Last updated: May 11, 2020
Welcome to Pilot.
Pilot Platform Inc., and its related affiliates and subsidiaries (“Pilot”, “us”, or “we”) respect your privacy. We provide services to manage payroll, benefits and compliance for international teams.
This Privacy Policy describes the types of Personal Data we collect through our payments products and services (“Services”) and via our online presence, which include our main website at pilot.co, as well as services and websites that we enable Internet users to access (collectively, our “Sites”). This policy also describes how we use Personal Data, with whom we share it, your rights and choices, and how you can contact us about our privacy practices. This policy does not apply to third-party websites, products, or services, even if they link to our Services or Sites, and you should consider the privacy practices of those third-parties carefully.
Pilot obtains Personal Data about you from various sources to provide our Services and to manage our Sites. “You” may be a visitor to one of our websites, a user of one or more of our Services (“User” or “Pilot User”).
Personal Data is any information that relates to an identified or identifiable individual. The Personal Data that you provide directly to us through our Sites and Services will be apparent from the context in which you provide the data. In particular:
When you respond to Pilot emails or surveys we collect your email address, name and any other information you choose to include in the body of your email or responses. If you contact us by phone, we will collect the phone number you use to call Pilot. If you contact us by phone as a Pilot User, we may collect additional information in order to verify your identity.
When we conduct fraud monitoring, prevention, detection, and financial compliance activities or provide such services to our Users, we will receive Personal Data from you (and your device) and about you through our Service and from our business partners, financial service providers, identity verification services, and publicly available sources (e.g., name, address, phone number, country), as necessary to confirm your identity and prevent fraud. Our fraud monitoring, detection and prevention services may collect Personal Data about you and use technology to help us assess the risk associated with an attempted transaction by you with a Pilot User.
You may also choose to submit information to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer, program or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.
Our Sites use cookies and other technologies to function effectively. These technologies record information about your use of our Sites, including:
We also collect information about your online activities on websites and connected devices over time and across third-party websites, devices, apps and other online features and services. We use Google Analytics on our Sites to help us analyze Your use of our Sites and diagnose technical issues.
To learn more about the cookies that may be served through our Sites and how You can control our use of cookies and third-party analytics, please see our Cookie Policy.
We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law. We use Personal Data to facilitate the business relationships we have with our Users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use Personal Data to complete payment transactions and to provide payment-related services to our Users.
We may send you email marketing communications about Pilot products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. For example, when we collect your business contact details through our participation at trade shows or other events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.
When you visit our Sites, we (and our service providers) may use Personal Data collected from you and your device to target advertisements for Pilot Services to you on our Sites and other sites you visit (“interest-based advertising”), where allowed by applicable law. For example, when you visit our Site, we will use cookies to identify your device and direct ads for our Services to you. You have choices and control over our cookies (or similar technologies) we use to advertise to you. Please see our Cookie Policy for more information. At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.
We do not use, share, rent or sell the Personal Data of our Users’ Customers for interest-based advertising. We do not sell or rent the Personal Data of our Users, their Customers or our Site visitors.
Pilot does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted entities, as outlined below.
You have choices regarding our use and disclosure of your Personal Data:
Where the processing of your Personal Data is based on your previously given consent, you have the right to withdraw your consent at any time. You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.
Process for exercising data protection rights. In order to exercise your data protection rights, you may contact Pilot as described in the Contact Us section below. We take each request seriously. We will comply with your request to the extent required by applicable law. We will not be able to respond to a request if we no longer hold your Personal Data. If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority in your country.
For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data. We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization against unauthorized access, destruction, loss, alteration or misuse. Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately.
We retain your Personal Data as long as we are providing the Services to you. We retain Personal Data after we cease providing Services directly or indirectly to you, even if you close your Pilot account or complete a transaction with a Pilot User, to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected, including to the United States. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.
If you are located in the European Economic Area (“EEA”), the UK or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to the US.
Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism, we use one or more of the following mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA or the UK, verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to the EU-US and Swiss-US Privacy Shield Framework.
The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services.
We may change this Privacy Policy from time to time to reflect new services, changes in our Personal Data practices or relevant laws. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services. We may provide you with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting you through the Pilot Platform, email address and/or the physical address listed in your Pilot account.
The Services may provide the ability to connect to other websites. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.
Australian residents. If you are an Australian resident, and you are dissatisfied with our handling of any complaint you raise under this Privacy Policy, you may wish to contact the Office of the Australian Information Commissioner.
Residents of the European Economic Area (EEA), the UK and Switzerland. To exercise your rights, you can contact us via privacy@pilot.co.
If you are a resident of the EEA and believe we process your information in scope of the General Data Protection Regulation (GDPR), you may direct your questions or complaints to the Office of the Data Protection Commissioner. If you are a resident of the UK and the UK is no longer a Member State of the EU, you may direct your questions or concerns to the UK Information Commissioner’s Office.
Mexican residents. Mexican residents may exercise data protection rights to access, correction, deletion, opposition or revocation under applicable law. You may be provided with further information about the steps to exercise your privacy rights, including identity verification, timing, the way to get in touch with the organization responding to your request for further communications about your request, and how your request may be honored. To exercise your rights, you can contact us via privacy@pilot.co.
United States - California residents. This section provides additional details about the personal information we collect about California consumers as well as the rights of California consumers under the California Consumer Privacy Act (CCPA).
To submit a request to exercise any of the rights described above, you may contact Pilot at privacy@pilot.co. We may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. Authentication based on a government-issued and valid identification document may be required.
If You have any questions or complaints about this Privacy Policy, please contact us electronically or send physical mail to:
Pilot Platform Inc.