SALUTARY DATA LLC.
- What Personal Information We Collect
- How We Use Your Personal Information
- How We Share Your Personal Information
- How We Protect Your Personal Information
- California Resident’s Privacy Rights
- Our Policy Regarding European Data Subject Information
- Contact Us
2. WHAT PERSONAL INFORMATION WE COLLECT
Information We Collect Through Our Site
Personal information means information that can be used to identify and contact you. You do not need to submit personal information to access our Site. If you access our Site, and if you choose to communicate with us by e-mail or otherwise complete an online form, you may provide us with information that personally identifies you, such as your name, your company, your work or personal e-mail address, or personal and/or business telephone numbers, which may be retained and used by us. You may choose not to provide us with any Personal Information. You may still use the Site to browse information about us and our services.
Information We Collect From Our Licensors
Salutary Data aggregates Personal Information licensed from third party data providers. This information is the type of information often found on a business card and includes:
- first and last name
- work email address
- name of the company/organization where a person works
- the company’s address
- a person’s work title
- a person’s work telephone number
- a person’s LinkedIn profile page URL
We license Professional Data from third party data providers who generally collect the information from publicly available websites, business directories, government sources, social networks, court records, and other commercial sources.
3. HOW WE USE PERSONAL INFORMATION
We use information that we collect about you when you interact with our Site in two ways. If you contact us through a contact form on the Site or via email, we may receive your email address, your name, the name of the company where you work, and perhaps your telephone phone number. We only use this information in order respond back to you regarding your email inquiry. We do not sell or provide this information you share with us.
The other information collected from your use of our Site is Traffic Data (as identified in Section 2 above). Traffic Data from our Site may be used by us and Google Analytics. Such analytics tools use information generated by cookies from your use of the Site, which is available and accessed by Google Analytics. This information is then used to evaluate users’ use of the Site and to compile statistical reports on our Site activity. As received by us, this data is anonymous, not personally identifiable, and not specific to any person. The Traffic Data might not be completely anonymous to Google Analytics. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. 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.
We share certain fields of Professional Data with our service providers who help us assess and verify the currency and accuracy of the data provided by our third party data providers; such fields of Professional Data include email addresses, telephone numbers, and whether a person is still working at a particular company.
We also license Professional Data directly to third parties to help them market their products and services to current or prospective customers. In addition, we license Professional Data through third parties, who incorporate the data as part of their products and services, which are then sub-licensed to their customers for their customers’ sales and marketing purposes.
Do Not Track
In compliance with California legislation, AB370, effective January 1, 2014, our practices in responding to “do not track” signals and collecting user information over time and across a network of websites when you visit the Site are as follows: we do not honor the request of “do not track” signals sent by your browser when you visit the Site. Additionally, we may collect user information about your online activities over time and across different websites, or authorize third parties to do so.
Many cookies are “session cookies” which means that they are automatically deleted at the end of each session, but some cookies are “persistent cookies” which means that they can stay on your device for an extended period of time. Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie, giving you a chance to decide whether or not to accept it. You can also use your browser to delete cookies.
We do not knowingly collect personal information from children under 16. We take children’s privacy seriously, and encourage parents to play an active role in their children’s online experience at all times.
4. OTHER WAYS WE MAY SHARE PERSONAL INFORMATION
Notwithstanding any of the foregoing, we may transfer, sell or assign your personal information to third parties, as a result of the sale, merger, consolidation, change in control, transfer of substantial assets, or reorganization or liquidation of us.
Additional Information You Should Know About Third Parties
5. HOW WE PROTECT PERSONAL INFORMATION
We take reasonable administrative, technical, and physical measures to safeguard against loss, unauthorized access, alteration or disclosure, and misuse of the Personal Information we collect.
Unfortunately, no data 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 Personal Information, we cannot ensure or warrant the security of such Personal Information, and any such Personal Information provided by you or through your use of the Site is your own risk. Once we receive your transmission, we make reasonable efforts to ensure security on our systems.
In the event that there is ever a breach of security regarding your Personal Information, we intend to comply with applicable laws regarding the same, including notification and disclosure to you and to the appropriate authorities of the circumstances surrounding the breach as may be required. We take appropriate measures to delete Personal Information when deletion is necessary or we no longer maintain the Personal Information.
6. CALIFORNIA RESIDENTS’ PRIVACY RIGHTS
The California Consumer Privacy Act of 2018 (the “CCPA”) is a California law that gives California residents (“consumers”), the right to learn about and control certain aspects of how a business handles the personal information that a business collects about them. Pursuant to the CCPA, effective January 1, 2020, consumers whose personal information have been collected by us, have additional rights.
7. Our Policy Regarding European Data Subject Information
Salutary Data does not direct any activity towards or knowingly process any personal data concerning individuals located within the European Union or European Economic Area (“EU Personal Data”). We request our third-party data providers to purge EU Personal Data prior to providing any data to us. If we discover EU Personal Data in our production database(s) for which we have no permission to use, we will delete it.
8. CONTACT US
CALIFORNIA RESIDENTS’ PRIVACY RIGHTS ADDENDUM
Effective: January 1, 2020
The California Consumer Privacy Act of 2018 (the “CCPA”) is a California law that gives California residents (“consumers”), the right to learn about and control certain aspects of how a business handles the personal information that a business collects about them. For purposes of this Addendum, Salutary Data is referred to as “we” or “our” or “us”. Pursuant to the CCPA, effective January 1, 2020, consumers have certain rights, including:
- The right to know the categories of personal information we’ve collected and the categories of sources from which we got the information;
- The right to know the business purposes for sharing personal information;
- The right to know the categories of third parties with whom we’ve shared personal information;
- The right to access the specific pieces of personal information we’ve collected;
- The right to delete your information;
- The right to opt-out of the sale of your information.
