Last Modified: December 31, 2019

 

At Datassential (“Datassential” or “we”), we understand how important your privacy is and want you to understand how we use your information. This Privacy Policy (“Policy”) applies to all of our websites, SNAP!, dataessential.com, and our mobile applications (collectively, the “Site”). This Policy will let you know what kind of information we collect on our Site, how we collect that information, and what we do with it. If this Policy or our Terms of Use are not consistent with your values or are not acceptable to you, we kindly ask that you do not use our website or services. 

While this Policy describes how we treat personal information, please be aware that additional terms and conditions may apply to other services and products we offer.

 

INFORMATION WE COLLECT 

Information You Provide to Us. We may collect personal information about you when you provide it to us while using or interacting with the Site such as your name, email address, telephone number, mailing address, business name, business title, login information, location, account information, messages you submit via the Site’s form, and other information that may personally identify you. 

Information We Collect Automatically. As you use our Site, we may use technologies that collect certain information about you automatically. We may collect, among other things, your IP address, location, device type, date and time of visit, operating system, your activities on the Site, and information about how you use the Site. If you are visiting the Site via a mobile device, we may also collect your mobile device’s unique device ID and information about how you use the Site. 

 

INFORMATION WE GET FROM THIRD PARTIES 

From time to time, we receive information about individuals from our third party service providers, affiliates, and partners. For example, we may receive information on our email campaigns from our third party service providers, including whether you have read an email sent by us or on our behalf, forwarded an email, and when and how many times you have opened an email. We may also receive information from third party analytics on the Site that allow us to improve our Site and services. 

 

AUTOMATIC INFORMATION COLLECTING TECHNOLOGIES 

Datassential and third parties may use a variety of technologies that collect information automatically, including cookies, web beacons, flash cookies, and logging. For example, we use Google Analytics to help us understand how our customers interact with the Site—you can read more about how Google uses your information here: https://policies.google.com/privacy. You can also opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout. It is important to understand cookies and web beacons: 

  • Cookies. A cookie is a small text file that is sent to your browser when you access a website, including the Site. We and the third parties described below may use session cookies. A session cookie is available only during the course of the browser session; the information is not sent to or stored on a computer’s hard drive. Closing the browser or logging off will invalidate the session cookie. We and the third parties described below may also use machine cookies, which do remain on a computer hard drive and gather information, sometimes over time and across websites. You can find more information about your choices regarding cookies under the heading “YOUR CHOICES.”
  • Web Beacons. “Web beacons” or “tracking pixels” are electronic images, tags, or scripts that allow a website to access cookies and among other things, help track general usage patterns of visitors to a website. Web beacons can recognize certain types of information, such as cookies, time and date of a page view, and a description of the page where the web beacon is placed. We and the third parties described below may use web beacons to compile information regarding your use of the Site. 

 

HOW WE USE INFORMATION

Uses of Information We Collect Automatically or Receive from Third Parties. Information that is collected automatically may be used for a variety of business purposes, such as monitoring website traffic, delivering relevant content, improving the Site, security of the Site, and use of the Site. We may also use information we collect automatically that is otherwise de-identified, aggregated, or anonymous for any purpose. 

 

Uses of Information You Provide to Us. We know your personal information is important to you. As a result, we want you to know how we may use it.  We use information for the following purposes: 

  • To provide the Site, related services, and products;
  • To respond to any request you have made, including for information, products, and/or services;
  • For our marketing efforts, including to keep you informed about existing and new products and services;
  • To provide you with customer support;
  • To resolve problems and disputes with the Site;
  • To improve the Site and our services;
  • To protect the security and integrity of the Site;
  • To monitor compliance with and enforce this Policy and any other applicable agreements and policies; 
  • To prevent fraud, protect our business, and to otherwise fulfill our legal obligations;
  • If necessary, to notify you about changes to the Site or to any products or services we offer;
  • In any other way we may describe when you provide the information, or any other purpose we deem necessary or appropriate; 
  • To fulfill any other purposes for which you provide it, or offer your consent; and
  • As generally permitted under applicable law.

