Privacy Center

Privacy Policy - January 1, 2020

The Pipeline Group Privacy Policy - The Pipeline Group understands that you care about how information about you is used. This privacy policy (the “Policy”) explains how we collect information pertaining to businesses and business people ("Business Information") and all other types of information through our website and online services (the "Site"); how we maintain, use and share that information; and how you can manage the way information about you is handled.

“TPG” for purposes of this Privacy Policy includes The Pipeline Group, Inc., a California corporation, and its affiliates.

For residents of the State of California, please click here to find out more about your rights under the California Consumer Privacy Act of 2018 (“CCPA”).

Where does TPG get the Business Information for its Public Profiles?

TPG creates profiles of business people and companies, which we call "Public Profiles," from different sources. Once we have collected Business Information about a person or company, we combine multiple mentions of the same person or company into a Public Profile. The resulting directory of Public Profiles (the "Database") is then made available to the users of the Site and our customers and strategic partners.

TPG obtains the data for its Public Profiles in several ways including:

(1) Our search technology scans the web and gathers publicly-available Information.
(2) We license Information from other companies.
(3) Users contribute Business Information about themselves or other people and companies.
(4) Through market research surveys and phone interviews conducted by our in-house research team.

How Else Does TPG Collect & Use Information?

Visitors to our Site may choose to submit their name, email address and/or other information so that they can learn more about our services, register to take part in a TPG-sponsored event, or participate in a survey, contest or sweepstakes, among other things. By accessing, using, and/or submitting information through the Site, you consent to the practices described in this Policy with regard to the information collected thereby as described herein. If you do not agree with this Policy, you must delete all cookies from your browser cache after visiting the Site and refrain from visiting or using the Site.

In order to use certain TPG products and services, you may be required to register as a user. From time to time, we may use your email address to send you information and keep you informed of products and services in which you might be interested. You will always be provided with an opportunity to opt out of receiving such emails. Your contact information may also be used to reach you regarding issues concerning your use of our Site, including changes to this Policy. A more detailed description of how we may collect and use customer information is found below under “Customer Information Collected.”

TPG may aggregate collected information about our users in a form that does not allow users to be personally identified for the purpose of understanding our customer base and enhancing the services that we and our strategic partners and customers can provide you.

TPG will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual about whom the information pertains. TPG will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.

We also collect information using cookies, as described below.


Cookies

Most websites, including our Site, use a feature of your browser to set a small text file called a "cookie" on your computer. The site placing the cookie on your computer can then recognize the computer when you revisit the site to allow auto login and track how you are using the site.

When you visit our Site, our servers and/or those of our service providers automatically record certain information that your web browser sends, such as your web request, Internet Protocol address, browser type, referring/exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, time and date of use and other information.

The information we collect using cookies does not allow you to be personally identified; but we may link this information to information that you submit while on our Site, which does allow you to be personally identified.

You are free to decline cookies. You can configure your browser to accept all cookies, reject all cookies, erase cookies or notify you when a cookie is set. Electing to reject or disable cookies may substantially limit your ability to use our Site.

TPG may adopt other technologies that serve similar functions as cookies. If we do so, we will disclose it in this Policy.

Customer Information Collected

TPG may collect the following information from or regarding its customers: (1) personal contact information regarding users of the Services (“User Information”); and (2) information uploaded to our system by a user of the Services (“Uploaded Information”).

Use of Customer Information
Customer Information may be used for TPG’s legitimate business interests in connection with your use of the Site, including to respond to user inquiries and fulfill user requests, complete transactions, provide customer service, send administrative information, and to personalize user experience with the Site. We may use Customer Information to better understand our users in general and to improve the content and functionality of the Site. We may use Customer Information to contact you in the future to tell you about services, promotions, opportunities, and other general information about TPG we believe will be of interest to you. We may use Customer Information to investigate and prosecute potential breaches of TPG’s security or license agreements.

TPG will not disclose Customer Information to any third party except in connection with a legitimate use as set forth herein, in connection with a bona fide legal dispute to which such information is relevant, in response to valid, compulsory legal process, or as otherwise required by law. TPG will, whenever possible, obtain confidentiality agreements from any person or entity to whom Customer Information is disclosed and ensure any recipients are committed to employing appropriate technological security measures.

