Platform Privacy Notice

Platform Privacy Notice

Effective Date: March 22, 2023

Contents

Scope
Personal Information We Collect
Why We Collect Your Personal Information
Sharing Personal Information
Third Party Services
Security of Personal Information
International Transfers of Personal Information
Accessing and Updating Personal Information
Retention of Personal Information
Children
Special Notice for Individuals in California
Special Notice for Individuals in the EEA, UK and Switzerland
Updates
How to Contact Us

1. Scope

Salesloft, Inc and its affiliate companies (“Salesloft,” “we,” “us,” or “our”) are committed to safeguarding the privacy of registered users of the Salesloft platform. This Notice informs you how Salesloft collects, uses, secures and shares your personal information when you use our platform and related services as a customer (“Services”).

If you do not feel comfortable with any part of this Notice, please immediately cease using our Service.

2. Personal Information We Collect

Personal information is generally any information that identifies you or makes you identifiable, such as your name, IP address or user preferences. We may collect from you, store and use the following personal information in relation to the Services:

a. Information You Voluntarily Provide. To register to use the Services or subscribe to our website services and/or email notifications, you or your account administrator for the Services must provide us with your first and last names and email address. In order to provide our Services, we are required to collect information about your transactions with us in relation to the Services, including information relating to any purchases you make of our goods or services. We may collect: first and last name, title, job position, employer, contact information (company, email, phone, physical business address), ID data, professional life data, personal life data. You may also provide additional information in the setup and ongoing use of the Services. We collect any information that you provide to us when you contact us for customer service, technical support, or for any other purposes.

b. Information We Automatically Collect.

(i) Log Data. When you use the Service, we automatically record information from your device, its software, and your activity using the Services (“Log Data”). This may include the device’s Internet Protocol (“IP”) address, browser type, the web page visited before you came to our website, information you search for on our website, locale preferences, identification numbers associated with your devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, metadata concerning your files, and other interactions with the Services. We may use your IP address to identify the general geographic area from which you are accessing the Services. While an IP address may reveal your ISP or geographic area, we cannot determine your identity solely based upon your IP address. If you use our Services to make calls or facilitate email engagement we may collect log information and data associated with your use of such features.

(ii) Location Data. We may collect geolocation and proximity of your device if location services are enabled on your device (e.g., GPS-based functionality on mobile devices used to access our website) and may use that information to customize the interactions with location-based information and features. If you access our website through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this.

(iii) Cookies and Other Tracking Technologies. We use cookies in the Services. A cookie is a text file sent by a web server to a web browser and stored by the browser. The text file is then sent back to the server each time the browser requests a page from the server. This enables the web server to identify and track the web browser. We may send one or more cookies which may be stored by your browser on your computer. The information we obtain from cookies is part of the personal information we collect. Our advertisers and service providers may also send you cookies. For more information about cookies and other tracking technologies we use, please see our Cookie Policy.

If you choose to limit our collection or use of your personal information or choose not to provide certain personal information, some or all of our Services and programs may not be available to you, and we may not be able to respond to your requests.

3. Why We Collect Your Personal Information

Personal information may be used for the following purposes:

a. To provide our Services to you. We process your personal information to provide you with the Services. We share this information with third parties upon your request, or our service providers or partners to the extent necessary to provide you with the Services. For instance, you or your employer may elect to connect a third-party email account to your Salesloft account. This allows you to compose and send email messages within the Services. We then import into the Services replies to such messages, and we employ a software technology called web beacons in our HTML-based emails to let you know which emails have been opened by a recipient. You also have the option to import and update events on your linked calendar. To the extent that you elect to connect the Services with a Gmail account, our use of personal information will be further limited as indicated in the “Additional Limits on Use of Your Google User Data” section of this Privacy Notice. Please note that we cannot provide you with Services without processing your personal information. [Performance of Contract, Legitimate Interest]

