Welcome to www.adaptivinsights.com (“Site”), a website owned and operated by Adaptiv Insights Corp, (“Adaptiv,” “we,” “us” or “our”). This Privacy Policy, explains how we collect, use, share and protect personal information processed in relation to the Site and the services that we offer (“Services”) (collectively, “Platform”) and other interactions (e.g., customer service inquiries, live chat, social media etc.) that you may have with Adaptiv. It also tells you about your choices with respect to our collection, use and disclosure use of your personal information.

We recommend that you read this Privacy Policy carefully as it provides important information about your personal information and your rights under the law.

IF YOU ARE AN INDIVIDUAL LOCATED IN THE EEA OR THE U.K.: If you are located in the European Economic Area (“EEA”) or the United Kingdom (“U.K.”), this entire Privacy Policy applies to you. However, please see the section titled Additional Information for Users in the EEA and the U.K., which provides more information about which rights you have regarding the processing of your personal data.

IF YOU ARE CALIFORNIA RESIDENT: If you are a resident of California, this entire Privacy Notice applies to you. However, please see the section titled Additional Information for California Residents below, which will inform you in detail about our information collection practices and your specific rights.

If you have any questions, comments, or concerns regarding this Privacy Policy, our Cookie Notice and/or our data practices, or would like to exercise your rights, do not hesitate to contact us at privacy@adaptivinsights.com or see our information below.

Who We Are and How to Contact Us

Adaptiv Insights is a California C-Corporation with the following contact information:

31562 Shoregrass Lane

Murrieta, CA 92563

United States

(949) 424-9443

privacy@adaptivinsights.com

Changes to This Privacy Policy

This Privacy Policy was last updated on the date indicated above. Our business and/or the Platform may change from time to time, and as a result, at times it may be necessary for Adaptiv to make changes to this Privacy Policy. Adaptiv reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. However, if we make changes that we believe will materially impact this Privacy Policy or your rights, we will promptly notify you of those changes. We encourage you to review this Privacy Policy from time to time. Your continued use of the Platform after any changes or revisions to this Privacy Policy will indicate your agreement to the terms of any such revised Privacy Policy.

Children’s Privacy

Adaptiv does not knowingly collect information from children under the age of 16. If you are under the age of 16, please do not submit any personal data through the Platform. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal data on our Platform without their permission.

If you have reason to believe that a child under the age of 16 has provided personal data to Adaptiv through the Platform, please contact privacy@adaptivinsights.com and we will endeavor to delete that information from our databases.

To Whom Does This Policy Apply

Throughout this Privacy Policy, “personal information” (or “personal data” as used interchangeably) refers to any information that is unique to an individual, such as name, address, email address, phone number, IP address and other information that can reasonably identify an individual. This Privacy Policy applies to personal information (that we collect, store, disclose or otherwise process) from or about:

• Site Visitors – this includes visitors to our Site, including those who do not register for our Services.
• Customers – this includes any individual who registers individually or on behalf of an entity or organization in order to use the Services, whether as part of a free trial or paid subscription.
• Business Profiles – our business is to help people connect professionally, and for this we collect and compile business information about individuals and their companies. As such, we store and process personal information to create Business Profiles of individuals as part of our Services. Please see below for more information on how this information is collected.

Personal Information That We Collect

What personal information we collect and process depends on a number of factors. As explain in more detail below, we process personal information that we receive directly from you when you provide it to us, such as when you sign up for our Services, or indirectly, such as through automated technologies (e.g., cookies) or from third parties. We also collect information for Business Profiles in a variety of ways as explained below.

Information We Collect Directly From You

You can generally visit our Site without having to submit any personal information. However, if you wish to use our Services, you will be asked to provide information about yourself.

Contacting Us

If you contact us through our “Contact Us” form on the Site, via the chat feature or otherwise send us an email, we process any personal information contained in those communications, including name, contact information, company and any other information that you submit to us.

