Consumer Data Policy

Last modified: 12/30/2019

Exit Row Solutions, Inc. Consumer Data Policy

The California Consumer Privacy Act (“CCPA”) provides consumers with specific rights regarding their Personal Information. You have the right to request that businesses subject to the CCPA disclose certain information to you about their collection and use of your Personal Information over the past 12 months. In addition, you have the right to ask such businesses to delete Personal Information collected from you, subject to certain exceptions. If the business sells Personal Information, you have a right to opt-out of that sale. Finally, a business cannot discriminate against you for exercising a CCPA right.

When offering services to its Customers, Pinwheel acts as a “service provider” under the CCPA and our receipt and collection of any consumer Personal Information is completed on behalf of our Customers in order for us to provide the Service. Please direct any requests for access or deletion of your Personal Information under the CCPA to our Data Privacy Office at

Consistent with California law, if you choose to exercise your applicable CCPA rights, we won’t charge you different prices or provide you a different quality of services. If we ever offer a financial incentive or product enhancement that is contingent upon you providing your Personal Information, we will not do so unless the benefits to you are reasonably related to the value of the Personal Information that you provide to us.

CCPA Specific Terms

  1. The definitions of: “controller” includes “Business”; "processor" includes “Service Provider”; “data subject” includes “Consumer”; “personal data” includes “Personal Information”; in each case as defined under CCPA.
  2. Pinwheel Services means the suite of services available for Pinwheel Customers to use, including without limitation, registration management, fundraising management, volunteer management, email marketing management, attendance app, and other related digital communications, analytics and tools made available through the Pinwheel platform, as may be further described on the Pinwheel website.
  3. Permitted Purposes shall include processing Customer Data only for the purposes described in this data privacy agreement and in accordance with Customer’s documented lawful instructions as set forth in this data privacy agreement, as necessary to comply with applicable law, as otherwise agreed in writing, or as otherwise may be permitted for “service providers” under the CCPA.
  4. All Pinwheel’s obligations regarding data subject requests apply to Consumer’s rights under the CCPA.
  5. Notwithstanding any use restriction contained elsewhere in Pinwheel’s Terms of Use and Privacy Policy, Pinwheel shall process Customer Data only to perform the Pinwheel Services, for the Permitted Purposes and/or in accordance with Customer’s documented lawful instructions, except where otherwise required by applicable law.
  6. Pinwheel may de-identify or aggregate Customer Data as part of performing the Service specified in the Agreement.
  7. Where Sub-processors process the personal data of Customer contacts, Pinwheel takes steps to ensure that such Sub-processors are Service Providers under the CCPA with whom Pinwheel has entered into a written contract that includes terms substantially similar to this data privacy agreement or are otherwise exempt from the CCPA’s definition of “sale”. Pinwheel conducts appropriate due diligence on its Sub-processors.

We have appointed a Data Privacy Officer, who may be contacted via the following email:


Any questions about this Data Policy should be addressed to or by mail at: Pinwheel, 56 Hanover Lane, Suite 100, Chico CA 95973 USA.