This Privacy Notice (this “Privacy Notice”) describes the policies and procedures of The Sage Project Inc. (d/b/a Pinto) (“Pinto,” “We,” “Us,” “Our”) relating to the collection, use and disclosure of the information We collect from you (“You”) in connection with Your access to and use of this website (the “Site”), the services, features, Content (as defined in the Terms of Use, and applications offered by Pinto (collectively, the “Services”). In the event that You are acting for a company or other entity, the term “You” refers to both You as an individual and such company or entity and You hereby represent and warrant Your personal and company or other entity authority to acknowledge this Privacy Notice.

Please read this Privacy Notice carefully before You begin to use the Services. By registering for, accessing or using the Services in any manner You acknowledge that You have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that You check this Privacy Notice periodically to remain fully informed.

For the purposes of this Privacy Notice, “partners” means service providers, licensors, vendors, manufacturers, distributors, or other third parties with which We have a business relationship.

1. What Does This Privacy Notice Cover?

   • This Privacy Notice is subject to the Terms of Use that govern Your use of the Services. This Privacy Notice applies regardless of the means used to access or provide information through the Services. This Privacy Notice covers the treatment of Personal Information (“Personal Information”) gathered when You use or access the Services. This Privacy Notice also covers Our treatment of any Personal Information that Our business partners share with Us or that We share with Our business partners. This Privacy Notice does not apply to the practices of third parties that We do not own or control, including but not limited to Our business partners, any third party websites, services and applications (“Third Party Services”) that You access through the Services or independently or to individuals that We do not manage or employ. While We attempt to facilitate access only to those Third Party Services that share Our respect for Your privacy, We do not and cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage You to carefully review the privacy policies of any Third Party Services You access.

2. What Information Do We Collect?

   • The information We gather enables Us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, We may request, collect and/or display some of Your Personal Information. We do or may collect the following types of information from You:

     • (a) Information You Share With Us. Some features of the Services allow You to provide Content (as defined in Terms of Use ) to the Services. All Content submitted by You to the Services may be retained by Us indefinitely, even if and after Your access to the Services is terminated, as further provided in the Terms of Use.

     • (b) Information Collected Automatically. We use common analytics and logging tools to automatically receive and record information from Your browser, system and device when You interact with the Services, including Your IP address, system and device information, and information about the network You use to access the Services. The Services also collect usage information, such as Your use of the Services, the elements or pages of the Services You select or access, and Your path through the Services. We may use this data in aggregate form (See “Aggregate Information” below), that is, as a statistical measure, but not in a manner that would identify You personally. This type of Aggregate Information enables Us and third parties authorized by Us to figure out how often individuals use parts of the Services so that We can analyze and improve them.

     • (c) Information Collected Using Cookies and Tracking Technologies. Cookies are pieces of text that may be provided to Your computer through Your web browser when You access our Site. Your browser stores cookies in a manner associated with each website You visit. We use cookies to enable Our servers to recognize Your web browser and tell Us how and when You visit and use the Site and the Services available through the Site. Most browsers have an option for turning off the cookie feature, which will prevent Your browser from accepting new cookies, as well as (depending on the sophistication of Your browser software) allowing You to decide on acceptance of each new cookie in a variety of ways. The Site and Services available through the Site are designed to rely on cookies and de-activating or limiting cookies could significantly reduce the features and functionality of the Site. This Privacy Notice covers Our use of cookies only and does not cover the use, placement, or accessing of cookies by third parties, who may use, place, or access cookies when you use the Site or Services available through the Site. We do not control when or how third parties place cookies on Your computer.

     • (d) Aggregate Information. We collect statistical information about how You and other users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This Aggregate Information is not Personal Information and cannot be tied back to You, or Your web browser.

     • (e) Information Obtained from Third Parties. We receive Personal Information from third parties that provide web analytics and usage information to Us such as Google Analytics. In addition, if You choose to interact with us or Our partners on social media by posting to Our pages, tagging us (or using certain hashtags or other identifiers) in posts, or participating in activities, We may collect certain information from the social media account You use to interact with us, including the name associated with the account, the account handle, recent activity, the content of any posts in which We are tagged, and other information that may be contained on Your social media profile to allow us to respond to the posts and understand and engage with Our audience.

3. How Do We Process Personal Information?

   • (a) We process Personal Information for two general purposes:

     • (i) For Our business operations (including communicating with You, responding to requests and inquiries, providing information about Our products and services, improving the Services, and complying with applicable legal requirements); and
     • (ii) To market and promote Our, and Our partners’ products and offerings.

   • (b) Operational Uses. We process Personal Information as part of Our operations, which include:

     • (i) Providing You with information tailored to Your requests, responding to inquiries, and delivering services and products;
     • (ii) Operating, maintaining, and improving the quality of the Services and such content, products and/or services as We may make available through the Services;
     • (iii) Communicating with You through the Services and by email, in each case with Your consent, if such consent is required in accordance with applicable laws, about products, services, order status, and other topics;
     • (iv) Compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies;
     • (v) Endeavoring to protect Our and Our partners’ rights, property, or safety, and the rights, property, and safety of Our users and other third parties; and
     • (vi) For other purposes, as permitted or required by law.

   • (c) Marketing Uses. We process Personal Information to send messages to You about Us, Our partners, and the products and services We and Our partners offer, which may from time to time include contests, rewards, events, and special offers for products and services. We process Personal Information collected through use of the Services, social media platforms, and web tracking technologies to market to and understand Our audience. We also process your Personal Information to provide recommendations and suggested products, including products produced by Our partners, through the Services. These communications are tailored based on the communications preferences You select when providing us with Your information and will only occur with Your prior consent, if such consent is required in accordance with applicable laws.

