PRIVACY POLICY

Last Date Modified: May 8, 2024

1. Scope of this Privacy Policy
2. Personal Information
3. Personal Information That We Collect
4. Salutary Data’s Use of the Information That We Collect
5. Salutary Data’s Disclosure of the Information That We Collect
6. Children’s Privacy
7. How We Protect Information
8. Privacy Notice for California Residents
9. Changes to this Privacy Policy
10. Contact Us

1. SCOPE OF THIS PRIVACY POLICY

Salutary Data LLC (“Salutary Data”, us”, “we” or “our”) aggregates information about U.S.-based business professionals (“Professional Data”) that is then licensed to: (a) third party businesses for redistribution via their products and services and, (b) end user businesses for various purposes including sales and marketing, recruiting, or research and analysis (collectively our, “Customers”).

We are committed to protecting the privacy of the individuals about whom we collect Professional Data. This privacy policy (“Privacy Policy”) is designed to assist you in understanding how we collect, use, share, safeguard, retain and delete the Professional Data and, in particular, any Personal Information (defined below) that we collect through: (a) our corporate website (the “Website”); (b) operation of the platform that we make available to Customers (the “Platform”); (c) other direct interactions with individuals; (d) third party data sources; and (e) service providers.

2. PERSONAL INFORMATION

For purposes of this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable natural person. Personal Information includes information referred to as “personal data,” “personally identifiable information” and such similar references as codified in applicable data protection and privacy laws (collectively, “Privacy Laws.”)

Generally, the information that Salutary Data collects through its operations pertains to persons operating in their capacity as an owner or employee of a company or other type of organization. Additionally, much of the information that we collect is publicly available information from widely distributed media. Under most U.S. Privacy Laws, such information is not considered “Personal Information.” However, under California law some of the information Salutary Data collects and processes may be considered “Personal Information”.

If you are a resident of California, please read Section 8 below. Salutary Data does not knowingly process any Personal Information concerning individuals residing, outside the United States (“Non-U.S. Personal Data”). We request that our third party data sources withhold Non-U.S. Personal Data prior to providing any data to us. If we discover Non-U.S. Personal Data in our system, we delete it.

3. PERSONAL INFORMATION THAT WE COLLECT

As explained above, Salutary Data does not collect the type of data that most U.S. states define as Personal Information. We are a B2B company that aggregates and licenses data about individuals in their professional capacity. Currently, such Professional Data is only considered to be Personal Information in the State of California. If you are a California resident, after reading through the information below, please access the information in Section 8 to understand more about our information practices.

However, with respect to Professional Data, Salutary Data receives it in a number of ways: (1) from Customers in connection with the establishment of an account with Salutary Data and our interactions with such individuals, including through our Platform (“Platform Users”); (2) from visitors to our Website (in limited quantities); (3) from vendors and Customers and other individuals with whom we interact in person, over the telephone, via email and other means of communication, and; (4) from third-party data sources.

Information We Collect Through Our Platform:

When companies form a business relationship with Salutary Data, they can access the information that we license using our Platform. Platform Users leverage the Platform to run queries for business contacts utilizing different search variables such as: title, function, company size, location, company type and industry, and then generate a list of Professional Data regarding potential business prospects. When a user registers to use the Platform, they submit certain information to us such as the company they work for, their email address, title and selected password. This information is not shared with third parties (except our service providers) nor re-distributed.

Information We Collect Through Our Website:

Information that you directly provide: When you visit our Website, you may (but are not required to) submit certain information to us through our Contact forms or when you complete our “Do Not Sell My Personal Information” form. The information collected through such forms includes: name, email address, company name, title, phone, current employer name, and employer street address. There also exist text boxes that enable you to provide free-form text.

Information collected via cookies: When you visit our Website, including when using our Platform, our goal is to make the experience simple and effective. To that end, we use text files, known as cookies, to track information about your use of our Website/Platform. A cookie is a text file that a website stores on a visitor’s computer to enable recognition of that visitor’s computer each time they return. As you navigate through and interact with our Website/Platform, we will automatically collect certain information about your equipment, browsing actions and patterns using these cookies. This may include information about: (i) your IP address and browser information; (ii) the general location from which you access our Website/Platform, (iii) the pages you access on our Website/Platform and time you spend on our Website/Platform, and; (iv) how you reached our Website (e.g., web searches, directly using our website URL, or third party referrals or hyperlinks.)

