at privacy@pingidentity.com 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.

CUSTOMER SERVICE AND RECOURSE

If you have concerns about this Notice, its implementation, or other related inquiries or concerns, please contact us at privacy@pingidentity.com. Any improper collection or misuse of information in violation of this Notice should be reported by e-mail to privacy@pingidentity.com. 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.

CHANGES IN THIS NOTICE

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.

CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

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.

DATA RETENTION

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.

CONTACT US

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: privacy@pingidentity.com

Mailing Address: 1001 17th Street, Suite 100, Denver, CO 80202