Effective date of this privacy policy is May 24, 2018.

This privacy policy applies to www.predictiveresponse.com owned and operated by Predictive Response. This privacy policy describes how Predictive Response collects and uses the personal information you provide on our web site: www.predictiveresponse.com. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

If you have questions or complaints regarding our privacy policy or practices, please contact us at:

Predictive Response, Inc.
75 Broadway, Suite 202
San Francisco, CA 94111
Attn: Legal Department
Email: privacy@predictiveresponse.com

Predictive Response participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. Predictive Response is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List.

Predictive Response complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Predictive Response has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit Privacy Shield.

Predictive Response is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Predictive Response complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Predictive Response is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC) and/or the Department of Transportation. In certain situations, Predictive Response may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Dispute Resolution

In compliance with the Privacy Shield Principles, Predictive Response commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Predictive Response at:

Predictive Response, Inc.
75 Broadway, Suite 202
San Francisco, CA 94111
Attn: Legal Department
Email: privacy@predictiveresponse.com

Predictive Response has further committed to refer unresolved Privacy Shield complaints to VeraSafe an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit VeraSafe for more information or to file a complaint. The services of VeraSafe are provided at no cost to you.

You may have the option to select binding arbitration under the Privacy Shield Panel for the resolution of your complaint under certain circumstances. For further information, please see the Privacy Shield website. To learn more about the Privacy Shield Framework, and to view Predictive Response’s certification, please visit Privacy Shield.

Collection of Information

We collect non-personally identifiable information about you in a number of ways, including tracking your activities through your IP address or most-recently-visited URL. However, we do not collect any personally identifiable information about you unless you voluntarily submit contact information to us, such as name, phone, email address, and mailing address by filling out a form or survey, registering your email address with us or emailing us. We may also collect personal information from you at other points on our site that state that personal information is being collected.

Disclosure of Information

We do not sell or rent your personally identifiable information to any third parties. We will share your personal information with third parties only in the ways that are described in this privacy policy.

We may provide your personal information to companies that provide services to help us with our business activities such as offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.

Use of Information

We use personally identifiable and non-personally identifiable information for internal marketing purposes, for trend analysis, for pattern detection, and for site administration. However, we do not use personally identifiable information collected from the website to send unsolicited mailings to you. Of course, if applicable, we do use personally identifiable information to perform the services for which such data was collected (i.e., if you sign up for an email newsletter, we will send the email newsletter to the address you provide us).

We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purposes, when we ask for this information. For example, if you purchase a product/service but do not wish to receive any additional marketing material from us, you can indicate your preference on by clicking on the unsubscribe link contained in the footer of the email.

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by clicking on the unsubscribe link in the footer included in each newsletter or communication or by emailing us at the reply address of the email or you may contact us by phone at 415-840-0564.

Third Party Sites

This policy only addresses our activities from our servers. Other sites (including those that we link to within an advertisement, article or otherwise, and third-party sites or services with which we offer or co-brand) may have their own policies, which we do not control, and thus are not addressed by this policy.

The forms referenced for Salesforce.com on our site will connect directly with websites owned and operated by Salesforce.com who have their own corporate privacy policy, and the policies contained herein do not apply to the data collected by them.

Testimonials

We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at privacy@predictiveresponse.com.

Social Media Widgets

Our Web site includes Social Media features, such as the Facebook and Twitter buttons and Widgets, such as the Share this button or interactive mini-programs that run on our site. These features may collect your IP address, which page you are visiting on our site, 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 Site. Your interactions with these features are governed by the privacy policy of the company providing it.

Review and Removal of Your Personally Identifiable Data

Upon request Predictive Response will provide you with information about whether we hold any of your personal information. If you provide us with personally identifiable information to have us perform ongoing services to you, we will provide you with a way to review the information we have on file and either change or remove such data. To do so, please notify us via post or email at the address above and we will provide you with your contact information for review. To make changes, send us the changes and we will respond to your request for access within thirty (30) days of the request. Unfortunately, to the extent that such information is also stored in other databases, we cannot always ensure that such corrections or deletions will reach the other databases. If you wish to have information you provided to us online removed from our records, please provide us with the information as you submitted it to us at the address above. We will use all reasonable efforts to ensure that your information is removed from our records.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Tracking Technologies

As is true of most web sites, we also gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.

Predictive Response and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. To manage Flash cookies, please go to the Macromedia site.

Behavioral Targeting

We partner with a third-party to either display advertising on our website or to manage our advertising on other sites. Our third-party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here) Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Legal Disclosure

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web site.

In certain situations, Predictive Response may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Security

We use industry-standard methods to protect your personally identifiable information from unauthorized access. Among other techniques, we usually store such information on a computer behind our “firewall” in a secure location, and we often restrict the number of employees internally who can access such data. Of course, there is no such thing as “perfect security” on the Internet.

Personal Information

By using our Websites, Services, and Marketing Activities you expressly give your consent for the collection and use of your personal information in compliance with this Privacy Policy. This does not affect lawful processing under applicable laws based on other legal basis such as contractual obligation, compliance with applicable laws, and legitimate purposes.

Right to Access or Correct Personal Information

If Predictive Response processes your personal information on behalf of or at the direction of one of our subscribers, you should first look to that subscriber for assistance regarding the modification or correction of your personal information.

You have the right to access and correct your personal information. If you want to review or correct your personal information, you can contact us through our Contact Us page, or you may send us an email to info@predictiveresponse.com.

Right to Delete Personal Information (“Right to be Forgotten”)

If Predictive Response processes your personal information on behalf of or at the direction of one of our customers, you should first look to that customer for assistance regarding the removal of your personal information.

