Last updated: September 26, 2016
Pinnacle 21 LLC (“Pinnacle 21”) is committed to helping protect the privacy of its users (“you”). This privacy statement explains the data collection and use practices for the Pinnacle 21 Software Improvement Program (“SIP”) for the Validator, Define.xml Generator, Data Converter, ClinicalTrials.gov Miner and related software tools (collectively, the “Pinnacle 21 Community”). This statement only applies to SIP and does not apply to other online or offline Pinnacle 21 sites, products, or services.
Collection and Use of Information
When you participate in SIP, Pinnacle 21 collects basic information about how you use Pinnacle 21 Community and about the computer you operate it on. Pinnacle 21 also collects information about how the Pinnacle 21 software tools are set up and performing. These reports are sent to Pinnacle 21 to help improve the features its customers use most often and to create solutions to common problems.
You can choose to participate in SIP when you first install Pinnacle 21 Community. To change your participation later, go to Preferences section in Pinnacle 21 Community.
SIP reports sent to Pinnacle 21 generally include information about:
- Performance and reliability, such as the time it takes to complete a validation or a data conversion tasks, and how many problems you experience with a program
- Program use, such as the features that you use the most often, how frequently you launch the software tools, how many records or how much data you process, what rule sets and dictionaries you use, and what issues are triggered when using the Validator.
As part of SIP, Pinnacle 21 will also obtain “Standard Computer information,” which typically includes certain information about your computer’s software and hardware, such as your IP address, operating system version, and your regional and language settings. Pinnacle 21 doesn’t intentionally collect, and Standard Computer Information does not usually include, personally identifiable information. Although when each SIP report is sent to Pinnacle 21, Standard Computer Information is sent as well, Pinnacle 21 does not store your IP address with your SIP reports.
SIP generates a globally unique identifier (GUID) that is stored on your computer to uniquely identify it. The GUID is a randomly generated number; it does not contain any personal information and is not used to identify you as an individual. SIP uses the GUID to determine how widespread the feedback is and how to prioritize it. For example, the GUID allows Pinnacle 21 to distinguish between one customer experiencing a problem one hundred times and other customers experiencing the same problem once. The GUID is stored on your computer and sent with every SIP report. SIP reports do not intentionally contain any contact information about you (such as your name, address, or phone number). However, some reports might unintentionally contain individual identifiers (other than the GUID). Pinnacle 21 tries to filter the information contained in SIP reports to try to remove any individual identifiers that they might contain.
Information that is collected by or sent to Pinnacle 21 may be stored and processed in the United States or any other country in which Pinnacle 21 or its affiliates, subsidiaries, or agents maintain facilities. Pinnacle 21 may disclose this information if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Pinnacle 21; (b) protect and defend the rights or property of Pinnacle 21, or (c) act in urgent circumstances to protect the personal safety of Pinnacle 21’s employees, users of Pinnacle 21’s software or services, or members of the public. Pinnacle 21 occasionally hires other companies to provide limited services on its behalf, such as hosting or performing statistical analysis of reports. Pinnacle 21 will provide those companies only the information they need to deliver the services. They are required to maintain the confidentiality of this information and are prohibited from using it for any other purpose. Pinnacle 21 may also use the services of a third-party to assist it in engaging in SIP.
Changing or Deleting Collected Information
In the event that we collect personal information (such as if you include it with test data), we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request, in either case if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backups), or for which access is not otherwise required. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
Please e-mail us at firstname.lastname@example.org with any questions, if you need assistance accessing or changing your personal information, or if you would like to have your personal information deleted. Also, even if you request that we delete your personal information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.
Pinnacle 21 is committed to helping protect the security of the information it collects. SIP uses a variety of security technologies and procedures to help protect reports from unauthorized access, use, or disclosure. For example, information is stored on computer systems with limited access, which are located in controlled facilities.
Changes to this Statement
Pinnacle 21 may occasionally update this privacy statement. When it does, it will also revise the "last updated" date at the top of the privacy statement. You are encouraged to periodically review this privacy statement to stay informed about how Pinnacle 21 is helping to protect the information.
Privacy Shield Notice for European Union Residents
We are a participant in the European Union (“EU”)–United States (“US”) Privacy Shield.
We comply with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between this Privacy Statement and these Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov.
The types of data we are collecting under the EU-US Privacy Shield, the purposes for which each such type of data is being collected and used, and the types of third parties to which we may disclose such information (and the purposes of such disclosure) are set forth above in this Privacy Statement.
You have rights, as set forth above in this Privacy Statement, to access, edit and have deleted your personal information if we happen to collect it. The choices and means offered you for limiting use and disclosure of your personal information are set forth above in this Privacy Statement.
Notwithstanding any language to the contrary in this Privacy Statement, in cases of onward transfer to third parties of personal information of EU individuals received pursuant to the EU-US Privacy Shield, we are potentially liable. In compliance with the EU-US Privacy Shield Principles, we commit to work to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this Privacy Statement should first contact us at:
Pinnacle 21, LLC
Attention: Privacy Complaints
531 Plymouth Road
Plymouth Meeting, PA 19462
We have further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to the American Arbitration Association, a non-profit alternative dispute resolution provider located in the United States. If you do not receive a response to your complaint from us within forty-five (45) days, or if your complaint is not satisfactorily addressed, please visit http://info.adr.org/safeharbor for more information and to file a complaint.
Please note that if your complaint is not resolved through the above channels, you may have the right, under certain limited conditions, to invoke binding arbitration before the Privacy Shield Panel to be created by the US Department of Commerce and the European Commission.
We are subject to the investigatory and enforcement powers of the United States Federal Trade Commission (“FTC”) with respect to its compliance with the EU-US Privacy Shield.
For More Information
Pinnacle 21 welcomes your comments regarding this Privacy Statement. If you believe that Pinnacle 21 has not adhered to this statement, please send an e-mail or postal mail, and we will use commercially reasonable efforts to promptly determine and remedy the problem.
Pinnacle 21 LLC
531 Plymouth Road
Plymouth Meeting, PA 19462