TPG employs reasonable security and back-up procedures to protect Customer Information. However, in the unlikely event there is a loss or corruption of Customer Information, TPG is not responsible or liable for such loss or corruption. We encourage our users to retain copies of all Uploaded Information on their own system.

When Does TPG Share Information?

Disclosures of Public Profiles
We may make any Business Information that our users contribute for inclusion in our Database, that we collect from public web sources or that we license from third parties available to users of the Site, to our strategic partners, and to our customers.

Disclosures to Service Providers
TPG may from time to time disclose Business Information or other collected information to service providers, solely for providing functions related to our operation of the Site and for no other purpose. For example:
TPG uses service providers to process credit card payments on our Site. When you use a credit card to pay for TPG services, information such as your name, billing address, phone number, email address and credit card Information will be submitted to service providers for verification and to manage any recurring payments.
TPG uses software hosted by a service provider to provide us with information regarding our visitors' activities on our Site. When you visit our Site, that service provider may set cookies on our behalf and may receive information about your browsing activity on our Site.

Disclosures for Legal Reasons
We may disclose collected information, including Business Information, to a third party if we believe in good faith that such disclosure is necessary or desirable: (i) to comply with lawful requests, subpoenas, search warrants or orders by public authorities, including to meet national security or law enforcement requirements, (ii) to address a violation of the law, (iii) to protect the rights, property or safety of TPG, its users or the public, or (iv) to allow TPG to exercise its legal rights or respond to a legal claim.

Disclosures to a Buyer of the Company
If our company or substantially all of our assets are acquired, or in the event of a merger or bankruptcy, information about you and/or information you provide to TPG may be among the transferred assets. You will be notified via email and/or a prominent notice on our Site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Other Disclosures
If you register for a TPG event with a third-party speaker, your information will generally be shared with the speaker.

If you provide information, including Business Information, in creating or updating your Public Profile, that information will be included in the Database and thus can be viewed by third parties.

We post customer testimonials on our Site which may contain the customer's name. We always get consent from the customer prior to posting any testimonial. If you wish to update or delete your testimonial, you can contact us.

Our Site offers publicly accessible blogs or community forums. You should be aware that any content you provide in these areas may be read, collected, and used by others who access them. You can request the removal of your personal information from our blog or community forum, by contacting us at privacy@thepipelinegroup.io. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

How Can You Change or Delete Your Information?

Professional Profiles
To find out if you are in the TPG database, send an email to privacy@thepipelinegroup.io. If you have a common name, please provide your geographical location or companies where you have worked.

Once you have located one or more TPG profiles in your name, consider these options for managing your professional profile on TPG:

Update Your Own Professional TPG Profile
Make sure your TPG profile is up to date for recruiters and others who may want to reach you. Simply, verify your TPG profile and you can update your work history, contact information and even delete web references you do not want associated with your professional profile.

Remove Your TPG Profile Completely
If you wish to completely remove your existing individual profile from the Database, please email remove@thepipelinegroup.io. If you make this choice, your name, employment history, web references and contact information (including email address) will be removed from our search results as soon as possible.

Company Profiles
To find out if your company is in the TPG database, email privacy@thepipelinegroup.io . Once you have located the TPG profile, consider these options for managing your company profile on TPG:

Update Your Company Profile on TPG
Simply, verify your TPG company profile to update your company description, industry, company location, and more.

Remove Your Company TPG Profile Completely
TPG is a specialized web search engine, similar to Google but focused on finding information about companies and professionals. We gather all information about companies from corporate web sites, press releases, and/or SEC documents filed with the US government. The company summaries are created automatically by TPG's software based on the information we find on those documents.

As a company policy, TPG does not remove company information from our search engine.

If any of the company information is incorrect, please update your company profile.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

How Can You Opt Out of Certain Uses of Your Information?

TPG gives you the opportunity to "opt out" of having your information used for certain purposes.

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by visiting /unsubscribe. After we receive your request, we will send you an email message to confirm that you have been unsubscribed.

TPG will not share information about you that you submit when you register for our services with third parties for promotional uses unless you opt in to such sharing within your TPG account or TPG has separately acquired such information from other sources, in which case TPG will give you the opportunity to opt out via email.