Signing up for our Services

If you sign up for our Services, whether as a free trial or paid subscription, we will collect personal information as follows:

• First and last name
• Company name
• Email address
• Username
• Password
• Job title
• Location (Country/State/Zip Code)
• Phone number
• Billing address

If you are a Customer, we use PCI-compliant third-party processors, as explained in Payment Processing. Payment information is processed by our payment service providers, and we receive a confirmation of payment, which we then associate with your account and any relevant transactions.

Customer Reviews

Customer reviews contain names, photos and contact information. If you submit a Customer review, with your consent, it may be posted on the Site and publicly visible. We may also share it with strategic partners.

Information We Collect Indirectly

Automatically Collected Information

If you are browsing or interacting with the Site, we collect the same basic information that many other websites collect. Even if you do not have an account, we, or authorized third parties engaged by us, automatically collect information about your use of the Site, which consists of:

• Device Information – information about the devices and software you use to access the Site – primarily the internet browser or mobile device that you use, the website or source that linked or referred you to the Site, your IP address or device ID (or other persistent identifier that uniquely identifies your computer or mobile device on the Internet), the operating system of your computer or mobile device, device screen size and other similar hardware and software information, and language preference
• Usage Information – information about your interactions with the Site, including access dates and times, device event information, log data, crash data, and cookie data. This information allows us to understand the screens that you view, how you’ve used the Site and/or our Services (which may include administrative and support communications with us), and other actions on the Site. We, or our authorized third parties, automatically collect log data when you access and use the Site for all Site Visitors, even if you have not created an account or logged in. We use this information to administer and improve the Services, analyze trends, track users’ use of the Site, and gather broad demographic information for aggregate use.
• Location Information – based on this Device and Usage Information – mainly IP address – we are also able to determine general location information (country, city).

We (and certain authorized third parties) uses cookies and similar technologies in order to collect Device, Usage and Location Information. Some cookies are necessary to make the Site and our content available to you, while others are meant to improve the Site and enable us to analyze and measure audience and traffic. For more information on our use of cookies and the data that they collect, see our Cookie Notice.

Business Profile Data

Adaptiv collects and compiles information about individuals with whom it does not have a direct relationship, but whose Business Profiles are included on our Platform. This information is gathered, compiled (and updated) and provided to our Customers as part of the Services. Information that we collect and store to create Business Profiles (“Business Profile Data”) consists of business or professional information and includes personal and non-personal information, as described below. We collect Business Profile Data in a variety of ways:

• Directly from individuals who submit Business Profile Data to us
• From the publicly-available information available on the internet or otherwise
• From third-party companies that collect information on our behalf and license it to us

A Business Profile includes (but does not always contain all of) the following Business Profile Data:

• First and last name
• Business e-mail address
• Business telephone (mobile in some cases)
• Company
• Job Title
• Location (City)
• Photo
• Education
• Experience
• Public social media handles

Individuals whose information is contained in a Business Profile on the Platform may contact us at privacy@adaptivinsights.com to access or have their Business Profile Data updated, rectified or deleted.

Google Analytics

We use third-party analytics services, such as Google Analytics, to generate and process statistical or demographic data. These third parties use cookies to compile reports on the Site’s activity and Site Visitors, and provide other services related to Site activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. To learn more about how to opt-out tracking by Google Analytics, please click here

Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize the Site and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g., how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our Site and Services with user feedback in mind. Hotjar uses cookies and other technologies to collect data on users’ behavior and their devices. This includes Device and Usage Information as well as geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden from selling any of the information that it collects on Adaptiv’s behalf.

For further details and information on blocking Hotjar, please click here.

Payment Processing

We collect payments from Customers only and do not directly collect or store payment information. We use third-party, PCI-compliant, payment processors, which collect payment information on our behalf in order to complete transactions with our Customers. While our administrators are able to view and track actual transactions via the client portals of the payment processors, we do not have access to, or process, credit card information.

Social Media

We use social media plug-ins (e.g., Facebook, Twitter). These features may collect your IP address and/or other information as set forth in each social platform’s privacy policy, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Adaptiv also has a presence on some social media platforms, including Twitter and LinkedIn. Through our accounts on social medial platforms, we may in some instances collect personal information when you interact with the Adaptiv accounts or otherwise communicate with us through those accounts. Any information that you post on social media is governed by each social platform’s privacy notices, and any personal information that we collect via our social media accounts will be processed in accordance with this Privacy Policy.

