THE BASICS 1. Definitions
We offer the Services on at least the websites ww.salespal.com
. 3. Questions & Concerns
If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please contact us at:
180, Strait Street Valletta,
Attn. Privacy Officer email@example.com YOUR INFORMATION 4. Are you a Customer, Customer Business Contact or Visitor?
This policy applies to the following classification of individuals that interact with FlippingBook Salespal:
5. Information We Collect
- Customers: Customers are individuals that are employees or associates of Salespal's direct customers, including customer personnel that are assigned a login ID and are authorized to access and use our Applications pursuant to an active Salespal agreement, or under a temporary evaluation license, if available. Additionally, Customers include individuals who self-register to access our Applications.
- Customer business contacts: Customer Business Contacts are individuals that interact with our Customers through our Applications. These include our Customers' current and prospective clients, members, attendees, sponsors, exhibitors, marketing partners, hotel guests or other business contacts. For example, Customer Business Contacts include individuals that register for an event organized by a Customer or Customer's stand visitors.
- Visitors: Individuals and prospective customers who interact with our Websites (for instance, to read about Salespal products and services, download a white paper, or sign up for an online demo) and whom we meet at a tradeshow or learn about through a referral from third parties or other external sources.
Our Applications are flexible and allow our Customers to collect a variety of personal data from and about their Customer Business Contacts, including name, organization, title, postal address, e-mail address, telephone number, fax number and other information including but not limited to dietary preferences, interests, opinions, activities, age, gender, education and occupation. Salespal's use of personal information collected through our Applications shall be limited to the purpose of providing the service for which our Customers have engaged Salespal, to improve our services, or as required or permitted by law.
If you do not agree with our policies and practices, you may choose not to use our Applications or not to agree to be registered in Application by our Customer.
c) Information from your use of the Service: We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. This type of information helps us to improve our Services for both you and for all of our users.
e) Cookies and tracking: Cookies are small data files that are placed on your computer or mobile device when you visit a Websites. Cookies are widely used by online service providers in order to (for example) make their websites or services work, or to work more efficiently, as well as to provide reporting information.
Cookies set by the website owner or service provider are called "first-party cookies". Cookies set by parties other than the website owner are called "third-party cookies". Third-party cookies enable third-party features or functionality to be provided on or through the website or service you are using (such as advertising, interactive content, and analytics). The third parties that set these third-party cookies can recognize your computer both when it visits the website or service in question and also when it visits certain other websites or services.
The specific types of first and third-party cookies served through our Websites and the purposes they perform are described in further detail below: Essential Website Cookies:
These cookies are strictly necessary to provide you with services available through our websites and to use some of its features, such as access to secure areas. Because these cookies are strictly necessary to deliver the websites, you cannot refuse them without impacting how our websites function. You can block or delete them by changing your browser settings, as described under the heading "You have the right to decide whether to accept or reject cookies:" below. Performance and Functionality Cookies:
These cookies are used to enhance the performance and functionality of our websites but are non-essential to their use. However, without these cookies, certain functionality may become unavailable. Analytics and Customization Cookies:
These cookies collect information that is used either in aggregate form to help us understand how our websites are being used or how effective our marketing campaigns are, or to help us customize our websites and application for you in order to enhance your experience. Advertising (Targeting) Cookies:
These cookies are used to make advertising messages more relevant to you and your interests. They also perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. Other tracking technologies:
We and our third-party partners may use other, similar technologies from time to time, like web beacons, pixels (or "clear gifs") and other tracking technologies. These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Websites or, in the case of web beacons, opened an email that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Websites to another, to deliver or communicate with cookies, to understand whether you have come to our Websites from an online advertisement displayed on a third-party website, to serve targeted advertisements to you and others like you, to improve site performance, and to measure the success of marketing campaigns. While you may not have the ability to specifically reject or disable these tracking technologies, in many instances, these technologies are reliant on cookies to function properly; accordingly, in those instances, declining cookies will impair the functioning of these technologies. Targeted online advertising:
We have engaged one or more third-party service providers to track and analyze both individualized usage and volume statistical information from interactions with our Websites. We also partner with one or more third parties (such as advertisers and ad networks) to manage and serve to advertise on other sites.
