SALUTARY DATA LLC.

PRIVACY POLICY

  1. Scope of this Privacy Policy
  2. What Personal Information We Collect
  3. How We Use Your Personal Information
  4. How We Share Your Personal Information
  5. How We Protect Your Personal Information
  6. California Resident’s Privacy Rights
  7. Our Policy Regarding European Data Subject Information
  8. Changes to this Privacy Policy
  9. Contact Us

1. SCOPE OF THIS PRIVACY POLICY

SALUTARY DATA LLC. (“Salutary Data”, us”, “we” or “our”) is committed to protecting the privacy of the individuals about whom we collect personal information (“user”, “you” or “your”). This privacy policy (“Privacy Policy”) is designed to assist you in understanding how we collect, use, share, safeguard, retain and delete any information you may provide us or that we collect from or about you through our website (the “Site”) as well as in connection information we receive from third party providers that we use as part of our data products that we license to third parties as discussed in this Privacy Policy.

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.

Personal Information that we may obtain from Google Analytics from your use of our Site may also include various aggregated and non-personally identifiable information including any of the following: (i) the number of unique and/or active users on our Site, (ii) the country where our Site visitors browse our website from, (iii) access times, times spent, and Site pages visited, (iv) the device type – desktop or mobile – of visitors to our Site (v) browser types, (vi) how Site visitors are acquired in terms of organic web searches, directly using our website URL, or third party referrals or hyperlinks; (vii) certain demographic information such as age range and gender. The information listed in the foregoing sub-items (i) thru (vii) are collectively referred to in this Privacy Policy as “Traffic Data”. Please refer to the discussion elsewhere in this Privacy Policy for further information on the use of cookies in terms of how Traffic Data is collected and obtained. This information may be aggregated to measure the number of visits, average time spent, page views, and other statistics about users. We also may use this data to monitor the Site’s performance and to make the Site easier and more convenient to use. While Google Analytics might collect online identifiers such as IP addresses, we do not receive such identifiers from Google Analytics.

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:

  1. first and last name
  2. work email address
  3. name of the company/organization where a person works
  4. the company’s address
  5. a person’s work title
  6. a person’s work telephone number
  7. a person’s LinkedIn profile page URL

Any of the above licensed information that also constitutes Personal Information is referred to in this Privacy Policy as “Professional Data”.

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.

Cookies

“Cookies” are small bits of electronic information that a website sends to a visitor’s browser and are stored on the visitor’s hard drive. Like many websites, we employ cookies in certain areas of the Site to allow us operate the site properly and to provide information to make your online experience more convenient. For example, when you return to the Site after logging in, cookies provide information to the Site so that the Site will remember who you are on subsequent visits, speeding up or enhancing your experience of the Site. While we may use cookies to track your visit to the Site, this information does not identify you personally and you remain anonymous.

Third parties whose websites are accessible through links on the Site may also use their own cookies when you link to their site or service. We do not control these third parties’ use of cookies and cannot guarantee that they will uphold the same privacy standards that we do. We expressly disclaim any and all liability related to the collection, use or disclosure of information by third parties. You should review the privacy policies of any third-party sites that you visit through a link from the Site to understand how these third parties use cookies and the information they collect through cookies.

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.

Children’s Privacy

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

Except as otherwise provided in this Privacy Policy, or any agreements you enter into with us, we will use reasonable measures to keep your Personal Information private and, except as authorized by applicable law, will not share it with third parties, unless such disclosure is necessary to: (a) comply with applicable laws, regulations, rules and the like, or legal process served on us; (b) provide our products and services; (c) protect our rights and/or property; (d) enforce our rights; (e) protect the interests of other users of the Site or any other person; (f) operate or conduct maintenance and repair of our equipment or Site; (g) detect, prevent and/or otherwise address fraud, security or technical issues; (h) verify that you are who you say you are.

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

The Site may contain direct links to websites operated by third parties. These third-party websites may collect information about you when you visit them or otherwise communicate with them. This Privacy Policy does not cover the information practices of third-party websites linked to the Site. We are not responsible for their collection and use of your personal information. You should refer to the privacy policies and statements of other websites or contact the respective webmasters of those websites to obtain information regarding their information collection, use and disclosure policies.

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.

To learn more about these rights, your personal information under the CCPA, or to exercise your rights, please go to our California Residents’ Privacy Rights Addendum located at the end of this Privacy Policy, which you can also access by clicking here. You can also email us at privacy@salutarydata.com or call us at the following toll free number: 1-866-451-4868.

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. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email.

8. CONTACT US

If you have any questions or concerns regarding our Privacy Policy or any questions about the security at our Site, 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.

This Privacy Policy is effective as of January 1, 2020.

SALUTARY DATA
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:
– Name
– 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:
– Name
– 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 We may collect, but do not sell your:
– Age range
– Gender
We collect this information through Google Analytics to understand our Site visitors.
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.


To learn more about the sources from which this personal information is collected, please refer to Section 2 of our Privacy Policy above, or by clicking here.

To learn more about why this personal information is collected and whom we share this personal information with, please refer to Sections 3 and 4 of our Privacy Policy above, or by clicking here.

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.

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 privacy@salutarydata.com. 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 privacy@salutarydata.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.

QUESTIONS:

If you have any questions about this 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.