If you have opted in to share your personal information with TPG subscribers, you may opt out by emailing remove@thepipelinegroup.io.

You may also communicate your opt-out request to TPG by email or postal mail by using the contact information at the bottom of this Policy.

How Do We Keep Your Information Secure?

We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. However, no method of Internet transmission or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

EU Residents

In the course of obtaining data to be included on the Site, if TPG obtains business contact information regarding an individual that TPG has reason to believe is based in the European Union, TPG will provide such individual with a notice detailing the information TPG has on such person, the purpose for which it will be used, and informing such person of their rights with respect to such information, including the right to know what information TPG possesses on them, to correct such information, or to opt out of data collection entirely. Such persons may opt out of the TPG database by emailing remove@thepipelinegroup.io.

Information for Users in Europe & Elsewhere Outside the U.S.

If you use our Site outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law.

Users in the European Union (EEA) and Switzerland

If you are a resident of the EEA or Switzerland, the following information applies.

Purposes of processing and legal basis for processing: As explained above, we process personal data in various ways depending upon your use of our Sites. We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests in providing the Sites where those interests do not override your fundamental rights and freedom related to data privacy. TPG’s collection of Business Information, and the creation and licensing of TPG’s Public Profiles and Database, are within TPG’s legitimate interests to organize and make available business contact information given the limited impact of this data on an individual’s private life and that this information, unlike personal contact details, is widely disclosed. TPG has put in place safeguards to protect personal privacy and individual choice, including disclosures of its data processing activities, the use of consent or opt-outs wherever possible, and the implementation of a privacy center.

Right to lodge a complaint: Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. Per the applicable requirements of the General Data Protection Regulation (GDPR), we will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR. Please see “Privacy Shield Frameworks” below regarding our compliance with the EU- and Swiss-US Privacy Shields.

Individual Rights: If you are a resident of the EEA or Switzerland, you are entitled to the following rights under the GDPR. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you.

The right to access and correction. You have the right to request access to, and a copy of, your personal data at no charge, as well as certain information about our processing activities with respect to your data. You have the right to request correction or completion of your personal data if it is inaccurate or incomplete. You have the right to restrict our processing if you contest the accuracy of the data we hold about you, for as long as it takes to verify its accuracy.

The right to request data erasure. You have the right to have your data erased from our Site if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.

The right to object to our processing. You have the right to object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

The General Data Protection Regulation (“GDPR”) 2016/679

TPG endeavors to comply with the provisions of the GDPR as to any information in its possession regarding European Union-based persons (“data subjects”). As such, TPG only processes personal information on data subjects where it has a lawful basis to do so, which may include the consent of the person (especially in the case of website visitors who provide their information), performance of a contract, compliance with a legal obligation, or the legitimate interest of the controller or a third party. TPG provides notice to all data subjects as required by GDPR Article 13 or 14, as appropriate, and honors the rights of data subjects provided in Articles 12-23, including the right to be forgotten. For any opt-out requests or other inquiries related to privacy, please visit our privacy center or email remove@thepipelinegroup.io.


Privacy Shield Frameworks

TPG complies with the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. TPG has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the policies in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, any rights you may have to binding arbitration before a Privacy Shield Panel, and to view our certification page, please visit  https://www.privacyshield.gov.

For information received under the Privacy Shield, TPG will require third parties to whom they disclose personal information to safeguard that personal information consistent with this Policy by contract, obligating those third parties to provide at least the same level of protection as is required by the Privacy Shield Principles. EU and Swiss citizens may choose to opt-out of such disclosures. TPG may have liability to you in case of failure to comply with the law or this policy in handling onward transfer of your information to third parties.

In compliance with the Privacy Shield Principles, TPG commits to resolve complaints about your privacy and its collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Policy should first contact TPG at  privacy@thepipelinegroup.io. European Union and Swiss individuals have the right to access their personal data.

TPG further has committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS (Judicial Arbitration & Mediation Services), an independent alternative dispute resolution provider located in the United States and recognized for this purpose by the US Department of Commerce. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information, and to file a complaint.

The Federal Trade Commission has enforcement authority regarding TPG's compliance with the Privacy Shield Principles.

Your California Privacy Rights

If you are a California resident, California law permits you to request certain information regarding the disclosure of your personal information by us to third parties for the third parties' direct marketing purposes. To make such a request, please send your request, by mail or email, to the address at the end of this Policy.


Changes to this Policy

TPG reserves the right to modify this Policy from time to time, so please review it regularly. If we make material changes to this policy, we will notify you here, by email, and/or by means of a notice on our homepage prior to the changes becoming effective.


Contact Us

If you have questions or concerns regarding this privacy policy, please contact us at:

The Pipeline Group

Attn: Privacy

1625 The Alameda, Suite 402

San Jose, CA 95126

Email: privacy@thepipelinegroup.io






Privacy Statement - CA

This PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS supplements the information contained in the TPG Privacy Policy. TPG has adopted this statement to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and other California privacy laws, and it applies solely to “consumers” as that term is defined in the CCPA. Any terms defined in the CCPA have the same meaning when used in this statement.

Information TPG Collects

TPG collects personal information. We have collected the categories of personal information indicated below within the last twelve (12) months:

Identifiers:

Personal Information Collected:

- Name

- Internet Protocol address

- Business email address

- Job title and department

- Business phone numbers (general, direct and fax)

- Business related postal address of consumer

- Social Networking URLs

Categories of Sources from which this Personal Information was Collected:

- Publicly available information

- First-hand research

- Submissions from TPG’s customers or freemium product users

- Third-party data vendors

- Directly and indirectly from activity on TPG’s website

- Directly and indirectly from our customers or their representatives

- Directly from vendors and other contractual counterparties

- Through communications with prospective customers and other businesses and their representatives

Purpose for Collection of this Personal Information:

- To fulfill or meet the purpose for which the information is provided.

- To provide the consumer with information, products or services that the consumer requests from TPG.

- To provide the consumer with email alerts, event registrations and other notices concerning TPG products or services, or events or news, that may be of interest to the consumer.

- To carry out TPG’s obligations and enforce TPG’s rights arising from any contracts entered into between TPG and a TPG customer or other contractual counterparty, including for billing and collections.

- To improve TPG’s website and present its contents to the consumer.

- For testing, research, analysis and product development.

- As necessary or appropriate to protect the rights, property or safety of TPG, our customers or others.

- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

- As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.

- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TPG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TPG is among the assets transferred.

- To modify, enhance, or improve TPG’s services and/or provision such services to TPG customers.

- To include in TPG’s database of business contacts, which TPG licenses to its customers for such customers to use for business-to-business sales and marketing and recruiting.


Categories of Third Parties with whom this Personal Information is Shared:

- TPG affiliates

- Service Providers

- TPG customers

Personal Information Categories Listed in the California Customer Records Statute

Personal Information Collected:

- Name

- Business address

- Business telephone number

- Employment

- Employment status


Categories of Sources from which this Personal Information was Collected:

- Publicly available information.

- First-hand research.

- Submissions from TPG’s customers or freemium product users.

- Third-party data vendors.

- Directly and indirectly from activity on TPG’s website.

- Directly and indirectly from our customers or their representatives.

- Directly from vendors and other contractual counterparties.

- Through communications with prospective customers and other businesses and their representatives.


Purpose for Collection of this Personal Information:

- To fulfill or meet the purpose for which the information is provided.

- To provide the consumer with information, products or services that the consumer requests from TPG.

- To provide the consumer with email alerts, event registrations and other notices concerning TPG products or services, or events or news, that may be of interest to the consumer.

- To carry out TPG’s obligations and enforce TPG’s rights arising from any contracts entered into between TPG and a TPG customer or other contractual counterparty, including for billing and collections.

- To improve TPG’s website and present its contents to the consumer.

- For testing, research, analysis and product development.

- As necessary or appropriate to protect the rights, property or safety of TPG, our customers or others.

- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

- As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.

- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TPG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TPG is among the assets transferred.

- To modify, enhance, or improve TPG’s services and/or provision such services to TPG customers.

- To include in TPG’s database of business contacts, which TPG licenses to its customers for such customers to use for business-to-business sales and marketing and recruiting.


Categories of Third Parties with whom this Personal Information is Shared:

- TPG affiliates

- Service Providers

- TPG customers

Internet or Other Similar Network Activity

Personal Information Collected:

- Information on a consumer's interaction with a website, application, or advertisement

- Internet Protocol address


Categories of Sources from which this Personal Information was Collected:

- Directly and indirectly from activity on TPG’s website.