How Do We Use Personal Information We Collect

We use your personal information for a number of different reasons, as further explained below.

In addition, for users located in the EEA and the U.K., we must have a valid legal basis in order to process your personal data. Generally speaking, the main legal bases under the European Union’s General Data Protection Regulation (GDPR) that justify our collection and use of your personal data are:

• Performance of a contract – When your personal data is necessary to enter into or perform our contract with you.
• Consent – When you have consented to our use of your personal data via a consent form (online or offline).
• Legal obligation – When we need to use your personal information to comply with our legal obligations.
• Legal claims – When your personal information is necessary for us to defend, prosecute or make a claim.
• Legitimate interests – When we use your personal data to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights. For instance, our processing of Business Profile Data in connection with our Services is within our legitimate interests because the business nature of the information (while still personal information) is widely available and distributed across the internet and otherwise. The information does not concern any special categories of data nor does it include personal details about individuals’ private lives. Moreover, Adaptiv provides adequate notice, access and choice (including the ability to delete said Business Profile Data directly by clicking here) and technical and organizational measures with respect to the Business Profile Data. As such, Adaptiv’s use of personal data as part of the Business Profile Data outweigh any prejudice to the individuals’ data protection rights. If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by contacting us at privacy@adaptivinsights.com.

Below are the general purposes and corresponding legal bases (in brackets) for which we may use your personal information:

• Providing, updating and maintaining the Platform – In particular, we will use your data to ensure that the Site loads and works for you, to set-up an account, or provide you with notices regarding purchases or other important information. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
• Collecting Business Profile Data to create and disclose Business Profiles for use by our Customers – See description above. Legitimate interests
• Processing and completing transactions, and sending you related information, including purchase confirmations and invoices – In particular, we will use your data to complete any purchases for the Services, set up billing and resolve any issues with respect to the foregoing. Performance of a contract
• Responding to your queries and requests, including to respond to rights requests and customer support requests – In particular, if you contact our support team we may use the information that you provide to us in order to help us respond to your enquiry. Our use of your personal information in this way is necessary to perform our customer service obligations to you, under our Terms of Use. If you are a Site Visitor or are an individual with a Business Profile, we may process your personal information for these purposes where it is in our legitimate interests to do so for customer services purposes. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
• To otherwise communicate directly with you – In particular, if you contact us or otherwise send as a communication, we may process your personal information. Depending on the context, performance of a contract, legitimate interests, and in some cases, legal claims
• Improving the content and general administration of the Platform, including to perform system maintenance and upgrades – In particular, we may use Device, Usage and Location Information to make changes to certain features or improve the Site, or use other information derived from personal information to offer new Services or make upgrades to the Platform. Legitimate interests
• Detecting fraud, illegal activities or security breaches – In particular, we may use information such as your IP address to help us prevent abuse of the Platform and investigate any potential unauthorized use of the Platform or other security breaches. Legitimate Interests
• Interacting with individuals on social media via our social media accounts and marketing our Platform – This includes any data we collect when you interact with our social media handles, and any advertising or re-targeting that we may undertake as set forth in this Privacy Policy. Consent where required (e.g., third-party cookies) or legitimate interests
• Conducting statistical analyses and analytics by monitoring and analyzing trends, usage, and activities in connection with the Platform – In particular, we do this internally or via third parties such as Google Analytics, Hotjar and other partners. Consent where required (e.g., third-party cookies) or legitimate interests
• Sending marketing communications, in line with your communication preferences
  Consent (depending on location and Customer relationship) or legitimate interests
• As required by applicable law, legal process or regulation – We may use your information to comply with valid court orders and similar legal or regulatory obligations which apply to us. This may include where we reasonably consider it is in our legitimate interests (or the legitimate interests of others) to comply, as well as where we are legally required to do so
  Legal obligations or claims

Disclosure of Personal Information

We disclose your personal information as described below.‍

Third-Parties and Service Providers

Adaptiv discloses users’ information to our third party agents, contractors or service providers who are hired to perform services on our behalf. These companies do things to help us provide the Platform, and in some cases collect information directly, for example as explained in Payment Processing above. Below is an illustrative list of functions for which we may use third-party service providers:

• Hosting and content delivery network services
• Analytics services
• Lead generation partners
• Marketing and social media partners
• Customer support services
• Payment processors
• Hosting and content delivery network services
• Functionality and debugging services

Professional service providers, such as auditors, lawyers, consultants, accountants and insurers

Customers

Business Profile Data is disclosed to our Customers and Site Visitors in connection with our Services, as well as strategic partners. To exercise your rights with respect to personal information contained in your Business Profile, please click email privacy@adaptivinsights.com.

Business Transfers

As we continue to grow, we may purchase websites, applications, subsidiaries, other businesses or business units. Alternatively, we may sell businesses or business units, merge with other entities and/or sell assets or stock, in some cases as part of a reorganization or liquidation in bankruptcy. In order to evaluate or as part of these transactions, we may transfer your personal information to a successor entity upon a merger, consolidation or other corporate reorganization in which Adaptiv participates, or to a purchaser or acquirer of all or a portion of Adaptiv’s assets, bankruptcy included.

Anonymized Information

We share aggregated, automatically-collected or otherwise non-personal information with third parties for various purposes, including (i) compliance with reporting obligations; (ii) for business or marketing purposes; (iii) to assist us and other parties in understanding our users’ interests, habits and usage patterns for certain programs, content, services, marketing and/or functionality available through the Platform. We do not share personal information about you in this case.

Legal Obligations and Security

In addition, Adaptiv will preserve or disclose your personal information in limited circumstances (other than as set forth in this Privacy Policy), including: (i) with your consent; (ii) when we have a good faith belief it is required by law, such as pursuant to a subpoena, warrant or other judicial or administrative order (as further explained below); (iii) to protect the safety of any person and to protect the safety or security of our Platform or to prevent spam, abuse, or other malicious activity of actors with respect to the Platform; or (iv) to protect our rights or property or the rights or property of those who use the Platform.

If we are required to disclose personal information by law, such as pursuant to a subpoena, warrant or other judicial or administrative order, our policy is to respond to requests that are properly issued by law enforcement within the United States or via mutual legal assistance mechanism (such as a treaty). However, if we receive information that provides us with a good faith belief that there is an exigent emergency involving the danger of death or serious physical injury to a person, we may provide information to law enforcement trying to prevent or mitigate the danger (if we have it), to be determined on a case-by-case basis.

Advertising & Marketing

Information We Use for Advertising and Marketing

We advertise our Platform by targeting (and measuring the performance of) ads to Site Visitors, Customers on other websites and platforms directly or through a variety of partners, including third party advertisers, ad server companies, social networks and ad networks (collectively, “External Ad Partners”). In order to advertise our Services, we or our External Ad Partners use the following information, whether separately or combined:

• Device Information and Location Information collected via cookies and similar technologies on our Site
• Information provided directly by Customers or individuals who reach out to us directly
• Usage Information from your use of the Platform
• Information from External Ad Partners
• Information inferred the categories of information described above.

When we serve ads based on the foregoing information, it is referred to as “targeted advertising” because External Ad Partners track your activity on and off the Site in order to deliver targeted advertising based on your activity, such as one of your visits to the Site. In addition, as noted above, the information that External Ad Partners collect from our Services may be combined with other information from other sources and be used to build profiles on you and other individuals for the purposes of delivering targeted advertising.

In addition to advertising our Services, we use Customer data and content to market our Services, promote additional features or encourage Customers to share our Platform.

For more information about interest-based advertising, please visit the Network Advertising Initiative website and/or the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising website. To learn more about interest-based advertising and to opt-out of this type of advertising by third parties that participate in the DAA’s AppChoices tool, please use this link. Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may also continue to receive advertising, but that advertising may be less relevant to your interests. You may have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.

Please visit our Cookie Notice for more information on the types of cookies that are used by us and our External Ad Partners within the Services, as well as information on your choices and how to opt -out.

For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies. If you opt-in and subsequently change your mind, you may withdraw your consent at any time by clicking here.

Links to Third Party Sites

This Privacy Policy applies only to the Platform. The Platform may contain links to other websites owned and operated by third parties – and therefore not controlled by Adaptiv (“Third Party Sites”). For instance, we may post YouTube videos with information about our Services. To the extent that Third Party Sites collect any personal data when you click on a link to their Third Party Sites, they are responsible for informing you of their data collection and privacy practices, among other things. When you click on a link that takes you to a Third Party Site, we suggest reviewing their privacy policies to understand what information they collect and how they collect it.

Social Media

We use social media plug-ins (e.g., Facebook, Twitter). These features may collect your IP address and/or other information as set forth in each social platform’s privacy policy, which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Adaptiv also has a presence on some social media platforms, including Twitter and LinkedIn. Through our accounts on social medial platforms, we may in some instances collect personal information when you interact with the Adaptiv accounts or otherwise communicate with us through those accounts. Any information that you post on social media is governed by each social platform’s privacy notices, and any personal information that we collect via our social media accounts will be processed in accordance with this Privacy Policy.

More information as regards our legal relationship with some of those social media platforms is available here for users in the EEA and the U.K.

“Do Not Track”

Adaptiv does not respond to Do Not Track (“DNT”) browser signals. For more information on DNT settings generally, please visit https://allaboutdnt.com.

How to Change Your Communication Preferences

To keep your information accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update any information in our possession that you have previously submitted via the Platform. Note that you may also manage your communications preferences and the receipt of any commercial communication by clicking the “unsubscribe” link included at the bottom of all emails from Adaptiv. You may also adjust your preferences through your account settings if you have an Adaptiv account, or send an email to privacy@adaptivinsights.com.

Your Choices

You have choices about how to protect and limit the collection, use, and sharing of information about you. Note that in order to protect your privacy and security, we will also take reasonable steps to verify your identity before granting you access or enabling you to make corrections or delete your information.

Accessing and Changing Your Information

You can access and change certain information through the Platform if you are a Customer, or by contacting us as privacy@adaptivinsights.com.

Deleting Your Account or Business Profile

If you are a Customer, you may delete your account information at any time by emailing us at privacy@adaptivinsights.com. We may retain certain information about you as required by law or for legitimate business purposes after you delete your account.

If you would like to delete your Business Profile Data, please click here.

Controlling the Use of Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject first and third-party cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. For more information on controlling how cookies and similar technologies are used on the Site, see our Cookie Notice.

For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies. If you opt-in and subsequently change your mind, you may withdraw your consent at any time by clicking here.

Controlling Advertising and Analytics

Some analytics providers we partner with may provide specific opt-out mechanisms. For example, you may manage the use and collection of certain information by Google Analytics via the Google Analytics Opt-out Browser Add-on. You can opt-out of the behavioral analytics services provided by Hotjar by clicking here.

As explained here, you may also generally opt-out of receiving personalized advertisements from certain third-party advertisers and ad networks. To learn more about these advertisements or to opt-out, please visit the sites of the Digital Advertising Alliance and the Network Advertising Initiative, or if you are a user in the European Economic Area, Your Online Choices.

For users in the EEA and U.K., we provide opt-in mechanisms with respect to non-essential cookies. If you opt-in and subsequently change your mind, you may withdraw your consent at any time.

Controlling Promotional Communications

You may opt-out of receiving some or all categories of promotional communications from Adaptiv by following the instructions/link contained in those communications or, if you are a Customer, by updating your email options in your account preferences. If you opt-out of promotional communications, we may still send you non-promotional communications, such as information about your account and/or transactions, or your use of the Services.

How Long Do We Keep Your Personal information?

