Effective Date: January 10th, 2025
Introduction
Welcome to PointSwitch, Inc. (doing business as “Margin”) (“Margin,” “we,” “us,” or “our”). This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website at [www.viewmargin.com] (the “Site”) and when you use any of our services (collectively, the “Services”).
By accessing or using our Site or Services, you indicate that you have read, understand, and agree to our collection, storage, use, and disclosure of your information as described in this Privacy Policy. If you do not agree, please do not access or use the Site or Services.
Section 1: Key Definitions
“Personal Data” or “Personal Information”
Any information that relates to an identified or identifiable individual. This can include details such as a name, email address, IP address, or any other data that can be reasonably linked to a specific person.
“Usage Data”
Information that is automatically collected from a user’s device when visiting or interacting with the Site or Services, such as IP addresses, browser type, device identifiers, pages visited, and the date and time of such visits.
“Cookies and Tracking Technologies”
Small data files (cookies) or similar tools (e.g., pixels, tags, scripts) placed on a user’s device that facilitate the collection of information about browsing activities and preferences. These technologies help us provide, analyze, and improve our Site and Services, and may include session cookies, persistent cookies, or third-party cookies.
“Data Controller”
The natural or legal person (in this case, Margin) who determines the purposes and means of processing personal data. When acting as a Data Controller, we decide how and why personal data is processed.
“Data Processor”
A natural or legal person (or service) that processes personal data on behalf of the Data Controller, according to the Controller’s instructions and subject to contractual obligations to maintain confidentiality and security of the data.
Section 2: Scope & Data Collection
2.1 Website Visitors
When you visit our Site ([www.viewmargin.com]) or interact with our online content, we may automatically collect certain information about your device and usage patterns. This can include:
Log Data
Such as IP addresses, date/time stamps, pages viewed, referrer URLs, and browser or device information.Cookies & Tracking Technologies
We use cookies and similar technologies to understand how visitors engage with our Site, improve functionality, and enhance security. Specifically, we use (or may use) the following categories of cookies:Strictly Necessary Cookies: Essential for the operation of our Site. They enable core functionalities such as security, network management, and accessibility. You cannot opt out of these cookies, as the Site cannot function properly without them.
Analytics Cookies: These cookies help us analyze usage trends and improve performance. They collect information about how visitors interact with the Site (e.g., pages visited, time spent on each page).
Functional Cookies: These allow the Site to remember your preferences (e.g., language settings) and provide enhanced, more personalized features.
Advertising (or Marketing) Cookies: If we use advertising, these cookies help us deliver relevant ads, measure the performance of our ad campaigns, and understand your interests based on your browsing behavior.
From time to time, we may also use third-party analytics or other tools to gather usage data and insights. These tools may set their own cookies or use other tracking mechanisms. We do not control how these third parties collect and use data, but we strive to work with reputable providers that adhere to industry standards and privacy obligations.
2.2 Additional Personal Data We May Collect
In addition to the categories of information described above, we may also collect and process other types of personal data from you, including but not limited to:
Phone Number (mobile or landline)
Physical or Mailing Address
Job Title or Company Name
Demographic Details (e.g., age, gender, or general location)
User-Generated Content (e.g., messages you send us, feedback, or inquiries)
We collect this information only when you voluntarily provide it—such as when filling out forms on our Site, communicating with us for support or inquiries, or signing up for specific services. We may use these additional personal details for the same purposes stated elsewhere in this Privacy Policy, including but not limited to:
Facilitating communication and support
Providing requested products, features, or services
Customizing user experience
Sending important notices or updates
When you choose to share this information, you acknowledge that it may be associated with you, and we will handle it in accordance with the data protection safeguards described in this Privacy Policy. If you do not wish to provide such information, you are free not to do so; however, certain features or functionalities of our Site or Services may require it for optimal use.
Note: We rely on you to provide accurate and complete personal information. Please ensure that you have any necessary consent to submit personal data belonging to others (if applicable) before sharing it with us.