- Directly and indirectly from our customers or their representatives.

- Through communications with prospective customers and other businesses and their representatives.


Purpose for Collection of this Personal Information:

- To carry out TPG’s obligations and enforce TPG’s rights arising from any contracts entered into between TPG and a TPG customer or other contractual counterparty, including for billing and collections.

- To improve TPG’s website and present its contents to the consumer.

- For testing, research, analysis and product development.

- As necessary or appropriate to protect the rights, property or safety of TPG, our customers or others.

- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

- As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.

- To modify, enhance, or improve TPG’s services and/or provision such services to TPG customers.


Categories of Third Parties with whom this Personal Information is Shared:

- TPG affiliates

- Service Providers

Professional or Employment-Related Information

Personal Information Collected:

- Business email

- Business telephone number

- Business physical address

- Current or past job history

- Title


Categories of Sources from which this Personal Information was Collected:

- Publicly available information.

- First-hand research.

- Submissions from TPG’s customers or freemium product users.

- Third-party data vendors.

- Directly and indirectly from activity on TPG’s website.

- Directly and indirectly from our customers or their representatives.

- Directly from vendors and other contractual counterparties.

- Through communications with prospective customers and other businesses and their representatives.


Purpose for Collection of this Personal Information:

- To fulfill or meet the purpose for which the information is provided.

- To provide the consumer with information, products or services that the consumer requests from TPG.

- To provide the consumer with email alerts, event registrations and other notices concerning TPG products or services, or events or news, that may be of interest to the consumer.

- To carry out TPG’s obligations and enforce TPG’s rights arising from any contracts entered into between TPG and a TPG customer or other contractual counterparty, including for billing and collections.

- To improve TPG’s website and present its contents to the consumer.

- For testing, research, analysis and product development.

- As necessary or appropriate to protect the rights, property or safety of TPG, our customers or others.

- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

- As described to the consumer when collecting such consumer’s personal information or as otherwise set forth in the CCPA.

- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TPG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TPG is among the assets transferred.

- To modify, enhance, or improve TPG’s services and/or provision such services to TPG customers.

- To include in TPG’s database of business contacts, which TPG licenses to its customers for such customers to use for business-to-business sales and marketing and recruiting.


Categories of Third Parties with whom this Personal Information is Shared:

- TPG affiliates

- Service Providers

- TPG customers


We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing prior notice.

Disclosure or Sale of Personal Information and the Right to Opt-Out

We sell personal information collected for our database to our customers. This database may contain information about consumers’ business personas including name, employer, job title, email address, phone number, office address, social media or professional profile link, and work or educational history. This information is sold to TPG’s customers for the purpose of business-to-business sales and marketing and recruiting and is provided subject to license agreements that limit its use to those purposes.


A consumer has the right to opt out of the sale of that consumer’s personal information by TPG by visiting our Privacy Center and submitting a request to remove the consumer’s profile or delete the consumer’s data. A consumer may also contact us by email to privacy@thepipelinegroup.io. In order to submit a request, a consumer or an authorized agent will be required to demonstrate that such person has control of an email inbox associated with the profile in question. If such person cannot, then we may be contacted regarding other means of verifying such person’s identity or the authorization of a third party to exercise a consumer’s rights on that consumer’s behalf.


In the preceding twelve (12) months, we have sold or disclosed the following categories of personal information for a business purpose:


Category A: Identifiers

Category A: California Customer Records personal information categories.

Category I: Professional or employment-related information.


For avoidance of doubt, the personal information disclosed and/or sold by TPG within the identified categories is limited to business contact information related to a consumer’s profile as an employee of its employer. No sensitive personal information (i.e. Social Security number, passport number, medical or financial information) is collected, shared, disclosed, or sold by TPG.


We do not sell the personal information of minors under 16 years of age.


A Consumer’s Other CCPA Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes a consumer’s CCPA rights and explains how to exercise those rights.


Access to Specific Information and Data Portability Rights

A consumer has the right to request that we disclose certain information to that consumer about TPG’s collection and use of that consumer’s personal information over the past 12 months. Once we receive and confirm a consumer’s verifiable consumer request, we will disclose:

- The categories of personal information we collected about that consumer.

