PRIVACY NOTICE
Last updated January 11, 2023
This privacy notice for Pana Partners, LLC (doing business as Pana Partners) ("Pana Partners," "we,"
"us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your
information when you use our services ("Services"), such as when you:
Visit our website at https://pana.agency, or any website of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and
choices. If you do not agree with our policies and practices, please do not use our Services. If you still have
any questions or concerns, please contact us at info@pana.agency.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about
any of these topics by clicking the link following each key point or by using our table of contents
below to find the section you are looking for. You can also click here to go directly to our table of
contents.
What personal information do we process? When you visit, use, or navigate our Services, we may
process personal information depending on how you interact with Pana Partners and the Services, the
choices you make, and the products and features you use.
Do we process any sensitive personal information? We may process sensitive personal information
when necessary with your consent or as otherwise permitted by applicable law.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer
our Services, communicate with you, for security and fraud prevention, and to comply with law. We may
also process your information for other purposes with your consent. We process your information only
when we have a valid legal reason to do so.
In what situations and with which parties do we share personal information? We may share
information in specific situations and with specific third parties.
How do we keep your information safe? We have organizational and technical processes and
procedures in place to protect your personal information. However, no electronic transmission over the
internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or
guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our
security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law
may mean you have certain rights regarding your personal information.
How do you exercise your rights? The easiest way to exercise your rights is by filling out our data
subject request form available here, or by contacting us. We will consider and act upon any request in
accordance with applicable data protection laws.
Want to learn more about what Pana Partners does with any information we collect? Click here to review
the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
7. DO WE COLLECT INFORMATION FROM MINORS?
8. WHAT ARE YOUR PRIVACY RIGHTS?
9. CONTROLS FOR DO-NOT-TRACK FEATURES
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context
of your interactions with us and the Services, the choices you make, and the products and features you
use. The personal information we collect may include the following:
- names
- phone numbers
- email addresses
- job titles
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law,
we process the following categories of sensitive information:
- data about a person's sex life or sexual orientation
- information revealing race or ethnic origin
- genetic data
All personal information that you provide to us must be true, complete, and accurate, and you must notify
us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device
characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information
does not reveal your specific identity (like your name or contact information) but may include device and
usage information, such as your IP address, browser and device characteristics, operating system,
language preferences, referring URLs, device name, country, location, information about how and when
you use our Services, and other technical information. This information is primarily needed to maintain the
security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance
information our servers automatically collect when you access or use our Services and which we
record in log files. Depending on how you interact with us, this log data may include your IP address,
device information, browser type, and settings and information about your activity in the
Services (such as the date/time stamps associated with your usage, pages and files viewed,
searches, and other actions you take such as which features you use), device event information
(such as system activity, error reports (sometimes called "crash dumps"), and hardware settings). - Device Data. We collect device data such as information about your computer, phone, tablet, or
other device you use to access the Services. Depending on the device used, this device data may
include information such as your IP address (or proxy server), device and application identification
numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier,
operating system, and system configuration information. - Location Data. We collect location data such as information about your device's location, which can
be either precise or imprecise. How much information we collect depends on the type and settings of
the device you use to access the Services. For example, we may use GPS and other technologies to
collect geolocation data that tells us your current location (based on your IP address). You can opt
out of allowing us to collect this information either by refusing access to the information or by
disabling your Location setting on your device. However, if you choose to opt out, you may not be
able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with
you, for security and fraud prevention, and to comply with law. We may also process your information for
other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with
our Services, including:
- To deliver and facilitate delivery of services to the user. We may process your information to
provide you with the requested service. - To respond to user inquiries/offer support to users. We may process your information to respond
to your inquiries and solve any potential issues you might have with the requested service. - To evaluate and improve our Services, products, marketing, and your experience. We may
process your information when we believe it is necessary to identify usage trends, determine the
effectiveness of our promotional campaigns, and to evaluate and improve our Services, products,
marketing, and your experience. - To identify usage trends. We may process information about how you use our Services to better
understand how they are being used so we can improve them. - To determine the effectiveness of our marketing and promotional campaigns. We may process
your information to better understand how to provide marketing and promotional campaigns that are
most relevant to you. - To comply with our legal obligations. We may process your information to comply with our legal
obligations, respond to legal requests, and exercise, establish, or defend our legal rights.