You have the right to decide whether to accept or reject cookies: Browser Controls:
Disabling Most Interest-Based Advertising: Most advertising networks offer you a way to opt out of Interest-Based Advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/
Mobile Advertising: You can opt out of having your mobile advertising identifiers used for certain types of Interest-Based Advertising, including those performed by us, by accessing the settings in your Apple or Android mobile device and following the most recent published instructions. If you opt out, we will remove all data about you and no further data collection or tracking will occur. The random ID we (or our third-party partners) had previously assigned to you will also be removed. This means that if at a later stage, you decide to opt-in, we will not be able to continue and track you using the same ID as before, and you will for all practical purposes be a new user to our system. Do Not Track:
Some Internet browsers — like Internet Explorer, Firefox, and Safari — include the ability to transmit "Do Not Track" or "DNT" signals. Since uniform standards for "DNT" signals have not been adopted, our Websites do not currently process or respond to "DNT" signals. Our company takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard. To learn more about "DNT", please visit All About Do Not Track
f) Web beacons: We use web beacons on our Websites and in our emails. When we send emails to Users, we may track behavior such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve our features for specific segments of Users. To do this, we include single-pixel gifs, also called web beacons, in emails we send. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details. We also include Web Beacons in the emails we deliver for you. We use the data from those Web Beacons to create reports about how our email campaign performed and what actions have you taken.
g) Information from other sources: From time to time we may obtain information about you from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include demographic information, device information (such as IP addresses), location, and online behavioral data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services. 6. How do our Customers collect personal data?
7. Use and Disclosure of Personal Information
- When Customer Business Contacts voluntarily and explicitly enter personal data into our Applications.
- When our Customers enter Customer Business Contacts into our Applications, when permitted, including by having a legitimate business interest or obtaining explicit consent from a Customer Business Contact.
- Automatically, as Customer Business Contacts interact with our Applications, using commonly used information gathering technologies such as cookies.
We may use and disclose Personal Information only for the following purposes:
a) To promote the use of our services to you and others. For example, if we collect your Personal Information when you visit our Website and do not sign up for any of the Services, we may send you an email inviting you to sign up. If you use any of our Services and we think you might benefit from using another Service we offer, we may send you an email about that. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send. In addition, we may use the information we collect in order to advertise our Services to you or suggest additional features of our Services that you might consider using. In addition, we may use your Personal Information to advertise our Services to potential or other users like you.
b) To send you informational and promotional content in accordance with your marketing preferences.You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.
c) To bill and collect money owed to us by our Users. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments. To learn more about the steps we take to safeguard that data, see Section 13 below.
e) To communicate with our Users about their account and provide customer support.
g) To protect the rights and safety of our Users and third parties, as well as our own.
h) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
i) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
j) To prosecute and defend a court, arbitration, or similar legal proceeding.
k) To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
l) To provide, support, and improve the Services we offer. This includes our use of the data that our Users provide us in order to enable our Users to use the Services. This also includes, for example, aggregating information from your use of the Services or visit our Websites and sharing this information with third parties to improve our Services. When we do have to share Personal Information with third parties, we take steps to protect your information by requiring these third parties to enter into a contract with us that requires them to use the Personal Information we transfer to them in a manner that is consistent with this policy.
As you use our Services, you may import into our system Personal Information you have collected from your Viewers or other individuals. We have no direct relationship with your viewers or any person other than you, and for that reason, you are responsible for making sure you have the appropriate permission for us to collect and process information about those individuals. As part of our Services, we may use and incorporate into features information you have provided, we have collected from you, or we have collected about viewers.
If you are a Customer Business Contact and no longer want to be contacted by one of our Customers, please contact the Customer directly to update or delete your data. If you contact us, we may remove or update your information within a reasonable time and after providing notice to the Customer of your request.
We will retain Personal Information we process on behalf of our Customer for as long as needed to provide our Services or to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements.
