- Entity Responsible for Personal Data
Our websites and services may contain links to other websites, applications, and services maintained by third parties. The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy policies, which you should review to better understand their privacy practices.
- What Personal Data do we collect?
2.1 Personal Data we may collect directly from you
The Personal Data we may collect directly from you includes identiﬁers, personal, professional or work-related information, ﬁnancial information, business and commercial information, and visual or graphic information. We collect such information in the following situations:
- If you express an interest in obtaining additional information about our products or services; request customer support; use our “Contact Us” or similar features; register to use our products or services; or download certain content, we may require that you provide to us your contact information, such as your name, job title, company name, address, phone number, and email address;
- If you register to use our products or services, we may require that you provide to us your ﬁnancial and billing information, such as billing name and address, credit card number or bank account information;
- If you interact with our websites or emails, we automatically collect information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identiﬁers, which may qualify as Personal Data (please see the “What device and usage data we process” section, below) using cookies, web beacons, or similar technologies;
- If you use and interact with our services, we automatically collect information about your device and your usage of our services through log ﬁles and other technologies, some of which may qualify as Personal Data (please see the “What device and usage data we process” section, below);
- If you voluntarily submit certain information to our services, such as ﬁlling out a survey about your user experience, we collect the information you have provided as part of that request; and
- If you visit our oﬃces, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival.
If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us by using the information in the “Contact Us” section below or posted at our website.
2.2 Personal Data we may collect from other sources
We may also collect information about you from other sources including customers and other third parties from whom we get Personal Data and from publicly available information. We may combine this information with Personal Data provided by you. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide products or services that may be of interest to you. The Personal Data we collect from other sources includes identiﬁers, professional or employment-related information, education information, business or commercial information, visual or graphic information, internet activity information, and inferences about preferences and behaviors. In particular, we collect or may collect such Personal Data from the following sources:
- Third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media proﬁles, LinkedIn URLs and custom proﬁles, for purposes of targeted advertising, delivering relevant email content, event promotion and proﬁling, determining eligibility and verifying contact information;
- Another individual at your organization who may provide us with your business contact information for the purposes of obtaining services.
- What device and usage data do we process?
We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies to automatically collect information that may contain Personal Data as you navigate our websites, our services, or interact with emails we have sent to you.
3.1 Device and usage data
As is true of most websites, we gather certain information automatically when individual users visit our websites. This information may include identiﬁers, business or commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identiﬁcation numbers and features, location, browser type, plug-ins, integrations, Internet service provider and/or mobile carrier, the pages and ﬁles viewed, searches, referring website, app or ad, operating system, system conﬁguration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the websites. This information is used to analyze overall trends, help us provide and improve our websites, offer a tailored experience for website users, and secure and maintain our websites.
In addition, we gather certain information automatically as part of your use of our products and services. This information may include identiﬁers, business or commercial information, and internet activity information such as IP address (or proxy server), mobile device number, device and application identiﬁcation numbers, location, browser type, Internet service provider or mobile carrier, the pages and ﬁles viewed, website and webpage interactions including searches and other actions you take, operating system and system conﬁguration information and date and time stamps associated with your usage. This information is used to maintain the security of the services, to provide necessary functionality, to improve performance of the services, to assess and improve customer and user experience of the services, to review compliance with applicable usage terms, to identify future opportunities for development of the services, to assess capacity requirements, to identify customer opportunities, and for the security of Saltegra generally (in addition to the security of our products and services). Some of the device and usage data collected by the services, whether alone or in conjunction with other data, could be personally identifying to you. Please note that this device and usage data is primarily used to identify the uniqueness of each user logging on (as opposed to speciﬁc individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers.
3.2 Cookies, web beacons and other tracking technologies on our website and in email communications
When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer browsing preferences, and improve and customize your browsing experience.
We may also use web beacons and pixels on our websites and in emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies to operate and improve our websites and marketing emails. For instructions on how to unsubscribe from our marketing emails, please see Section 9.4 below.
3.3 Notices on behavioral advertising and opt-out for website visitors
As described above, we or one of our partners may place or read cookies on your device when you visit our website for the purpose of serving targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). To opt-out of targeted advertising that is provided to us, please contact us by using the information in the “Contact Us” section below or posted at our website.
