Privacy Policy Updated: June 15, 2023 Introduction
Persado Holdings Limited and its affiliated entities (collectively, “Persado” or the Company”) value the trust of their employees and clients, and are committed to protecting personal data. The purpose of this Privacy Policy (the “Policy”) is to give you information about what personal information the Company collects, uses, transfers and discloses, and why.
For purposes of this Policy, “Personal Data” means any information relating to an identified or identifiable natural person or household.
Personal Data We Collect, and Have Collected in the Past 12 Months
We collect, and have collected in the past 12 months, the following types of Personal Data:
First and last name
Company name
Job title
Contact information, including email address, telephone number, or mailing address
Demographic information, such as age, nationality, or gender.
We may also collect, and may have collected in the past 12 months, technical information automatically when you access or interact with our website. This can include:
Information about the device(s) you use to access the website
Your device’s IP address
Your device’s operating system
The type of application you are using
The type and version of internet browser you are using
The time and date of your visit
Pages of our website that you visit and time spent on those pages
Unique device identifiers and other diagnostic data.
If you apply for a job with us, or are employed by us, we may collect Personal Data in a number of circumstances. Personal Data we may collect includes: name, address, telephone number and other contact information; social security number or tax ID number; educational or other credentials; employment history and experience; volunteer work; and other information necessary to evaluate a candidate’s suitability for employment; together with any other information we may collect with your consent or as required by applicable law.
Sensitive Data We Collect or Share, and Have Collected or Shared in the Past 12 Months
“Sensitive Data” means Personal Data that reveals a consumer’s racial or ethnic origin; religious beliefs; mental or physical health diagnosis; sexual orientation or sexual history; citizenship or immigration status; union status; genetic or biometric data; social security number; driver’s license number; passport number; mail, e-mail and/or text message contents; account and/or financial account access information; and precise geolocation. We collect, and have collected in the past 12 months, the following types of Sensitive Data:
Social security number
E-mail or text message contents (in messages sent to or by us)
Bank account information
Debit/Credit card number
Driver’s license number
Passport number
ethnic information.
We collect this Sensitive Data for the following purposes:
For employment purposes, as required by law
For marketing purposes, in relation to e-mail and text messages
For medical insurance purposes, as required by law
For compliance purpose, in particular with regard to ISO and EEOC.
If you are a resident of California, you have the right to limit Persado’s use of your Sensitive Data. To exercise this right, contact [email protected] or by telephone at 1-(888)-276-0576.
Personal Data We Disclose, and May Have Disclosed in the Past 12 Months
We disclose, and may have disclosed in the past 12 months, Personal Data in the following situations:
To third-parties providing services to us, such as professional advisors, service providers, or vendors
To link your information to a third-party social network such as Facebook, Twitter, LinkedIn, or YouTube through the use of tools such as a “share this” button
In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company
When necessary: (1) upon lawful request, in response to legal process, and when required to comply with laws; (2) to enforce our agreements, corporate policies, and terms of use; (3) to protect the rights, property or safety of our employees, agents, customers, and other third-parties; (4) to investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; or (5) to investigate and defend against any third-party claims or allegations.
Due to the global nature of Persado operations, we may transfer Personal Data to other countries (including countries other than where you are based, that have a different data protection regime than is found in the country where you are based). If you are located in the European Economic Area (the “EEA”) this may include countries outside of the EEA, including the United States.
For Personal Data transferred outside the EEA to countries that have not been determined by the European Commission to provide an adequate level of data protection, Persado shall ensure that appropriate data protection safeguards (e.g., the European Commission’s Standard Contractual Clauses) are in place.
Persado does not sell Personal Data or Sensitive Data.
Sources of Personal Data We Collect
We collect Personal Data from the following sources:
Why We Collect Personal Data
Most of the Personal Data we collect is provided to us directly by you so that we can bring our services and products to you or your organization. Your Personal Data is collected for our legitimate business interests or those of our service providers, as outlined below:
To provide our services as instructed or requested by you or your organization
To provide and maintain our website
To manage and administer you or your organization’s relationship with us, such as billing, marketing, providing support services, and other activities relevant to the performance of our business relationship
To contact you regarding updates to our products and services
To provide you with news and general information about us and our services (unless you have opted not to receive such information)
To detect, prevent, and address technical issues
To personalize the quality of our communications with you
To prevent and detect criminal and/or fraudulent activity that would be damaging to you or us
For employment purposes
To promote our business to new and existing clients
To analyze information so that we can improve our services.
