Privacy Policy

Last Updated: September 2, 2020

Exfluential, Inc. (“Exfluential”, “we”, “our”, “us”) provides a software-as-a-service advocate engagement platform with a suite of applications and related services (the “Services”) to our Service visitors and or end-users (“you” or “your”).

This Privacy Policy describes and is intended to help you understand our privacy principles, what information we collect (including Personal Data), how we use that information, how we share that information, your choices concerning our data practices, and other important information.

We consider “Personal Data” to be any information that alone or in combination with other information in our possession could be used to identify you. This Privacy Policy does not apply to any third party applications or software that integrate with the Services through our platform (“Third Party Services”), which are governed by their own respective privacy policies.

When you access our Services through your employer or another entity to which you are affiliated (our “Customer”), please note that our Customers maintain control over the Services for their organization, including the data associated with their account. If you have any questions about the specific settings and privacy practices of a Customer account, please contact the Customer whose account you are affiliated for more information.

Before using the Service or submitting any information to us, please review this Privacy Policy carefully and contact us if you have any questions. If you do not agree with the terms, please do not access or use the Services, Site (, or any other aspect of Exfluential’s business.

We recognize that you must entrust us with information about you to receive our Services. Maintaining your trust is extremely important to us. We share our privacy principles to enable you to understand the key hallmarks of Exfluential’s approach to data privacy. - We only use your Personal Data in connection with our Services. We act as a “service provider” with respect to data transmitted to us by you or our Customers. - We do not sell your Personal Data. We recognize that receiving your Personal Data is vital to providing our Services to our Customers.

When you interact with us through the Services, we may receive Personal Data as well as other information and data (“Other Information”), as explained in more detail below.Information You Provide Us - We collect your Personal Data when you or our Customers register to use the Service, provide information when using the Service, update your account information, add additional services, submit information to verify your identity, contact customer support, contact us with questions or feedback, or otherwise communicate with us. This Personal Data may vary depending on what you choose to share with us and the Services you use, and may include identification information, contact information such as email address, online activity information, geolocation data, and preference information.
Other Information: We may also collect, generate, and/or receive Other Information as follows:

- Services Metadata. When you interact with the Services, metadata is generated that provides additional context about the way our authorized users utilize the Services.

- Log Data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Site or Services and record it in log files. Such log files may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time Services were used, information about browser configuration and plugins, language preferences and cookie data. - Device Information. We collect information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings. - Cookie Information: We use cookies and similar technologies to operate and administer our Services, gather and analyze usage, and improve your experience. We may also allow third party service providers to use cookies or similar technologies to collect information about your browsing activities over time and across different websites following your use of the Services. For example, we use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Service. For more information on how Google uses this data, go to Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

Exfluential uses information that we collect in accordance with Customer instructions, if applicable, Customer’s use of Services functionality, and as required by law. Exfluential acts the “service provider,” where applicable, of Personal Data, and Customer acts as the “controller” or “business,” where applicable. A Customer may, for example, use the Services to assign roles and configure settings, access, modify, export, share and remove Personal Data and otherwise apply its policies to the Services.
More specifically, we may use and share the information we collect as follows:

- To provide our Services. We use the information we collect to provide, update, maintain, and protect the Services.

- To improve and customize the Service. As we seek to improve your experience with the Service, we may analyze data we collect about your use of the Service to inform how we can improve our Services, including our software, infrastructure, user interfaces, and integrations with our partners.

- To respond to inquiries, comments, feedback, or questions. If you contact us, we may use the information that you provide to respond.

- To communicate with you. We may send you service, technical and other administrative emails, messages, and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices.

- To advertise and market to you. We may contact you to tell you about new product features, promotional communications or other news we believe may be of interest to you. Additionally, as noted above, we may also utilize cookies, to recognize your browser or mobile device in order to serve you advertisements, and analyze the effectiveness of our advertising and marketing campaigns. We may also use third party services, data, and software tools to provide advertising to you, help us identify and reach potential customers, and perform analysis on the performance of our site and advertising. Our advertising vendors do not have any independent right to use Exfluential data or that of its customers.

