Pearingly Privacy - Data Policy

Last updated 8/20/25

I. Introduction

At Pearingly, data privacy is important to us. This Privacy Policy details our privacy practices for the activities described in this document. Please take the time to read this Privacy Policy carefully to understand how we collect, share, and otherwise process information related to individuals ("Personal Data"), and to learn about your rights and choices regarding our processing of your Personal Data.

In this Privacy Policy, "Pearingly," "we," "our," and "us" each mean Pearingly, LLC, a Ramberg Group company. Our website is located at pearingly.com.

II. Pearingly's Roles & Responsibilities

Pearingly is the controller of your Personal Data as described in this Privacy Policy. This means we determine the purposes and means of processing your data.

We act as a service provider or intermediary to connect small-to-medium businesses (SMBs) with managed service providers (MSPs). As part of this process, we collect information from both parties to facilitate a match. This Privacy Policy covers the data we collect and process as a controller. It does not apply to any data our clients (SMBs or MSPs) may collect or process on their own, even if a connection was made through our service. We are not responsible for the privacy or data security practices of our clients.

If your Personal Data has been submitted to us by or on behalf of an MSP, and you wish to exercise any rights you may have under applicable data protection laws, please inquire with the applicable MSP directly. If you wish to make your request directly to us, please provide the name of the MSP who submitted your Personal Data to us. We will refer your request to that MSP and support them as needed in responding to your request within a reasonable timeframe.

III. Personal Data We Collect and Data Sources

This Privacy Policy applies to the processing of Personal Data that we collect when you provide it to us, when you interact with our website, and when other sources provide it to us.

Based on our current practices, we collect the following categories of information:

• Contact and Professional Data: We collect contact and professional data when you communicate with us through our website. For example, when you use our contact form or sign up for a white paper, you provide your name, email address, phone number, and company name. This data may also include your job title and industry. We also may collect this data from other sources, such as by purchasing leads from business intelligence providers, to identify and communicate with potential clients.

• Audio, Electronic, or Visual Data: If you agree to a recorded telephone or video meeting with us, we may record the meeting. We may use this information for business purposes, such as quality assurance, and for marketing to better inform the public about our services and provide testimonials.

• Contract and Payment Data: We may receive contract details and use payment processing services for our MSP clients. This may contain Personal Data, such as billing name, billing address, and payment card details, in connection with our services.

• Device Data, Usage Data, and Metadata: Like most websites, we collect certain data when you access and use our site. This helps us understand how individuals use our website and allows us to improve our services, and detect and investigate fraud or malicious behavior. The data we collect can include:

  • Device Data: Information from and about your device, such as unique device identifiers, browser type, operating system, and certain device configurations.

  • Usage Data: Data about your use of our website, including logs of your usage and click activities, and login history.

  • Metadata: Technical data about your performance or use of our website. We use cookies and beacon technology to collect this data. We do not use these technologies to "sell" or "share" data for cross-context behavioral advertising.

IV. How We Use Personal Data

We use your Personal Data as is necessary to run our business and carry out our day-to-day activities.

• To communicate with you and facilitate interactions: We use your Personal Data, such as contact data and metadata, to respond to your inquiries, provide tailored communications based on your activity, and send transactional communications.

• For marketing our services: We use your Personal Data to send promotional communications that may be of specific interest to you and your organization. This includes sending emails about our services.

• To analyze, predict, and improve results and operations: We use Personal Data to analyze and predict results from our sales and marketing efforts, and to improve the performance and functionality of our website and customer support.

• For the purpose of processing payments: We process Personal Data to the extent necessary to complete transactions with our MSP clients.

• For security and to manage operations: We use Personal Data to verify accounts, monitor suspicious or fraudulent activity, and identify any misuse of our services. We also process Personal Data for security and operations management, such as to protect against misuse or abuse of our products and services.

• Other purposes with your consent: We may use your Personal Data if you have given us consent to do so for a specific purpose not listed above.

V. Personal Data Disclosed by Pearingly and Data You Choose to Disclose to Other Entities

We may disclose Personal Data as described below.