2.3 Data Not Collected
Personal Financial Information: We do not intentionally collect credit card numbers, bank account details, or other sensitive financial information.
Special Categories of Personal Data: We do not request or process any government IDs, health records, or other special categories of data (e.g., sensitive personal data under applicable laws).
Children’s Data: Our Site and Services are not directed to children. We do not knowingly collect personal information from individuals under the age of 13 in the U.S., or under the age of 16 in the EU/UK (subject to lower age limits that individual Member States or the UK may set). If you believe that we have inadvertently collected personal data from a child, please contact us immediately at [email protected], and we will promptly investigate and delete such information.
2.4 Changes to Data Collection
We may update the methods or tools we use to collect data over time. If we make significant changes to our data collection practices, we will revise this Privacy Policy accordingly and indicate the date of the most recent update.
2.5 Our Role as Data Controller and Data Processor
For purposes of applicable data protection laws (including the EU and UK GDPR), Margin acts as a “data controller” when we collect and process personal information related to website visitors (e.g., analytics, cookies, or scheduling data). This means we determine the purposes and means of processing such personal data.
Section 3: Data Use & Sharing
3.1 How We Use Website Visitor Data
We may process information collected from or about you for various legitimate business purposes, including but not limited to:
To Facilitate Account Creation and Authentication
We may process your information to enable you to create and log in to an account on our Site or Services, and to keep that account in good working order.To Deliver and Facilitate Delivery of Services
We may process your information to provide you with the Services or features you request, ensuring a smooth user experience.To Respond to Inquiries and Provide Support
We may process your information to address questions, requests, or feedback you submit, and to resolve any technical or operational issues.To Send Administrative Information
We may process your information to send updates about new features, changes to our terms or policies, or other administrative and product-related messages.To Enable User-to-User Communications
If our Services allow direct communication between users, we may process your information for the purpose of facilitating these interactions.To Request Feedback
We may process your information to request feedback about your experience with our Services and to help us improve.To Send Marketing and Promotional Communications
We may process the personal information you provide for our marketing purposes, in accordance with your preferences. You can opt out of marketing emails at any time.To Deliver Targeted Advertising
We may process your information to develop and display personalized ads, content, or offers that align with your interests or location.To Protect Our Services
We may process your information as part of our ongoing efforts to keep our Site and Services safe and secure, including fraud monitoring and prevention.To Identify Usage Trends
We may analyze how you use our Site and Services in order to improve their design, functionality, and user experience.To Determine the Effectiveness of Our Marketing Campaigns
We may process your information to understand which promotional campaigns are most relevant or effective.To Save or Protect an Individual’s Vital Interest
In rare circumstances, we may process your information when necessary to protect someone’s vital interests, such as to prevent imminent harm.
3.2 When We May Share Data
We do not sell personal information. However, we may share or transfer information in the following circumstances:
Business Transfers
We may share or transfer 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 by another company.Affiliates
We may share information with our affiliates, in which case we will require them to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other entities under common control with us.Vendors & Service Providers
We may share certain anonymized data with trusted vendors or service providers (including cloud hosting providers like Amazon Web Services (AWS)) for purposes such as website hosting, data enrichment or other forms of enhancing our core services. Such third parties are required to maintain the confidentiality of the data and use it only for the services we authorize.Legal or Regulatory Requirements
We may disclose information if required by law, legal process, or government request, or if disclosure is necessary to protect our rights, the rights of our users, or the public in compliance with applicable laws.
3.3 Lawful Bases for Processing (EEA/UK Residents)
We process personal data in compliance with the legal bases under the EU and UK General Data Protection Regulation (GDPR). Specifically, we rely on:
Consent: Where required by law (e.g., for certain marketing communications or non-essential cookies), we will obtain your consent before processing your information.
Legitimate Interests: We may process your information to pursue our legitimate interests, such as improving our Site, enhancing security, preventing fraud, and engaging in limited direct marketing. We balance these interests against your rights and interests.