- The categories of sources for the personal information we collected about that consumer.

- Our business or 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 that consumer (also called a data portability request).


Deletion Request Rights

A consumer has the right to request that TPG delete any of its personal information that we have collected and retained, subject to certain exceptions. Once we receive and confirm a consumer’s verifiable consumer request, we will delete (and direct our service providers and/or customers to delete) that consumer’s personal information from our records, unless an exception applies.


We may deny a consumer’s deletion request if retaining the information is necessary for us or our service providers or customers to:

(1) Complete the transaction for which we collected the personal information, provide a good or service that a consumer requested, take actions reasonably anticipated within the context of our ongoing business relationship with that consumer, or otherwise perform our contract with that consumer.

(2) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

(3) Debug products to identify and repair errors that impair existing intended functionality.

(4) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

(5) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

(6) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if a consumer previously provided informed consent.

(7) Enable solely internal uses that are reasonably aligned with consumer expectations based on a consumer’s relationship with us.

(8) Comply with a legal obligation.

(9) Make other internal and lawful uses of that information that are compatible with the context in which a consumer provided it.


Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

- Visiting www.thepipelinegroup.io

- Contacting us at privacy@thepipelinegroup.io


Only a consumer or a person registered with the California Secretary of State that a consumer authorizes to act on a consumer’s behalf, may make a verifiable consumer request related to a consumer’s personal information. A consumer may also make a verifiable consumer request on behalf of that consumer’s minor child.


A consumer may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

- Provide sufficient information that allows TPG to reasonably verify a consumer is the person about whom we collected personal information or an authorized representative.

- Describe a consumer’s request with sufficient detail that allows TPG to properly understand, evaluate, and respond to it.


We cannot respond to a consumer’s request or provide a consumer with personal information if we cannot verify the consumer’s identity or authority to make the request and confirm the personal information relates to that consumer. Making a verifiable consumer request does not require a consumer to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.


Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform the consumer of the reason and extension period in writing. We will deliver our written response by mail or electronically. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide a consumer’s personal information that is readily useable and should allow a consumer to transmit the information from one entity to another entity without hindrance.


We do not charge a fee to process or respond to a consumer’s verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell the consumer why we made that decision and provide the consumer with a cost estimate before completing that consumer’s request.


Non-Discrimination

We will not discriminate against a consumer for exercising any CCPA rights.


Changes to Our Privacy Statement

We reserve the right to amend this privacy statement at our discretion and at any time. When we make changes to this privacy statement, we will provide notification by email or through a notice on our website homepage.


§999.317(g)(1) Metrics

During the previous calendar year, TPG received the following number of requests from residents of California:

The number of requests to know that the business received, complied with in whole or in part, and denied;

Received: NA*

Complied: NA*

Denied: NA*


The number of requests to delete that the business received, complied with in whole or in part, and denied;

Received: NA*

Complied: NA*

Denied: NA*


The number of requests to opt-out that the business received, complied with in whole or in part, and denied;

Received: NA*

Complied: NA*

Denied: NA*


*The Effective Date of the CCPA is January 1, 2020 and, therefore, we do not have prior year metrics at this time.


We anticipate our median number of days within which the business substantively responded to requests to know, requests to delete, and requests to opt-out will be three (7) business days based on similar operations, however, given the effective date of the CCPA, we do not have these metrics at this time.


Contact Information

If there are any questions or comments about this statement, our Privacy Policy, the ways in which we collect and use a consumer’s personal information, how to receive a copy of the Privacy Policy and/or this statement in an alternative format (for consumers with a disability), a consumer’s choices and rights regarding such use, or wish to exercise consumer rights under California law, please do not hesitate to contact us at:


The Pipeline Group

Attn: Privacy

1625 The Alameda Suite 402

San Jose, CA 95126

Email: privacy@thepipelinegroup.io



This statement was last updated on February 23, 2020.


Request Access to Collected Data

To exercise the access rights, please submit a verifiable consumer request to us by either contacting us at privacy@thepipelinegroup.io.

Request Removal

To exercise the deletion rights, please submit a verifiable consumer request to us by contacting us at privacy@thepipelinegroup.io.