• Service Providers: We disclose Personal Data to our service providers for various business purposes, including but not limited to: auditing interactions with users, debugging our website, security purposes, payment processing, and other services on our behalf.

• Protection of Rights, Security, and Fraud Detection: We may disclose your Personal Data for business purposes to protect our customers and users, to secure our physical and intellectual property, and to prevent or investigate security or fraudulent attempts.

• Law Enforcement and Legal Requests: We may disclose Personal Data to comply with applicable law or to respond to valid legal requests, such as a subpoena, from law enforcement or other authorities.

• Related to Corporate Transactions: We may disclose your information as required for us to carry out a corporate transaction, such as a merger or sale of assets of all or part of our company.

• Sale of Personal Data: Our business model is a referral service. The "sale" of your contact information to an MSP is the core mechanism of how we provide our service and generate revenue. We will only "sell" your contact information to an MSP after a mutual agreement is reached to connect, and only if you subsequently sign a service contract with that MSP. We do not sell or share your data with any third-party advertising partners.

• Anonymous or De-identified Usage Data: We may disclose anonymized or aggregated usage data with third parties or the public. The data disclosed in this category is not Personal Data.

VI. Pearingly's Security Posture & Measures Taken

Security is a critical priority for Pearingly. We maintain a comprehensive information security program that contains industry-standard administrative, technical, and physical safeguards designed to prevent the loss or theft and unauthorized access, use, disclosure, or alteration of Personal Data.

However, no security system is perfect, and due to the inherent nature of the Internet, we cannot guarantee that data, including Personal Data, is absolutely safe from intrusion or other unauthorized access by others. You are responsible for protecting your password(s) and other authentication factors, as well as maintaining the security of your devices.

VII. International Data Transfers

We only operate in the United States. Therefore, all of your Personal Data will be collected, transferred to, processed, and stored by us only in the United States.

VIII. Children

Pearingly's website and services are not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe that your child has provided us with Personal Data without your consent, please contact us using the information in the "How to Contact Pearingly" section, and we will take steps to delete such Personal Data from our systems.

IX. How Long Does Pearingly Keep Your Data?

We will retain your Personal Data for a period of time that is consistent with the original purpose of the data collection, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We determine the appropriate retention period by considering the amount, nature, and sensitivity of the Personal Data processed, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements.

X. Your Information Choices

We describe how you may unsubscribe, opt out, or otherwise modify settings related to our processing of your Personal Data below.

• Direct Email Marketing: If you wish to withdraw from direct email marketing communications from Pearingly, you may click the "unsubscribe" button included in our emails. Please note that you cannot unsubscribe from critical transactional emails related to our service.

• Cookie Preferences: You may adjust your web browser settings to opt-out of non-essential cookies. Please understand that blocking or deleting non-essential cookies may affect our website's functionality.

• Right to Opt-Out of the Sale of Personal Data: Residents of California, Virginia, Colorado, Connecticut, Utah, Delaware, Iowa, Indiana, Tennessee, Texas, Oregon, and other states with similar privacy laws, have the right to opt out of the "sale" of their personal information. As our business model is a referral service, we "sell" your contact information to an MSP after a contract is signed. By using our service, you are opting in to this business model. However, you can exercise your right to opt out by sending an email to privacy@pearingly.com. Please note that if you opt out of this "sale," we will be unable to provide our service to you.

• Your Privacy Rights: Depending on your jurisdiction, you may have certain rights with respect to your Personal Data that we process in our capacity as a data controller. If you would like to make a request to exercise your rights, please use our online form or contact us at privacy@pearingly.com.

XI. Changes to the Policy

This Privacy Policy may be updated from time to time to reflect changes in our practices, technologies, additional factors, and to be consistent with applicable data protection and privacy laws and principles, and other legal requirements. If we do make updates, we will update the "effective date" at the top of this Privacy Policy. If we make a materially significant update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you using the email address you provided.

XII. How to Contact Pearingly

If you would like to contact us with questions or concerns about our privacy policies and practices, you may contact us via our online form or by emailing us at: privacy@pearingly.com.