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Pave's successful SOC 2 Type 2 report was issued by the Johanson Group and is actively monitored by Drata.
At Pave, we take your privacy seriously. Please read this privacy policy (“Privacy Policy”) to learn about how we treat your Personal Data when using or accessing our Website Services (as defined below).
Please note that your use of Pave's website is at all times subject to our Terms of Use (https://www.pave.com/terms-of-use) which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms of Use.
Trove Information Technologies, Inc. dba Pave ("Pave," "we," or "us"), located at 1 Montgomery St., Suite 700, San Francisco, CA 94104, United States of America, is responsible for the processing of your Personal Data. If you have any questions about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please contact us at privacy@pave.com.
Further, we have appointed Bitkom Service GmbH, located at Albrechtstraße 10, 10117 Berlin, Germany, as our external data protection officer. You can reach the data protection officer at datenschutz@bitkom-consult.de.
Pave’s mission is to build the world's best compensation tools and easily accessible market data so companies (our “Customers”) can plan, communicate and benchmark in real-time. Our Customers have access to accurate and reliable compensation benchmarks in real-time (the “Benchmarking Product”). As part of the Benchmarking Product, our Customers provide a selection of data from their employees (“Customer Data”), which is subsequently aggregated, de-identified and integrated into the Benchmarking Product for the Customers’ use of the Benchmarking Product. For more detailed information on the Benchmarking Product, please see here.
This Privacy Policy describes the collection of personal information and certain other information by us from each user (“you” or “user”) of our website at www.pave.com (the "Website"), as well as all applications, widgets, software, tools and other services provided by us and on which a link to this Privacy Policy is displayed (collectively, and together with the Website, our "Website Services").
“Personal Data” means any information that identifies or relates to a particular individual, and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations.
Note that this Privacy Policy does not cover how we treat Personal Data that we process as a data processor or service provider when Customers use our products, or the practices of companies we don’t own or control or people we don’t manage.
This chart details the categories of Personal Data that we currently collect and process:
We generally collect Personal Data from the following categories of sources:
Our commercial or business purposes for collecting Personal Data vary depending on the context of our activities.
When providing our Website Services, we process Personal Data from users to:
When users access and interact with our Website, we process Personal Data from users to:
For communication purposes, we process Personal Data to:
In fulfillment of our legal obligations under applicable law, regulation, court order or other legal process, we process Personal Data to:
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
In connection with the Website Services, we disclose your Personal Data to the categories of service providers and other parties listed in this section.
Service Providers. These parties help us provide the Website Services or perform business functions on our behalf. They include:
Advertising Partners. These parties help us market our products to users and provide our Customers with other offers that may be of interest. They include:
Analytics Partners. These parties provide analytics on web traffic or usage of the Website Services. They include:
If we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part), all of the Personal Data that we collect may be transferred to the third party. Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
The Website Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Website Services, analyze trends, learn about our user base and operate and improve our Website Services. Cookies are small pieces of data – usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Website Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).
We use the following types of Cookies in connection with the Website Services:
You can decide whether or not to accept Cookies through our cookie consent manager or, alternatively, your internet browser’s settings. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our Website and some of the Website Services may not work. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/, or https://ico.org.uk/for-the-public/online/cookies/.
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Website Services. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Interest-Based Ads”). Information for Interest-Based Ads (including Personal Data) may be provided to us by you, or derived from the usage patterns of particular users of the Website Services and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Website. To accomplish this, we or our service providers may deliver Cookies, including a file (known as a “web beacon”) from an ad network to you through the Website Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own Cookies on your browser, just as if you had requested a web page from their site.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.
With respect to the Website Services, we retain Personal Data about you only as long as is necessary for the fulfillment of the relevant purposes. After the end of the purpose, we delete your Personal Data in compliance with legal retention rights and obligations and insofar as other legal regulations do not conflict with this.
As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data about children under 16 years of age. If you are a child under the age of 16, please do not attempt to register for or otherwise use the Website Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at privacy@pave.com.
If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our Customers’ employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at privacy@pave.com.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information:
If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data disclosed to each category of third party recipient. We have not sold your Personal Data over the last twelve (12) months and Pave does not sell Personal Data.
You have the right to request that we delete the Personal Data that we have collected about you. Under the California Consumer Privacy Act (“CCPA”), this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Website Services or complete a transaction or other action you have requested. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may submit a Valid Request by emailing us at privacy@pave.com.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
In this section, we use the term ‘sell’ as it is defined in the CCPA. We do not sell your Personal Data.
As described in the “Our Use of Tracking Tools and Advertising” section above, we have incorporated Cookies from certain third parties into our Website Services. These Cookies allow those third parties to receive information about your activity on our Website Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads when using our Website Services or on other websites you visit. You can opt out of these sales by following the instructions in this section.
You always have full control over whether these technologies work on your devices. You can disable them entirely using our cookie consent manager.
In addition, under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at privacy@pave.com.
We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Website Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us at privacy@pave.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway or Iceland, you may have additional rights under the EU General Data Protection Regulation (Regulation (EU) 2016/679) (the “EU-GDPR”), the United Kingdom Data Protection Act 2018 and the United Kingdom General Data Protection Regulation with respect to your Personal Data, as outlined below.
If there are any conflicts between this this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at privacy@pave.com.
The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains for which purposes we use your Personal Data.
We will only process your Personal Data if we have a legal basis to do so pursuant to Art. 6 EU-GDPR. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.
1. Contractual Necessity
We process Personal Data used for providing and customizing our Website Services as a matter of “contractual necessity” according to Art. 6 (1) lit. b of EU-GDPR, meaning that we need to process the data to perform under our Terms of Use with you, which enables us to provide you with the Website Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Website Services that require such data.
2. Legitimate Interest
Further, we process Personal Data where we consider it to be the legitimate interest of us or third parties according to Art. 6 (1) lit. f of EU-GDPR. Our interests here are:
3. Consent
In some cases, we process Personal Data based on the consent you expressly grant to us according to Art. 6 (1) lit. a of EU-GDPR. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection. We mainly obtain consent for:
4. Other Processing Grounds
From time to time we may also need to process Personal Data to comply with our legal obligations, if it is necessary to protect the vital interests of you or other data subjects or if it is necessary for a task carried out in the public interest.
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@pave.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Right to File Complaint: You have the right to lodge a complaint about Pave's practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here:https://edpb.europa.eu/about-edpb/board/members_en.
We only transfer your Personal Data to external third parties if this is necessary for the processing or handling of your request, if another legal permission exists or if we have your consent for this. External recipients of user data can be, in particular, service providers that we use for the provision of services, for example in the areas of technical infrastructure and maintenance of our Website. Such service providers as processors are carefully selected and regularly reviewed by us. They may only use the data for the purposes specified by us and in accordance with our instructions.
The Website Services are hosted and operated in the United States (“U.S.”) through Pave and its service providers. If you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. Processing Personal Data outside the EU / EEA requires additional safeguards to ensure a similar level of protection of the EU-GDPR. To achieve this, we have integrated the standard data protection clauses (SCC) into a data privacy agreement (DPA), which we conclude with third parties for processing personal data.
We’re constantly trying to improve our Website Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any such changes by placing a notice on the Website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Website Services.
Pave's successful SOC 2 Type 2 report was issued by the Johanson Group and is actively monitored by Drata.