Customers will also have access to information (including personal data and Content usage data) related to how Customer Business Contact interact with the Content they use. In such instances, the Customers act as data controllers towards the Customer Business Contact, under the European Economic Area ("EEA") data protection laws. Therefore, Salespal cannot and does not take responsibility for the privacy practices of Customers.
The information practices of our Customers are governed by their privacy policies. We encourage Customer Business Contacts to review the Customers' privacy policies to understand their practices and procedures.
Salespal does not use personal data of our Customer Business Contacts for any purposes other than to provide services that our Customers have contracted us to provide through our Applications, as noted below, to improve our services, or as required or permitted by law. Cvent does not sell personal data of our Customer Business Contacts. 9. Data Collected from Viewers on behalf of Users
It is the User who chooses which Viewers to interact with through the Services. As a User, you are responsible for having the appropriate permission and consent for us to collect and process personal and/or anonymous usage information about Viewers. In this case Salespal is only processing the personal data for and on behalf of the Salespal User.
We may collect two types of data about the Viewers of Content: Collected Personal Information and anonymous usage information. Collected Personal Information
Collected Personal Information may include:
- Viewer's email address, first name, last name and is collected through lead collection form
- Viewer's interactions with content. For example, number of views, number of visitors, average time spent, number of links clicked.
As a User, you should know that your usage of Collected Personal Information is limited to:
- promoting the use of your services;
- sending informational message;
- providing customer support;
- providing, supporting, and improving the services you offer.
As a User, you may not use the Collected Personal Information for sending information that is not consistent with this policy, also sending messages in bulk and/or that are unauthorized, unexpected by recipients, including spamming. In case of transferring Collected Personal Information to third parties you as a User are responsible for making sure that their manner of use of Personal Information is consistent with this policy. Anonymous usage information
We collect anonymous usage information when Viewer reads the Content. As a part of our Services here is the anonymous usage information that we collect regarding Viewer's use of Content:
10. Public Information and Third-Party Websites
- Anonymized usage data: usage data about the Viewer whenever he/she interacts with our services. For example, number of views, number of visitors, average time spent, number of links clicked.
- Anonymized device and application data: data about the device and application the Viewer uses to access its services, such as, among others, browser type, and operating system. We may also collect the geographic location based on the Viewer's anonymized IP address and use IP address masking, a technique used to anonymize IP addresses collected by Google Analytics to prevent them from being traced back to individual users.
- Anonymized referral data: information about the source that referred the Viewer to Content(i.e. a link on a website or in an email).
a) Blog. We have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us. If we are unable to remove your information, we will tell you why.
b) Social media platforms and widgets. Our Websites include social media features. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We also maintain presences on social media platforms including Facebook, Twitter, and LinkedIn. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
We may disclose Personal Information to the following types of third parties for the purposes described in this policy:
a) Service Providers. Sometimes, we share your information with our third-party Service Providers, who help us provide and support our Services. For example, if it is necessary to provide you something you have requested (like enabling a feature), then we may share your and/or your Subscribers' Personal Information with a Service Provider for that purpose. Just like with the other third parties we work with, these third-party Service Providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this policy. Examples of Service Providers include payment processors, hosting services and content delivery services.
The GDPR requires all organisations that process personal data to have a "Lawful Basis" for doing so. The Lawful Bases on which we process your personal data are as follows:
Legitimate Interest: means the legitimate interest of us, and our customers, in our conducting and managing our business to enable us to give you the best service and the best and most secure Salespal experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at firstname.lastname@example.org
Performance of Contract: means processing your data where it is necessary for the performance of a contract between us and you or to take steps at your request before entering into such a contract.
Legal Obligation: means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent: your affirmative consent to particular instances of our processing personal data. 13. Contest and Promotions
We may, from time to time, offer surveys, contests or other promotions on our Websites or through social media (collectively "Our Promotions"). Participation in our Promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, username, and similar details. We use the information you provide to administer Our Promotions. We may also unless prohibited by the Promotion's rules or law, use the information provided to communicate with you, or other people you select, about our Services. We may share this information with our affiliates and other organizations or Service Providers in line with this policy and the rules posted for the Promotion. 14. User content
As you use our Services, you may upload Content into our system. You are responsible for making sure you have the appropriate permission for us to store and process information the Content you have imported. As part of our Services, we may use and incorporate into features information you have provided or we have collected from you.
