Doc: LEGPOL012 Issue: 003 Date: 5 March 2024 Document Classification: Public
Privacy Notice on Direct Marketing
Issue: 003
At Park Place Technologies (Park Place Technologies, LLC, 5910 Landerbrook Drive, Mayfield
Heights, OH 44124, USA) and all our subsidiaries, including Curvature LLC (“Park Place Technologies”,
“us”, “we”), we are fully committed to the privacy of our customers. That’s why we have drafted this
Privacy Notice – so you can understand how seriously we take your privacy and the protection of
your personal data.
By reading this Notice, you will be able to understand how we handle the contact data that we
acquire directly from you and/or that we collect via acquisition from third-party providers and make
informed choices about how we may process your personal data.
Please note that the processing of personal data for marketing purposes by means of cookies and
other tracking technologies is addressed within our website privacy policy, available at the following
link: https://www.parkplacetechnologies.com/privacy-policy/.
All personal data that we collect from third parties is treated in a lawful, fair and transparent manner,
based on Regulation (EU) 2016/679 (“GDPR”). We follow internationally recognized principles on this,
such as the principles of purpose limitation, storage limitation, data minimization, data quality and
confidentiality.
1. Data controller
We are a data controller of all personal data that is collected and processed by Park Place
Technologies for marketing purposes.
For any questions related to this Privacy Notice, please contact: dataprivacy@parkplacetech.com.
2. Personal data processed
We collect and process certain personal data relating to you, either when you provide such data to
us, or through the use of third party providers who specialize in providing marketing leads for
Business to Business marketing (as better detailed in section 4, below). In particular, we process:
Doc: LEGPOL012 Issue: 003 Date: 5 March 2024 Document Classification: Public
a. Name, contact details and other personal data
Park Place Technologies acquires contact details of business organizations and the executives and
professionals who work for those organizations. We may acquire any or all of the following
categories of personal information about you, past or current:
• Name;
• Company;
• Office Address;
• Telephone Number;
• Email Address;
• Job Title;
• Job Function and Responsibilities;
• Education;
• Social Media URL;
• Interests and content preferences;
• Publicly available information about you.
b. Special categories of personal data
It is important to mention that we do not process special categories of personal data for the
purposes set out in this notice.
3. Purposes of the processing and legal bases
Why does Park Place Technologies process my personal data?
Direct Marketing
• We use your personal data to send you information, offers and promotions related to Park
Place Technologies services, as well as surveys concerning our services.
• We use your personal data in this way because we have a legitimate interest in promoting
our services to our existing and potential customer base. You are not required to allow us to
use your personal data for this purpose and you will not suffer any consequences if you
choose not to do so (although you may not receive further marketing communications from
us thereafter).
• We may contact you for the above purpose by means of e-mail or phone-calls with operator.
Doc: LEGPOL012 Issue: 003 Date: 5 March 2024 Document Classification: Public
Profiled Marketing
• We use your personal data to send you personalized promotions related to Park Place
Technologies services.
• We use your personal data in this way because we have a legitimate interest in promoting our
services to our existing and potential customer base. You are not required to allow us to use
your personal data for this purpose and you will not suffer any consequences if you choose not
to do so (although you may not receive further marketing communications from us thereafter).
• We may contact you for the above purpose by e-mail.
Compliance
• When we collect your personal data, we may be required to store it for a certain amount of
time, or report it to official authorities, because we are legally required to do so.
• This may be the case, for example, when you opt-out from receiving marketing
communications from us: in that case, we will retain only personal data strictly necessary to
ensure that we do not contact you again in the future (in this case, under restricted conditions
of use).
• We only handle your data in this manner where this is strictly necessary in order to comply
with our legal obligations.
4. Sources of personal data
We may collect personal data from third-party providers who specialize in providing leads for
Business to Business (B2B) marketing. In particular:
- Park Place Technologies LLC and its subsidiaries (excluding Curvature LLC), collect personal
data from the following third-party providers:
THIRD-PARTY PROVIDER
INFORMATION NOTICE AND RELEVANT INFORMATION
DiscoverOrg Data, LLC (“ZoomInfo”)
ZoomInfo’s privacy notice may be found at the following
address: https://www.zoominfo.com/about-
zoominfo/privacy-policy.
More information on how ZoomInfo collects personal data
may be found at the following link:
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https://www.zoominfo.com/b2b/faqs/data/how-does-
zoominfo-get-my-info.
You can also file an opt-out request directly to Zoominfo,
by using the functions at the following link:
https://privacyrequest.zoominfo.com/remove/verify.
Lusha Systems, Inc. (“Lusha”)
Lusha’s privacy notice may be found at the following
address: https://www.lusha.com/legal/privacy_policy/.
You can also file an opt-out request directly to Lusha, by
using the functions at the following link:
https://www.lusha.com/privacy-center/request-
removal/.
TechTarget, Inc. (“TechTarget”)
TechTarget’s privacy notice may be found at the following
address: https://www.techtarget.com/privacy-policy/.