Information We Collect Through Email, Snail Mail, Phone Calls and other Communications:

If you communicate with us by e-mail, mail, phone or otherwise, you may provide Salutary Data with information that identifies you, such as your name, your company name, your e-mail address, or telephone numbers. We use this information solely to communicate with you regarding your request. We do not share or re-distribute this information.

Information We Collect From Our Third-Party Data Sources

Salutary Data aggregates Professional Data that we license from third-party data sources. The third-party data sources typically collect this Professional Data from publicly available websites, business directories, government sources, social networks, court records, and other commercial sources. To the extent available, the Professional Data that we offer includes, but is not limited to:

1. first and last name
2. work email address
3. name of the company where a person works
4. the company’s address
5. job title and level
6. telephone number
7. revenue range of associated company
8. employee count of associated company
9. SIC code and description
10. NAIC code and description
11. LinkedIn profile page URL
12. Gender
13. Interests
14. Facebook URL

4. SALUTARY DATA’S USE OF THE INFORMATION THAT WE COLLECT

Information We Collect Through Our Platform:

Salutary Data uses the information we collect from our Platform Users in order to authenticate our Platform Users, to provide services to such Platform Users, to manage their account, and sometimes to communicate with Platform Users.

Information We Collect Through Our Website:

Information that you directly provide: Salutary Data uses the information that you provide through our webforms in order respond to your inquiry or request. We do not use the information for any other purposes. We do not sell, share or otherwise provide this information to anyone other than our own vendors in the context of their performing services for us.

Information collected via cookies: The information we collect via cookies helps us to improve our Website/Platform and deliver better and more personalized content and services, enables us to estimate our audience size and usage patterns and recognize when a specific device returns to our Website/Platform.

• Salutary Data’s Website uses Google Analytics. Google Analytics places cookies on your computer that generate specific information about you including the URL of the page you are visiting and your IP address. Google may also set cookies on your browser or read cookies that are already there. That information is transmitted to and stored by Google. Google uses the information shared to deliver their services, maintain and improve them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalize content and ads you see on Google and on their partners’ sites and apps. You can read more about this at https://policies.google.com/technologies/partner-sites and https://policies.google.com/privacy. You can opt out of Google Analytics’ collection and use of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.

Salutary Data uses the information collected through cookies to evaluate use of our Website/Platform, improve the functionality and useability of our Website/Platform and for similar operational purposes.

There are different types of cookies. Many cookies are “session cookies,” which means that they are automatically deleted at the end of each Website session. Other cookies are “persistent cookies,” which means that they can stay on your device for an extended period of time. You can manage cookies through your web browser. Different browsers provide different methods to block and delete cookies. You can change the settings of your browser to block/delete the cookies. Please note that disabling a cookie or category of cookies does not delete the cookie from your browser unless manually deleted through your browser function. Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers.

Google Chrome: https://support.google.com/accounts/answer/32050

Safari: https://support.apple.com/en-in/guide/safari/sfri11471/mac

Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox?redirectslug=delete-cookies-remove-info-websites-stored&redirectlocale=en-US

Internet Explorer: https://support.microsoft.com/en-us/topic/how-to-delete-cookie-files-in-internet-explorer-bca9446f-d873-78de-77ba-d42645fa52fc

Microsoft Edge: https://support.microsoft.com/en-us/windows/microsoft-edge-browsing-data-and-privacy-bb8174ba-9d73-dcf2-9b4a-c582b4e640dd

If you use any other web browser, please visit your browser’s official support documents.

If you disable a cookie that was previously placed on your device, we will cease collecting any further information during your user experience. However, the information collected prior to the preference change may still be used.

With respect to marketing cookies, when you opt out of tracking, a new cookie is placed on your device to prevent future tracking.

Disabling cookies may impact your ability to use certain features of the Website.

To learn more about the choices that advertisers generally provide individuals to influence how information is collected and used about their online activities over time and across third-party websites or online services, visit the Network Advertising Initiative at http://www.networkadvertising.org/managing/opt_out.asp and the Digital Advertising Alliance at http://www.aboutads.info/.

To find out more about cookies, including how to see what cookies have been set and how to block and delete cookies, please visit http://www.aboutcookies.org/.