b. To administer and improve the Service’s usability, and provide you with important Services updates. When you sign up for our Service, we will send administrative or account-related information to you to keep you updated about our Service, inform you of relevant security issues or updates, or provide other transaction-related information. We process your contact information to send you such communications. Service-related communications are not promotional in nature. You are not able to unsubscribe from such communications, otherwise you may miss important developments relating to your account or the Services that could affect your use of the Services. [Performance of Contract, Legitimate Interest]

c. To personalize your experience on the Services. We process your personal information to improve your browsing experience via modification and replacement of text, images, videos, and links to increase relevance to the visitor. By personalizing the Service, you get to enjoy our Services even more because we keep track of your preferences (e.g., your language selection, your time zone, etc.). [Performance of Contract, Legitimate Interest, Consent]

d. To respond to your inquiries and provide customer service. We process your personal information when you contact us, such as with questions, concerns, feedback, disputes, issues or requests. [Performance of Contract, Legitimate Interest]

e. To enforce our terms, agreements or policies. We process your personal information to actively monitor, investigate, prevent and mitigate any alleged, suspected or actual prohibited use or illicit or illegal activities on our Service; investigate, prevent, or mitigate violations of our terms, agreements or policies; enforce our agreements with third parties and partners; and, as applicable, collect fees based on your use of our Services. [Performance of Contract, Legitimate Interest, Compliance with Legal Obligations]

f. To ensure the security of the Services. We are committed to ensuring our customers and your safety and continued enjoyment of our Services. To do so, we process your personal information to: combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and monitor and verify your identity so that unauthorized users do not access your account with us. [Performance of Contract, Legitimate Interest, Compliance with Legal Obligations]

g. To provide you with information about other services. We process your personal information to send you marketing and other communications relating to the Services, the sales industry, and our business or the businesses of carefully selected third parties which we think may be of interest to you by post, email, social media or similar technology. Where required by law, we will not send you promotional communications without first obtaining your consent. [Legitimate Interest, Consent]

h. To maintain the services and conduct research and development. We use your personal information to understand how our Services are being used and to ensure our services are reliable and working as intended, such as by tracking outages or troubleshooting issues that you report to us. Also, we collect information about the way you use and interact with our Services for research and development purposes. Research and development help us update and improve our Services and build new services and customized features. We may also provide other companies with statistical, de-identified information about our users. The information we provide to other companies will not identify any individual user. [Performance of Contract, Legitimate Interest, Consent]

If you choose to limit our collection or use of your personal information, some or all of our Services may not be available to you and we may not be able to respond to certain of your requests.

If, in the future, we use your personal information in a way that is not described in this Privacy Notice, we will provide notice. Notice may be provided in accordance with Section 13 (Updates).

4. Sharing Personal Information

We may share personal information about you as described below:

a. Service Providers, Business Partners and Others. We use trusted third-party companies to help us provide, analyze and improve the Services, including but not limited to providing data center hosting services, database hosting services, dialer infrastructure services, email sync services, and to enable our third-party processors to provide sales and marketing operations services. These third parties may have access to your personal information only for purposes of performing these tasks on our behalf.

b. Compliance with Laws and Law Enforcement Requests; Protection of Our Rights. We may disclose files stored in your Salesloft account and other information about you to third parties when we have a good faith belief that disclosure is reasonably necessary to: (i) comply with a law, regulation or legal requests including to meet national security or law enforcement requirements; (ii) protect the safety of any person from death or serious bodily injury; (iii) prevent fraud or abuse of Salesloft or its users, or (iv) protect Salesloft’s property rights.

c. Business Transfers. If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction, but we will notify you (for example, via email and/or a prominent notice on our website) of any change in control, or if you become subject to a different Notice.

d. Affiliates. We may share your personal information with our affiliates so that they can help provide or support our websites or services, service your account, or troubleshoot concerns or support other legitimate business operations.

