PRIVACY POLICY

Last updated August 21, 2023.

Your privacy is important to us. This Privacy Policy describes the types of information Point Three Group LLC (“Point Three”) collects from you when you visit www.pointthree.co (our “Site”) or otherwise interact with us online. This Privacy Policy also explains how Point Three may use and disclose your information, as well as your ability control certain uses of your personal information.

INFORMATION COLLECTION

Information Collected About Visitors to our Website, Prospective Employees, Job Applicants, and Clients

We collect information from you when you voluntarily share it with us.  This may include when you visit our Site, request information from us, or contact us.

The personal information we collect may include the following:

  • Contact information, including your name, address, email addresses, phone numbers;
  • Career-related information, such as your job title, job role, profession, education, industry, years of experience, skills, and related documents such as your resume or other files as provided voluntarily;
  • Career interests, such as current student status, majors, locations interested in working, work area of interest, profession interest, and other career topics;
  • Employer-related information, such as your title and the company’s name, address, and phone number;
  • Email activity, such as emails opened and clicks in email;
  • Any other information you submit to us, such as trading strategy performance, supplementary materials, details about your requests made to us, etc.;
  • Jobs applied for or interested in.

Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate our Site. 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 Site, and other technical information. This information is primarily needed to maintain the security and operation of our Site, and for our internal analytics and reporting purposes.

The information we may collect also 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 Site 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 on the Site (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 data such as information about your computer, phone, tablet, or other device you use to access our Site. Depending on the device use, this 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.

We may use cookies, JavaScript, or other technologies to collect certain information about visitors to our Site and interactions with our emails to allow Point Three to keep track of analytics and certain statistical information which enables us to improve our Site and provide you with more relevant content and advertising on our Site.

Deletion of Cookies, Tracking Options, and DO-NOT-TRACK Disclosures

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.

Information Collected from Third Parties or Other Sources

We may obtain personal or other information about you from third parties or other sources, and combine this information with the information we collect from you. We may also obtain information about you from other online sources, including when you connect with Point Three through its official corporate pages on third party social networks such as LinkedIn. This information may include your name, user name, updated address or contact information, interests, and publicly-observed data.  We may combine this information with the information we collect from you through our Site.

INFORMATION USE

Point Three may use the information we collect from and about your for any of the following purposes:

  • For recruiting services, such as matching your qualifications with job openings, facilitating interviews, and communicating with you about potential opportunities;
  • To deliver Point Three’s broader services to you;
  • To review the usage and operations of our Site, and improve our content, products, and services;
  • To provide you with customized Site content, or with your consent where applicable via email, telephone, text message, and other marketing channels;
  • To contact you when necessary, including for recruiting purposes, by email, telephone, or text message;
  • To use your data in an aggregated non-specific format for analytical purposes;
  • To develop new products or services and to conduct analysis to enhance current products and services;
  • As otherwise described to you at the point of data collection.

INFORMATION SHARING

Point Three may need to disclose the personal information we collect from you in the following ways:

  • With our third party service providers that provide business, professional, or technical support functions for us;
  • As necessary if we believe that there has been a violation of our Terms of Use or of our rights or the rights of any third party;
  • To respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law;
  • As otherwise described to you at the point of collection.

LINKS TO OTHER WEBSITES

The Site, and email messages from us, may contain links to third-party websites, which may have privacy policies that differ from our own.  You should be aware that the collection, retention and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this Privacy Policy. We are not responsible for the practices of such websites.

DATA STORAGE

Your personal information may be stored on servers in the United States and is subject to the laws of the United States, where the data protection and other laws may differ from those of other countries.  Your personal information may be disclosed in response to inquiries or requests from government authorities or to respond to judicial process in the countries in which we operate.

DATA SECURITY

We have implemented appropriate and reasonable technical, physical, and administrative security measures to protect the personal information we collect and process from our clients, candidates, and Site visitors. 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 guarantee our security measures against cybercriminals, or other unauthorized third parties who attempt to defeat our security and improperly collect, access, steal, or modify your information. Transmission of personal information to and from our Site is at your own risk. You should only access the Site within a secure environment.

CHILDREN’S PRIVACY

Protecting children’s privacy is important to us. We do not knowingly solicit data from or market to children under 18 years of age. By using our Site, you represent that you are at least 18 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of our Site. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to promptly delete such data from our records.

PRIVACY RIGHTS

You may review, change or terminate your express consent and/or implied consent depending on the applicable law, at any time. To access, review, or update your information stored by Point Three, or withdraw your consent, you may contact us at privacyinquiries@pointthree.co.

CALIFORNIA RESIDENTS PRIVACY RIGHTS

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 our Site, 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 our Site but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.)