- California residents also have the right to not be discriminated against if they choose to exercise their privacy rights.
YOUR PERSONAL INFORMATION UNDER THE CCPA:
|CATEGORIES OF PERSONAL INFORMATION UNDER THE CCPA||WHAT WE COLLECT AND/OR SELL||WHY WE COLLECT THAT INFORMATION|
|Identifiers||We may collect and sell your:
– Work Email address
We may collect, but do not sell your:
– IP address
|We collect this information in order to provide our products to customers who may market to you or to respond to your inquiries via our website.|
|Personal information described in California Civil Code section 1798.80||We may collect and sell your:
– Work phone number
|We collect this information in order to provide our products to customers who may market to you.|
|Protected classifications under California or federal law||Age and Gender – We do not collect this information.||Not applicable.|
|Commercial information||We do not collect this information.||Not applicable.|
|Biometric information||We do not collect this information.||Not applicable.|
|Internet or other electronic network activity information||We may collect, but do not sell your:
– Browser type
– Device type
– Domain names
– Access time/logs
|This information is collected through Google Analytics in order to understand which pages visitors use the most and to optimize our website.|
|Geolocation data||We may collect this information through our use of Google Analytics.||We collect this information to understand the approximate country and/or region or state of visitors to our Site.|
|Audio, electronic, visual, thermal, olfactory, or similar information||We do not collect this information.||Not applicable.|
|Professional or employment-related information||We may collect and sell your:
– Job title
– Company name and address
– Work email address
– Work phone number
– LinkedIn profile address
|We collect this data for use in our products to customers who may market to you.|
|Education information||We do not collect this information.||Not applicable.|
|Inferences drawn from any of the above to create a profile about a consumer||We do not collect this information.||Not applicable.|
YOUR RIGHTS UNDER THE CCPA:
Right to Opt-Out of Sale of Your Personal Information
Consumers have the right to request that a business that sells the Consumer’s personal information, or that discloses it for a business purpose, inform the Consumer of what has been collected about them and who it has been sold or disclosed to. Consumers also have the right, at any time, to direct a business that sells personal information about them not to sell their personal information.
- To exercise your right to opt-out of the sale of personal information, please click here:
DO NOT SELL MY PERSONAL INFORMATION
Right to Access / Data Portability
Consumers have the right to request that a business that collects personal information about them disclose the following: (1) The categories of personal information it has collected about that consumer; (2) The categories of sources from which the personal information is collected; (3) The business or commercial purpose for collecting, disclosing or selling personal information; (4) The categories of third parties with whom the business shares personal information; (5) The specific pieces of personal information it has collected about that consumer. Our disclosure will cover a 12-month period preceding the date of your request.
- To exercise your right to access, please submit a Verifiable Consumer Request by sending an email to firstname.lastname@example.org. Please include “Request for Access” in the subject line.
- We will reach out within 10 days to confirm that we have received your request.
- We will then take steps to determine whether your request is a valid Verifiable Consumer Request. If you have an account, we may ask you to log in to confirm this information. We will not ask you to create an account if you do not already have one. We will only ask for information that is reasonable in light of the nature of your request.
- Within 45 days, we will provide you with a copy of the information listed in “Right to Access / Data Portability,” above, by mail or electronically. To the extent possible, this information shall be provided in a portable and useable format.
- In the event we need additional time, we will inform you within the initial 45-day period of our need for an additional 45 days (for a maximum of 90 days between request and provision of information).
- We are not required to provide personal information to a Consumer more than twice in a 12-month period.
Right to Deletion
Consumers have the right to request that a business delete any personal information about them. However, there are exceptions to this rule. For example, a business does not have to delete information if it is necessary to: a) complete a transaction; b) prevent illegal activity; c) exercise free speech; d) comply with a legal obligation; e) identify or repair errors that impair functionality; or f) otherwise use a Consumer’s personal information, internally, that is compatible with the context in which the Consumer provided that information.
- To exercise your right to deletion, please submit a Verifiable Consumer Request by sending an email to email@example.com. Please include “Request for Deletion” in the subject line.
- We will reach out within 10 days to confirm that we have received your request.
- We will then take steps to determine whether your request is a valid Verifiable Consumer Request. If you have an account, we may ask you to login to confirm this information. We will not ask you to create an account if you do not already have one. We will only ask for information that is reasonable in light of the nature of your request.
- We have created a two-step process for responding to requests for deletion. After you submit the initial request, we will ask that you separately confirm that you would like your information deleted.
- If your request does not fall within one of the exceptions to deletion listed in “Right to Deletion,” above, we will confirm deletion within 45 days. If we are not required to delete your account, we also let you know within 45 days.
Right to Non-Discrimination
A business cannot discriminate against a Consumer because the Consumer exercised any of the Consumer’s rights listed above.
If you have any questions about this California Privacy Rights, or any Salutary Data privacy practices, please reach out to us at firstname.lastname@example.org. You can also write to us at: Privacy Officer, Salutary Data, 29 Locust Ave., Lexington, MA 02421.