Propensity Privacy Policy

PROPENSITY PRIVACY POLICY
Last Modified: July 19, 2023

We at Propensity and our Affiliates are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by Propensity when you interact with us on our websites or through other channels (for example, by communicating with us or attending one of our events), and when you use our products and services.

This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. It also describes your choices and rights with respect to your Personal Data, including your rights of access and correction of your Personal Data. If you do not agree with this Privacy Policy, you should not use our websites or the Subscription Service. Customers may collect and manage Personal Data when using the Subscription Service. Propensity processes such data as a processor under the direction of our customers.

Our customers, as data controllers, are responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to collecting their customers’ Personal Data using the Subscription Service. Please see the below section "Information We Collect and Process When You Use the Subscription Service".

We update this Privacy Policy from time to time and we encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email notification. Terms not otherwise defined in this Privacy Policy will have the meaning as set forth in the Propensity Customer Terms of Service. For the purposes of this Privacy Policy “Personal Data'' shall mean any information relating to an identified or identifiable individual where such information is protected similarly as personal data or personally identifiable information under applicable Data Protection Laws.

If you have any questions about this Privacy Policy or our treatment of your Personal Data, please email success@Propensity or write to us by mail at Propensity, Inc., 19 Hampton Road, Suite 6, Exeter, NH USA, Attn: Privacy and Data Protection Officer.  

1. WHAT INFORMATION WE COLLECT ABOUT YOU

a. Information You Provide to Propensity
When you interact with us via our websites or use the Subscription Service, we may collect Personal Data and other information from you, as further described below.When You Visit Our Websites
We collect Personal Data from you when you submit web forms or interact with our websites, for example subscribing to a Propensity blog, signing up for a webinar, or requesting customer support. We may ask for your email address, first and last name, job title, and other similar business information. You are free to explore some of our websites without providing any Personal Data about yourself. Event Information When you register for a Propensity event, we collect information such as name, address, phone number, and email address. We use this information to communicate with you and in some cases facilitate your registration.
Additionally, we may share your registration data with service providers in order to provide event information and improve your experience at future Propensity events. Account and User InformationWe collect Personal Data when you sign-up for a Propensity account, create or modify user information, set preferences, or provide any other related information to access or utilize our Subscription Service. Payment Information We collect payment and billing information when you register for paid products or services. For example, we may ask you to provide a billing address, or a billing contact for your Propensity account. If you give us payment information, we use it solely as authorized by you in accordance with this Privacy Policy. You may also provide payment information, such as a credit card number or bank account numbers, when purchasing products or services.
We use secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.  Customer Testimonials We post customer testimonials and comments on our websites, which may contain Personal Data. We obtain each customer's consent via email or through other agreements between customers and Propensity prior to posting the customer's name and testimonial.
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b. Information We Collect and Process When You Use the Subscription Service
Log Files
When you visit our websites or when you use the Subscription Service, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. Usage Data We collect usage data when you or your users in your Propensity account interact with the Subscription Service.
We engage third-party providers to collect usage data. Usage data includes metrics and information regarding your use and interaction with the Subscription Service such as what product features you use the most, when an object (like a ticket) is opened and closed, and how often certain features (like workflows) are triggered in your account.  Mobile When you access or use the Subscription Service via our mobile applications, we automatically collect information such as your device model and version, operating system, or device identifier.  Third Party Integrations You may connect third party integrations to your Propensity account, which may ask for certain permissions to access data or send information to your Propensity account. It is your responsibility to review any third party integrations you authorize.  

c. Information We Collect From Other Sources
‍Propensity Partners
We may receive information about you or other users of your Propensity account from our global network of partners. We may receive this data from our deal and/or lead registration process through our partners or through our partner co-marketing agreements. Third Parties We may receive information from third party service providers, from related companies, and from our business and solution partners.  

d. Information We Process on Behalf of Customers
Our online Subscription Service allows our customers to create and share marketing, sales and customer service content. When customers use the Subscription Service, they may collect Personal Data such as first and last name, email address, physical address, phone number, or other information about you. We do not control the content of our customers' webpages or the types of Personal Data that our customers may choose to collect or manage using the Subscription Service. We store our customers' information on our service providers' servers but process it as a processor under our customers’ instructions which prohibit us from using the information except as necessary to provide and improve the Subscription Service and as required by law.Our customers control and are responsible for correcting, deleting or updating the information they process using the Subscription Service and for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to Propensity for processing purposes.

2. HOW WE USE YOUR INFORMATION

a.To Provide the Product and Services
To Market and Promote the Subscription Service
We use the information you provide to Propensity to market and promote the products, services, and other offerings. For example, we use the information, like your email or physical address, to send information or Propensity content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business. We use this information to promote the use of our services to you and share promotional and information content with you in accordance with your communication preferences. We may also reach out to you via telephone to ask about other Propensity products or services you may be interested in. If you have a call scheduled with an Propensity representative, we may record and transcribe the call. You will be notified prior to the call that the call is being recorded, and you will be offered an opportunity to opt-out of having the call recorded.

To Communicate with You About the Services
We use the data you provide to Propensity when signing up for the Subscription Service to contact you via email or in-app notification about billing, account management, and other administrative matters. We send updates to you regarding our Customer Terms of Service or other legal agreements. We may also communicate with you about security incidents via email or in-app notification. We use your information to provide customer support, such as resolving technical issues you encounter and analyzing product outages or bugs.

To Provide and Improve the Subscription Service
We use your account information and Customer Data to provide the product and services to you. For example, we use the email address you provide when signing up for the product to create your user account, and we use your payment information to process payments for paid use of the Subscription Service. We collect data about how our products and services are used by monitoring and tracking our product users. We use this data to develop and improve our products and services.  For example, we use usage data to assess trends and usage across the product to help us determine what new features or integrations our users may be interested in. We may share usage data externally but will only do so in an anonymized and/or aggregated manner to build and improve product features.  

To Secure and Protect our Product and Propensity Users
We use your account information to investigate and help prevent security incidents. We may also use this information to meet legal requirements. We use your information to verify user accounts and new product sign-ups, and to detect and prevent product abuse.

For Research and Development
We may share externally or provide other companies with statistical information about our users, but this information will not be used to identify any individual user and will only be shared on an aggregate and de-identified basis. For example, we may publish blog posts on trends or insights into how users are interacting with the product.

For Log Files
Log files are used by Propensity to provide general statistics regarding use of the websites. For these purposes, we do link this automatically-collected data to other personal data such as name, email address, address, and phone number. We also use log files to troubleshoot and investigate security incidents.

Third Parties
We receive information from third party service providers. We may receive and use this information from these service providers in combination with other information we collect through other means described in this Privacy Policy for the purposes of providing you with updates and an improved Subscription Service, like personalized communications, event promotion, and tailoring the websites or product to improve user experience.

Social Media Features
Our websites include social media features, such as the Facebook ‘like’ button and widgets, such as the share button or interactive mini-programs that run on our websites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

Public Forums
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the websites if you so request, as described in the section "To Unsubscribe From Our Communications" below.Or other purposes if we obtain your consent  

We share your data with third parties when you give us consent to do so.

3. HOW WE SHARE INFORMATION WE COLLECT
a. Compelled Disclosure
We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process. If you use the Subscription Service, Customer Data is considered Confidential Information and you should review the Confidentiality terms in the Customer Terms of Service for more information.  

4. HOW WE STORE AND SECURE YOUR INFORMATION
a. Data Storage and Security
We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Data is protected using appropriate physical, technical and organizational measures.

b. Retention of Personal Data
How long we keep information we collect about you depends on the type of information and how we collect and store it.  After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible. We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the section "How to Access & Control Your Personal Data" below.If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Propensity account.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created. The data our customers process in connection with the Subscription Service is retained according to Propensity Customer Terms of Service and Data Processing Agreement.

5. COOKIES AND SIMILAR TECHNOLOGIES
a. Cookies
When you visit our websites, sign up for a Propensity account, attend a Propensity virtual event, or request more information about Propensity, we collect information automatically using tracking technologies, like cookies and tracking pixels. Propensity and our partners use cookies or similar technologies (such as web beacons and JavaScript) to analyze trends, administer the website, monitor how visitors navigate around the websites, and to gather demographic information about our user base as a whole.

b. Advertising
We partner with third party ad networks to display advertising on our website or to manage our advertising on other sites. Our ad network partner uses cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests.  If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by using these services: https://optout.networkadvertising.org/ or https://optout.aboutads.info/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising you will continue to receive generic ads.

c. Third Party Tracking Technologies
The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy.

6. HOW TO ACCESS AND CONTROL YOUR PERSONAL DATA
a. Reviewing, Correcting and Removing Your Personal Data
You have the following data protection rights:
- You can request access, correction, updates or deletion of your Personal Data.
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- You can object to our processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data.
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- If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
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- You have the right to complain to a data protection authority about our collection and use of your Personal Data.

Contact details for data protection authorities in the EEA are available here).To exercise any of these rights, please contact us at success@propensity.com or by mail to Propensity, Inc., 19 Hampton Road, Suite 6, Exeter, NH 03833 USA, Attention: Privacy and Data Protection Officer. We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of the action we have taken.If you are a customer, prospect, or otherwise interact with an Propensity customer that uses our Subscription Service and would like to access, correct, amend or delete your data controlled by the customer, please contact the relevant customer directly. Propensity acts as a processor for our customers and will work with our customers to fulfill these requests when applicable.

b. Anti-Spam Policy
Our Acceptable Use Policy applies to us and to our customers and, among other things, prohibit use of the Subscription Service to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the Subscription Service of an "opt-out" mechanism and other required information. We require all of our customers to agree to adhere to the Acceptable Use Policy at all times, and any violations of the Acceptable Use Policy by a customer can result in immediate suspension or termination of the Subscription Service.

c. To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our emails, updating your communication preferences, or by contacting us at success@Propensity or write to us by mail at Propensity, Inc., 19 Hampton Road, Suite 6, Exeter, NH USA, Attention: Privacy and Data Protection Officer. Customers cannot opt out of receiving transactional emails related to their account with us or the Subscription Service.

d. To Unsubscribe From Our Customers' Communications
Our customers are solely responsible for their own emails and other communications; we cannot unsubscribe you from their communications.

7. CALIFORNIA PRIVACY RIGHTS
a. Applicability
This section applies only to California consumers. For purposes of this section "Personal Information" has the meaning given in the California Consumer Privacy Act (“CCPA”). It describes how we collect, use, and share California consumers' Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act ("CCPA") requires businesses to disclose whether they sell Personal Information. Propensity is a business, and does not sell Personal Information. We may share Personal Information with third parties 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 Information.
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b. How We Collect, Use, and Share your Personal Information
We have collected the following statutory categories of Personal Information in the past twelve (12) months:- Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or from third party sources.

- Commercial information, such as subscription records. We collect this information directly from you.

- Internet or network information, such as browsing and search history. We collect this information directly from your device.

- Geolocation data, such as IP address. We collect this information from your device.

- Financial information, such as Payment Information or financial account numbers in the process of providing you with a subscription. We collect this information from you.

- Inferences.

- Other Personal Information, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the Subscription Service. The business and commercial purposes for which we collect this information are described in Section 2 of this Privacy Policy. The categories of third parties to whom we "disclose" this information for a business purpose are described in Section 3 of this Privacy Policy.

c. Your California Rights
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months. The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions. The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights. Propensity does not sell Personal Information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018).

d. How to Exercise your California Rights
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your Personal Information. Please use the contact details below, if you would like to: - Access this policy in an alternative format;- Exercise your rights;- Learn more about your rights or our privacy practices; or- Designate an authorized agent to make a request on your behalf.

8. DATA PROTECTION OFFICER
If you have any questions about this Privacy Policy or our privacy practices, or if you have a disability and need to access this notice in a different format, please contact us at success@propensity.com or write to us by mail at Propensity, Inc., 19 Hampton Road, Suite 6, Exeter, NH USA, Attn: Privacy and Data Protection Officer.

9. OTHER IMPORTANT PRIVACY INFORMATION
a. We Never Sell Personal Data
We will never sell your Personal Data to any third party.

b. Information About Children
The websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect Personal Data about children under 16. If you believe that we have collected Personal Data about a child under 16, please contact us  at support@propensity.com, so that we may delete the information.