5. Third Party Services

Our Services may contain links to other websites and third-party products, which you may elect to use at your sole discretion. We are not responsible for what the third parties and their services do with your personal information or the information that you choose to share with them. Your use of these third-party services will be subject to their respective terms of service and privacy policies.

You may ask us to collect information about you or about others from organizations. For example, you can ask us to import your contacts by giving us access to your third-party services (for example, your email account) or you can share your social networking information with us if you give us access via a social network connection service.

Additional Limits on Use of Your Google User Data

Notwithstanding anything to the contrary in this Notice, if you provide the Salesloft platform access to the following types of your Google user data, Gmail (read, write, modify, and control), the platform’s use of such data will be subject to these additional restrictions:

a. The platform will only use access to read, write, modify, or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a solution that allows your users of the platform to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide, support and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.

b. The platform will not use this Gmail data for serving advertisements.

c. The platform will not allow humans to read the data, unless: (1) we have your affirmative agreement to view specific messages, files, or other data; (2) doing so is necessary for security purposes such as investigating abuse; (3) it is necessary to comply with applicable law; or (4) the data is aggregated and used for the platform’s internal operations in accordance with applicable privacy and other jurisdictional legal requirements.

d. The platform’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

We may amend this section from time to time to comply with the “Google API Services User Data Policy,” to the extent it relates to our use of such Gmail data. For the avoidance of doubt, the additional restrictions contained in this section shall only apply to Gmail data received through the Google OAuth API, to the extent such use is applicable to you.

6. Security of Personal Information

We will take reasonable precautions to prevent the loss, misuse, or alteration of your personal information. Data transmission over the Internet is inherently insecure and we cannot guarantee the security of information sent over the Internet.

We will store all the personal information you provide or that we collect about you on our secure servers. You are responsible for keeping your passwords confidential. We will not ask you to disclose any of your passwords.

We have procedures in place to ensure we can react quickly to any reasonably foreseeable issue. If you ever find a security issue, or simply have a security related concern, please reach out directly to us by contacting Salesloft Support or sending an email to [email protected].

7. International Transfers of Personal Information

If you access or use our Services or provide your information to us, your personal information may be transferred to, processed, and maintained on servers or databases located outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use our Services.

8. If you are a citizen of, or reside in, the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to third counties. For more information, see Section 12 (Special Notice for Individuals in the EEA, UK, and Switzerland).

9. Accessing and Updating Personal Information

If you are a registered user, you may review, update, or correct the personal information provided in your registration or account profile. If your personal information changes you may update it by making the change on your account settings. Notwithstanding the foregoing, as a Service user, we depend on you to update and correct your personal information to the extent necessary for the purposes for which that data was collected, such as contact information you provide so that we can provide you support for the Services and administrative information, such as invoicing information.

In some cases, we may retain copies of your personal information if required by law. For questions about your personal information processing by our Services, please contact [email protected]. We will use responsible efforts to respond to your inquiry as soon as practicable. When updating your personal information, we may ask you to verify your identity before we can act on your requests.

10. Retention of Personal Information

We retain your personal information (i) until it is requested to be purged from our systems by an authorized member of your organization and/or (ii) for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements, or to resolve disputes. Consistent with these requirements, we will look to delete your information promptly upon request. Please note, however, that there might be latency in deleting information from our servers and backed-up versions might exist for a period after deletion. In addition, we may not delete information that you have in common with other users. While retention requirements can vary by country, we generally apply the retention periods noted below:

a. Interactions on Our Services. We may store any information about your interactions on our Services or any content created, posted, or shared by you on our Services (e.g., pictures, comments, support tickets, and other content) after the closure of your account as needed to continue to provide the Services to your employer, or for the establishment or defense of legal claims, audit, and crime-prevention purposes.

b. Web Behavior Data. We retain any information collected via cookies, clear gifs, flash cookies, web-page counters, and other technical or analytics tools for up to one year from expiry of the cookie or the date of collection. Please refer to our Cookie Policy for more information.

c. Telephone Records. As required by applicable law, we will inform you that a call will be recorded before doing so. Any telephone calls with you may be kept for a period of up to six years.

