PRIVACY POLICY

Last Revised: 2021/02/05

Pinnacle Financial Solutions Inc., an Ontario, Canada incorporation, doing business as Pinnacle Institute (“Pinnacle Institute”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (“Policy”). In accordance with Pinnacle Institute’ existing Terms and Conditions, we are committed to complying with the requirements of applicable data privacy laws. To that end, this Policy shares how Pinnacle Institute collects, stores, uses, shares and disposes of your personal data, as well as advises you of ways in which you can exercise your rights.

This Policy describes the types of information we may collect from you or that you may provide when you visit the website www.pinnacleinstitute.com (the “Site”) and our practices for collecting, using, maintaining, protecting and disclosing that information. This Policy should be read in conjunction with our Site Terms and Conditions into which this Policy is incorporated by reference.

This Policy applies to information we collect on the Site or in email and other electronic messages between you and the Site. It does not apply to information collected by us offline or through any other means, including on any other website operated by a third party.

1. DATA CONTROLLER: WHO WE ARE.

  1. Pinnacle Institute is responsible for this Policy and is a “Controller” for purposes of processing personal data and as defined in the General Data Protection Regulation (“GDPR”). We are responsible for operating and maintaining the Site.
  2. Without limiting the generality of the foregoing or any other provision hereof, You acknowledge and agree:

i. that the content, data, materials, services, information, and other intellectual property contained or embodied in the Site are owned by the Pinnacle Institute and are protected by patent, copyright, trademark and other similar laws;
ii. not to promote, offer for sale or sell any product or service, including, without limitation, any financial or investment product, security or service, or any contest or promotion on the Site;
iii. not to transmit, send or otherwise post unauthorized commercial communications (such as spam), or other similar materials or advertisements, using the Site;
iv. Not to use or launch any automated system or access the Site using any automated means, including, without limitation, harvesting bots, robots, spiders, offline readers, or scrapers. Notwithstanding the foregoing, Pinnacle Institute grants the operators of public search engines permission to use spiders to copy materials from the Site for the sole purpose of creating publicly available searchable indices of the Site, but not caches or archives of the Site;
v. not to engage in multi-level marketing using the Site, including, without limitation, pyramid schemes and similar marketing concepts;
vi. not to upload, use or disseminate viruses or other malicious code or other abusive scripts or processes;
vii. not to solicit login, account or other personal information of another person or request or obtain access to an account of another person;
viii. not to bully, intimidate, or harass any person;
ix. not to post content that is hateful, threatening, illegal, or pornographic, incites violence, or contains nudity, graphic material, gratuitous violence or anything else found to be objectionable by Pinnacle Institute in its sole discretion;
x. not to use the Site in any manner that is, or could reasonably be construed to be, unlawful, including, without limitation, in violation of any law, rule or regulation related to securities or investments, or any rules or regulations promulgated by the U.S. Securities and Exchange Commission (SEC), Canadian Securities Administrators (CSA), and/or rules of any national or other securities exchange and any regulations or other pronouncements having the force of law;
xi. not to use the Site in any manner that is, or could reasonably be construed to be, in violation of these Terms and Conditions, fraudulent, misleading, malicious or discriminatory;
xii. not to take any action that could disable, overburden, or impair the operation or availability of the Site, such as a denial of service attack;
xiii. not to engage in manipulative practices designed to obfuscate the true intent of Your submissions to the Site, or to artificially generate traffic to another website;
xiv. not to facilitate or encourage any violations of these Terms and Conditions;
xv. not to post or make any defamatory, disparaging or false statements, claims or allegations related to the Site, Pinnacle Institute, or any other product or service of Pinnacle Institute;
xvi. not to make Your account or any portion thereof or the services provided thereby available to the general public or any portion thereof;
xvii. not to issue chargeback disputes against the Pinnacle Institute.
xviii. not to use patented, copyrighted, trademarked or other protected intellectual property without the prior written consent and authorization of the owner of such property;
xix. not to copy, distribute or disseminate the Site or any portion thereof, and not to transfer the Site, or any portion thereof, to another person or “mirror” the Site, or any portion thereof, on any other server;
xx. not to decompile or reverse engineer, or attempt to decompile or reverse engineer, the Site or any portion thereof;
xxi. not to take any other action that could result in any damage or disruption to the Site, or that could otherwise result in any liability, damages, costs or expenses on the part of the Pinnacle Institute;
xxii. not to share personal information with members or request personal information from members;
xxiii. all content, materials and services related to the Site shall be solely used for, and You hereby agree to solely use it for, Your own personal and non-commercial use in connection with Your trading activities, and for no other use.

2. GOODS AND SERVICES: WHAT WE OFFER.

The Site is a platform through which Pinnacle Institute provides information on its products and services, and provides data, material, content or information relating to the fields of finance, including but not limited to securities trading and financial markets, credit management, and managing portfolio risks (collectively, the “Content”).

3. PERSONAL DATA: WHAT WE COLLECT.

  1. We only collect basic personal data about you or from you, and do not intentionally collect any sensitive data. The personal data we collect may include:
    • Your first and last name
    • Your company name
    • Your email address
    • Your mailing address
    • Your phone numbers
    • Payment information (i.e., credit card numbers)
    • Comments or messages provided in text boxes
    • Email correspondence with us

 

Automatic collection of data. As you navigate through and interact with Our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

  • Details of your visits to our Site, including traffic data, location data, and other communication data and the resources that you access and use on the Site.
  • Information about your computer and internet connection, including your IP address, operating system and browser type.

 

The technologies we or our trusted third parties use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
  • Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of our third-party marketing partners may use Web Beacons to track your interaction with online advertising banners on our Site. This information is only collected in aggregate form and will not be linked to your personal information. Please note that any image file on a webpage can act as a Web Beacon.
  • Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the personal information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
  • Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Site and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.

 

Do Not Track Disclosure. We do not currently track customers over time and across third party websites to provide targeted advertising and therefore we do not respond to Do Not Track (DNT) signals. The information we collect automatically is statistical data and does not include personal information. Notwithstanding the foregoing, we reserve the right to track customers over time and across third party websites in the future. To the extent we do track customers over time and across third party websites, we will not respond to DNT signals.

4. PURPOSES: WHY WE NEED YOUR PERSONAL DATA.

We use information that we collect about you or that you provide to us, including any personal data:

  • To present our Site and its contents to you.
  • To provide you with information, products or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and Pinnacle Institute including for billing and collection.
  • To notify you about changes to our Site or any products or services we offer or provide though it.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your informed consent.

5. PROCESSING: WHAT WE DO WITH YOUR PERSONAL DATA.

  1. All personal data we process is processed by our staff or trusted third parties in the United States of America, Canada and other countries. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal data that we collect, or you provide as described in this Policy:
  • To our trusted subsidiaries and affiliates.
  • To contractors and service providers we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Pinnacle Institute’s assets, whether as an ongoing concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Pinnacle Institute about our Site users is among the assets transferred.
  • To fulfill the purpose for which you provide the personal data.
  • For any other purpose disclosed by us when you provide the personal data.
  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms and Conditions available at: www.pinnacleinstitute.com
  • If we believe disclosure is necessary or appropriate to protect the rights or the property of Pinnacle Institute, our customers, or others.

We may otherwise disclose your personal data only for purposes disclosed in this Policy or on the Site, as required by law, or with your informed consent.

  1. You acknowledge and agree that Pinnacle Institute may, in its sole discretion and without prior notice, cancel, suspend or terminate Your Account if You breach these Terms and Conditions. Pinnacle Institute may refuse, in its sole discretion, to permit any use of the Site, and may refuse to permit any person to access or use the Site or Your Account for any reason at any time.
  2. You acknowledge and agree that if Your Account is canceled, suspended, or terminated by Pinnacle Institute for breaching these Terms and Conditions You may not request a refund from Pinnacle Institute. All money spent on services and products, memberships, etc. are forfeited upon cancellation, suspension, and/or termination of the Account, regardless of cause.

6. ORGANIZATIONAL AND TECHNICAL SAFEGUARDS: HOW WE PROTECT YOUR PERSONAL DATA.

Processing of personal data happens in strict accordance with Pinnacle Institute’s data governance program, which includes implementing reasonable organizational and technical safeguards to protect personal data from unauthorized use, disclosure, or destruction. Such organizational safeguards include binding our trusted third parties to contracts and requiring the same or better organizational or technical safeguards for your personal data.

We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the 100% security of your personal data transmitted to our Site. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

7. RETENTION: HOW LONG WE KEEP YOUR PERSONAL DATA.

We only retain your personal data as required to complete the processing we have disclosed in this Policy.

8. MARKETING: WHAT WE WOULD ALSO LIKE TO DO WITH YOUR PERSONAL DATA.

With your consent, we would like to use your contact information to inform you about our products and services. This contact information is not shared with third parties or used for other purposes, and you can unsubscribe from any such marketing via the unsubscribe option in any such marketing email you receive from us.

9. WHAT ARE YOUR RIGHTS?

You can exercise any of the following rights by directly making changes in our Site or notifying us as described below.

You can exercise any of the following rights by directly making changes in our Site or notifying us as described below.

  • Access. You can access and verify what personal data our Site currently contains by logging into our Site and visiting your account profile page. Some of the personal data, including payment information, i.e., credit card details, may not be available on your account profile page. 
  • Correction or Rectification. You may send an email to support@pinnacleinstitute.com to request that we correct or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
  • Restrict Processing. When applicable, you may restrict the processing of your personal data within our Site by submitting a request via email to support@pinnacleinstitute.com. When such restrictions are not possible, Pinnacle Institute will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
  • Object to Processing. When applicable, you have the right to object to some of the processing of your personal data by submitting a request via email to support@pinnacleinstitute.com. When such objections are not possible, Pinnacle Institute will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.
  • Portability. Upon request, and when possible, Pinnacle Institute can provide you copies of your personal data. When such a request cannot be honored, Pinnacle Institute will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent.
  • Withdraw Consent. At any time, you may withdraw your consent to Pinnacle Institute’s processing of your personal data through the Site by notifying us via email at support@pinnacleinstitute.com. Using the same email address associated with your Site account, simply type the words “WITHDRAW CONSENT” in the subject line of your email.
    Upon receipt of such a withdrawal of consent, Pinnacle Institute will confirm receipt, proceed to stop processing your personal data and erase your data in accordance with this Policy.
  • Erasure. If you should wish to cease use of the Site and have your personal data deleted from the Site, please notify Pinnacle Institute at the email address below. Pinnacle Institute will confirm receipt and erase your personal data.
  • Submit complaints or questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. If you reside in a European Union member state, you may also lodge a complaint with the supervisory authority in your country.

10. WILL THIS POLICY CHANGE?

If we make material changes to how we process your personal data, we will notify you by email to the email address specified in your account and/or through a notice on our Site.

11. CONTACT US.

Questions or concerns about this Policy and our processing of your personal data can be directed to: support@pinnacleinstitute.com