3.4 Opt-Out from the setting of cookies on your individual browser
In many cases you may opt-out from the collection of non-essential device and usage data on your web browser (see the “What device and usage data we process” section, above) by managing your cookies at the browser or device level. Please note, however, that by blocking or deleting cookies and similar technologies used on our website, you may not be able to take full advantage of the websites.
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites. Saltegra takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
3.5 Social Media Features
Our website may use social media features (“Social Media Features”). Social Media Features may allow you to post information about your activities on our website to outside platforms and social networks. Social Media Features may also allow you to highlight information we have posted on our website. Social Media Features are either hosted by each respective platform or hosted directly on our website. To the extent the Social Media Features are hosted by the platforms themselves, and you click through to these from our websites, the platform may receive information showing that you have visited our website. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our website with your social media proﬁle.
Saltegra may also allow you to log in to our website using sign-in services. These services authenticate your identity and provide you the option to share certain Personal Data from these services with us such as your name and email address to pre-populate our sign-up form.
Your interactions with Social Media Features are governed by the privacy policies of the companies providing them.
3.6 Telephony log information
If you use certain features of our services on a mobile device, we may also collect telephony log information (like phone numbers, time and date of calls, duration of calls, SMS routing information and types of calls), device event information (such as crashes, system activity, hardware settings, browser language), and location information (through IP address, GPS, and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and cell towers).
- Purposes for which we process Personal Data and the legal bases on which we rely
We collect and process your Personal Data for the following purposes. Where required by law, we obtain your consent to use and process your Personal Data for these purposes. Otherwise, we rely on another authorized legal basis (including but not limited to the (a) performance of a contract or (b) legitimate interest) to collect and process your Personal Data.
- Promoting the security of our website and services: We process your Personal Data by tracking use of our website and services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent it is necessary for our legitimate interest in promoting the safety and security of our services, systems and applications and in protecting our rights and the rights of others;
- Providing necessary functionality: We process your Personal Data to provide our website and to perform our contract with you for the use of our services;
- if we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to provide you with the necessary functionality required for your use of our website and services;
- Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of a consulting agreement or service agreement;
- Handling contact and user support requests: If you ﬁll out a contact web form or request user support, or if you contact us by other means including via a phone call, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulﬁlling your requests and communicating with you;
- Managing payments: If you have provided ﬁnancial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you;
- Developing and improving our website and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our website and services to the extent it is necessary for our legitimate interest in developing and improving our website and services and providing our users and customers with more relevant content and product and service offerings, or where we seek your valid consent;
- Assessing and improving user experience: We process device and usage data as described in Section 3.1 above, which in some cases may be associated with your Personal Data, to analyze trends and assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the product or service offering, or where we seek your valid consent;
- Reviewing compliance with applicable contract terms: We process your Personal Data to review compliance with the applicable usage terms in our customer’s contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms;
- Assessing capacity requirements: We process your Personal Data to assess the capacity requirements of our services to the extent that it is in our legitimate interest to ensure that we are meeting the necessary capacity requirements of our services; Identifying customer opportunities: We process your Personal Data to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers;
- Registering oﬃce visitors: We process your Personal Data for security reasons, to register visitors to our oﬃces and to manage agreements that visitors or customers may be required to sign, to the extent such processing is necessary for our legitimate interest in protecting our oﬃces and our conﬁdential information against unauthorized access;
- Displaying personalized advertisements and content: We process your Personal Data to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our products or services or, where necessary, to the extent you have provided your prior consent (please see the “Your rights relating to your Personal Data” section, below, to learn how you can control how the processing of your Personal Data by Saltegra for personalized advertising purposes);
- Sending marketing communications: We may process your Personal Data or device and usage data, which in some cases may be associated with your Personal Data, to send you marketing information, product or service recommendations and other non- transactional communications about us and our aﬃliates and partners, including information about our products, services, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see the “Your rights relating to your Personal Data” section, below, to learn how you can control the processing of your Personal Data by Saltegra for marketing purposes);
- and Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.
If we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.
- Who do we share Personal Data with?
We may share your Personal Data as follows:
- Partners and Service Providers: With our partners and contracted service providers for the purposes or providing products or services to you;
- Customers With Whom You Are Aﬃliated: If you use our services, we may share your Personal Data with your aﬃliated customer responsible for your access to the services to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies;
- Third party networks and websites: With third-party social media networks, advertising networks and websites, so that Saltegra can market and advertise on third party platforms and websites;
- Professional Advisers: In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers – including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data;
- and Third Parties Involved in a Corporate Transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by third party, with such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaﬃliated third party.
