Organization Information:

Pluck Corporation
200 Academy Drive, Suite 120
Austin, Texas 78704
Phone: 512-457-5220
Fax: 512-457-5221
Contact Information:

Contact Office: Pluck Corporation
Phone: 512-457-5220 Fax: 512-457-5221 Email:

Corporate Officer Information:

Corporate Officer: Rachel Brush, VP, Operations & Content Services
Phone: 512-519-5202 Fax: 512-457-5221 Email:

Safe Harbor Information:

Signed up to safe harbor 02/29/2008 11:05:41 AM
Next certification 02/28/2010
EU/EEA Countries From Which Personal Information Is Received: Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, United Kingdom
Industry Sector: Computer Software - (CSF)
Personal Information Received From the EU: PRIVACY POLICY
Pluck is committed to protecting your privacy and respects the privacy of individuals who use Pluck's software and services. This Privacy Statement covers how Pluck treats personal information that is either collected or received. This includes, but is not limited to email addresses, phone numbers, names, addresses, age, gender, and interests.
Pluck's SiteLife product provides a white-label solution used by Pluck's customers ("Customers") to implement social networking communities. Each of Pluck's Customers determine how to provide the Pluck functionality to end-users. In this arrangement Pluck's Customers have final control on what information is collected and the end-user's ability to opt-out/opt-in of the information gathering process. When registering with one of Pluck's Customers' websites, some or all of the information gathered from end-users may be stored by Pluck. All information collected by Pluck Customers is governed by such Customer's privacy policy. Any information provided to Pluck by the Customer, or collected by Pluck as a result of Customer's configuration of the Pluck Services, will be governed by this Privacy Policy.
Because protecting your privacy is important to Pluck, we adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union ("EU") to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce ("Principles") with respect to all data that we receive, whether directly from the end user or from one of our Customers. If there is any conflict between the policies in this statement and the Principles, the Principles will govern. This statement outlines our general policy and practices for implementing the Principles, including the types of information we receive, how we use it, and the choices affected individuals have regarding our use of, and their ability to correct, that information.
This privacy statement applies to all personal information we receive (except as noted below). For purposes of this privacy statement, "personal information" means information that:
# is transferred from the EU to the United States;
# is recorded in any form;
# is about, or pertains to, a specific individual; and
# can be linked to that individual.
It does not include information that pertains to a specific individual, but from which that individual could not reasonably be identified.
Principles Protecting Individuals' Privacy
Notice and Choice
Because the Customer determines what personal information is collected, end users should review the Customer privacy policy to determine the types of personal information collected from them, the purposes for which such information is collected and used, and the types of non-agent third parties to whom the personal information is disclosed. The Customer should also be consulted regarding the choices and means, if any, offered to individuals for limiting the use or disclosure of their information. Customers' privacy policies will govern their collection and disclosure of any such information. Pluck stores all personal information solely for use by Customers and end users related to their use of Pluck services.
Disclosures and Transfers
Pluck will not disclose an individual's personal information to third parties, except when one or more of the following conditions is true:
# Our Customer that provided the information to us asks for us to transfer it back to them for whatever purpose the Customer chooses;
# We have the individual's permission to make the disclosure, whether such permission is made directly to Pluck or to our Customer;
# The disclosure is required by law or professional standards;
# The disclosure is reasonably related to the sale or disposition of all or part of our business;
# The information in question is publicly available;
# The disclosure is reasonably necessary for the establishment or defense of legal claims; or
# The disclosure is to another Pluck entity or to persons or entities providing services on our or the individual's behalf (each a "transferee"), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
- is subject to law providing an adequate level of privacy protection;
- has agreed in writing to provide an adequate level of privacy protection; or
- subscribes to the Principles.
Permitted transfers of information, either to third parties or within Pluck, include the transfer of data from one jurisdiction to another, including transfers to and from the United States of America. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated. Notwithstanding, Pluck may share aggregate data with 3rd parties per our agreement with the Pluck Customer. This information will not identify the related end-user.
Data Security
Pluck takes your security seriously and takes reasonable steps to protect your information. To prevent unauthorized access or disclosure, maintain data accuracy, and ensure the appropriate use and confidentiality of information, either for its own purposes or on behalf of our clients, Pluck has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we process. However, we cannot guarantee the security of information on or transmitted via the Internet or stored by our Customers.
Data Integrity
We process personal information only in ways compatible with the purpose for which it was collected or subsequently authorized by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.
Access and Correction
An end-users' ability to manage the data stored by Pluck is controlled by Pluck's Customers. However, if an individual becomes aware that information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may contact us using the contact information below and we will take reasonable steps to work with our Customer to correct the problem. The individual will need to provide sufficient identifying information, and we may request additional identifying information as a security precaution. In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the Safe Harbor Agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal information.
Enforcement and Dispute Resolution
Pluck utilizes the self-assessment approach to assure its compliance with our privacy statement. Pluck periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented, and in conformity with the Principles. We encourage interested persons to raise any concerns with us using the contact information below. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this policy.
If you would like to speak to someone at Pluck about your information, or if you have a concern about information we have collected or stored, please contact We will do our best to respond to you in a timely and professional manner to answer your questions and resolve your concerns.
In the unfortunate and unlikely event that we cannot resolve your concerns, we have contracted with BBBOnline as a dispute resolution provider. You can contact the BBBOnline at and follow their guidelines for initiating their dispute resolution procedures.
Privacy Statement Changes
This privacy statement may be changed from time to time, consistent with the requirements of the Safe Harbor. We will post any revised policy on this Web site, or a similar Web site that replaces this Web site.
Pluck reserves the right to modify all or some of this privacy statement at any time without notice.
Privacy Policy Effective: 02/11/2008
Regulated by: Federal Trade Commission
Privacy Programs: None
Verification: In-house
Dispute Resolution: We have signed up for the BBBOnline's Safe Harbor Privacy Dispute Resolution Procedure. Information is available at Because we have signed up recently, our name may not yet be listed on the Web site as a member.
Personal Data Covered: Online
Human Resource Data Covered: No

Do you agree to cooperate and comply with the European Data Protection Authorities? Select Appropriate Response

Certification Status: Current
Compliance Status:

Safe Harbor Overview | Safe Harbor Documents | Workbook | Safe Harbor List
Information Required for Certification | Certification Form