Pillar Project

Pillar Data Protection Policy, including Data Subject Rights and Cookies and Tracking Guidelines

This Data Protection Policy (hereinafter, “Policy”) applies to all activities of Pillar with respect to the protection of personal data that we collect, process and store in the course of our business activities, including through our websites and applications (or “apps”), as well as other electronic interfaces with data subjects that we operate.

Pillar is registered in the UK, with its head office located at Level 9, 9 Appold Street, EC2A 2AP, London. For any questions regarding the collection, processing or use of your personal data (as explained below) please contact our Data Protection Officer here: [email protected].

A. General principles

Pillar is committed to ensuring that your personal data and its privacy are protected in accordance with the best practices available, as well as according to our relevant legal obligations. This Policy explains your rights regarding the personal data we collect, process and use, including via the websites and apps, as well as our use of safeguards to protect these rights. The Policy also explains Pillar’s use of cookies and tracking on the website and application interfaces, as specified in the Cookies and Tracking Guidelines below.

Your personal data is collected and stored lawfully, fairly and transparently by Pillar. In processing your data, we act in good faith, in a proportionate manner, and with the appropriate technical and organizational measures in line with the state-of-the-art best practices and in accordance with the risks represented by the processing and the nature of the data protected.

The collection, processing and use of personal data may also be carried out by external data processors on our behalf, in the course of Pillar’s business and supply of services. We require them to comply with relevant legal data protection rules and legislation applicable to the services they provide us, within the framework of our contracts with such external processors.

Pillar may revise this Policy from time to time, and such changes shall come into effect from the moment we notify you of such changes and/or updates, either on the websites, apps or in some other reasonable and transparent manner.

Important note: please refrain from logging in and making use of the websites and apps, or otherwise providing Pillar with your personal data, if you do not consent to the collection, use, processing and disclosure of this data as set forth below.

B. Data Subject Rights

1. Your rights as a data subject

1.1 Consent We will only process personal data if you have consented to such processing, unless we are otherwise legally authorized or obliged to collect and further process personal data relating to you. If we process data solely based on your informed consent, it will be used only for the purposes stated in the consent procedure and as explained below.

1.2 Withdrawal of consent You may revoke or withdraw your consent at any time by notifying our Data Protection Officer directly using this Consent Revocation Form and sending it here [email protected]. Upon receipt of your Form, we will delete your data unless we are legally obliged or authorized to retain it, including for ongoing legitimate business interests of Pillar.

1.3 Minimization of data processingPillar processes and stores a minimum of your personal data, as needed for providing our services to you.

1.4 The “right to be forgotten” and data correction You may also request the deletion or correction of all or part of your personal data held by Pillar. Upon receiving your request to our Data Protection Officer using this Data Deletion or Correction Form, we will correct or delete your personal data from all of our records, as soon as reasonably possible and when technically feasible, unless there is an overriding legal interest or other legal basis for the continuation of the data processing. Please understand that in the event of deletion or correction of personal data upon your request, Pillar may not be able to further provide services via the websites, apps and other interfaces in whole or in part. In requesting data deletion or correction, you irrevocably agree and waive any claim against Pillar’s inability to provide said services, or any interruption or malfunction resulting therefrom. Note that your request for deletion or correction may also be rejected by Pillar for lack of relevant or accurate information provided by you, or because of inadequate verification of your identity.

1.5 Transparency and portability of personal data – You are entitled to receive from Pillar, upon request, information about the type of personal data about you that we have collected. You are also entitled to obtain it in a commonly-used and machine-readable form, subject to technical feasibility and lawfulness considerations. Please forward your request with this Data Transparency and Portability Form to our Data Protection Officer [email protected].

1.6 Automated decision-making on the basis of your personal dataPillar does not intentionally take any potentially-damaging decision concerning you based on automated processing operations without human intervention; and commits to giving you the opportunity to obtain human intervention in such a decision, express your point of view, and obtain an explanation of the decision. Please send your request regarding automated decision-making with this Automated Decisionmaking Form to our Data Protection Officer [email protected].

1.7 Personal data relating to children and minors – Pillar does not knowingly collect or process personal data relating to children and minors under the age of 16 years, unless we are legally obliged to do so. If we become aware that personal data was transferred to us or collected by us relating to children and minors under the age of 16 years without the informed consent of a parent or legal guardian, we will delete such personal data without undue delay. Please forward your request with this Children and Minors Data Deletion Form to our Data Protection Officer [email protected].

In the implementation of these data protection rights, Pillar is committed to providing a timely, transparent and appropriate response to your requests.

2. Why Pillar uses your personal data

2.1 We use your personal data to provide the business services requested by you and to process your requests and inquiries, including those that include payment-related data, where applicable.

2.2 Your personal data is also used for the cookies and tracking utilized in the websites and apps to distinguish you from other users, to improve your use of these interfaces, and to ensure that content in the websites, apps and other relevant interfaces is presented in the most effective manner for you.

2.3. Additional information about our use of cookies and tracking may be found in our Cookies and Tracking Guidelines below.

3. The types of personal data we collect and how we use it

3.1 The personal data collected and used by Pillar is limited strictly to the data necessary for us to provide you with services we supply in the course of our ongoing business, while operating under the relevant data protection and other regulatory obligations.

