Privacy Policy

Last Modified: March 29, 2023

This privacy policy (“Privacy Policy”) explains how Salsify, Inc. and Alkemics SAS ("Salsify", "we", "our" or "us"), collects, uses, and discloses your Personal Data (defined below).

If you reside in the European Economic Area, the United Kingdom, and Switzerland, Alkemics SAS is the controller for your personal data. For all other individuals, Salsify, Inc. is the controller for your personal data. For Customer Account Management where the contracting entity is Alkemics SAS, Alkemics SAS and Salsify, Inc are joint controllers. For Customer Account Management where the contracting entity is Salsify Inc, Salsify, Inc is data controller.

Introduction.

We are committed to respecting your privacy and recognize the need for appropriate protection and management of any Personal Data that is shared with us as part of using our Site. As used in this Privacy Policy, “Personal Data” means any information that relates to an identified or identifiable individual.

Changes to this Privacy Policy.

We reserve the right, at our discretion, to change the terms of this Privacy Policy at any time. You can see when this Privacy Policy was last updated by reviewing the “Last Updated” legend on the top of this page. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS NOTICE IS REQUIRED UNDER APPLICABLE LAW, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING TO THE SITE.

Processing activities covered.

This Privacy Policy applies to:

Personal Data that we collect, receive and store about individuals in connection with the use of our websites: https://www.salsify.com/, https://www.salsify.com/fr/, https://www.digitalshelfinstitute.org/, or any other website that we operate (each, together with its sub-domains, content and services, a "Site")
Personal Data that we collect, receive and store about individuals in connection with our prospecting and marketing activities including emails which reference this Privacy Policy.
Personal Data that we collect as part of planning and managing events and webinars.
Personal Data that we collect as part of our customer account management. We collect business contact information for account management purposes related to the use of Salsify SaaS platform or professional services (“Customer Account Management”).

Our Site may contain links to third-party websites and services that are not owned or controlled by Salsify. We are not responsible for the privacy practices or the content of third-party websites, services and advertisements, and you visit them at your own risk.

Information Collected.

We may receive and/or collect Personal Data in the following ways:

4.1 Personal Data You Provide To Us On Our Site.

If you send us a "Contact Us" request or feedback, or in connection with setting up an account on our Site, or if you use any of our free tools, or when you download any of our content, you may be required to provide us with certain information that may constitute Personal Data, such as:

Your name;
Email address;
Address;
Company name;
Country
Job title;
Phone;
Information you post on any public forums; and
Communications you send to us.

4.2 Personal data that we obtain from our Customer Account Management activities. We may collect the following Personal Data for account management purposes related to the sale of Salsify SaaS platform or professional services:

Your name;
Email address;
Address;
Company name;
Job title;
Phone;
Communications you send to us;
If you communicate with us via a phone call, your voice and any other Personal Data voluntarily shared

4.3 Personal data that we obtain from Third-Party Sources

Salsify may also collect, in compliance with applicable data privacy laws, business contact information about you from other sources including third parties from whom we have purchased business contact information and from publicly accessible websites, such as your company’s website, professional network services, or press releases. We may combine this information with Personal Data provided by you. This helps us update, expand, and analyse our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you.

We may collect your Personal Data from partners who may receive this data when you use their services.
When you attend an event or a webinar where Salsify is a participating vendor, your Personal Data may be shared with Salsify by the event organiser.
Business contact information may include:

Full name,
Name of employer,
Job title,
Business email address
Office location
Business telephone number.

4.4 Personal data that we obtain as part as planning and managing events and webinars

If you register to attend an event or a webinar sponsored by Salsify, we may require certain data, including:

First name
Last name
Business email
Telephone number
Company name
Emergency contact (in some instances)
Dietary preferences (in some instances)
Health and safety information (in some instances)
Billing information (such as billing name, billing address, and credit card number)

4.5. Personal data that we collect automatically:

Certain information is collected automatically as users interact with our Site. Alone or in combination with other information, such automatically collected information may constitute Personal Data. Some of our service providers (described in Section 5, below) may use cookies or other methods to gather information regarding your use of our Site.