Information We Collect Through Email, Snail Mail, Phone Calls and other Communications:

Salutary Data uses the information we collect through these methods of communication in order to provide services to those with whom we communicate, manage our Customer and vendor accounts, and respond to inquiries and requests.

Information We Collect From Our Third-Party Data Sources

We aggregate Professional Data obtained from our third-party data sources to build database(s) from which our Customers can license data to help them market their products and services to current or prospective commercial customers. In addition, we license Professional Data to other data aggregators who sublicense the data as part of their products and services to their end user customers for several purposes such as sales and marketing, recruiting, or research and analysis.

5. HOW SALUTARY DATA SHARES THE INFORMATION THAT WE COLLECT

As explained above, Salutary Data licenses the Professional Data that we collect to Customers (a) for redistribution via their products and services and, (b) for various purposes including sales and marketing, recruiting, or research and analysis. Some Customers license a subset of our Professional Data for redistributing programmatic and social advertising segments to end users via public data exchanges and similar marketplaces.

There are circumstances in which Salutary Data may disclose Professional Information to trusted entities in order to improve, protect and support our business. For instance, Salutary Data may disclose Personal Information: (i) to service providers (e.g., hosting providers, entities that verify accuracy and currency of our contact records, business advisors, auditors, etc.); (ii) to potential purchasers or investors in the business, and; (iii) if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with a legal obligation; (b) protect and defend our rights or property; or (c) protect the rights, property, or safety of our Customers, visitors to our Website, or the public. Salutary Data requires our Platform hosting developer and provider to process Personal Information strictly for Customer use of the Platform. We bind those service providers to whom we disclose Personal Information to contractual privacy and security obligations consistent with this Privacy Notice and applicable laws.

6. CHILDREN’S PRIVACY

Neither the Platform nor the Website is marketed to, and neither is intended for use by, children. In addition, the Professional Data that we procure does not contain personal information of children. Therefore, Salutary Data does not knowingly collect any Personal Information from children under the age of 17. If you know or believe that such information has been provided to us, please contact us at privacy@salutarydata.com. If we become aware that we have collected Personal Information about a child under the age of 17, we will delete it.

7. HOW WE PROTECT INFORMATION

We take reasonable administrative, technical, and physical measures designed to safeguard against unauthorized access to, loss alteration, disclosure or misuse of the information we collect. We update and assess our security controls on a regular basis. We also make our personnel aware of the importance of confidentiality, security and privacy and limit our personnels’ access to Personal Information to only those employees who require access based on their job duties. Electronic information, including the information about visitors to our Website and information submitted by our Customers through the Platform regarding their account and log-in information, is stored on systems of an enterprise third party cloud provider in the United States.

Unfortunately, no transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information, we cannot ensure or warrant the security of such information, and any such information provided by you or through your use of the Website or Platform is your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems.

8. CALIFORNIA RESIDENTS’ PRIVACY NOTICE

The California Consumer Privacy Act of 2018, as amended, (the “CCPA”) is a law that gives California residents (“Consumers”), the right to learn about and control certain aspects of how a business handles the Personal Information that the business collects about them.

IF YOU ARE A CALIFORNIA RESIDENT, PLEASE VISIT OUR PRIVACY RIGHTS ADDENDUM FOR CALIFORNIA RESIDENTS LOCATED AT THE END OF THIS PRIVACY POLICY (or by CLICKING HERE) TO LEARN ABOUT YOUR PRIVACY RIGHTS. You can also email us at privacy@salutarydata.com or call us at the following toll free number: 1-866-451-4868, to learn more.

9. CHANGES TO THIS PRIVACY POLICY

Over time, we may update this Privacy Policy to align with changes in the Website/Platform, our business and/or Privacy Laws. The “Last Date Modified” at the beginning of this Privacy Policy reflects the last date on which the Privacy Policy was updated. We recommend that you periodically review the Privacy Policy to stay informed of changes. We will ask for your consent to such changes if required by Privacy Law. In other cases, please note that your continued use of the Platform and your continued use of the Website after any change means that you agree to the terms of the updated Privacy Policy. If you disagree with the Privacy Policy, please stop using the Platform and Website.

10. CONTACT US

If you have any questions or concerns regarding our Privacy Policy or any questions about the security of our Website/Platform, you can contact us via email at privacy@salutarydata.com. You can also reach us at: 617-917-4084 or toll free at 1-866-451-4868.

SALUTARY DATA
PRIVACY RIGHTS ADDENDUM FOR CALIFORNIA RESIDENTS

Last Updated Date: May 8, 2024
The California Consumer Privacy Act of 2018, as amended, (the “CCPA”) is a law that gives California residents (“Consumers”) certain rights as it relates to the Personal Information that a business collects about them. Those rights include the following:

• • Right to Know Before Collection of Personal Information: At or before the point your Personal Information is collected, Salutary Data must inform you of the following:
    • The categories of Personal Information to be collected and the purposes for which they are collected or used;
    • The categories of Sensitive Personal Information to be collected and the purposes for which the information is collected and used;
    • Whether Personal Information and/or Sensitive Personal Information is sold or shared;
    • The length of time Salutary Data intends to retain each category of Personal Information (including Sensitive Personal Information) collected or, if that is not possible, the criteria used to determine that period.

Note that Salutary Data does not knowingly collect, sell or share the Personal Information of individuals under the age of 17.

• Right to Know What Personal Information Is Collected and Right to Access: California residents have the right to request from Salutary Data disclosure of the following information, up to twice in a twelve-month period:
  • • the categories and specific pieces of Personal Information that Salutary Data has collected about them;
    • the categories of sources from which that Personal Information is collected;
    • the business or commercial purpose for collecting, selling or sharing that Personal Information, and;
    • the categories of third parties to whom Salutary Data discloses Personal Information.

Before providing such information to you, Salutary Data must verify your identity. We will utilize the information that you submit with your request in order to do so and to locate any information that we maintain about you and for no other purpose.

• Right to Know About Personal Information Disclosed: California residents have the right to know the categories of Personal Information disclosed about them for a business purpose and the categories of persons to whom each category of Personal Information was disclosed. Before providing such information to you, Salutary Data must verify your identity.
• Right to Know About Personal Information Sold or Shared: California residents have the right to know the categories of Personal Information sold and/or shared about them, the categories of third parties to whom each category of Personal Information was sold and/or shared and the purpose for doing so. Before providing such information to you, Salutary Data must verify your identity.
• Right to Opt-out of the Sale or Sharing of Personal Information: California residents have the right to opt out of Salutary Data’s sale and/or sharing of their Personal Information to third parties at any time. Please review the Notice of Right to Opt Out of Sale/Sharing to learn more.
• Right to Request Deletion: California residents have the right to request, at any time, that Salutary Data delete any Personal Information that we collected directly from them. Salutary Data collects Personal Information directly from California residents as described in the Section titled “Personal Information that We Collect” above and as described further in the chart below. The obligation to delete Personal information upon request is not absolute. The CCPA allows businesses to retain Personal Information for certain purposes even when a deletion request is received. In addition, before deleting Personal Information in response to your request, we must verify your identity.
• Right to Correct Inaccurate Personal Information: California residents have the right to request, at any time, the correction of inaccurate Personal Information that Salutary Data maintains about them. Before correcting Personal Information in response to your request, we must verify your identity.
• Right to Limit Use and Disclosure of Sensitive Personal Information: California residents have the right, at any time, to direct companies to limit the use of their Sensitive Personal Information to that necessary to provide the services requested by such individual and to those purposes otherwise allowed by California law. Salutary Data does not collect Sensitive Personal Information.
• Right to Non-Discrimination: California law prohibits Salutary Data from discriminating or retaliating against a California resident based on such individual’s exercise of the privacy rights described herein. For example, Salutary Data cannot deny you services or provide a different level or quality of services to you as a result of your exercise of such rights.

Collection and Use of Personal Information About California Residents

The table below sets forth the categories of Personal Information Salutary Data has collected in the preceding twelve (12) months, the categories of the sources of such information and the purpose or use for which Salutary Data collects Personal Information.

California Data Subject Request Metrics

In the calendar year 2023, Salutary Data received 18,875 California Data Subject requests to delete, to know, to access, or opt-out of the sale or sharing.  The mean and median number of days that Salutary Data took to respond was 35 days.  Presently, Salutary Data rejects less than 40 deletion requests per year from qualified California data subjects where their record is not found in our database and more information was requested but the data subject chose to not respond further.