3.2 The data collected and processed is both general in nature, (for example, for technical purposes) and may include, depending on the services you select and utilize, personal data such as your name, identifying numbers, your IP address and internet service provider, browser type, software identification, as well as the websites you have visited before being transferred to Pillar websites and apps, including keywords used for searches and the sites from which you have been transferred (e.g., search engine or linked content)

3.3 Some automatic processing of your personal data may occur. As is true of most organizations operating websites and apps, Pillar gathers certain information automatically and stores it in log files. This information includes but is not limited to IP addresses, browser type, internet service provider, referral pages, operating systems, a date/time stamp and clickstream data. We may use this information to analyze trends, to administer the website and apps, to track users’ movements through them and to gather information about our user base as a whole. Pillar may link this automatically-collected data to personal information for legitimate business purposes, such as to detect and prevent fraudulent activity; and for other legally-authorized purposes.

3.4 When you receive services from Pillar through the websites, apps and other electronic interfaces, you may also be directed to third-party processors such as payment service providers, including credit card or online payment providers. When we use such third-party payment processors, we do not store credit card details, but instead rely on the third-party service provider to process personal data in order to provide these services. We contractually require such third-party payment processors to comply with the data protection and other laws and regulations applicable to their payment processing services. Please check the respective service provider’s relevant data protection terms and compliance with applicable laws prior to usage of any such processor’s services. The same applies to any links to and from websites of third-party networks, advertisers and affiliates. Such third-party websites are governed solely by such third parties’ data protection policies and you are advised to be careful and check any such third party’s privacy policies and compliance with laws, prior to supplying them with any of your personal data to them.

3.5 Please note that Pillar may also disclose your data to a third party if we are required to do so by applicable law, court order or governmental regulation; or if such disclosure is otherwise authorized and necessary in support of any criminal or legal investigation or proceeding in accordance with applicable laws and regulations.

3.6 Pillar may need to transfer the data submitted by you for the purposes described above to third parties in locations outside the country in which you are physically located, potentially including countries which may not require an adequate level of protection for your personal data compared with that provided in your country. By accepting this Policy, you consent to such data transfer as described in this section.

4. Pillar’s protection of your personal data

4.1 We have taken all reasonable, industry-standard technical and organizational measures to protect your personal data against loss, alteration, theft or access by unauthorized third parties.

4.2 We will not sell, share, transfer or use the data we collect from you for purposes other than those purposes stated expressly herein above.

4.3 We will delete your personal data where the business purpose for which the data was being collected or processed ceases to apply, or if applicable data protection rules require us to delete such personal data.

4.4 The above notwithstanding, Pillar will not be liable or responsible for any damage or loss resulting from the improper use or any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, your personal data.

C. Pillar Cookies and Tracking Guidelines

This Cookies and Tracking Policy applies to all activities of Pillar with respect to the cookies that we collect and store in the course of our business activities, including through the websites, apps, and other electronic interfaces with data subjects that we operate.

Important note: You may indicate your consent to this Cookies Policy by clicking “I agree” on the button that appears in the banner at the top of the website.

1. What’s a cookie? A cookie is a small file sent from a website, which is then stored by your web browser. The information in the cookie can be used to recognize your last session with Pillar. Cookies cannot install malicious software such as viruses on your device, and they do not store any of your personal data or account information.

2. Why do we use cookies? We use cookies to save and maintain Pillar users’ settings and selected preferences during browsing sessions, for saving repeating users’ preferences for future use (e.g. geographical location, accessibility and language selections and preferences), and for statistical analysis of the performance of websites and apps, trend analysis, and monitoring and identifying errors.

3. Where do cookies come from? Cookies originate from two types of sources: 1st-party and 3rd-party. This classification refers to the internet domain that is placing the cookie. 1st-party cookies are those set by a website that is being visited by the user at the time. 3rd-party cookies are cookies that are set by a domain other than that of the site being visited by the user. If a user visits a website and another entity sets a cookie through that site this would be a 3rd-party cookie.

4. Opting out: When you first visit the websites and apps, you may accept or decline the use of cookies. You can also control the use of cookies at the individual browser level, and instructions for managing cookie usage can be found for the following browsers at:

Google Chrome

Internet Explorer

Firefox

Safari

Safari Mobile

Opera

If you opt out of cookies, you may still use the websites and app’s, but your ability to use some features may be limited. Many browsers allow a private mode to be activated through which the cookies are always erased after the visit, and you hereby irrevocably and unconditionally waive any claim or demand in this regard.

5. Do Not Track/Privacy Mode

“Do not track” or “privacy mode” is a function that allows users to opt out from being tracked by websites for any purpose including the use of analytics services, advertising networks and social platforms. Do not track options are available in a few browsers including:

Firefox

Internet Explorer

Chrome

Safari

Opera

If you have enabled the “do not track” function in your browser, you will not be tracked. This is in addition to you opting-out of the aggregation and analysis of data for the Website and App statistics.

6. Categories of cookies we use

Pillar places a high priority on the security and confidentiality of the information stored in the persistent cookies we use. For example, we do not store any of your personal information, payment information or passwords in persistent cookies.

7. Any questions?

For any questions about the use of cookies by Pillar, please be in touch with our Data Protection Officer [email protected].