Persado’s sales team uses analytical tools to optimize email messaging, which may involve processing and analysis of emails exchanged with the sales team. Persado may collect audio recordings of calls it receives to optimize development and learning. In such cases, we will request consent if required by applicable law.
Persado collects deidentified information that cannot reasonably be used to infer information about, or otherwise be linked to, you or any individual. Persado will not attempt to reidentify such deidentified information.
Once collected, Personal Data is retained for as long as necessary for the purposes for which the Personal Data was collected or where Persado has an ongoing legitimate business need to do so, or to comply with applicable legal, tax or regulatory requirements.
Security
Persado has implemented appropriate physical, administrative, and technical safeguards to protect the confidentiality, integrity and availability of Personal Data. Persado will take commercially reasonable steps to protect Personal Data, including requiring service providers to protect the confidentiality and security of Personal Data. However, no method of transmission over the internet is 100% secure. You understand that Persado cannot ensure the security of any information you transmit to us.
Please note that once you leave our website through an external link, or interact with or are redirected to a third-party website or application, you are no longer governed by our Policy. We are not responsible for the privacy practices of third parties and encourage you to read the privacy statements of any third-party website you are directed to.
Do Not Track
Do Not Track is a preference you can set in certain web browsers to inform websites you do not want to be tracked. You can enable or disable this by visiting the preferences or settings page of your web browser. Currently, given the lack of uniform implementation across browsers, our website does not respond to “do not track” signals.
Children
Our website is not intended for use by those under the age of 16, nor is it targeted to those under the age of 16. We do not knowingly collect or sell Personal Data from those under the age of 16 online. If you are under the age of 16, we ask that you do not provide any information on our website through any of its features, and promptly discontinue use of our website. If we become aware that we have collected Personal Data from children without verification of any required parental consent, we will take steps to remove that Personal Data from our servers.
Data Rights
Subject to applicable law, you may have the right to request and obtain information about, or copies of, your Personal Data that we process, where we obtained your information, the business or commercial purpose for collecting your information, and the third parties with whom your information is shared. You may also have the right to correct your Personal Data, or object to its processing. Lastly, you may ask us for information about when we typically delete stored information, or ask that information be anonymized or destroyed, depending on the situation and applicable laws. To inquire about any data rights you may have, please contact us at [email protected] or by telephone at 1-(888)-276-0576.
Persado endeavors to respond within 45 days of a verified Data Rights request or sooner, if required by law. When necessary, we may extend the time of our response up to 45 days, as allowed by law. To verify the request, Persado may require you, or your authorized representative, to provide certain information such as account number, username, and/or e-mail address. In certain instances, Persado will notify you that we decline to take action with respect to a request. You, or your authorized representative, may appeal Persado’s response to your request by contacting [email protected] or by telephone at 1-(888)-276-0576 within a reasonable time after you receive Persado’s response. Persado will respond to any appeal within 60 days.
California Residents
California’s Shine the Light law permits users that are residents of California to request the following information regarding our disclosure of your Personal Data to third parties for those third parties’ direct marketing purposes:
A list of certain categories of personal information that we have disclosed to certain third parties for their direct marketing purposes during the immediately preceding calendar year
The identity of certain third parties that received personal information from us for their direct marketing purposes during that calendar year
Where the nature of the third parties’ business is not reasonably determinable, examples of the products or services marketed (if we have that information).
If you are a California resident and would like to make such a request, please email us at [email protected].
EEA Personal Data
Where we process Personal Data in the context of our establishment in the EEA, for example in relation to our office(s) in the European Union, data subjects in the EEA have the right to lodge a complaint with the relevant supervisory authority listed below:
Hellenic Data Protection Authority Kifissias 1-3, PC 115 23, Athens, Greece
Tel.: +30-210 6475600
Persado as a Processor or Service Provider
Please note that Persado may process Personal Data on behalf of its customers. Where we have collected or otherwise received Personal Data from our customers for purposes of the services we provide to them, we are acting as a processor or service provide under applicable law. In such a scenario, please contact the Persado customer that provided us with your information, if you wish to assert any of your rights in relation to such data. Note, as part of its services to its customers, Persado may use automated tools to allow its customers to tailor their outreach to consumers based on consumer interactions with emails and websites. To learn more about these services, visit our Personalization page here.
Contact Us
If you have any questions about this Privacy Policy, how we process Personal Data, please contact us at [email protected] or by phone at 1-(888)-276-0576.