You may not use the Service for uploading, sending, transferring, or otherwise publishing Content that is not specifically allowed for publishing, including bulk, unauthorized, and/or unexpected by recipients, unsolicited mail, including those with multiple duplications of one email address (spamming); creating conditions for illegal use of the Content by third parties;
As our User, you retain any and all rights to the Content while using the Service.
If a grounded claim is received from the respective copyright holder with regard to infringement of its lawful rights, Salespal is entitled to delete the Content placed by the User or block access to them without notifying the User or giving reasons.
The User assumes responsibility for any Content published by him/her. In case third parties assert a claim with respect to the Content placed by the User, the User shall settle such claims independently and at his/her own expense.
If the User distributes the results of using the Service he/she does it at his/her own risk. Salespal is not responsible for the actions of such individuals and cannot monitor their motives and goals. The Service provides only the technical possibility of presenting the results of the Service usage. Salespal has the right to discontinue providing the service to any person upon receiving from an interested person a reasonable claim fulfilling the requirements of current legislation. SECURITY 15. Notice of Breach of Security
If a security breach causes an unauthorized intrusion into our system that materially affects you then Salespal will notify you as soon as possible and later report the action we took in response. 16. Safeguarding Your Information
We take reasonable and appropriate measures to protect Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.
Our credit card processing vendor uses security measures to protect your information both during the transaction and after it is complete. Our vendor is certified as compliant with card association security initiatives. If you have any questions about the security of your Personal Information, you may contact us.
Salespal accounts require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Account passwords are encrypted, which means we cannot see your passwords. We cannot resend forgotten passwords either. We will only reset them. COMPLIANCE
17. Our servers operate in the United States
Our servers are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy. By using our Websites, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this policy. 18. Data Transfers from Switzerland or the EU to the United States
Salespal stores all the Personal Information using AWS servers. Amazon Inc. is certified under the EU-US Privacy Shield and as an AWS customer, we transfer personal data from the EU to the US in a compliant way. You can view Amazon Inc.'s certification here
. We are committed to subjecting all Personal Information received from European Union (EU) member countries in reliance on Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Frameworks visit the U.S. Department of Commerce's Privacy Shield website: https://www.privacyshield.gov/welcome
. A list of Privacy Shield participants is maintained by the Department of C6. Accuracy and Retention of Data
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. We will retain your information for as long as your account is active or as long as needed to provide you with our Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements. 19. Access
We will give an individual access to any Personal Information we hold about them within 30 days of any request for that information. Individuals may request to access, correct, amend or delete information we hold about them by contacting us. Unless it is prohibited by law, we will remove any Personal Information about an individual from our servers at your request. There is no charge for an individual to access or update their Personal Information. 20. Use by our customers
Under the General Data Protection Regulation
you have a number of important rights free of charge. In summary, those include rights to:
- access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address;
- require us to correct any mistakes in your information which we hold;
- require the erasure of personal information concerning you in certain situations;
- receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
- object at any time to processing of personal information concerning you for direct marketing;
- object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you;
- object in certain other situations to our continued processing of your personal information;
- otherwise restrict our processing of your personal information in certain circumstances.
If you would like to exercise any of those rights, please:
- email us at email@example.com,
- let us have enough information to identify you, and
- let us know the information to which your request relates, including any account or reference numbers, if you have them
If you would like to unsubscribe from any promotional material we send you, you can also click on the 'unsubscribe' button at the bottom of the email. 22. Do Not Track Disclosure
"Do Not Track" is a standard that is currently under development. Because it is not yet finalized, Salespal adheres to the standards in this policy and does not monitor or follow any Do Not Track browser requests. That said, some of our features may have the ability to monitor or follow Do Not Track browser requests.To get started using Salespal, you'll need to download it from App Store
, Google Play
, or reach admin panel of your company located on a subdomain of www.salespal.com