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following
third parties.
We may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during
negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of
our business to another company. - When we use Google Maps Platform APIs. We may share your information with certain Google
Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy
Policy, please refer to this link.
4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store
information. Specific information about how we use such technologies and how you can refuse certain
cookies is set out in our Cookie Notice.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy
notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this
privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or
other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either
delete or anonymize such information, or, if this is not possible (for example, because your personal
information has been stored in backup archives), then we will securely store your personal information and
isolate it from any further processing until deletion is possible.
6. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical
security measures.
We have implemented appropriate and reasonable technical and organizational security measures
designed to protect the security of any personal information we process. However, despite our safeguards
and efforts to secure your information, no electronic transmission over the Internet or information storage
technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Although we will do our best to protect your personal
information, transmission of personal information to and from our Services is at your own risk. You should
only access the Services within a secure environment.
7. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services,
you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to
such minor dependent’s use of the Services. If we learn that personal information from users less than 18
years of age has been collected, we will deactivate the account and take reasonable measures to promptly
delete such data from our records. If you become aware of any data we may have collected from children
under age 18, please contact us at privacy@pana.agency.
8. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal
information, you also have the right to complain to your local data protection supervisory authority. You can
find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located in Switzerland, the contact details for the data protection authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on your consent to process your personal information, which
may be express and/or implied consent depending on the applicable law, you have the right to withdraw
your consent at any time. You can withdraw your consent at any time by contacting us by using the contact
details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor,
when applicable law allows, will it affect the processing of your personal information conducted in reliance
on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing
and promotional communications at any time by clicking on the unsubscribe link in the emails that we send,
or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate
with you — for example, to send you service-related messages that are necessary for the administration
and use of your account, to respond to service requests, or for other non-marketing purposes.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer,
you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to
remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of
interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.
If you have questions or comments about your privacy rights, you may email us at privacy@pana.agency.
9. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track
("DNT") feature or setting you can activate to signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this stage no uniform technology standard for
recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to
DNT browser signals or any other mechanism that automatically communicates your choice not to be
tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform
you about that practice in a revised version of this privacy notice.
10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your
personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are
California residents to request and obtain from us, once a year and free of charge, information about
categories of personal information (if any) we disclosed to third parties for direct marketing purposes and
the names and addresses of all third parties with which we shared personal information in the immediately
preceding calendar year. If you are a California resident and would like to make such a request, please
submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you
have the right to request removal of unwanted data that you publicly post on the Services. To request
removal of such data, please contact us using the contact information provided below and include the email
address associated with your account and a statement that you reside in California. We will make sure the
data is not publicly displayed on the Services, but please be aware that the data may not be completely or
comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a
temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your
personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
Category Examples Collected
A. Identifiers
Contact details, such as real name, alias, postal
address, telephone or mobile contact number, unique
personal identifier, online identifier, Internet Protocol
address, email address, and account name
YES
B. Personal information categories
listed in the California Customer
Records statute
Name, contact information, education, employment,
employment history, and financial information
YES
C. Protected classification
characteristics under California or
federal law
Gender and date of birth YES
D. Commercial information
Transaction information, purchase history, financial
details, and payment information
NO
E. Biometric information Fingerprints and voiceprints NO
F. Internet or other similar network
activity
Browsing history, search history, online behavior,
interest data, and interactions with our and other
websites, applications, systems, and advertisements
NO
G. Geolocation data Device location NO
H. Audio, electronic, visual,
thermal, olfactory, or similar
information
Images and audio, video or call recordings created in
connection with our business activities
NO
I. Professional or employment-
related information
Business contact details in order to provide you our
Services at a business level or job title, work history,
and professional qualifications if you apply for a job
with us
YES
J. Education Information Student records and directory information NO
K. Inferences drawn from other
personal information
Inferences drawn from any of the collected personal
information listed above to create a profile or
summary about, for example, an individual’s
preferences and characteristics
NO
L. Sensitive Personal Information Racial or ethnic origin, sex life or sexual orientation
and genetic data YES
We will use and retain the collected personal information as needed to provide the Services or for:
- Category A - As long as the user has an account with us
- Category B - As long as the user has an account with us
- Category C - As long as the user has an account with us
- Category I - As long as the user has an account with us
- Category L - As long as the user has an account with us
- Category L information may be used, or disclosed to a service provider or contractor, for additional,
specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.