 

DISCLOSURE OF YOUR INFORMATION 

We may share your information, including your personal information: 

  • To our subsidiaries and affiliates;
  • To our subcontractors, service providers, and other third parties we use to support our business or the Site;
  • To a buyer or other successor in the event of or during a merger, divestiture, restructuring, dissolution, or other sale or transfer of some or all of Datassential’s assets or equity, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Datassential is among the assets transferred;
  • For any other purposes disclosed by us when you provide the information, or any other purpose we deem necessary or appropriate; or
  • With your consent. 

We may also share your personal information to comply with any court order or legal obligation, including responding to any lawful government or regulatory request, or if we believe disclosure is necessary to enforce or protect our rights, property, or safety, or that of our users or third parties. 

 

YOUR CHOICES 

If you are a California resident, please see Privacy Information for California residents, see Appendix A.

Cookies. If you do not wish us to place cookies, you may set your browser to refuse some cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of the Site may then be inaccessible or may not function properly. Information on deleting or controlling cookies can be found at www.aboutcookies.org. 

Opt-Out. You may opt out of receiving future marketing communications from us any time we request your personal information. You can opt out by using the unsubscribe process by emailing us at privacy@datassential.com with “unsubscribe” in the subject line. We will use commercially reasonable efforts to process such request in a timely manner.

 

EXTERNAL WEBSITES

Our Site may contain links to websites operated and maintained by third parties, including social media platforms. We have no control over and are not responsible for the privacy policies or content on those websites. Links to third party websites do not imply an affiliation between Datassential and the website owner, or any endorsement, approval, or verification of any content contained on those websites. Privacy policies on third party websites may be different from our Policy. You access such links at your own risk. We recommend you read the privacy policy of a website before disclosing any of your information. 

 

CHILDREN UNDER THE AGE OF 13

We do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under the age of 13 without parental consent, we will delete that information and otherwise comply with the requirements of any applicable law including the Children’s Online Privacy Protection Act. If you believe that we might have any information from or about a child under the age of 13, please contact us at privacy@datassential.com.

 

SECURITY

We strive to use reasonable means to secure your personal information; however, please keep in mind that the transmission of information over the Internet and on mobile platforms is not always secure, which means we cannot and do not guarantee the complete security of any personal information you provide to us. Please consider this prior to submitting personal information to us via the Site. The confidentiality of your password for the Site is your responsibility.

 

CHANGES TO THIS POLICY

We may update this Policy to reflect material changes in the manner in which we deal with personal information, including complying with laws or for business purposes. The Policy posted here will always be current. We encourage you to review it regularly. If we make a material change to this Policy, we will either post a notice on the Site or send you an email notifying you of the update. Your continued use of this Site after we make changes to this Policy is deemed to be your acceptance of any changes regardless of whether you receive an email.

CALIFORNIA RESIDENTS

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit Privacy Information for California Residents found in Appendix A.

 

CONTACT US

To ask questions or comment about this Policy or to remove or change your contact information in our database, or to not receive certain mailings or other communications, please contact us using one of the options below: 

  • Via telephone: 312-655-0622
  • Via mail: Datassential 

Attn: Privacy Officer 

18 S. Michigan, 9th Floor

Chicago, IL 60603

 

Appendix A

Privacy Information for California Residents

Effective Date: December 31, 2019

This Appendix supplements the information contained in Datassential (“Datassential” or “we,” “us,” or “our”) Privacy Policy, and applies solely to individuals who reside in the State of California (“consumers” or “you”). We adopt this Appendix to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Appendix.  This Appendix does not apply to personal information outside the scope of the CCPA. 

Datassential as a Service Provider

When Datassential acts as a service provider for its customers, we collect personal information (as defined below) on behalf of our customers subject to our contractual obligations.  When we act as a service provider, we follow the instructions of our customer on how to process personal information on our customer’s behalf. The below provisions of this Appendix do not apply to the personal information that Datassential processes on behalf of our customers. 

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). The below chart lists the categories of personal information that we may collect and have collected in the past 12 months and how we use such information.

