Privacy Policy

Last Modified: 22 January 2024

Pigeonhole Live is committed to protecting your privacy and being transparent with how we use the data collected from you. We comply with the privacy requirements as may be applicable to you, depending on where you are located.

This Privacy Policy explains how PigeonLab Pte. Ltd. ("PigeonLab", "we", "us") collects and uses data or information that identifies you, or relates to you as an identifiable person (hereinafter referred to as "personal data" or "personal information") when you visit our Websites and/or use our Services (defined below).

If you do not agree with our Privacy Policy, you should not access or use our Services.

Pigeonhole Live is a real-time audience engagement platform offered by PigeonLab as a service ("Services") via the https://pigeonholelive.com and https://pigeonhole.at websites ("Websites") and through first-party integrations built for use within Zoom, Cisco Webex, Microsoft Teams, SharePoint, PowerPoint, Google Slides and more. There are several ways that you (the "user") may use our Services:

• As a Visitor to our Websites, if you visit or view our Websites without registering for a user account;

• As an Organiser or Speaker who uses Pigeonhole Live to organise and host real-time audience engagement sessions or presentations ("Session") to collect questions, responses, comments, votes and other similar information in real time from others, such as event attendees and audience members ("Attendees") who are participating in the Session;

• As an Attendee, if you are an audience member, a moderator or a speaker that participates in a Session.

Like many websites, we will collect your internet protocol address, browser type, browser language, internet service provider (ISP), referring/exit pages, operating system, date and time of visit, clickstream data and cookies that can identify you and your browser session, when you visit our Website or use our Services. This is applicable to all Visitors, Organisers, Speakers and Attendees.

You may also provide the following data to us in specific instances such as when you sign up for a Pigeonhole Live account, use or access our Services, contact our customer support team, choose to integrate our Services with a third-party service provider, or otherwise communicate with us in one way or another:

• Contact details such as your name, e-mail address, non-specific location, company name, and job title.

• Account information such as your e-mail address, name, contact details, profile picture, and other data you have provided to us when you registered for an account or update your account settings.

• Contact information to process payment for goods and services, such as your name, and email and shipping address. We use a third-party payment processor to collect and process your financial information such as credit card particulars.

• Personal information that you have communicated to us when you reach out to us either by sending an email or through other means. Metadata associated with those messages will also be collected.

During a Session, we collect information from you on behalf of the Organiser(s) or Speaker(s) of such Session. If you have provided any personal data during or in relation to a Session, please contact the Organiser(s) or Speaker(s) of such Session directly regarding the processing of your personal data.

If you log-in to our Services using your social network account ("Third-Party Social Network Account"), we may collect information such as your account user id, profile name, profile picture and such other information as you may provide when you choose to log-in to our Website in this manner.

To the extent necessary, we may collect, process and use your personal information for our legitimate interests and the following business purposes:

We use your personal data to provide you with a safe, smooth, efficient, and customized experience when you use our Services. This allows PigeonLab to provide services and features that will most likely meet your needs, and to customise our Services according to your preferences and setting to make your experience safer and easier.

If you are an Attendee of a Session, any personal data that is disclosed during the Sesson will be collected on behalf of the Organiser(s) or Speaker(s) of such Session, and will be made available to such Organiser(s) or Speaker(s).

We will send you a welcome e-mail to verify the email address associated with your user account. We will also send you service-related announcements on occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you a notification e-mail.

If you do not wish to receive such service-related announcements, you have the option to deactivate your user account.

We will communicate with you to respond to your inquiries, to provide the services you request, and to manage your account. We may communicate with you via messages on the Website or by e-mail. Should you send e-mail or other communications to PigeonLab, we may retain those communications in order to process your inquiries, respond to your requests and improve our Services. We will never contact you by telephone unless you specifically agree to it. You may contact customer support at https://help.pigeonholelive.com.

If you purchase or subscribe to fee-based Services or purchase other products or services from us, we will use your personal information and the relevant payment information we have collected from you to process payment and any refund. If we have trouble processing an order, we will use this information to contact you.

We may use usage behaviours and account activity to provide insights to usage levels and feature utilisation, and to identify areas for improvement and/or further development. Such data may also be used to improve the security of our information system and to detect, investigate, prevent and/or take action in relation to illegal activities, suspected fraud, situations involving potential threats to physical safety of any person and violation of this Privacy Policy.

We may also email you to invite you to provide feedback on our Services.

We may use your data to comply with our obligations under the law or pursuant to law enforcement requests.

Your usage behaviour and event activity levels may be used to perform data analytics to improve our Services and to provide certain features to you. We may also use such data to create aggregated and/or anonymised data. For clarity, anonymised data cannot be used to personally identify you, whether directly or indirectly.

If you register for our Services, sign up for our newsletter or e-mail updates, or provide contact information during our marketing campaigns, booth exhibitions or other events, you agree for us to send you from time to time, information that is tailored to you regarding products, services, special deals, and promotions provided by PigeonLab.

You may opt out of such newsletter or e-mail updates via your account profile page, or through the unsubscribe link at the footer of each e-mail. We will stop sending you our newsletter and e-mail updates once you have unsubscribed from the same.

If you request for materials on our Services to be removed because you believe they infringe your copyright, we will ask you to provide your contact details, in particular your name, address, telephone number, and email address, so that we may process your take-down request.

We may disclose data that we have collected from you in limited circumstances to the following third-parties:

To deliver our Services and other business-related functions to you, we may share your personal information with our trusted third-party vendors and hosting partners which provide us with the necessary hardware, software, networking, storage, and related technology. These third-party vendors include:

• Cloud hosting providers, including Amazon Web Services (AWS), to store and process your personal data; and

• Data processors, such as a third-party payment processing company to process payments for our Services and a third-party platform to provide our customer support. For a list of our service providers, please refer to the list at Annex A below.

We only use service providers that have data protection standards that are equivalent to ours. We enter into written agreements with our service providers to ensure that they only process personal information in accordance with our documented instructions and for no other purposes other than to carry out the data processing on our behalf. We work with our service providers for any AI enabled capabilities and features to ensure that they do not use any data provided by you for the training or building of AI models.

For Organisers, if you choose to integrate our Services with other third-party applications, API, integrations or plugins, we may, on your behalf, disclose the personal data we collect or receive to these service providers, as a data processor or as otherwise provided for in this Privacy Policy, to enable you to use the third-party applications, and plugins.

These third-party applications and plugins may collect and process such personal data in accordance to their own privacy practices. We encourage you to read their privacy notices properly before you choose to integrate our Services with these third-party applications and plugins.

Use of such third-party integration is optional.

In the event of a reorganization, merger or acquisition, we may transfer any and all of your personal data to the relevant buyer or potential buyer (and its agents and advisors) as part of the transaction, provided that the conditions of this Privacy Policy would continue to apply.

We may disclose your data to companies in the PigeonLab group, which include affiliates, subsidiaries and business units that form part of the PigeonLab group.

Your personal information may be disclosed if it is necessary to achieve our legitimate interests. For example, if we have to enforce and defend our legal rights (including to take action regarding a breach or intended breach of our Terms of Service), protect other users, investigate complaints, and prevent unlawful use of our Services and website.

We may disclose your personal information if we are so requested by the law, government agencies or statutory bodies, to the extent permitted under the applicable law. We may disclose your personal information in response to a court order or subpoena. We may also disclose your personal data to a law enforcement agency's request or where we believe it is necessary to prevent, investigate, or take action regarding, illegal activities or suspected fraud.

We may also disclose your personal data to any other third parties with your consent.

We use cookies and similar technologies to enhance your experience when you visit our website and use our Services. This Privacy Policy only covers the use of cookies by PigeonLab on our website and excludes the use of cookies by any advertisers or any other third-parties.

• Cookies. We may associate cookies collected on our website with the data that you have provided to us when you visit our website or use our Services. PigeonLab may use both "session ID" cookies and "persistent cookies".

  • A "session ID cookie" expires when you close your browser. We use session ID cookies to manage your browser and mobile sessions for your convenience. This makes it easier for you to navigate our website.

  • A "persistent cookie" remains on your device for an extended period of time. PigeonLab may set a persistent cookie to store some of your login credentials, so you do not have to enter your password more than once. We also use persistent cookies to track the interests of our users to enhance the experience when navigating our website.

• Rejection of cookies. You may disable the use of cookies via your browser setting. If you reject cookies, you may still use our website, but your ability to use some areas of our website may be limited.

• Web beacons. We may use web beacons and related technology such as clear gifs and web bugs to track what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of visitors on our website. We may tie the information gathered by clear gifs to your personal data. We use clear gifs in our HTML-based e-mails to let us know which e-mails our users have opened. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

• Embedded script. We may use an embedded script, which is a software that collects information about your interactions with the website, such as the links you click on. This may be associated with the personal information that we have collected about you. The software is temporarily downloaded onto your device from our server or a third-party provider and is deactivated or deleted when you disconnect from our website.

• Log files. When you visit our website or use our Services, PigeonLab will automatically gather certain information that may contain your personal data and store it in log files. We use the information collected in the log files to analyse trends, track activities on our website and gather demographic information about our users. We may process these automatically collected personal data in the log files to troubleshoot access issues.

• Third-party tracking service. We may use a third-party tracking service that uses log files and cookies to track and aggregate statistical / non-personal data about visitors to the website. This service captures usage and volume statistics as well as geographical location data to compile usage reports and maps for optimization and troubleshooting purposes.

When our Services are used to conduct a real-time audience engagement session, we allow our Organiser(s) or Speaker(s) to combine the use of artificial intelligence, machine learning, natural language processing, and other automated processing functions ("AI Features") with the responses, comments, votes and other similar information collected by our Organiser(s) or Speaker(s) in real time to generate, synthesis, summarise and/or translate the responses collected.

If you use our Services as an Attendee, we act as the data processor in respect of your data which we collect and process on behalf of the Organiser(s) or Speaker(s).

Please contact the Organiser(s) or Speaker(s) of the Session before participating in any Session to find out if AI Features are used for automated decision-making, including profiling, which may affect you.

If the Organiser(s) or Speaker(s) has enabled AI Features and you do not consent to such automated decision-making, you should immediately inform the Organiser(s) or Speaker(s) and stop participating in the Session.

If you are located in the European Economic Area, your rights in your personal data are set out in the General Data Protection Regulation ("GDPR").

• The right to access, request for a copy of, rectify, transfer, erase, object to and/or restrict our processing of, your personal data.

• If you have consented to the processing of your personal data, you have the right to withdraw your consent, including withdrawing your consent to receiving any marketing e-mail or newsletter from us. However, your withdrawal of consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance of other lawful processing grounds apart from consent.

• You have the right to object to the processing of your data, including where we build profiles for sending of marketing messages personalised for you.

Depending on the situation, your data privacy right may be limited and subject to exceptions under the applicable law.

If you are a resident of California, your data protection rights are provided under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (the "CCPA").

If you access our Services as an Attendee, then the Organiser organising the Session and granting you access to our Services is the "business" under the CCPA, and PigeonLab is the "service provider" under the CCPA. In this case, you may exercise your rights under the CCPA by directing your request to the appropriate Organiser(s).

If you access our Services as a visitor to our website or as an Organiser, you have the following rights under the CCPA: the right to find out about the collection and use of your personal information, the right to request us to delete your personal information (subject to certain exceptions), the right to correct any inaccurate information about you and the right to limit the use and disclosure of sensitive information. Businesses under the CCPA cannot discriminate you for exercising your rights.

We do not sell your personal information.

If the Personal Data Protection Act 2012 ("PDPA") applies to you, we will ensure that the collection, use and disclosure of your personal data complies with the applicable requirements under the PDPA.

You may withdraw your consent and request us to stop collecting, using or disclosing your personal data immediately. You have the right to access or obtain a copy of your personal data which we hold about you, and request for your personal data to be corrected.

You may exercise some of your rights by accessing your account dashboard here, which will provide you with the opportunity to view, edit and delete your personal information, as well as withdraw your consent to our processing of your data (including the withdrawal of receiving marketing e-mails). Otherwise, we request that you write to us at legal@pigeonlab.com with your request to exercise your rights under the data protection law applicable to you.

To process, we may need specific information from you to help us confirm your identity when processing your privacy requests including your name and country of residence.

We endeavour to process your request free of charge. However, we may charge a reasonable administration fee if your request is clearly unreasonable, unfounded, repetitive, or excessive. We will respond to you within one (1) month (or thirty (30) days if you are exercising your rights pursuant to the PDPA) of receipt of your request. However, we may take longer if your request is complex or voluminous.

If you are an Attendee and wish to exercise your rights in relation to any personal data that you have provided during a Session, or in any other way to an Organiser or Speaker, please contact your Organiser or Speaker directly. We will assist the Organiser or Speaker accordingly.

PigeonLab takes the security of your personal data seriously. We maintain comprehensive technical and organizational measures to prevent unauthorised access, use, disclosure, modification and other similar risks. To find out more about our security measures, please click here.

We will take reasonable steps to inform any relevant authority within the required time frame, and will otherwise comply with any data breach notification obligations under the applicable data protection law.

We will inform you of the data breach incident if the risk to your individual rights and freedoms is high, or if it necessary to do so under the applicable data protection law. We may have other grounds for delaying or not notifying a data breach under the applicable law, which we may choose to rely on.

We collect information globally and may transfer, process and store your information outside of your country of residence, where we or our third-party service providers operate for the purpose of providing you with our Services. This may involve countries where the data protection, privacy rights and other laws that are equivalent to those where you reside.

Whenever we make international transfers of your information, within the PigeonLab group or to our sub-processors, we ensure that the recipient of your personal information offers an adequate level of protection by entering into appropriate agreements, binding corporate rules or other appropriate measures.

We only retain personal information for so long as it is reasonably necessary to fulfil the relevant business or legal purposes, including for the purposes of satisfying any legal, accounting, or reporting requirements. When such purposes no longer exist, we will delete or anonymise your information in accordance with the applicable law.

PigeonLab’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

If we decide to change our Privacy Policy, we will post changes to this Privacy Policy on the website and other places we deem appropriate so that you are aware of what information we collect, why the information is collected, and how the information is otherwise processed, used and disclosed. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement and consent with the terms of such revised Privacy Policy. If you disagree with any revisions or updates of this Privacy Policy, you must immediately terminate your registration with us and discontinue your use of our website and Services.

We do not knowingly collect personal information from children under the age of 13. If we become aware that a child under the age of 13 has provided us with personal information, we will take steps to remove that information and terminate the applicable account.

If you have any questions regarding this privacy policy or how we handle your personal information, you may contact our designated Data Protection Officer (DPO) at legal@pigeonlab.com.

Last Updated: 16 July 2024