We may also collect other personal information outside of these categories through instances where you
interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at info@pana.agency, by visiting https://pana.agency/contact, 2121 Biscayne
Blvd #1029 Miami, FL 33137, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out we may deny a request if the
authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract
between us and each service provider. Each service provider is a for-profit entity that processes the
information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal
research for technological development and demonstration. This is not considered to be "selling" of your personal information.
Pana Partners, LLC has not disclosed, sold, or shared any personal information to third parties for a
business or commercial purpose in the preceding twelve (12) months. Pana Partners, LLC will not sell or
share personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information,
we will respect your request and delete your personal information, subject to certain exceptions provided
by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our
compliance requirements resulting from a legal obligation, or any processing that may be required to
protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information; the purposes for which the collected personal information is used; whether we sell or share personal information to third parties; the categories of personal information that we sold, shared, or disclosed for a business purpose; the categories of third parties to whom the personal information was sold, shared, or disclosed for a In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
If the business collects any of the following:
- social security information, drivers' licenses, state ID cards, passport numbers
- account login information
- credit card numbers, financial account information, or credentials allowing access to such accounts
precise geolocation - racial or ethnic origin, religious or philosophical beliefs, union membership
the contents of email and text, unless the business is the intended recipient of the communication
genetic data, biometric data, and health data - data concerning sexual orientation and sex life
you have the right to direct that business to limit its use of your sensitive personal information to that use
which is necessary to perform the Services. - Once a business receives your request, they are no longer allowed to use or disclose your sensitive
personal information for any other purpose unless you provide consent for the use or disclosure of
sensitive personal information for additional purposes. - Please note that sensitive personal information that is collected or processed without the purpose of
inferring characteristics about a consumer is not covered by this right, as well as the publicly available
information.
To exercise your right to limit use and disclosure of sensitive personal information, please email
privacy@pana.agency or submit a request form by clicking here.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person
about whom we have the information in our system. These verification efforts require us to ask you to
provide information so that we can match it with information you have previously provided us. For instance,
depending on the type of request you submit, we may ask you to provide certain information so that we can
match the information you provide with the information we already have on file, or we may contact you
through a communication method (e.g., phone or email) that you have previously provided to us. We may
also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make
the request. To the extent possible, we will avoid requesting additional information from you for the
purposes of verification. However, if we cannot verify your identity from the information already maintained
by us, we may request that you provide additional information for the purposes of verifying your identity and
for security or fraud-prevention purposes. We will delete such additionally provided information as soon as
we finish verifying you.
Other privacy rights
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to
restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We may
deny a request from an authorized agent that does not submit proof that they have been validly
authorized to act on your behalf in accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal information to third parties.
Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no
later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at info@pana.agency, by visiting
https://pana.agency/contact, 2121 Biscayne Blvd #1029 Miami, FL 33137, or by referring to the contact
details at the bottom of this document. If you have a complaint about how we handle your data, we would
like to hear from you.
11. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated
"Revised" date and the updated version will be effective as soon as it is accessible. If we make material
changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or
by directly sending you a notification. We encourage you to review this privacy notice frequently to be
informed of how we are protecting your information.
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at privacy@pana.agency or by post
to:
Pana Partners, LLC
2121 Biscayne Blvd #1029
Miami, FL 33137
United States
13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal
information we collect from you, change that information, or delete it. To request to review, update, or
delete your personal information, please submit a request form by clicking here.