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as

(1) Every individual who is in the State of California for other than a temporary or transitory purpose and

(2) Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information

Information We Collect

In the course of our business, we collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”).  Depending on how you have interacted with us, we may have collected the following categories of Personal Information from you in the last twelve (12) months, which we may also share with third parties for the purposes outlined in this Privacy Notice.  The categories below are those identified in the California Consumer Privacy Act (CCPA).

Please note that we have not collected every type of Personal Information identified in the Examples below, and the types of Personal Information we have collected on any consumer depends on how the consumer has interacted with us.

Category

Examples

Collected

Identifiers

This category may include:  name, postal address, unique personal identifiers, online identifiers, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.  Under the CCPA, “unique identifiers” or “unique personal identifier” means a persistent identifier that can be used to recognize a consumer, a family, or a device that is linked to a consumer or family, over time and across different services, including, but not limited to, a device identifier; an Internet Protocol address; cookies, beacons, pixel tags, mobile ad identifiers, or similar technology; customer number, unique pseudonym, or user alias; telephone numbers, or other forms of persistent or probabilistic identifiers that can be used to identify a particular consumer or device.

YES

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) and protected classification characteristics under California or federal law.

This category may include:  name, signature, Social Security number, physical characteristics, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education or employment information, financial account numbers, medical information, health insurance information, age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex and gender information, veteran or military status, or genetic information.

YES (for prospective candidates and job applicants)

Commercial Information

This category may include: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

Biometric Information

This category may include: fingerprints, voiceprints, eye imagery

NO

Internet or other electronic network activity information

Browsing history, search history, and information regarding interactions with an Internet Web site, application, or advertisement

YES

Geolocation data

Device location

YES

Sensory data

This category may include: audio, electronic, visual, thermal, olfactory, or similar information.

NO

Professional or employment-related information

Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job listed on our Site.

YES

Education Information

Education records directly related to a student maintained by an educational institution or party acting on its behalf (e.g., grades, transcripts, schedules, and student ID numbers)

YES (for prospective candidates or job applicants)

Inferences drawn from other personal information

Inferences drawn from any of the collected personal information listed above that may reflect preferences, characteristics, predispositions, behavior, interests, attitudes, or similar behavioral information.

 YES

Sensitive Personal Information

 

NO

Please note that some of the categories of personal information described in the CCPA overlap with each other; for instance, your name is both an Identifier and a type of data described in Cal. Civil Code 1798.80(e).

Personal information does not include publicly available information from government records or any de-identified or aggregated consumer information.  In addition, the CCPA excludes the following from its scope:  health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; and personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Use and Sharing of Personal Information

More information about our data collection and sharing practices can be found in this privacy notice. You may contact us at privacyinquiries@pointthree.co or by referring to the contact details at the bottom of this document. If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Sales of Personal Information

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCP. We may use your personal information for our own business purposes, such as for undertaking internal research. This is not considered to be “selling” of your personal information. We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights and Choices

The CCPA provides eligible California residents with specific rights with respect to our collection, retention, and use of Personal Information.

a) Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we provide certain information to you about our collection and use of your Personal Information over the past twelve (12) months.  Specifically, you have the right to request disclosure of the categories of Personal Information and specific pieces of Personal Information we have collected about you over the last 12 months.  Upon the submission of a verifiable consumer request (see Exercising your California Privacy Rights, below), we will disclose to you:

  • the categories of personal information we collect about you;
  • the categories of sources from which personal information was collected;
  • the business purposes for collecting, disclosing, or selling personal information;
  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose; and
  • the specific pieces of personal information we collected about you, subject to certain exceptions under applicable law, if you also request access to such information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

b) Right to Request to Delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

c) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you for exercising any of your privacy rights.

d) Verification Process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate. We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

e) Exercising Your California Privacy Rights

To exercise these rights, you can contact us by email at privacyinquiries@pointthree.co or by referring to the contact details at the bottom of this document.

END OF CALIFORNIA PRIVACY RIGHTS

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 see “Contact Us” below.

CONTACT US

If you have questions or comments about this notice, you may email us at privacyinquiries@pointthree.co or contact us by mail at:

Point Three Group LLC

418 Broadway, STE N

Albany, NY 12207

USER’S ACCEPTANCE OF THIS PRIVACY POLICY

By using the Site and our Services, you confirm that you have read and understood this Privacy Policy.  If you do not agree with the terms of this Privacy Policy, please do not use our Site or Services at all.

REVISIONS TO THIS PRIVACY POLICY

Point Three reserves the right, at its sole discretion, to change, modify, add, remove, or other revise portion of this Privacy Policy at any time. If we do, we will provide access to the immediately prior version of the Privacy Policy on the Site. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information. Your continued use of the Site following the posting of changes to these terms means you accept these changes.