Privacy Policy of LINGA rOS

This Application collects some Personal Data from its Users.

 

Users may be subject to different protection standards and broader standards may therefore apply to some. In order to learn more about the protection criteria, Users can refer to the applicability section.

This document contains a section dedicated to Californian consumers and their privacy rights.

This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

4501 Tamiami Trail N
Suite 400
Naples, FL 34103

Owner contact email: [email protected]

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Tracker; Usage Data; device information; purchase history; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); email address.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Traffic optimization and distribution, Analytics, Displaying content from external platforms, Tag Management, Advertising, Remarketing and behavioral targeting and Managing contacts and sending messages.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section “How to opt-out of interest-based advertising” in this document.

JSDELIVR (jsdelivr.com)

JSDELIVR is an advertising service provided by jsdelivr.com.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

NextRoll (NextRoll, Inc.)

NextRoll is an advertising service provided by NextRoll, Inc. NextRoll, Inc. performs a hash of the User’s email address in order to serve targeted advertising to other devices connected to them (i.e. cross-device tracking).

Personal Data processed: device information; purchase history; Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: identifiers; commercial information; internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Ads conversion tracking (Google LLC)

Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on this Application.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Google Fonts (Google LLC)

Google Fonts is a typeface visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Video Vimeo (Vimeo, LLC)

Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Application to incorporate content of this kind on its pages.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

YouTube video widget (Google LLC)

YouTube is a video content visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Font Awesome (Fonticons, Inc. )

Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows this Application to incorporate content of this kind on its pages.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Sendgrid (Sendgrid)

Sendgrid is an email address management and message sending service provided by Sendgrid Inc.

Personal Data processed: email address.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: identifiers.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Twilio (Twilio, Inc.)

Personal Data processed: phone number.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes:

• a sale according to the CCPA, VCDPA, CPA, CTDPA and UCPA
• a sharing according to the CCPA
• targeted advertising according to the VCDPA, CPA, CTDPA and UCPA

Remarketing and behavioral targeting

This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section “How to opt-out of interest-based advertising” in this document.

LinkedIn Website Retargeting (LinkedIn Corporation)

LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Traffic optimization and distribution

This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User’s browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User’s browser, while also allowing analytical data from this Application to be collected.

Personal Data processed: Tracker.

Place of processing: United States – Privacy Policy.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Applicability of broader protection standards

While most provisions of this document concern all Users, some provisions expressly only apply if the processing of Personal Data is subject to broader protection standards.

Such broader protection standards apply when the processing:

• is performed by an Owner based within the EU;
• concerns the Personal Data of Users who are in the EU and is related to the offering of paid or unpaid goods or services, to such Users;
• concerns the Personal Data of Users who are in the EU and allows the Owner to monitor such Users’ behavior taking place in the EU.

Cookie Policy

This Application uses Trackers. To learn more, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

California Consumer Privacy Act Privacy Notice

Changes to Our California Privacy Notice

PNC will update this notice in response to changing legal, technology, or business developments. We will
post the most up-to-date notice on pnc.com/privacy. You can see when the notice was last updated by
checking the “last updated” date displayed at the top. If you have questions about changes, please contact
PNC through our website or by following the details below.

1 INTRODUCTION

1.1 PNC Financial Services Group, Inc. (collectively, “we,” “our,” “us,” “PNC”) is committed to protecting the privacy of personal information of individuals. This Privacy Notice supplements the information contained in the Privacy Policy of PNC and its subsidiaries and applies solely to residents of the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act (CCPA) and the regulations promulgated thereto, each as amended, including pursuant to the California Privacy Rights Act of 2020 (the “CPRA”). Any terms defined in the CCPA have the same meaning when we use them in this notice.

1.2 This Notice does not apply to or describe information that is not personal information or is otherwise exempt from the CCPA, including:

•  Publicly available information from government records.
•  Information that a business has a reasonable basis to believe is lawfully made available to the general public by the consumer or from widely distributed media.
•  De-identified or aggregated consumer information.
•  Information excluded from the CCPA’s scope, like:
  •  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.
  •  Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

2 CATEGORIES OF PERSONAL INFORMATION COLLECTED AND DISCLOSED

2.1 We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”). In particular, we have collected and processed the categories of personal information (as defined by the CCPA) as listed in Section 2.2 in the last twelve (12) months.

2.2 While our processing of personal information varies based upon our relationship and interactions with consumers, the table below identifies, generally, the categories of personal information (as defined by the CCPA) that we have collected about California residents, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose. Please note that not all examples listed in the table below are collected from every consumer.