11. Children

Our Services are not directed to persons under 18, and we do not knowingly collect personal information from children under 18. Any individuals under the age of 18 must have consent from their parent or guardian to use the Services. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at [email protected]. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete such information from our files.

12. Special Notice for Individuals in California

This section applies only to California residents and the terms used have the same meaning as set out in the California Consumer Privacy Act of 2018 (“CCPA”) as amended by the California Privacy Rights Act 2020 (“CPRA”).

Personal Information Collected. Below is a summary of the personal information categories that we collected in the last 12 months, the reason we collect your personal information, where we obtain the personal information we collect about you, and the third parties with whom we share your personal information. For more information about the personal information we collect, please refer to Section 2 (Personal Information We Collect).

Identifiers: We may collect identifiers such as a name, address, unique personal identifiers, email, phone number, your device’s IP address, software, and identification numbers associated with your devices and other similar identifiers.
Commercial information: We may collect commercial information such as records of products or services purchased, obtained, or considered by you.
Internet or other electronic network activity information: We may collect information regarding your browsing history, search history, your interaction with our services, your interaction with an internet website, the web page visited before you came to our website, length of visit and number of page views, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information.
Geolocation data: We may collect information that is sufficient to identify your general location, such as your IP Address. For the avoidance of doubt this does not currently include precise geolocation data.
Sensory data, such as audio, electronic, visual, or other similar information: We may collect audio or video recordings when you elect to use certain Services features.
Inferences: We may collect information about your preferences, characteristics, behavior, and attitudes.
Professional/Employment-related information or Education information: We may collect professional or employment-related information or education information, such as your job title, professional affiliations, and employment history, but only to the extent voluntarily provided by you or made available to us by trusted third parties.
Sensitive Personal Information: When you log into or use our Services we may collect account log-in data in combination with a security or access code, password, or credentials to authenticate and enable access to your accounts. We collect such information directly from you through your interactions with our services or web pages and, in some cases, from third-party user identification or authentication services that you utilize. We do not sell or share (as such terms are defined by the CCPA) this information.

We collect the above information for the purposes described in Section 3 (Why We Collect Your Personal Information) as well as any other purposes separately notified to you.

Further, we share the personal information described above with the parties identified in Section 4 (Sharing Personal Information).

California Residents Rights. California residents have the following rights (“Rights”) listed below. Certain rights are not absolute, such as your right to know and right to deletion, and are subject to certain exceptions. For instance, we cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us, or the security of the business’s systems of networks.

Right to Know. You have the right to know what personal information about you we have collected, used, disclosed, sold, and shared, if applicable, during the preceding 12 months. You have the right to request in writing from us a copy of the categories of personal information we have collected about you, the categories of sources from which we collected that information, why we collected information about you, and the business or commercial purpose for selling, sharing, or disclosing your personal information (if applicable), the categories of third parties with whom we disclosed, sold, or shared your personal information, and the categories of personal information that we disclosed, sold, or shared about you for a business purpose. We are only required to respond twice per calendar year to your right-to-know requests.
Right to Deletion. You have the right to request that we delete any personal information we have collected from you or maintain about you. We honor such requests unless an exception applies, such as when the information is necessary to complete the transaction or contract for which it was collected or when information is being used to detect, prevent, or investigate security incidents, comply with laws or legal obligation, identify and repair bugs, or ensure another consumer’s ability to exercise their free speech rights or other rights provided by law.
Right to Opt-Out of the Sale of Your Personal Information. If a business sells your personal information, you have the right to opt-out. We will not sell any of your personal information unless we first notify you separately in writing. You may opt out of the sale of your personal information by utilizing the “do not sell or share my personal information” banner on our website.
Right to Information on Personal Data Sharing. You may have the right to request information from us regarding whether we share certain categories of your personal information with third parties for the third parties’ direct marketing purposes, including the categories of information we disclosed to third parties for the third parties’ direct marketing purposes during the preceding calendar year; the names and addresses of third parties that received such information, or if the nature of their business cannot be determined from the name, then examples of the products or services marketed. To the extent we participate in such sharing, you are entitled to receive a copy of this information in a standardized format and the information will not be specific to you individually.
Right to Opt-Out of the Sharing of Your Personal Information. You have the right to opt out of a business sharing your personal information with third parties. We may engage in “sharing” under the CCPA, which is broadly defined as disclosing personal information for purposes of cross-context behavioral advertising, including instances where companies target advertising based on personal information obtained from a consumer’s activity across distinctly branded websites or services. We share information as outlined in our Cookie Policy and Section 4 (Sharing Personal Information). You may opt out of the “sharing” of your personal information by utilizing the “do not sell or share my personal information” banner on our website.
Right to Correct Inaccurate Personal Information. You have the right to request that we correct inaccurate personal information. We will use commercially reasonable efforts to correct your personal information as directed by you, or provide you with instructions on how you can correct your information. In some instances, you may be able to correct your information via your Services account.
Right to Non-Discrimination. We will not discriminate against you for exercising your rights. Specifically, we will not deny you services, charge you different prices or rates for services, or provide you a different level or quality of services, because you elected to exercise your rights.
Right to limit the use of Sensitive Personal Information. The CCPA allows you to limit certain uses and disclosures of your sensitive personal information to certain purposes specified by law (e.g., providing you with services you request or preventing fraud, or for other purposes that don’t involve deriving your attributes). Because of our limited use of your sensitive personal data, we are not required to offer you this opt out right.

Exercising Your Rights. You may exercise your rights by contacting us as outlined in Section 13 (How to Contact Us). To verify your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity from this information, we may request additional information, which will only be used for the to verify your identity, and for security or fraud-prevention purposes. In some instances, we may seek for you to identify at least three pieces of your personal information maintained by the business and submit a signed declaration under penalty of perjury that you are a California consumer whose personal information is the subject of the request.

You may designate an authorized agent to make a request to exercise your rights outlined in this Notice. We will respond to your authorized agent’s request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to Probate Code section 4000 to 4465. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf.

In certain situations, You may have the right to appeal the denial your request to exercise your rights. Please submit an appeal using the contact information in Section 13 (How to Contact Us).

Do Not Track Disclosure. Salesloft does not have a mechanism in place for responding to browser “do not track” signals or other similar mechanisms used to limit collection of information for use in online behavioral advertising.

13. Special Notice for Individuals in the EEA, UK, and Switzerland

This section only applies to interactions with individuals who are citizens of, or at the time of data collection reside in, the EEA, UK, or Switzerland (collectively, the “Designated Countries”).

a. Role. Salesloft is a data controller with respect to any personal information collected from users of the Services. Any third parties that handle your personal information in accordance with our instructions are our service providers and are “data processors.” You are a “user.” Users are individuals providing personal information to us via the Services pursuant to a contract that has been entered into with Salesloft.

b. Marketing. We will only contact individuals located in the Designated Countries by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law, or the individual’s consent, as applicable. If you do not want us to use your personal information in this way please go to the email settings for your account to opt out, click an unsubscribe link in your emails, or contact us at [email protected] or via our Preference Center You can object to direct marketing at any time and free of charge.

c. Additional Privacy Rights. We provide you with the rights described below. We may limit these privacy rights requests (a) where denial of access is required or authorized by law, (b) when granting access would have a negative impact on others’ privacy, (c) to protect our rights and properties, or (d) where the request is frivolous or burdensome. If you would like to exercise your rights under applicable law, please contact us at [email protected]. We may seek to verify your identity when we receive your privacy rights request to ensure the security of your personal information.