4. How, And With Whom, Is Personal Information Shared?

   • The Services are designed to help You share information with others. As a result, some of the information generated through the Services is shared publicly or with third parties.

   • (a) Public Information About Your Activity On The Services. Some of Your activity on and through the Services is public by default. This may include, but is not limited to, content You have posted publicly on the Site or otherwise through the Services. Information concerning Your use of the Services (such as what pages You have visited) may be tracked anonymously through the use of cookies and stored by Us. Please also remember that if You choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading that information may use or disclose it to other individuals or entities without Our control and without Your knowledge, and search engines may index that information. We therefore urge You to think carefully about including any information You may deem private in content that You create or information that You submit through the Services.

   • (b) Information You Elect To Share with Third Parties. You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Services. We are not responsible for the privacy policies and/or practices of these Third Party Services, and You are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Notice only governs information collected through Our Services.

   • (c) Aggregate Information. We share Aggregate Information with Our partners, service providers and other persons with whom We conduct, or seek to conduct, business. We share this type of statistical information so that Our partners can understand how and how often people use Our Services and their services or websites, the types of content our users search for and view, and the products in which demographic groups have expressed interest. This sharing of Aggregate Information facilitates improving both their services and how Our Services interface with them. In addition, these third parties may share with Us non-private, aggregated or otherwise non Personal Information about You that they have independently developed or acquired.

   • (d) Information Shared With Our Representatives. We employ and contract with people and other entities that perform certain tasks on Our behalf and who are under Our control (Our “Representatives”). We may need to share Personal Information with Our Representatives in order to provide products or services to You. Unless We tell You differently, Our Representatives do not have any right to use Personal Information or other information We share with them beyond what is necessary to assist Us.

   • (e) Information Disclosed Pursuant To Business Transfers. We may, in the future, sell or otherwise transfer some or all of Our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal Information We obtain from or about You via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.

   • (f) Information Disclosed For Our Protection And The Protection Of Others. We also reserve the right to use and disclose any information as We reasonably believe is reasonable or necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Notice or the Terms of Use, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect Our rights, property or safety, and the rights, property or safety of Our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

   • (g) Information We Share With Your Consent. Except as set forth above, You will be notified when Your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

5. Is Information About Me Secure?

   • We employ safeguards designed to protect user information and to keep it private; however, We cannot guarantee the security of any information, including Personal Information. However, no method of safeguarding information is completely secure. While We use measures designed to protect Personal Information, We cannot guarantee that Our safeguards will be effective or sufficient. In addition, You should be aware that Internet data transmission is not always secure, and We cannot warrant that information You transmit utilizing the Services is or will be secure.

6. What Information Of Mine Can I Access?

   • (a) Deletion of Cookies. Users can access and delete cookies placed by the Site through their web browser settings, to the extent Your particular browser allows.

   • (b) California Privacy Rights. Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask Us for a notice identifying the categories of personal customer information, if any, which We share with third parties (including, as applicable, affiliates) for marketing purposes, and providing contact information for such third parties. If You are a California resident and would like a copy of this notice, please submit a written request to the following address: The Sage Project Inc. (d/b/a Pinto), 335 Madison Avenue, 6th Floor, Suite F4, NY, NY, 10017 Attn: Privacy Office.

7. What Choices Do I Have Regarding Personal Information?

   • You can use many of the features of the Services without registering, thereby limiting the type of information that We collect. You can always opt not to disclose certain information to Us, even though it may be needed to take advantage of some of Our features, and You may also opt out of receiving certain email messages from Us. You may opt out of receiving marketing or other communications from Us at any time through a given communications channel (such as email or telephone) by following the opt-out link or other unsubscribe instructions provided in any email message received, by contacting Us as provided at the end of this Privacy Notice, or by informing Our customer service representatives of Your desire to opt out. If You wish to opt out by sending us an email to the address provided below, please include “Opt-Out” in the email’s subject line and include Your name and the email address You used to sign up for communications in the body of the email. Note that if You do business with Us in the future, You may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g., e-commerce).

8. Collection of Personal Information from Children.

   • Children under 18 years of age are not permitted to use the Services, and We do not knowingly collect information from children under the age of 18. By using the Services, You represent that You are 18 years of age or older, or are 13 years of age or older and have valid parental consent to do so.

9. Do Not Track.

   • We use analytics systems and providers that process Personal Information about Your online activities over time and across third-party websites or online services, and these systems and providers may provide some of this information to us. Neither We, nor the Site or Services, currently process or comply with any web browser’s “do not track” signal or similar mechanisms.

10. International Use.

    • Your Personal Information will be stored and processed in the United States. If You are using the Services from outside the United States, by Your use of the Services You acknowledge that We will transfer Your Personal Information to, and store Personal Information in, the United States, which may have different data protection rules than in Your country, and Personal Information may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities in the United States.

11. When and How Could We Change This Privacy Notice?

    • We reserve the right to change or modify this Privacy Notice at any time in Our sole discretion without further notice. Such changes, revisions, or modifications shall be effective immediately upon being posted in relation to the Services. Continuing to use the Services after We post changes to this Privacy Notice constitutes Your acceptance of those changes. You are expected to check this page so You are aware of any changes, as they are binding on You. We will use reasonable efforts to notify You in the event material changes are made to this Privacy Notice, such as by posting a notice on the Services or sending You an email.

12. Who Do I Contact With Questions or Concerns?

    • If You have any questions about this Privacy Notice, please contact Us at The Sage Project Inc. (d/b/a Pinto), 335 Madison Avenue, 6th Floor, Suite F4, NY, NY, 10017, Attn: Privacy Office or via e-mail at hello@pinto.co.

13. Last Updated

    • Last Updated: December 24, 2021