General Retention Periods

We use the following criteria to determine our retention periods: the amount, nature and sensitivity of your information, the reasons for which we collect and process your personal data, the length of time we have an ongoing relationship with you and provide you with access to our Platform, and applicable legal requirements. We will retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to comply with applicable legal, tax or accounting requirements). Additionally, we cannot delete information when it is needed for the establishment, exercise or defense of legal claims (also known as a “litigation hold”). In this case, the information must be retained as long as needed for exercising respective potential legal claims.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

For any questions about data retention, please contact privacy@adaptivinsights.com.

Anonymization

In some instances, we may choose to anonymize your personal data instead of deleting it, for statistical use, for instance. When we choose to anonymize, we make sure that there is no way that the personal data can be linked back to you or any specific user.

Data Security and Integrity

We take steps that are reasonably necessary to securely provide our Platform. We have put in place reasonably appropriate security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to personal data only to those employees, agents, contractors and the third parties who have a business need-to-know.

We also have procedures in place to deal with any suspected data security breach. If required, we will notify you and any applicable regulator of a suspected data security breach. We also require those parties to whom we transfer your personal information to provide acceptable standards of security.

Notwithstanding, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Platform may not be secure. Therefore, take special care in deciding what information you send to us via email. For any questions about the security of your information, please contact privacy@adaptivinsights.com.

Notice to Nevada Consumers

We may sell your personal information within the scope of, and according to the defined meaning of, a “sale” under NRS 603A. If you would like to opt-out of such sales of your personal information, please contact privacy@adaptivinsights.com. We will respond to verifiable requests as required by NRS 603A.

International Transfers

We are located in the United States, and the personal information that we collect is stored on servers located in the United States. This means that your personal information will be collected, processed and stored in the United States, which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region, such as the GDPR.

By sending us personal information, you agree and consent to the processing of your personal information in the United States, which may not offer an equivalent level of protection to that required in other countries (particularly the European Union), and to the processing of that information by us on servers located in the United States, as described in this Privacy Policy.

We have implemented safeguards designed to ensure that the personal information we process remains protected in accordance with this Privacy Policy. Safeguards we may take in our discretion include, for instance, entering into standard contractual clauses in connection with any onward transfers of personal information, as can be viewed here for transfers from the European Union, Switzerland and the United Kingdom. We may implement other mechanisms and take similar appropriate safeguards with our third-party service providers and partners. Further details can be provided upon request.

Note: Customers are considered independent controllers of Business Profile Data that they receive in connection with the Services. As such, for Customers that are not located in the EEA, the U.K or a third country deemed adequate by the European Union and that access and create a back-up copy of Business Profile Data must enter into and adhere to the standard contractual clauses (controller to controller) as set forth in our Terms and Conditions.

Additional Information for Users in the EEA and the U.K.

If you are in the EEA or the U.K., please read this section for more information.

Staying In Control of Your Information: Your Rights

If you are in the EEA or the U.K., you have certain rights in relation to your personal data:

• The right to be informed – our obligation to inform you that we process your personal data (and that’s what we’re doing in this Privacy Policy);
• The right of access – your right to request a copy of the personal data we hold about you (also known as a ‘data subject access request’);
• The right to rectification – your right to request that we correct personal data about you if it is incomplete or inaccurate (though we generally recommend first making any changes in your account settings);
• The right to erasure (also known as the ‘right to be forgotten’) – under certain circumstances, you may ask us to delete the personal data we have about you (unless it remains necessary for us to continue processing your personal data for a legitimate business need or to comply with a legal obligation as permitted under the GDPR, in which case we will inform you). Note that Business Profile Data may be deleted by clicking here;
• The right to restrict processing – your right, under certain circumstances, to ask us to suspend our processing of your personal data;
• The right to data portability – your right to ask us for a copy of your personal data in a common format (for example, a .csv file);
• The right to object – your right to object to us processing your personal data (for example, if you object to us processing your data for direct marketing); Rights in relation to automated decision-making and profiling – our obligation to be transparent about any profiling we do, or any automated decision-making; and
• The right to lodge a complaint at any time to the supervisory authority for data protection issues in your country of residence – however, we ask that you please contact us first so that we can first address your concerns.

These rights are subject to certain rules around when you can exercise them.

If you are located in the EEA or the U.K. and wish to exercise any of the rights set out above, you may contact us at privacy@adaptivinsights.com. If you are in the EEA, you may contact our representative in the EU, as explained below.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights) unless your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request under those circumstances.

We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. If we cannot reasonably verify your identity, we will not be able to comply with your request(s).

We will respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated as required by law.

Social Media and Joint Controllership for Individuals in the EEA

Sometimes, Adaptiv acts as a ‘joint controller’ with certain third parties, namely certain social media sites, such as LinkedIn. When Adaptiv and a partner act as joint controllers, you (as a data subject) may exercise your rights against Adaptiv and/or the third party. For a list of joint controller relationships, please contact us at privacy@adaptivinsights.com.

Facebook

In order to market our Platform and stay in touch with users, we maintain a Facebook page and use Facebook Pixel (“Facebook Products”). With respect to our use of these Facebook Products, we are jointly responsible with Facebook Ireland for the processing activities (“Joint Processing”):

Facebook Ireland Ltd.,

4 Grand Canal Square, Grand Canal Harbor

Dublin 2, Ireland

Information about the personal data that is collected from you by Facebook, as well as how and why it is processed by Facebook, can be found at https://www.facebook.com/about/privacy. Adaptiv and Facebook have entered into entered into an agreement in order to determine the respective responsibilities for compliance with our obligations in connection with the Joint Processing within the meaning of the GDPR. This joint controller agreement, which sets out the reciprocal obligations, is available here.

Please note that Facebook Ireland is responsible for enabling data subjects’ rights under Articles 15-20 of the GDPR with regard to the personal data stored by Facebook Ireland in connection with the Joint Processing, as further described in Facebook’s privacy policy. To exercise your rights, please go to your Facebook settings or contact Facebook as set forth in its privacy policy.

It cannot be excluded that some processing by Facebook Ireland Ltd. will also take place in the United States by Facebook Inc.

LinkedIn

With respect to our use of the “Page Insights”, we are joint controllers of your personal data with LinkedIn. You may find the joint controller addendum at https://legal.linkedin.com/pages-joint-controller-addendum.

Representative in the European Union and in the U.K.

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Adaptiv LLC has appointed European Data Protection Office (EDPO) as its GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:

• Using EDPO’s online request form: https://edpo.com/gdpr-data-request/
• Writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

UK General Data Protection Regulation (GDPR) – UK Representative

Pursuant to Article 27 of the UK GDPR, Adaptiv LLC has appointed EDPO UK Ltd as its UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR by:

• Using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/
• Writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom

Additional Information for California Residents

This Notice for California Residents (“CCPA Notice”) supplements the information contained in the Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“Consumers”). We have created this CCPA Notice in order to comply with the California Consumer Privacy Act of 2018 (“CCPA”).

Please note that this CCPA Notice does not apply to employees and job applicants.

Categories of Information We Collect

Within the last twelve (12) months, Adaptiv has collected the following categories of personal information (as defined in the CCPA) from or about Consumers (note that the lettered categories are according to lettering in the CCPA):

• A. Identifiers, such as a real name, unique personal identifier, online identifier, IP Address, email address, or account name
• B. Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)), such as a name, signature or telephone number
• C. Protected classification characteristics under California or federal law, such as age or gender
• D. Commercial information, such as records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• F. Internet or other similar network activity, such as browsing history or information on a Consumer’s interaction with a website or application.
• G. Geolocation data, such as physical location.
• H. Visual information, such as a photograph.
• I. Professional or employment-related information
• K. Inferences drawn from other personal information, such as profile information reflecting a person’s preferences.

Personal information does not include:

• Publicly available information from government records
• Deidentified or aggregated Consumer information
• Certain other information that is already regulated by other laws or regulations

Information that is specifically exempt from the scope of the CCPA.

Categories of Sources of Personal Information

As explained in more detail here, Adaptiv obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, when you sign up to use the Services.
• Indirectly. For example, from observing your actions on our Services, or from the internet (including publicly-available sources) – this includes data collected via cookies (or similar technologies) or from third parties.