- To investigate and help prevent security issues and abuse of our Services. We may use your Personal Data and Other Information to protect the rights, property, and safety of Exfluential, our employees, Customers, our users, and third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

- To comply with applicable law, regulation, or legal process. We may use your Personal Data and Other Information as permitted by law or reasonably necessary to comply with applicable law (e.g. civil or criminal subpoenas, court orders, and other compulsory orders), and to enforce this Privacy Policy, our Terms of Service, and other related agreements.

- With consent. We may use Personal Data and Other Information with third parties when we have consent to do so.

Exfluential is not in the business of selling your information. We consider maintaining your trust over your information to be a vital part of our relationship with you. In certain circumstances, however, Exfluential may share the information we collect with third parties for the legitimate business purposes set forth below.

- To comply with Customer’s instructions. We may share and disclose Personal Data in accordance with a Customer’s instructions, including any applicable terms in the Terms of Service or related agreements, Customer’s use of Services functionality, and in compliance with applicable law and legal process. In addition, Customer administrators and other personnel may be able to access, modify, or restrict access to Personal Data and Other Information. This may include, for example, your employer using Service features to export logs of Services activity. We ensure access to sensitive data is granted solely on a need-to-know basis, and revoked when the need no longer exists.

- To send you system alert messages while administering the Service and providing certain features to our Customers. For example, we may contact you about temporary or permanent changes to our Service, or send you account, security or compliance notifications, such as new features, version updates, releases, abuse warnings, and changes to this privacy policy.

- To perform data analytics projects in reliance on our legitimate business interests in improving and enhancing our products and services for our Customers.

- To work with our vendors and service providers. We may engage third party companies or individuals as service providers, vendors, or business partners to process Personal Data and Other Information and support our business. These third parties may, for example, provide cloud computing and storage services, work as a contractor to support some development initiatives, or we may share business information to develop strategic partnerships to support our common customers.

- To facilitate a change in Exfluential’s business. As our business develops, we may be involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, and the information we collect may be shared or transferred in the diligence or conclusion of any such corporate event.

- To investigate and help prevent security issues and abuse of our Services. We may share your Personal Data and Other Information to protect the rights, property, and safety of Exfluential, our employees, Customers, our users, and third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.

- To comply with applicable law, regulation, or legal process. We may disclose your Personal Data and Other Information if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of Exfluential, prevent fraud, act in urgent circumstances to protect the personal safety of users of the Services or the public, or protect against legal liability.

- With corporate affiliates. We may share information we collect with our corporate affiliates, parents and/or subsidiaries, provided that our affiliates, parents and/or subsidiaries use Personal Data and Other Information in a manner consistent with this Privacy Policy.

- With consent. We may share Personal Data and Other Information with third parties when we have consent to do so.

We respect your choices over your Personal Data. When visiting our Site or using our Services, you have the following choices with respect to your Personal Data. - Accessing the Site. You can visit our Site ( without providing any Personal Data. - Reviewing, Updating, and Correcting Your Information. If you have questions, please contact our Customer to update the information they have provided to us for your account. - Marketing and Promotional Communications. You may unsubscribe from emails that we send to you by following the instructions contained in each email we send you. If you unsubscribe, you will no longer receive system emails, but we may continue to contact you on behalf of our Customer, pursuant to our Customer agreement.

- Do Not Track. Some web browsers may transmit “Do Not Track” signals. There is no current standard that governs what, if anything, websites should do when they receive these signals. We do not currently respond to “Do Not Track” signals. If and when a standard is established, we may revise our policy on “Do Not Track” signals.

If you would like to take additional steps to correct, amend, object to the processing or profiling of, or to delete your Personal Data not currently available through the Exfluential platform, please coordinate your request with the Customer whose account you use (e.g. your employer or former employer). You can also email us at, and we will coordinate your request with our Customer.