Contractual Necessity: Where processing is necessary for us to provide you with the Services you request or to perform our contract with you (e.g., creating an account or scheduling a meeting).
Legal Obligation: Where processing is required by law or necessary for compliance with a legal obligation (e.g., responding to lawful requests from government authorities).
3.4 International Data Transfers
Given our global operations, the personal data we collect may be transferred to and processed in countries outside of your home jurisdiction, including the United States. When transferring personal data from the EEA or the UK to third countries, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum, or other legally recognized transfer mechanisms.
By using our Site or Services or otherwise providing information to us, you acknowledge that your data may be transferred to and processed in countries outside of your own. We take steps to ensure that such data receives an adequate level of protection, including technical and organizational security measures as described in Section 5 (Security Measures).
We may disclose personal data in response to lawful requests by public authorities, including to meet law enforcement requirements.
Section 4: Data Retention
4.1 Website Visitor Data
We retain server logs and related website visitor data only for as long as necessary to fulfill the purposes for which it was collected, or as required under the applicable laws and regulations of the EU, US, and UK—whichever imposes the shortest retention period. We may also keep this data to comply with our legal obligations, resolve disputes, or enforce our agreements. After this period, we will either delete or anonymize the data in a secure manner.
4.2 Updates to Retention Practices
From time to time, we may update our data retention practices in accordance with changes to law, regulations, or business needs. If we make material changes to our retention periods, we will revise this Privacy Policy accordingly and indicate the date of the most recent update.
Section 5: Security Measures
We take data security seriously. Our security program is designed to align with industry best practices and SOC 2 requirements, including the following safeguards:
5.1 Encryption
Encryption in Transit: All data transmitted between our systems and external parties is protected using Transport Layer Security (TLS) to prevent interception or tampering.
Encryption at Rest: We store data using strong encryption methods (e.g., AES-256) to protect against unauthorized access while data resides on our servers.
5.2 Access Controls
Least Privilege: We apply the principle of least privilege, ensuring that employees only have access to the data necessary for their job responsibilities.
Role-Based Permissions: System access is granted based on defined roles and is regularly reviewed and updated as needed.
5.3 Monitoring & Logging
We maintain logs of critical system and application events, which are monitored for unusual or unauthorized activities.
Security alerts are investigated promptly to reduce the risk of data breaches or misuse.
5.4 Vulnerability Management
Regular vulnerability scans and penetration tests help us identify and address potential security weaknesses.
We deploy security patches and updates promptly to maintain the integrity of our systems.
5.5 Incident Response
We have an incident response plan in place to address security events swiftly and effectively.
In the event of a data breach, we will take immediate steps to contain and investigate the incident and, where required by law, notify affected parties and authorities.
5.6 Employee Training & Policies
Our personnel receive ongoing security and privacy training to ensure they understand and follow best practices.
We maintain internal policies and procedures designed to preserve the confidentiality and integrity of all data we handle.
Section 6: User Rights & Choices
Depending on the applicable laws in your jurisdiction (e.g., those in the US, UK, EU, or elsewhere), you may have certain rights regarding your personal information. This section describes how you can exercise those rights and manage your data preferences.
6.1 Managing Cookies & Tracking Technologies
Browser Settings
You can configure your web browser to refuse some or all cookies, or to alert you when cookies are being sent. If you choose to disable or refuse cookies, some features of our Site may become inaccessible or not function properly.Consent Mechanism for Non-Essential Cookies
In jurisdictions requiring cookie consent (e.g., the EU, UK), we will only place non-essential cookies (such as analytics or advertising) on your device after you have consented via our cookie banner or settings preference center. You can withdraw or modify your consent at any time by adjusting your cookie preferences or browser settings. Essential cookies necessary for the operation of the Site cannot be disabled without affecting basic functionality.Do Not Track Signals
“Do Not Track” (DNT) is a privacy preference users can set in their web browsers. We acknowledge these signals; however, we do not currently respond to them in a different manner than other browser requests. If we change our practices in the future, we will update this Privacy Policy accordingly. To learn more about Do Not Track, visit https://allaboutdnt.com.Third-Party Tools
If we use third-party analytics or advertising tools, you may opt out of certain tracking through those providers’ own opt-out mechanisms or through industry opt-out sites, where applicable.
6.2 Accessing, Updating, or Deleting Your Information
Website Visitor Data
If you have provided personal information via our scheduling form (e.g., name, email address), you may contact us at any time to request access to, correction of, or deletion of this information. We will respond within a reasonable timeframe in accordance with applicable law.
6.3 Opting Out of Marketing Communications
Email Marketing
If you receive marketing or promotional emails from us, you can unsubscribe at any time by clicking the “unsubscribe” link in those emails or by contacting us directly. We will process your request as soon as possible.
Other Communications
We may still send you administrative or transactional messages related to our Services (e.g., important updates or service-related notifications), even if you opt out of marketing emails.
6.4 Other Privacy Rights
Depending on your jurisdiction, you may have additional rights under local law. These could include:
Right to Restrict Processing: The right to request that we limit the use of your personal data.
Right to Data Portability: The right to receive a copy of your personal information in a structured, commonly used, and machine-readable format.
Right to Object: The right to object to certain processing activities, including direct marketing.
Right to Lodge a Complaint: The right to lodge a complaint with a supervisory authority.
Right to Lodge a Complaint with a Supervisory Authority
If you reside in the European Economic Area (EEA) or the United Kingdom (UK) and believe we have not complied with applicable data protection laws, you have the right to lodge a complaint with a supervisory authority. You can find information for your local Data Protection Authority on the European Data Protection Board website. UK residents may contact the Information Commissioner’s Office (ICO) via https://ico.org.uk.
6.5 Additional U.S. State Privacy Disclosures (e.g., CCPA)
We do not currently meet the thresholds for coverage under the California Consumer Privacy Act (CCPA), or other U.S. state privacy laws, and therefore these laws may not apply to us at this time. However, we do not sell personal information, and we remain committed to safeguarding consumer privacy.
If you are a resident of California (or another state with a comprehensive privacy law) and believe that these laws should apply to your interaction with Margin, or if you have questions about your privacy rights under these laws, please contact us at [email protected].
If you would like to exercise any of these rights, please contact us using the details provided in Section 7. We will consider all requests and provide our response in accordance with applicable law.
Section 7: Contact Information & Policy Updates
7.1 How to Contact Us
If you have any questions, comments, or concerns about this Privacy Policy or our data practices, or if you wish to exercise any of your privacy rights, please contact us at:
PointSwitch, Inc. (d/b/a Margin)
Email: [email protected]
Mailing Address: Senna Building, Gorsuch Pl, London, United Kingdom, E2 8JF
We will make every effort to respond to your request or inquiry in a timely manner, and in accordance with applicable laws.
7.2 Changes to This Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we make material changes, we will take appropriate measures to inform you in a manner consistent with the significance of the changes (e.g., by prominently posting a notice on our Site or by directly sending you a notification if you have provided your email address).
Each version of this Privacy Policy will be identified by its effective date, which can be found at the top of the document. We encourage you to review this Privacy Policy periodically to stay informed about our data practices and the ways you can help protect your privacy.
7.3 Data Protection Officer (DPO) or EU/UK Representative
If you have any questions or concerns about how we process personal data from individuals in the EEA or UK, you may also contact our appointed Data Protection Officer (DPO) or EU/UK Representative at:
Name: Fryderyk Sitnik
Email: [email protected]
Address: Senna Building, Gorsuch Pl, London, United Kingdom, E2 8JF
This individual serves as our primary point of contact for regulatory matters and data subject inquiries under EU and/or UK data protection laws.
End of Privacy Policy