Use of Personal Information

We may use, or disclose the personal information we collect for one or more of the following business purposes as described here.

Disclosure of Personal Information

Service Providers

Adaptiv may disclose your personal information to service providers for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the services for us. As explained in more detail above, we also share your personal information with certain categories of service providers who assist us in providing our Services and with our business.

In the preceding 12 months, Adaptiv has disclosed the following categories of personal information for a business purpose:

• A. Identifiers
• B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• C. Protected classification characteristics under California or federal law
• D. Commercial information
• F. Internet or other similar network activity
• G. Geolocation data
• H. Visual information
• I. Professional or employment-related information
• K. Inferences drawn from other personal information

Sale of Personal Information

The CCPA defines ‘sale’ very broadly. It includes the sharing of personal information with third parties in exchange for anything of value. According to this broad definition, in the year before this section was last updated, we may have sold the following categories of personal information to third parties:

• A. Identifiers
• B. Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))
• C. Protected classification characteristics under California or federal law
• F. Internet or other similar network activity
• G. Geolocation data
• H. Visual information
• I. Professional or employment-related information
• K. Inferences drawn from other personal information

The third parties to whom we may sell personal information are:

• Our Customers
• Social Media Platforms – these third parties maintain networks connecting individuals and organizations – such as Facebook, LinkedIn, or Twitter
• Advertising Partners – these third parties help us advertise our Services
• Promotional Partners

Your Rights and Choices

The CCPA provides Consumers with specific rights regarding their personal information, provided that we are able to verify their identities.

Opting-out of Sales of Personal Information

If your information is contained in a Business Profile and you would like to opt-out of us selling your personal information, please click here.  You can also opt-out of the sale of your personal information that is collected automatically when you visit the Site by clicking here.

Access to Specific Information and Data Portability Rights

You have the right to request that Adaptiv disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your request and verify your identity, we will disclose such information to you.

Deletion Request Rights

You have the right to request that Adaptiv delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request and verify your identity, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Note: we may deny your deletion request if retaining the information is necessary for us or our service provider(s) for certain reasons as permitted and set forth in the CCPA, in which case we will inform you of those reasons.

Exercising Your Consumer Rights

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable Consumer request related to your personal information. You may also make a verifiable Consumer request on behalf of your minor child. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

An authorized agent is a natural person or a business entity registered with the Secretary of State that a Consumer has authorized to act on his or her behalf. When a Consumer uses an authorized agent to submit a request to know or a request to delete, Adaptiv may require that the Consumer provide the authorized agent written permission to do so and verify his or her own identity directly with Adaptiv, unless the Consumer has provided the authorized agent with a valid power of attorney. Adaptiv may deny a request from an agent that does not submit proof that he or she has been authorized by the Consumer to act on his or her behalf.

Please note that the methods for verification are set forth in the CCPA, which also requires us to consider a number of factors, such as the type, sensitivity, and value of the personal information or the risk of harm posed by unauthorized access or deletion, on a case-by-case basis.

To exercise the rights described above, please submit a verifiable Consumer request to us by either:

• Emailing privacy@adaptivinsights.com
• Business Profile Data may be deleted by clicking here

You may only make a verifiable Consumer request for access or data portability twice within a 12-month period. We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

We endeavor to respond to a verifiable Consumer request within the timeframes set forth in the CCPA. If applicable, in our response, we will also explain the reasons we cannot comply with a request.

Non-Discrimination

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. Please note that to use our Services, we do require the collection of your personal information – for example, to sign you up or to complete a paid transaction. While you may request to delete your personal information under CCPA, such deletions may affect our ability to offer the Services.

Other California Privacy Rights

California residents may request information about our disclosures of certain categories of personal information to third parties for such third parties’ direct marketing purposes. California residents may make such request to us at privacy@adaptivinsights.com.

We will provide a list of the categories of personal information disclosed to such third parties for their direct marketing purposes during the immediately preceding calendar year, along with the names and addresses or these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email specified in this section.

If you have any questions regarding this CCPA Notice, please contact us directly at privacy@adaptivinsights.com.