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Partnered Privacy Policy

Last Modified: November 6th, 2020

Welcome to Partnered, an account-based partnership platform that provides users with a simpler way to manage sales partnerships. From the very beginning, our goal has been to design privacy into our platform in a way that respects the rights of our users and the needs of their partners and target companies. This Privacy Policy explains how Partnered collects, uses, and shares the personal information we collect from visitors to our website (“Site”), as well as how we collect and use information from our Corporate Customers and our Corporate Customers’ end-users (collectively referred to as our “Customers”) during the provision of our services to those Customers (“Service(s)”).

You should read this full Privacy Policy to understand what data we collect, how we use it, and the limited circumstances in which we may share it. By accessing or using our Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

Please note that if you reside in the European Union or other regions outside the United States, information collected through our Service will be transferred to and processed in the U.S. or elsewhere. While Partnered abides by the EU’s Standard Contractual Clauses governing transfers to non-EU countries, these locations may not have the same data protection laws as the country in which you initially used our Services. By using our Services, you consent to any transfer and processing in accordance with this Policy. If you have any questions, please contact us at hello@partnered.io. For the purposes of EU data protection laws ("Data Protection Law"), Partnered is data controller of the information collected from visitors via the Site and where we process basic contact details of our Corporate Customers for the purposes of entering into a contract with those Corporate Customers.

1 What Information We Collect and How We Use It.

We collect personal and non-personal information from our Site visitors in order to provide you with a personalized, useful and efficient experience, and we collect personal and non-personal information from our Customers to provide them with our Services.

We collect this information for the following purposes:

  • To provide, maintain, promote, protect, and improve the Services, to develop new ones, and to protect Partnered and our users;
  • Manage our organization and its day-to-day operations;
  • Communicate with individuals, including via email, text message, social media and/or telephone calls;
  • Market to individuals, including through email, direct mail, phone, or text message;
  • Administer, improve, and personalize our Services;
  • Facilitate client benefits and services, including customer support;
  • Conduct research and analytics on our client base and our Services;
  • Help maintain the safety, security, and integrity of our property and Services, technology assets, and business;
  • Defend, protect, or enforce our rights or applicable contracts and agreements;
  • Prevent, investigate, or provide notice of fraud or unlawful or criminal activity; and
  • Comply with legal obligations.

The categories of information we collect can include:

Information that you provide to us

  1. Site visitor information. We collect your personal information (e.g., name, postal address, email address) in order for you to communicate with us. We may also collect any communications that you exchange with us, as well as any information you provide if you take part in any interactive features of the Site (e.g., promotions, surveys, etc.).
  2. User information. We collect information that Corporate Customers and their end users provide to us when they set up an account with us, use our Services, or communicate with us. For example, we may request Corporate Customers’ personal information (e.g., name, postal address, email address, telephone number) or applicable business information (e.g., company name, title, social profile links) when the Corporate Customer registers for an account or purchases our Service. We may also collect any communications that Corporate Customers or their end users exchange with us, as well as any information provided if they take part in any interactive features of the Service (e.g., promotions, surveys, etc.). We collect information Corporate Customers and their end users provide when they create content or commentary on our Service in the form of profile information, content posts, comments, and the like.  Please note that User Content is published on our Site, but it will only be viewable by other users with whom you have formed connections or when you have designated it for publication.  
  3. Business content. We collect information that you may upload through the Site or push through to us through our API or through the API of one of our third-party service providers (“Business Content”).

Information we receive from social networking sites

When Site visitors and our Corporate Customers’ end-users interact with our Site through various social media, such as when they share Partnered content on LinkedIn, Google or other sites, or when Corporate Customers login through your Salesforce, LinkedIn or Google account, we may receive information from the social network including, without limitation, profile information, profile picture, gender, user name, user ID associated with that social media account, age range, language, country, friends list, and any other information which the Site visitors or Corporate Customers permit the social network to share with third parties. The data we receive is dependent upon privacy settings with the social network. Please review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our Site or Service.

Address book information

With the permission of Corporate Customers, Partnered may access their contact list available on their systems, in email accounts, or in Salesforce, Google or LinkedIn accounts so that they can locate contacts on the Service and invite those contacts to connect with our Service. Partnered obtains an individual’s permission via an opt-in onboarding process within the Service. When we send the invitation to those contacts to join the Service, we will include the Corporate Customer’s name and business name to let them know the identity of the person extending the invitation. After sending these invitations, we may also send reminder emails to those invitees on behalf of the Corporate Customer, which may also include the Corporate Customer’s name and business name. We will store these contacts for purposes of alerting the Corporate Customers when those contacts join the Service at a later time so that Corporate Customers may connect with them on the Service, solely to the extent that such contacts have not opted out of this feature. Please note that there is an option for Corporate Customers to opt out within the Service.

Information from other sources

We may obtain information from other sources, such as third-party information providers, or through mergers and acquisitions, and combine this with information previously collected. In these cases, our Privacy Policy governs the handling of the combined personal information.