 

Category	Examples*
A. Identifiers	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security Number, driver’s license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship or immigration status, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data	Such as precise physical location or movements within 1850 feet.
H. Sensory data	Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information	Current or past job history or performance evaluations.
J. Education information	Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). This category of PII is not collected by PNC.
K. Inferences drawn from other personal information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
L. Sensitive Personal Information	Personal information that reveals a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; or genetic data.

*We may not collect all items listed as examples in a particular category.

2.3 PNC does not “sell” or “share” (as defined by the CCPA) personal information or sensitive personal information about California residents, including those we know to be under sixteen (16) years of age.

2.4 We obtain the categories of personal information listed above from the following categories of sources:

•  Directly from you or your authorized agents — for example, from documents that our customers provide to us related to the services for which they engage us.
•  Indirectly from you or your authorized parties — for example, through information we collect from our customers (including your employer) in the course of providing services to them.
•  Directly and indirectly from activity on our websites — for example, from submissions through our website portal or website usage details we collect automatically and the devices you use to access our website.
•  From third parties that interact with us in connection with the services we perform — for example, from credit bureaus when we offer or extend credit to you.

2.5 We retain the personal information we collect only as reasonably necessary for the purposes described in this notice or otherwise disclosed to you at the time of collection. The length of time varies depending upon the circumstances, including the type of information, purposes of collection, and applicable compliance, risk management and legal obligations. (For example, we will retain your transactional data for as long as necessary to comply with our tax, accounting, compliance, risk management and recordkeeping obligations, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with legal obligations.)

3 PURPOSES FOR COLLECTION, USE AND DISCLOSURE

3.1 Subject to Section 3.2, we may collect, use, and disclose the personal information we collect about California consumers for one or more of the following business or commercial purposes:

•  To fulfill or meet the reason for which the information was provided. For example, if you, your employer, or another entity with whom we do business, shares your name and contact information to request a financial product or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your request.
•  To provide, support, personalize, and develop our websites, products, and services.
•  To create, maintain, customize, and secure your account with us.
•  To process and respond to your requests, purchases, transactions, and payments and prevent transactional fraud.
•  To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
•  To communicate with you, including transactional and account-related information as well as news, updates, and marketing communications.
•  To personalize your website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads, including through our websites and via phone, email, or text message (with your consent, where required by law).
•  To help maintain the safety, security, and integrity of our business websites, products and services, databases, and other technology assets.
•  For testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
•  To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
•  As described to you when collecting your 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 PNC’s assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by PNC about our website’s users is among the assets transferred.

3.2 Notwithstanding Section 3.1, we only use and disclose sensitive personal information as reasonably necessary (i) to perform our services requested by you, (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents, (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct, (iv) to verify or maintain the quality and safety of our services, (v) for compliance with our legal obligations, (vi) to our service providers who perform services on our behalf, and (vii) for purposes other than inferring characteristics about you. We do not use or disclose your sensitive personal information other than as authorized pursuant to section 7027 of the CCPA regulations (Cal. Code. Regs., tit. 11, § 7027 (2022)).

3.3 We may disclose each of the above categories (refer to table in section 2.2) of your personal information for a business purpose to the following categories of third parties:

 

Categories of Third Parties	Categories of Data that May Be Disclosed
Service Providers	All*
Advisors & Agents	• A: Identifiers   • B: Personal information categories listed in the California Customer Records statute   • C: Protected classification characteristics under California or federal law   • D: Commercial information   • K: Inferences drawn from other personal information
Regulators, Government Entities, & Law Enforcement	All*
Affiliates and Subsidiaries	• A: Identifiers • B: Personal information categories listed in the California Customer Records statute • C: Protected classification characteristics under California or federal law • D: Commercial information • F: Internet or other similar network activity • I: Professional or employment-related information • K: Inferences drawn from other personal information
Advertising Networks	• A: Identifiers   • B: Personal information categories listed in the California Customer Records statute   • F: Internet or other similar network activity   • K: Inferences drawn from other personal information
Data Analytics Providers	• A: Identifiers • B: Personal information categories listed in the California Customer Records statute • D: Commercial information • F: Internet or other similar network activity • K: Inferences drawn from other personal information
Social Networks	N/A
Internet Service Providers, Operating Systems and Platforms	• A: Identifiers • B: Personal information categories listed in the California Customer Records statute • D: Commercial information • G: Geolocation data • H: Sensory data • K: Inferences drawn from other personal information
Data Brokers	• F: Internet or other similar network activity • G: Geolocation data
Business Customer/Client	N/A
Other Users (in accordance with your privacy settings)	All*
Others as Required by Law (e.g., disclosures of sweepstakes and contest winners	All*

*PNC does not collect the information described in Category J Education Information

3.4 The CCPA also requires that we disclose how we ‘sell’ and ‘share’ personal information. Under the CCPA, a ‘sale’ is defined broadly to include disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value, and ‘share’ broadly includes disclosing or making available personal information to a third-party for purposes of cross-context behavioral advertising. While we do not disclose or make available personal information in exchange for monetary compensation, we may share identifiers, internet and other network activity information with advertising networks and third-party ad companies, data analytics providers and social networks, in order to improve and evaluate our marketing and advertising campaigns and better reach customers and prospective customers with more relevant ads and content. However, we do not sell or share personal information (including sensitive personal information) of consumers we know to be under sixteen (16) years of age.

