Last Updated: January 9, 2020
Personal Information Collected
We also may use data collection devices such as “cookies” on certain pages of the website to help analyze our web page flow, measure effectiveness, and promote trust and safety. “Cookies” are small files placed on your hard drive that assist us in providing our services. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the website and you may be required to reenter your password more frequently during a session. These cookies do not provide PFM with any data analytics or enable behavioral advertising. PFM may also collect and analyze information such as your IP address, the state or country from which you accessed the websites, files you download, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the websites, and other similar information.
PFM’s website does not currently support “Do Not Track” requests. Therefore, “Do Not Track” signals sent from your browser or device to our website will not be implemented (i.e., Do Not Track requests will be ignored).
When visitors to the website choose to email PFM using links available on PFM’s website, such senders’ names, email addresses, IP addresses and other personal information may be collected by PFM as part of the process of sending and receiving email. Email and other electronic communications sent or received by PFM are subject to mandatory retention periods, as required by applicable laws and regulations and PFM’s policies to implement such requirements.
PFM’s Use of Personal Information
- Affiliates and Subsidiaries. PFM may share your information with our affiliates and subsidiaries to deliver our services, ensure a consistent level of service, enhance our products, services and your customer experience, and for our affiliates’ and subsidiaries’ everyday business purposes.
- Law enforcement entities. PFM may disclose personal information to courts, governmental or non-governmental regulators, and to law enforcement when required by a valid subpoena or court order, or as otherwise permitted or required by law.
Data and Network Security
PFM maintains operational policies to help safeguard and provide reasonable security for its data networks. However, no security measures are infallible. Always use caution when transmitting information over the Internet.
Data minimization is a responsibility shared by you and PFM. Please, do not send PFM personal information through the website or via email or other electronic communications unless PFM specifically requests or requires such information.
You are responsible for all actions taken with your user name and password. Therefore, we recommend that you do not disclose your password to anyone. If your password has been compromised, you should contact us immediately for a new password.
California “Shine the Light” Law
Pursuant to California’s “Shine the Light” law, California residents have the right, once per calendar year, to request, free of charge, information about the personal information (if any) disclosed to third parties for direct marketing purposes in the previous calendar year. To PFM’s knowledge, no personal information is shared with third parties for those third parties to use for direct marketing purposes.
CCPA Rights Afforded to California Residents
If you are a California resident whose information is covered by the relevant provisions of the California Consumer Privacy Act (“CCPA”), you may have additional privacy rights.
The additional rights described in this section do not apply to personal information that is exempted from the requirements of the CCPA. The CCPA exempts, among other things, publicly available information, information protected by the U.S. Gramm-Leach-Bliley Act of 1999, and information collected and used in a business-to-business context.
Right to Request Information Collected and Used
California residents may submit a request for the following personal information PFM may have collected over the 12-month period preceding the request:
- The categories of personal information PFM has collected about you.
- The categories of sources from which the personal information was collected.
- The business or commercial purposes for collecting such personal information.
- The categories of third parties with whom PFM shared the personal information.
- The specific pieces of personal information PFM collected.
California residents may also submit a request for the following information:
- The categories of personal information (if any) that PFM has sold about you, the categories of third parties to which PFM has sold that information, and the category or categories of personal information sold to each third party.
- The categories of personal information that PFM has disclosed for a business purpose.
Right to Request Deletion of Your Information
We will consider all requests and provide our response within the time-period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation except where retention is permitted by the CCPA (e.g., to comply with federal, state or local laws; exercise or defend legal claims; perform a contract between you and PFM; maintain the functionality or security of PFM systems; or comply with or exercise rights provided by law).. We may request you provide us with information necessary to confirm your identity before responding to your request.
How to Exercise Your Rights
To exercise the rights above, contact us at +1 (415) 281-1000 or use the contact details set out at the end of this Privacy Notice.
How PFM will Verify an Information Request
PFM’s verification process varies depending on the nature of your request. If PFM is unable to verify your identity with the degree of certainty required, PFM will not be able to satisfy the request.
If a request is received via email, PFM will contact you to confirm receipt of your request. PFM may also contact you to request additional information necessary to verify your request.
How PFM will Handle a Request
PFM expects to respond to verified requests free of charge, but in certain situations, you may be required to pay a reasonable fee to cover the administrative costs of providing the information.
Our services and websites are not intended for persons under the age of 18 and persons under the age of 18 are not eligible to use our website or our services. If we become aware that we have collected personal data from a person under the age of 18, we will take reasonable steps to delete such information as soon as possible and will not sell that information to third parties.
How to Contact PFM about Your Privacy