We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you. We may also send you Service-related emails or messages (e.g., account verification, purchase confirmation, changes or updates to features of the Service, technical and security notices). Similarly, if you request information from us through an online contact form or if you email us, we collect the information you provide (e.g., name, telephone number, email address) so that we can respond to you. For more information about your communication preferences, see “Control Over Your Information” below.

2 How We Use Cookies and Other Tracking Technology To Collect Information

Cookies. We, and our third party partners, automatically collect certain types of usage information when you visit our Site, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including without limitation, cookies, web beacons, file information and similar technology (collectively, “Tracking Technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our Site—for example, the site from which you came and the site to which you are going when you leave our Site, the pages you visit, the links you click, how frequently you access the Site, whether you open emails or click the links contained in emails, and other actions you take on the Site.

Mobile device information. When you access our Site from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including without limitation, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including without limitation, GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.

Analytics data. We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Site and to understand more about the demographics of our users. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

Purpose. We use or may use the data collected through Tracking Technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the Site; (b) provide custom, personalized content and information, including without limitation, targeted content and advertising; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Site; (e) diagnose or fix technology problems; and (f) otherwise plan for and enhance our Service.

Advertising. We and our third party partners may also use cookies and Tracking Technologies for advertising purposes. For more information about Tracking Technologies, please see “Third Party Tracking and Online Advertising” below.

Declining to accept Tracking Technologies. If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Site, as some features and services on our Site may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.

3 How and With Whom We Share Personal Information

We may share the information we collect from our Site and Services for the following purposes:

  • We may share your personal information with third-party service providers or business partners who help us deliver or improve our Service or who perform services on our behalf, such as identifying and serving targeted advertisements, processing payments, sending postal mail, providing back-office services, or measuring Site traffic. Note that individuals can opt in or opt out by logging into the Service and updating the communication preferences section of their settings page.
  • We may aggregate, or strip information of personally identifying characteristics, and then share that aggregated or anonymized information with third parties, including without limitation, to publish research reports.
  • We may share or disclose your personal information if we determine, in our sole discretion, that we are required to do so under applicable law or regulatory requirements, or if we reasonably believe disclosure is necessary to prevent harm or financial loss, or in connection with preventing fraud or illegal activity, and/or to enforce our Terms of Service.
  • We may share with other companies and brands owned or controlled by Partnered, Inc., and other companies owned by or under common ownership as Partnered, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy;
  • We reserve the right to transfer any information we collect in the event we sell or transfer all or a portion of our business or assets (including without limitation, any shares in the company) or any portion or combination of our products, services, businesses and/or assets. Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this Privacy Policy.

4 Customer Data

In providing our Service, our Corporate Customers may upload or push Business Content to our Service, which may include personal information or data about our Corporate Customers’ end users (all of which we call “Customer Data”). Customer Data is owned and controlled by our Corporate Customers, and any Customer Data that we maintain or process we consider to be strictly confidential. We collect and process Customer Data solely on behalf of our Corporate Customers, and in accordance with our agreements with the Corporate Customers, including without limitation the Terms of Service and the Data Processing Agreement. We do not use or disclose Customer Data except as authorized and required by our Corporate Customers and as provided for in our agreements with our Corporate Customers, including without limitation the Terms of Service and the Data Processing Agreement.

5 Control Over Your Information

Email Communications. From time to time, we may send you emails regarding updates to our Site, products or services, notices about our organization, or information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication or respond with "unsubscribe". Note that you cannot unsubscribe from certain Services-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices). For users in the European Economic Area (including the EU, the United Kingdom, Iceland, Liechtenstein, and Norway) and Switzerland (the “EEA”), we will send you marketing communications only with your prior consent. Please see the section “GDPR: Information for EEA Users” below.

Modifying Account Information. Where Corporate Customers have an online account with us, they have the ability to modify certain information in their account (e.g., your contact information) through “profile,” “account,” “settings,” or “preferences” options provided on the Site or Service. If Corporate Customers have any questions about modifying or updating any information in their account, please contact us at the email or postal address provided below. Please note that Partnered does not own or control the Business Content uploaded to our Service by our Corporate Customers, and cannot modify or delete Business Content except at the request of our Corporate Customer, or as permitted by our Terms of Service.

6 Third Party Tracking and Online Advertising

We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our Site over time so that they may play or display ads that may be relevant to your interests on our Site as well as on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including without limitation, hashed data, click stream information, browser type, time and date you visited the Site, and other information. This information is used to display targeted ads on or through our Site or on other websites or apps, including without limitation, on Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org/choices, and/or the Digital Advertising Alliance’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your settings on Facebook and the other websites or apps we may use to display targeted ads. You may also be able to opt out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at http://www.youronlinechoices.eu. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at hello@partnered.io.