You can also file an opt-out request directly to TechTarget,
by using the functions at the following link:
https://reg.techtarget.com/Corporate-Unsubscribe-
Page.html.
- Our subsidiary Curvature LLC collects personal data from the following third-party providers:
THIRD-PARTY PROVIDER
INFORMATION NOTICE AND RELEVANT INFORMATION
DiscoverOrg Data, LLC (“ZoomInfo”)
ZoomInfo’s privacy notice may be found at the following
address: https://www.zoominfo.com/about-
zoominfo/privacy-policy.
More information on how ZoomInfo collects personal data
may be found at the following link:
https://www.zoominfo.com/b2b/faqs/data/how-does-
zoominfo-get-my-info.
You can also file an opt-out request directly to Zoominfo,
by using the functions at the following link:
https://privacyrequest.zoominfo.com/remove/verify.
6sense Insights, Inc. (“6sense”)
6sense’s privacy notice may be found at the following
address:
Doc: LEGPOL012 Issue: 003 Date: 5 March 2024 Document Classification: Public
may be found at the following address:
https://6sense.com/privacy-policy/.
You can also file an opt-out request directly to 6sense, by
using the functions under the section ‘Your rights’:
https://6sense.com/privacy-center/.
5. Recipients of personal data
Your personal data may be shared with the following people/entities (“Recipients”):
• People, companies or firms that provide us with advice and consultancy concerning
accounting, administrative, legal, tax, financial and debt collection matters in connection to
our processing activities.
• Entities that help us carry out our processing activities, such as hosting providers and email
platform providers.
• People we authorise to carry out technical maintenance (such as maintenance of network
equipment and electronic communications networks).
• People we authorize to process personal data in order to perform activities that are related to
the activities indicated in this Notice, like our employees. These people are under binding
confidentiality obligations (either legal and/or contractual).
• Other companies within the Park Place Technologies Group.
• Public entities, bodies or authorities with whom we share personal data, when strictly
required by law (such as local tax, customs or law enforcement authorities).
6. Transfers of personal data
Since we are a global Group with presence in many countries, your personal data may be transferred
to recipients in multiple countries. We genuinely care about your privacy and for that reason we
have implemented appropriate safeguards to protect your information when it is transferred. Some
of these safeguards include adequacy decisions of the European Commission, standard data
protection clauses adopted by the European Commission, or other safeguards or conditions that are
considered adequate to the relative transfer of data.
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7. Retention of personal data
Retention for Marketing Purposes
We will keep your data that we process for marketing until you unsubscribe or opt-out of such
communications.
If you decide to opt-out, we will not use your data for marketing purposes anymore; however, we
may need to keep it for longer if we have an existing business relationship with you, in order to
protect ourselves from liability or as strictly necessary to ensure that we do not contact you again in
the future (in this case, under restricted conditions of use).
Retention for Profiled Marketing Purposes
We will keep your data that we process for profiled marketing until you unsubscribe or opt-out of
such communications.
If you decide to opt-out, we will not use your data for profiled marketing purposes anymore;
however, we may need to keep limited amount of your personal data for longer if we have an
existing business relationship with you, in order to protect ourselves from liability or as strictly
necessary to ensure that we do not contact you again in the future (in this case, under restricted
conditions of use).
Retention for Compliance Purposes
We will keep data we process as long as required by the specific obligation or by the applicable law.
8. Data subjects’ (your) rights
What are my rights, regarding my personal data?
As a data subject, you can exercise the following rights at any time:
• Access your personal data that we are processing (or receive a copy of those personal data)
and obtain further information about such processing.
• Correct or modify your personal data that we are processing when it is inaccurate or
incomplete.
• Request that we erase your personal data that we are processing, when you feel that the
processing is unnecessary or unlawful.
Doc: LEGPOL012 Issue: 003 Date: 5 March 2024 Document Classification: Public
• Request restriction of the processing of your personal data, when you feel that the personal
data we have on you is inaccurate, unnecessary or has been unlawfully processed, or when
you have previously objected to its processing.
You can exercise any of the rights mentioned above by sending a written request to:
dataprivacy@parkplacetech.com.
You can also object to the processing of your personal data for Marketing and Profiled Marketing,
without needing to provide any justification for this, by selecting the appropriate link included at the
bottom of marketing e-mail messages, or by sending a written request to the e-mail address
indicated above.
As a data subject, you are entitled to file a complaint with the competent supervisory authorities for
the protection of personal data, if you believe that the processing of your personal data carried out
by us is unlawful.
9. Amendments
This version of our Privacy Notice entered into force on March 5, 2024. We reserve the right to partly
or fully amend this Privacy Notice, or simply to update its content, for example, as a result of
changes in applicable law. We will inform you of any changes we deem important as soon as they
are introduced (by sending out an e-mail to the contacts on our mailing lists, and by temporarily
adding a pop-up banner to our website), and they will be binding as soon as they are published on
our website.