A. Our Policy Toward Children
- Exfluential does not knowingly collect Personal Data from children under the age of 13, except to the extent necessary that they are a dependent of an employee of our Customers, provided by their primary. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Exfluential through the Services, please contact us, and we will endeavor to delete that information from our databases.

B. Links to Other Websites
- This Privacy Policy applies only to the Services. The Services may contain links to other web sites not operated or controlled by Exfluential (the “Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of those Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these Third Party Sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.

C. Security
- We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction and to comply with applicable state and federal privacy and security laws. Incoming security requests are monitored by our Security Committee on a regular basis. If you become aware of any breach of security or privacy, please notify us immediately. You can reach our Security teams by emailing:

D. Data Retention
- We keep Personal Data for as long as reasonably necessary to comply with our Customer agreements, for the purposes described in this Privacy Policy while we have a business need to do so, meet regulatory requirements, resolve disputes, or prevent fraud and abuse. We may also retain Personal Data, for a limited period of time, if requested by law enforcement.

E. Aggregated or Pseudonymized Data.
- In an ongoing effort to better understand and serve the users of our Services, we conduct research on our Customer demographics, interests and behavior based on the Personal Data and Other Information provided to us. Such research may be compiled and analyzed on an aggregated or pseudonymized basis. This aggregated or pseudonymized information does not identify you. We may share aggregated or pseudonymized data with affiliates and partners for business or research purposes. We may also disclose aggregated or pseudonymized user statistics in order to describe our services to current and prospective business partners, and to third parties for other lawful purposes.

F. California Privacy Rights Disclosure
- Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we act as a “service provider” with respect to the Personal Data that we receive and process through our Services. We do not sell Personal Data.
If you are a resident of California and use the Services of our Customer, you may also have additional notice rights under CCPA. In particular, CCPA provides employees and contractors residing in California with the right to be informed of the categories of Personal Data collected and the purposes for which such Personal Data is used. If you have any questions about the application of CCPA to you, please contact the Customer whose account you use for more information, including any applicable CCPA privacy notices. - If you are a resident of California and have applied for a position at Exfluential, we may collect and use your Personal Data for human resources and business management purposes, including identifying and evaluating candidates for potential employment as well as for future roles that may become available, recordkeeping in relation to recruiting and hiring, ensuring compliance with legal requirements including diversity and inclusion requirements and practices, conducting background checks as permitted by applicable law, protecting our legal rights to the extent authorized or permitted by law, or emergency situations where the health or safety of one or more individuals may be endangered. Your Personal Data may be accessed by recruiters and interviewers. We use third party service providers to provide a recruiting software system. We also share your personal data with other third party service providers that may assist us in recruiting talent, administering and evaluating pre-employment screening and testing, and improving our recruiting practices.

- If you are a resident of California and believe we have collected your Personal Data outside of a “service provider” relationship, you may request to know more details about the categories or specific pieces of Personal Data we collect (including how we use and disclose this information), to delete your Personal Data (where applicable), and to not be discriminated against for exercising these rights. Please see this Privacy Policy for more details about our privacy practices. You may make a data request pursuant to your rights under CCPA by contacting us at We will verify your request using the information associated with your account, including email address. Government identification may be requested. You may also designate an authorized agent to exercise these rights. Notwithstanding the foregoing, please note that if you do not have a Exfluential account through one of our Customers, we may not have enough information about you to verify your data requests, and as such, may be unable to verify and honor your requests.

G. International Users
- By using our Service, you understand and acknowledge that your Personal Data may be transferred from your location to our facilities and servers in the United States. Please note that Exfluential does not specifically market or sell into countries in the EU and does not act as a data controller in our marketing or sales capaciting in the EU.

H. Changes to Exfluential’s Privacy Policy
- The Services and our business may change from time to time. As a result, it may be necessary for Exfluential to make changes to this Privacy Policy. Exfluential reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated to be effective as of the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy indicate your agreement with the terms of such revised Privacy Policy.

If you have any questions about our Privacy Policy or information practices, please feel free to contact us at