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”).
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.
1. OUR PRIVACY PRINCIPLES
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.
2. INFORMATION WE COLLECT
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.
3. HOW WE USE INFORMATION
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.
- With consent. We may use Personal Data and Other Information with third parties when we have consent to do so.
4. HOW WE SHARE INFORMATION
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 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 consent. We may share Personal Data and Other Information with third parties when we have consent to do so.
5. YOUR CHOICES
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 (https://exfluential.com) 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 email@example.com, and we will coordinate your request with our Customer.
6. IMPORTANT INFORMATION
A. Our Policy Toward Children
B. Links to Other Websites
- 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: firstname.lastname@example.org
D. Data Retention
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.
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.
7. CONTACT US