We may also share anonymous or de-identiﬁed usage data with Saltegra’s partners and service providers for the purpose of helping Saltegra in such analysis and improvements. Additionally, Saltegra may share such anonymous or de-identiﬁed usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our services.
Anyone using our communities, forums, blogs, or chat rooms on our websites may read any Personal Data or other information you choose to submit and post.
For more information on the recipients of your Personal Data, please contact us by using the information in the “Contact Us” section, below or posted at our website.
- International transfer of Personal Data
We do not currently share, transfer or store your Personal Data outside of the United States of America. If at any time we do intend to share, transfer or store your Personal Data outside of the United States of America, we will only share, transfer or store your Personal Data outside of the United States of America with your prior consent.
Our website is not directed at children. We do not knowingly collect Personal Data from children under the age of 16. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contact Us” section below or posted at our website and we will take steps to delete their Personal Data from our systems.
- How long do we keep your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of collection (see the “Purposes for which we process Personal Data and the legal bases on which we rely” section, above) or as long as required to fulﬁll our legal obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation). After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data. For more information on data retention periods, please contact us by using the information in the “Contact Us” section below or posted at our website.
- Your rights relating to your Personal Data
9.1 Your rights
You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:
- Access your Personal Data held by us; Know more about how we processed your Personal Data; Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
- Erase or delete your Personal Data (also referred to as the right to be forgotten), to the extent permitted by applicable data protection laws;
- Restrict our processing of your Personal Data, to the extent permitted by law; Transfer your Personal Data to another controller, to the extent possible (right to data portability); Object to any processing of your Personal Data. Where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any speciﬁc reason for such objection;
- Opt out of certain disclosures of your Personal Data to third parties; If you’re under the age of 16, opt in to certain disclosures of your Personal Data to third parties;
- Not be discriminated against for exercising your rights described above; Not be subject to a decision based solely on automated processing, including proﬁling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites or in our services;
- and Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.
9.2 How to exercise your rights
To exercise your rights, please contact us by using the information in the “Contact Us” section below or posted at our website. We try to respond to all legitimate requests within one month and will contact you if we need additional information from you in order to honor your request. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of an Saltegra customer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information
Some registered users may update their user settings, proﬁles, organization settings and event registrations by logging into their accounts and editing their settings or proﬁles.
To update your billing information, discontinue your account or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in the “Contact Us” section below or posted at our website.
9.3 Your preferences for email and SMS marketing communications
If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from Saltegra by notifying us using the information in the “Contact Us” section below or posted at our website.
Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.
9.4 Your preferences for telemarketing communications
If we contact you, directly or indirectly, using telemarketing communications, you can always let us know during a telemarketing call that you do not want to be called again for marketing purposes.
- How we secure your Personal Data
We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use.
While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, please contact us by using the information in the “Contact Us” section below or posted at our website.
- Contact Us
Saltegra Consulting LLC (Attention: Privacy Team) 4041 MacArthur Blvd, Suite 400 Newport Beach, CA 92660 USA
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.
- Additional Disclosures for California Residents
The California Consumer Privacy Act requires businesses to disclose whether they sell Personal Data. As a business covered by the CCPA, we do not sell Personal Data. We may share Personal
Data with third parties or allow them to collect Personal Data from our sites or services if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Data, or if you use Saltegra websites or services to interact with third parties or direct us to disclose your Personal Data to third parties.
California law requires that we detail the categories of Personal Data that we share or disclose for certain “business purposes,” such as disclosures to partners or service providers that assist us with offering or providing our products or services or marketing our products. We disclose the following categories of Personal Data for our business purposes:
- Business and commercial information;
- Internet activity information;
- Financial information;
- Professional and work-related information;
- Customer education information;
- and Inferences drawn from any of the above information categories.
California law grants state residents certain rights, including the rights to access speciﬁc types of Personal Data, to learn how we process Personal Data, to request deletion of Personal Data, and not to be denied goods or services for exercising these rights.
If you are a California resident under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to our website. Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another user.
We may need to verify your identity and place of residence before completing your rights request.