Right to withdraw consent. For any consent-based processing of your personal information, you have the right to withdraw your consent. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.
Right of access/right of portability. You may have the right to access the personal information that we hold about you, and in some limited circumstances, have the personal information provided to you so that you can provide that personal information to another controller.
Right to rectification. You may request to correct any of your personal information in our files.
Right to erasure. In certain circumstances, you may have a right to the erasure of your personal information that we hold on you.
Right to restriction. You have the right to request that we restrict our processing of your personal information in certain circumstances.
Right to object to processing. You have the right to object to our processing of your personal information at any time and as permitted by applicable law if we process your personal information on the legal bases of: consent; contract; or legitimate interests. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
Notification to third parties. When we fulfill your individual rights requests for correction, erasure or restriction of processing, we will notify third parties also handling the relevant personal information unless this proves impossible or involves disproportionate effort.
Right to Lodge Complaint. We commit to resolve complaints about our collection or use of your personal information. EEA, UK, or Swiss individuals with inquiries or complaints regarding this privacy notice should first contact us at: [email protected]. You also have the right to lodge a complaint with the supervisory authority of your habitual residence, place of work or place of alleged infringement, if you consider that the processing of your personal information infringes applicable law.

d. International Transfers. In the delivery of the Services, we may need to transfer your personal information outside the Designated Countries, including to countries that do not provide the same level of protection for personal information. In such case, we will only transfer personal information to recipients that provide an adequate level of data protection or as permitted by applicable data-protection laws by implementing appropriate safeguards, including, but not limited to, relevant data-transfer agreements based on the EU Standard Contractual Clauses or UK Standard Contractual Clauses, as applicable (“Clauses”). The Clauses shall apply to any transfers of personal information from the Designated Countries to countries which do not ensure an adequate level of data protection within the meaning of the applicable law.

e. Legal Bases for Processing Personal Data. Our legal bases for collecting and using the personal information described above will depend on the type of personal information collected, the specific context in which we collect it and the purposes for which it is used. We rely on the following legal bases under the European Union’s General Data Protection Regulation (“GDPR”) (or the equivalent legal bases under the UK GDPR) in processing your personal information. Article 6(1) of the GDPR describes when processing can be done lawfully. When we process your personal information for a specified purpose, we shall apply one of the Article 6 legal bases described below.

Whenever we require your consent for the processing of your personal information such processing will be based on Article 6(1) lit. (a) GDPR.
If the processing of your personal information is necessary for the performance of a contract between you and Salesloft or for taking any pre-contractual steps upon your request, such processing will be based on Article 6(1) lit. (b) GDPR. If this data is not processed, Salesloft will not be able to execute the contract with you or provide you with access to the Services.
Where the processing is necessary for us to comply with a legal obligation, we will process your information on the basis of Article 6(1) lit. (c) GDPR, for example for complying with obligations under anti-money laundering laws.
Where the processing is necessary for the purposes of Salesloft’s or another party’s legitimate interests, such processing will be made in accordance with Article 6(1) lit. (f) GDPR, for example to enforce legal claims.

14. Updates

We may update this Platform Privacy Notice from time to time. If we make material changes to the way we collect, use, share or process the personal information that you provide, we will provide you with notice through our Services, or by other means permitted by law. We may also provide additional “just-in-time” disclosures or additional information about our data collection, processing, use and sharing practices of specific services. These notices may supplement or clarify Salesloft’s privacy practices or may provide you with additional choices about how Salesloft processes your personal information. We encourage you to periodically review this Privacy Notice so that you are always aware of how we process your personal information.

15. How to Contact Us

To exercise your rights, or if you have any questions about this Notice or our treatment of your personal information, please send us an email at [email protected] or by post to Salesloft, Inc., 1180 West Peachtree Street NW, Suite 2400, Atlanta, GA 30309 USA.