7 Data Protection and Security

Deactivating your account or deleting your personal data. Except as described in the “Customer Data” section above, you can choose to deactivate your account so that you are no longer included in the Service. You may also request that we delete information about you. You can request deactivation or deletion by contacting us using the information listed in the “Contact Us” section below.

Data retention. Following termination or deactivation of your user account, Partnered may retain your information for a commercially reasonable time for record keeping, audit or other purposes. Any Business Content, including without limitation any Customer Data that we have access to, shall be retained, stored, and deleted according to our agreement with our business customer, including without limitation the Terms of Service and the Data Processing Agreement. For individuals based in the EEA we store personal data for as long as necessary to fulfill the purposes for which we collect the data, except if required otherwise by law.

Data storage and transfer. Your information may be stored and processed in the United States or any other country in which Partnered or its subsidiaries, affiliates or service providers maintain facilities. In addition, if you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Policy. Such transfers are made pursuant to appropriate safeguards. If you wish to enquire further about these transfers, please see our standard Data Processing Agreement[a] or contact us using the details set out at the end of this Privacy Policy.

Keeping information safe. Partnered cares about the security of your information and uses industry standard, commercially reasonable physical, technical and organizational measures designed to preserve the integrity and security of all information we collect. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Customer obligations. Partnered’s obligations with respect to Customer Data are defined in our agreements with our customers, including without limitation the Terms of Service, and are not made part of this Privacy Policy. Each customer will remain responsible for the privacy and security of the Customer Data that it collects and processes and for compliance with data protection laws that may apply to the collection, processing and disclosure of Customer Data through the Services.

8 Links to Third-Party Websites and Services

For your convenience, our Site and Services may provide links to third-party websites or services that are not governed by this Privacy Policy. To the extent that any linked third-party websites or services you visit are not owned or controlled by Partnered, we are not responsible for those websites’ or services’ content or information practices. We encourage you to review the privacy policies of any site or service before providing any personal information.

9 Children’s Privacy

Partnered’s Site and Services are intended for use strictly by adults. We do not knowingly solicit or collect personal information from children under the age of 13. If we learn that any personal information has been collected inadvertently from a child under 13, we will delete the information as soon as possible. If you believe that we might have collected information from a child under 13, please contact us at hello@partnered.io.

10 Changes to Privacy Policy

We reserve the right to change this Privacy Policy from time to time in our sole discretion. If we make minor changes to the Policy without materially changing your rights, we will post the modified Policy on our website. We will notify you by email, through the Partnered Service, or by presenting you with a new Privacy Policy to accept if we make a modification that materially changes your rights. When you use the Partnered Service after a modification is posted, you are telling us that you accept the modified terms.

11 Your California Privacy Rights

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may make one request each year by emailing us at hello@partnered.io or mailing us at 417 Adams St, Suite 1L, Hoboken, NJ 07030.

12 GDPR: Information for EEA Users

Legal basis for processing in the EU

In the EU, the purposes for which we process your personal data are:

  1. Where we need to perform the contract we are about to enter into or have entered into with you for the Service;
  2. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and
  3. Where we need to comply with a legal or regulatory obligation in the EU.

Please contact us at hello@partnered.io if you need details about the specific legal basis we are relying on to process your personal data where more than one legal basis has been set out.

What rights do I have?

If you are located in the EU, you have the following rights under the General Data Protection Regulation (GDPR) in respect of your personal data that we hold:

a) Right of access. The right to obtain access to your personal data.

b) Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.

c) Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.

d) Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.

e) Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.

f) Right to object. You have a right to object to processing based on legitimate interests and direct marketing.

You are providing consent

As described in this Policy, when Partnered processes your data at the direction of one of our Corporate Customers, we act as their Processor and comply with requests they send us under GDPR. As a Partnered user, we rely on your consent as a lawful basis for processing personal data to provide you with access to our Services, to enable the Services to function as expected, to communicate with you in response to customer service inquiries, to deliver service-related emails, and to deliver marketing or promotional communications.

How may I exercise my individual rights?

Partnered account holders and users may exercise their rights regarding their personal data as follows:

  • You can access your personal data through your account settings on the Partnered Site or by contacting us to request a personal data report at hello@partnered.io;
  • You may withdraw your consent to receive cookies by adjusting your browser settings;
  • You may withdraw your consent to receive marketing or promotional communications at any time by clicking the “unsubscribe” link found within email updates from Partnered and changing your contact preferences;
  • Except as described in the section “Customer Data” above, you can request deletion of your data as described in the section “De-Activating Your Account or Deleting Your Personal Data.”

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact the appropriate data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm. We encourage you to first reach out to us by using the contact details set out below so that we can have an opportunity to address your concerns directly, and so that we may find a solution together before you lodge a complaint.

13 Contact Us

For additional inquiries about this Privacy Policy, or if you wish to remove any of your personal information from our records, please send us an email at hello@partnered.io, or contact us at:

Partnered, Inc.

417 Adams St, Suite 1L

Hoboken, NJ 07030