Personal Information Disclosed to Third Parties for a Business Purpose

There are certain circumstances in which Salutary Data may disclose Personal Information to trusted entities in order to improve, protect and support our business. For instance, Salutary Data may disclose Personal Information: (i) to service providers (e.g., hosting providers, entities that verify accuracy and currency of our contact records, business advisors, auditors, etc.); (ii) to potential purchasers or investors in the business, and; (iii) if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with a legal obligation; (b) protect and defend our rights or property; or (c) protect the rights, property, or safety of our Customers, visitors to our Website, or the public. Salutary Data requires our Platform hosting developer and provider to process Personal Information strictly for Customer use of the Platform and in accordance with our contract with such service provider. We bind those service providers to whom we disclose Personal Information to contractual privacy and security obligations consistent with this Privacy Notice and applicable laws.

During the preceding twelve (12) months, Salutary Data disclosed Personal Information for business purposes as described in the chart below. Salutary Data does not disclose Sensitive Personal Information.

Personal Information Sold to and/or Shared With Third Parties

As explained above, Salutary Data is a boutique aggregator of U.S. based business contact information that is licensed to Customers: (a) for redistribution via their products and services and, (b) for various purposes including sales and marketing, recruiting, or research and analysis. Some Customers license a subset of our Professional Data for redistributing programmatic and social advertising segments to end users via public data exchanges and similar marketplaces.

The chart below reflects: (i) the categories of Personal Information sold to and/or shared with third parties in the preceding twelve (12) months; (ii) the categories of third parties to which the Personal Information was sold/shared, and (iii) the purpose for sale/sharing.

Method to Submit Requests:
Requests to Delete, Correct and to Know

If you wish to exercise your right to delete, correct and / or know (as described above, you may do so by calling Salutary Data toll-free at 1-866-451-4868, or alternatively, via our website form. Finally, you can submit such requests to the following email address:

• Email address: privacy@salutarydata.com

If you submit your request by Email or snail mail, please provide your name, address, phone number and any other identifiers that you think will help us to verify you. Upon receipt of your request, Salutary Data will use the information you provide to verify your identity. Salutary Data may occasionally request additional information to assist in facilitating verification. Any Personal Information received by Salutary Data with respect to a request delete, to correct and / or to know will be held strictly in confidence, used only for the purposes of processing your request and in accordance with applicable data privacy laws and regulations.

We will confirm receipt of your request within 10 business days. We will then take steps to verify your identity. Within 45 calendar days of receiving your request, we will comply with your request unless there is a legal basis for denying your request. In the event we need additional time to respond, we will inform you within the initial 45-day period.

Right to Opt-Out of Sale of Your Personal Information

If you wish to exercise your right to opt-out of the sale of your Personal Information, please click here:
DO NOT SELL MY PERSONAL INFORMATION

How An Authorized Agent Can Make a Request for You:

California law allows you to designate an authorized agent to submit a request to delete, to correct or to know on your behalf. The agent may call Salutary Data toll-free at 1-866-451-4868. Alternatively, the agent may submit a request to the following email address:

• Email address: privacy@salutarydata.com

We will require the agent to provide proof that you gave the agent signed permission to submit the request on your behalf. We may also require the agent to verify their own identity. If you provided the agent with power of attorney pursuant to Probate Code section 4121 to 4130, evidence of that power of attorney is sufficient.

HOW LONG DO WE RETAIN PERSONAL INFORMATION?

Information about Platform Users: Salutary Data retains Personal Information collected from Platform Users as long as necessary to fulfill the purpose(s) for which it was collected, including legal, accounting, and reporting requirements or as otherwise set forth under applicable law.

Information about Website Visitors: Salutary Data retains Personal Information about those who visit the Website as long as necessary to fulfill the purpose(s) for which it was collected, including legal, accounting, and reporting requirements or as otherwise set forth under applicable law.

Information from Third Party Data Sources: Salutary Data retains Personal Information obtained from third party data sources for as long as permitted by contract and so long as such information is deemed reliable and of use to the markets we serve.

Other Information: Salutary Data retains other Personal Information as long as necessary to fulfill the purpose(s) for which it was collected, including legal, accounting, and reporting requirements or as otherwise set forth under applicable law.

QUESTIONS:

If you have any questions about California privacy rights, or any Salutary Data privacy practices, please reach out to us at privacy@salutarydata.com. You can also write to us at: Privacy Officer, Salutary Data, 29 Locust Ave., Lexington, MA 02421.