Category of Personal Information Categories of Sources from which the Personal Information is Collected How We Use the Personal Information (Business Purposes) Categories of Third Parties with whom Personal Information is Shared
Identifiers. This may include a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. You or your agents; through our third party service providers; social media networks; and our affiliates. To provide you with information, products, or services; to improve our products; to conduct consumer research; to advertise or market to you; and for our own legal obligations and business needs. Entities that we are legally required to share with pursuant to law; service providers; our affiliates; prospective purchasers of our business; and social networks.
Internet or other similar network activity. This may include browsing history, search history, or information on how you interact with a website, email, application, or advertisement. You; through our third party service providers; social media networks; and our affiliates. To provide you with information, products, or services; to advertise or market to you; to improve our services and products; to conduct consumer research; to secure our website; and for our own business needs. Entities that we are legally required to share with pursuant to law; service providers; our affiliates; data analytics providers; and social networks.
Device information. This may include mobile operating system, device identifier, geolocation information, or the type of device you are using. You; through our third party service providers; social media networks; and our affiliates. To provide you with information, products, or services; to advertise or market to you; to improve our services and products; to secure our website; and for our own business needs. Entities that we are legally required to share with pursuant to law; service providers; our affiliates; data analytics providers; and social networks.
Inferences drawn from other personal information. This may include profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. You; through our third party service providers; and our affiliates. To provide you with information, products, or services; to advertise or market to you; to improve our services and products; to conduct consumer research; and for our own business needs. Entities that we are legally required to share with pursuant to law; service providers; our affiliates; and social networks.
Social Media Data.  This may include information you may post on social media pages, including your profile information. You; through our third party service providers; social media networks; and our affiliates. To provide you with information, products, or services; to advertise or market to you; to improve our services and products; and for our own business needs. Service providers; our affiliates; and social networks.
Other Information You Submit. This may include requests or communications you submit to us, including emails. You; through our third party service providers; our affiliates. To provide you with information, products, or services; to advertise or market to you; to improve our services and products; to conduct consumer research; and for our own legal obligations and business needs. Entities that we are legally required to share with pursuant to law; service providers; our affiliates; prospective purchasers of our business; and social networks.

 

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This Section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights (“Right to Know”)

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.  You could request:

  • The categories of personal information we collected about you;
  • The categories of sources of the personal information we collected about you;
  • Our business or commercial purpose for collecting that personal information;
  • The categories of third parties with whom we share that personal information; or
  • The specific pieces of personal information we collected about you.

Our employees and employees of our business partners and service providers also do not have a Right to Know.

Deletion Request Rights 

You have the right to request that we delete some or all of the personal information that we have collected from you and retained, subject to a number of exceptions.  We are not required to delete personal information that is: (a) necessary to complete a transaction with you or for warranty or product recalls; (b) used for security purposes, to prevent fraud, to fix errors, or to comply with law; (c) reasonable for us to use for internal purposes given our relationship with you; or (d) compatible with the context in which you provided the information.  The list of exceptions above is not exhaustive and we may also deny a deletion request as otherwise permitted by law.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: 

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. If you are making a request on behalf of another person, you must provide written legal documentation that you are authorized to act on behalf of that individual. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We may not be able to fulfill 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.  We do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. To verify your identity, we may request up to up to three pieces of personal information about you, and we reserve the right to take additional steps as necessary to verify your identity if we have reason to believe a request is fraudulent.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the date we receive your verifiable consumer request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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. 

Non-Discrimination

You have the right to not be discriminated against for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

Changes to This Appendix 

Datassential reserves the right to amend this Appendix at our discretion and at any time. When we make changes to this Appendix, we will post the updated notice on the Site and update the Appendix’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

Contact Information

If you have any questions or comments about this Appendix, the ways in which Datassential collects and uses your information, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 312-655-0622

Website: www.datassential.com

Email: privacy@datassential.com

Postal Address: Datassential

Attn: Privacy Officer

18 S. Michigan, 9th Floor

Chicago, IL 60603 

21521769.2