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

4 YOUR RIGHTS AND CHOICES

4.1 The CCPA provides consumers with specific rights regarding their personal information, as further described in this Section 4. PNC will respond to your requests as required by and subject to certain exceptions and limitations set forth in the CCPA. Please review this section for a description of your CCPA rights and how you make exercise those rights.

4.2 Access to Specific Information and a Copy of Personal Information (Right to Know)

You have the right to request, up to twice per year, that we disclose certain information to you about our collection and use of your personal information and to request a copy of the specific pieces of personal information that we have collected about you (collectively, referred to as your “access” right), including:

•  The categories of personal information we have collected about you;
•  The categories of sources for the personal information we collected about you;
•  Our business or commercial purpose for collecting, selling, or sharing that personal information;
•  The categories of personal information we have disclosed for a business purpose and third parties to whom we have disclosed your personal information for a business purpose;
•  The categories of personal information we have sold to or shared and the categories of third parties to whom such information has been sold or shared (if applicable); and
•  The specific pieces of personal information we collected about you (also called a data portability request).

4.3 Deletion Request Rights You have the right to request we delete any of your personal information we collected from you and retained, subject to certain exceptions and limitations.

4.4 Correction Rights You have the right to request the correction of inaccurate personal information.

4.5 Do-Not-Sell or Share Rights California residents may submit a request to opt out of sales and sharing, as defined by CCPA, by clicking the “Do Not Sell or Share My Personal Information” link at the bottom of https://pnc.com. In addition, our website responds to global privacy control- or “GPC”- signals, which means that if we detect that your browser is communicating a GPC signal, we will process that as a request to opt that particular browser and device out of sales and sharing (i.e., via cookies and tracking tools) on our website. Note that if you come back to our website from a different device or use a different browser on the same device, you will need to opt out (or set GPC for) that browser and device as well. More information about GPC is available at: https://globalprivacycontrol.org/.

4.6 Limit Use and Disclosure of Sensitive Personal Information Right California residents also have the right to direct PNC to limit certain uses and disclosures of their sensitive personal information, which go beyond those specifically authorized pursuant to the CCPA. However, as stated in Section 4.2 above, we do not use and disclose sensitive personal information about California residents beyond these authorized purposes.

4.7 Submitting Request to Know/Access, Correct, and Delete

To exercise your right to know/access, correct, or delete as described above, please submit a verifiable consumer request (as described more fully below) to us by either:

•  Calling us at 1-888-PNC-BANK (1-888-762-2265).
•  Visiting pnc.com/privacy.

California residents may submit a verifiable request to know/access, correct, or delete their personal information on their own behalf and on behalf of their minor child. Pursuant to the CCPA, authorized agents may also submit a verifiable request on behalf of another consumer for whom they have been duly appointed. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

A verifiable consumer request must:

•  Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
•  Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will take steps to verify your request and to identify our relevant records that contain your personal information. We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the personal information relates to you. Making a verifiable consumer request does not require you 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. We endeavor to respond to a verifiable consumer request for access to personal information within 45 days of receiving it. If we require more time (up to a total of 90 days), we will inform you of the reason and extension period in writing. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

4.8 Non-Discrimination California consumers also have the right to exercise their CCPA rights without being subject to discriminatory treatment or retaliation, and to receive transparent disclosures about any financial incentives a business offers them with regard to the collection, use and disclosure of their personal information.

Discrimination may exist where a business takes or suggests that it will take the following actions in response to a consumer exercising rights under the CCPA, unless doing so is reasonably related to the value provided to the consumer by the consumer’s data:

•  Deny access to or use of goods or services.
•  Charge different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
•  Provide a different level or quality of goods or services.

5 CHANGES TO OUR PRIVACY NOTICE

We may amend this privacy notice from time-to-time. We will provide notice of any material changes we make to this privacy notice, such as by through a notice on our website homepage or via email.

6 CONTACT INFORMATION

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-888-PNC-BANK (1-888-762-2265)

Website: pnc.com/privacy

A Spanish version of this document is available at pnc.com/privacy as a courtesy to our clients who use Spanish as their primary language. Although PNC has taken every precaution possible to translate the original document correctly, the Spanish translation is only a courtesy to our clients. Please take note that all official documents from PNC will be in English only.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: August 29, 2023

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