You have the right to request deletion of personal information we hold about you and we have the obligation to erase your personal information, where:

  • the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed,
  • you withdraw consent on which the processing is based and where there is no other legal ground for the processing,
  • you object to the processing and there are no overriding legitimate grounds for the processing,
  • the personal information has been unlawfully processed, or
  • the personal information has to be erased for compliance with a legal obligation in the European Union or a Member State law to which Predictive Response is subject.

If you want to request removal of your personal information from our Websites or Services, you can contact us through our Contact Us page, or you may send us an email to info@predictiveresponse.com. You can also request closure of your account. We will respond to your request within 30 days.

In some cases, we may not be able to remove your personal information, in which case we will let you know that we are unable to do so and why.

Right to Data Portability

If Predictive Response processes your personal information on behalf of or at the direction of one of our customers, you should first look to that customer for assistance regarding the data portability of your personal.

You have the right to receive or transfer a copy of your personal information, where:

  • we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for the processing, and
  • personal information is processed by automatic means.

This copy will be provided to you in a common machine-readable format. You may also require us to transmit it to another party where this is technically feasible.

If you want to request a copy of your personal information, you can contact us through our Contact Us page, or you may send us an email to info@predictiveresponse.com.

Right to Restrict Personal Information Processing

If Predictive Response processes your personal information on behalf of or at the direction of one of our customers, you should first look to that customer for assistance regarding the data portability of your personal.

You have the right to request the restriction of processing of your personal information, where:

  • you contest the accuracy of the personal information until we take sufficient steps to correct or verify its accuracy,
  • where the processing is unlawful but you do not want us to erase the personal information,
  • where we no longer need the personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims, or
  • where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether Predictive Response has compelling legitimate grounds to continue processing.

Where personal information is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise, or defense of legal claims. This right includes restricting the processing of your personal information to only include storage of your personal information (e.g. during the time when Predictive Response assesses whether you are entitled to have personal information erased).

If you want to request restriction of processing of your personal information, you can contact us through our Contact Us page, or you may send us an email to info@predictiveresponse.com.

Right to object to processing justified on legitimate interest grounds

If Predictive Response processes your personal information on behalf of or at the direction of one of our customers, you should first look to that customer for assistance regarding the data portability of your personal.

Where we are relying upon legitimate interest to process personal information, you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the personal information for the establishment, exercise, or defense of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

If you want to object to the processing of your personal information, you can contact us through our Contact Us page, or you may send us an email to info@predictiveresponse.com.

Right to be informed of the appropriate safeguards where personal information is transferred to a third country or to an international organization

If Predictive Response processes your personal information on behalf of or at the direction of one of our customers, you should first look to that customer for assistance regarding the data portability of your personal.

Refer to the Terms of Service for information on the safeguards that have been put in place to protect your personal information for transfer outside of the European Economic Area. For transfers to countries without an adequacy decision by the European Commission, Predictive Response puts appropriate safeguards through contractual obligations.

Right to Withdraw Consent

If Predictive Response processes your personal information on behalf of or at the direction of one of our customers, you should first look to that customer for assistance regarding the data portability of your personal.

Where you have provided us with your consent to process personal information, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You can do this by:

  • using certain web browser and opt-out options
  • contacting us through our Contact Us page
  • following the unsubscribe instructions included in emails
  • sending an email to info@predictiveresponse.com

Right to Submit Complaints or Report Abuse

You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the processing of your personal information infringes applicable laws.

If you need to report abuse, please contact us by email at abuse@predictiveresponse.com.

Choice

Our Services collect personal information for our customers. As a data processor of this personal information on our customer’s behalf, Predictive Response has limited ability to access personal information our customers submit to our services. If you are a data subject for whom a customer has submitted personal information to the services and would like your information not to be disclosed to a third-party or to be used for a purpose that is materially different from the purpose(s) for which the personal information was originally collected, then you should contact the customer directly. Concerns with personal information hosted or transmitted at the direction of our customers may be reported through our Contact Us page. We will refer your requests to the appropriate customer.

Subscriber Data Integrity and Purpose Limitation

As a data processor, Predictive Response hosts, transmits, discloses, and processes data, which may include personal information about EU personnel of our subscribers administering, using or supporting the Services. Predictive Response may process data to provide services, to prevent or address technical or service problems, to follow the instructions of our customers and their personnel who submitted the personal information, or in response to contractual or legal requirements. Predictive Responsedoes not control or own the data submitted by its customers, or their internet clients or end users, to the services. Predictive Response may share personal information with its subsidiaries, contractors, or third-parties if Predictive Response under goes a business transaction, such as a merger, acquisition by another company or sale of all or substantially all of its assets.

Data Subject Rights to Subscriber Data

Predictive Response acknowledges that you have the right to access your personal information. Predictive Response has no direct relationship with the individuals whose personal information our services process on behalf of our customers. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate personal information should direct his or her query to the appropriate customer (i.e., the data controller). Our customers have the ability to fulfill these requests, and Predictive Response will provide assistance for requests that our customers are not able to complete. If a request is made that Predictive Response remove the personal information, we will refer your request to the applicable party, and we will respond to the request within 30 days.

Subscriber Data Retention

Predictive Response retains the personal information we process on behalf of our customers for as long as needed to provide the Services to our subscribers and in accordance with our subscription agreements. To the extent not deleted by our subscribers, Predictive Response may also retain and use certain personal information for a reasonable period of time thereafter as necessary to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements.

Changes in this Privacy Statement

If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective.