Privacy Policy
Effective Date: February 27, 2026
Last Updated: February 27, 2026
1. Introduction and Jurisdictional Scope
PanVanguard Corporation ("we," "us," or "our") operates the website https://panvanguard.com (the "Site"). We receive mail at 447 Broadway, 2nd Floor Suite #3182, New York, New York 10013, USA. This Privacy Policy explains how we collect, use, and protect your personal information in compliance with the New York SHIELD Act, the California Consumer Privacy Act (CCPA) as amended, the General Data Protection Regulation (GDPR), the Nigeria Data Protection Act (NDPA), and South Africa’s Protection of Personal Information Act (POPIA).
2. Information We Collect (Notice at Collection)
We collect information that identifies, relates to, or is reasonably capable of being associated with you. In the preceding 12 months, we have collected:
Identifiers: Name, email, phone number, IP address, and LinkedIn profile.
Sensitive Personal Information: Account login credentials and precise geolocation.
Commercial Information: Membership tier, business revenue range, and application history.
Professional Information: Job title, company name, and industry.
Internet Activity: Browsing history, interaction with our site, and search history.
Inferences: Profile characteristics and behavior patterns used for peer group matching.
3. Algorithmic-Assisted Decision Making (ADMT) and Profiling
We utilize technology to facilitate membership applications and peer matching.
Hybrid Review Process: Our system uses automation to determine eligibility. However, no decision is solely automated. All applications and matchings undergo a manual review by a PanVanguard representative who has the authority to override algorithmic outputs.
Your Rights: You have the right to opt out of the use of ADMT for "significant decisions." If you opt out, your application will be reviewed entirely via manual processes. You also have the right to receive an explanation of the logic behind eligibility and matching decisions.
4. Legal Basis for Processing (International Requirements)
We process your data under the following legal bases:
Consent: For marketing communications and non-essential cookies.
Contractual Necessity: To provide the peer advisory services you have requested.
Legal Obligation: To comply with New York and international regulatory mandates.
Legitimate Interests: To maintain security, prevent fraud, and improve our services, in a way that does not override your fundamental rights and freedoms.
5. How We Share Your Information
We do not sell your personal information. We may share data with:
Service Providers: Trusted vendors assisting in our operations (e.g., AWS, HubSpot) under strict Data Processing Agreements (DPAs) that prohibit them from using your data for their own purposes.
Legal Requirements: When required by law or to protect our rights under the SHIELD Act.
6. Third-Party Services
HubSpot CRM: We use HubSpot to manage our relationship with you. Your data is stored securely in HubSpot’s environment, governed by HubSpot's privacy practices.
Marketing Tools: We use tools such as Meta Pixel and LinkedIn Insight Tag for measurement and targeted outreach. Where required by law, we obtain your consent before placing or reading non‑essential cookies or similar technologies, and you can opt out of targeted advertising by using our cookie or privacy controls or the relevant platform settings.
7. International Data Transfers
PanVanguard operates globally, which means your information may be processed in countries other than where you reside. These countries may have different data protection laws than your home country, but we take steps to ensure an adequate level of protection for your information.
Service providers (such as our website host and other vendors) may process your data in the United States and other jurisdictions. Where required, they implement appropriate safeguards for transfers from the EEA/UK and similar regions, including the use of Standard Contractual Clauses or equivalent protections as recognized by applicable law.
Where adequacy decisions exist between jurisdictions (for example, mutual adequacy arrangements between Brazil and the European Union), we rely on those decisions so that data can flow without requiring additional transfer tools.
For transfers to other countries, including jurisdictions such as Nigeria and South Africa, we ensure that a lawful transfer mechanism applies, such as adequate data protection laws in the recipient country, appropriate contractual safeguards with our service providers, or another ground permitted under local data protection rules.
8. Data Retention and Secure Disposal
We retain personal information only for as long as necessary for the purpose it was collected.
Applicant Data: 3 years from last interaction.
Member Records: Duration of membership plus 7 years (for tax and legal compliance).
Disposal: We delete or anonymize personal information when it is no longer needed, including by removing records from our systems and directing our service providers to do the same, in line with their retention and deletion processes..
9. Your Privacy Rights
Depending on your residency, you may have the right to:
Access/Know: Request a copy of the specific pieces of data we hold.
Delete: Request erasure of your data, subject to legal retention mandates.
Correct: Rectify inaccurate or incomplete information.
Opt-Out: Stop the sharing of data for targeted advertising.
Limit Use of SPI: Direct us to only use sensitive data for essential service provision.
You can exercise these rights by contacting us at privacy@panvanguard.com. We will respond to your request in accordance with applicable law and may need to verify your identity before acting on it.
10. Marketing Communications
You may opt out of marketing at any time by:
Clicking the "unsubscribe" link in any email.
Emailing privacy@panvanguard.com.
Note: You will still receive non-promotional messages regarding your membership or transactions.
11. Data Security
We take the protection of your information seriously and use a combination of administrative, technical, and physical safeguards that are appropriate to our size and the nature of our business. These measures are designed to reduce the risk of unauthorized access, use, or disclosure of your information.
Encryption: Our website is hosted on Squarespace, which uses HTTPS/TLS to encrypt data in transit between your browser and our site. Where our service providers offer it, we also rely on their safeguards (which may include encryption and other security controls) to protect data they store on our behalf.
Access controls: Access to personal information is limited to people who need it to perform their roles and is restricted through account-based permissions. Where available, we enable additional security features such as multi‑factor authentication for administrator and account access.
Security practices: We periodically review our tools, settings, and service providers, and we select vendors that commit to maintaining reasonable security measures in their own systems, in line with applicable data protection laws (including, where relevant, New York’s SHIELD Act requirement for “reasonable safeguards”).
No method of transmission or storage is perfectly secure, so we cannot guarantee absolute security, but we strive to protect your information and respond promptly to any suspected issues.
12. Children's Privacy
Our services are not directed to individuals under 18. We do not knowingly collect information from children. If we discover such data has been collected, we will delete it immediately.
13. Changes to This Privacy Policy
We may update this policy to reflect regulatory changes. Material changes will be notified via email or a prominent notice on our Site. Continued use of the Site after an update indicates acceptance.
14. Contact Us
For questions or to exercise your rights, contact our Data Protection Office:
Email: privacy@panvanguard.com
Mail: PanVanguard, 447 Broadway, 2nd Floor Suite #3182, New York, NY 10013, USA