The information inside our log files includes internet protocol (“IP”) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. For more information, please refer to our Cookies Notice.

How we use the information we collect

We collect and process your Personal Data for the following purposes and we rely on the following legal bases:

5.1 Performance of a contract:

We process your Personal Data to perform our contract with you for the provision of our services and to satisfy our obligations under the applicable terms of use. This includes the processing activities under the Customer Account Management activities and responding to queries sent to our customer services team.

5.2 Salsify’s legitimate interest.

We use your Personal Data in our legitimate interest, including for:

Compiling marketing statistics and analyses, in order to understand how you use our Site to learn about our software as a service platform and related service offerings;
Monitoring, measuring, conducting analytics on, and improving marketing campaigns and efforts;
Sending you marketing communications including our newsletter. You can unsubscribe from our marketing newsletter service by clicking on the unsubscribe link indicated at the bottom of each newsletter.
Contacting you in connection with our event and webinars and certain services, notifications, programs or offerings that you may have registered for.
Creating a user profile (profiling). To do this, we analyse data that you share with us or generate when you use our range of services, in order to build profiles (also known as segments, personas, etc.) that align with your preferences and interests.
Conducting surveys (e.g. customer satisfaction, feedback). These surveys allow us to get to know you better and provide valuable insight that can help us offer solutions that meet your needs and expectations. You may receive emails from our trusted partners, offering you the opportunity to participate in a survey;
Operating, maintaining, protecting, improving, and optimizing the Site and our software as a service platform and related service offerings;
For training, quality assurance and administration purposes (including recording phone calls);
Detecting and preventing fraud and other harmful activity;
Conducting security investigations and risk assessments;
Ensuring the technical functionality of our Site.

5.3 Your consent

Cookies and other trackers

With the exception of strictly necessary cookies which are always on when you visit our Site. On your first visit to the site, we will tell you about our other types of cookies and ask you to choose which cookies we can use. You can always edit your preferences by clicking on the “Manage Cookie Preferences” link above.

Direct marketing

In some cases, we may ask you for your consent to process your Personal Data, such as when we need your consent for marketing purposes. Please note that we may also rely on legitimate interest to process your Personal Data for this purpose (subject to applicable law).

Sharing your Personal Data Business partners and Event sponsors

In some cases, we may ask for your consent to share your Personal Data with our Business partners and Event sponsors (please see sections 6.3 and 6.4 for more information) (subject to applicable law).

5.4 Statutory obligations

We may process your data in order to fulfill our statutory obligations. In some cases, we may use your Personal Data to process and resolve legal disputes, for regulatory investigations or compliance with applicable law, to enforce our terms of use or to comply with requests from authorities.

Information that we share with third parties

6.1 Sharing data with our subsidiaries

We may share Personal Data with other Salsify affiliates to provide services on our behalf.

6.2. Our Third-Party Service Providers.

We transfer Personal Data to our third-party service providers to perform tasks on our behalf and to assist us in achieving the purposes listed above. These third-party service providers may use data we provide to them only as instructed by us.

For a list of our main service providers and the types of services they provide to us, please see this page and please also refer to our Cookies Notice. We only give them the parts of your Personal Data that they need. And we make it clear to them that they must keep your personal data safe and only use it for those specific services.

6.3. Business Partners.

From time to time, we may partner with other companies to jointly offer products or services. If you purchase or specifically express interest in a jointly offered product or service from us, we may share Personal Data collected in connection with your purchase or expression of interest with our partners. The use of your Personal Data by the Business Partners will be in accordance with their own privacy policies.

6.4 Event sponsors.

If you attend an event or webinar organised by us, we may share your Personal Data with sponsors of the event or participating vendors. If required by applicable law, we may ask for your consent to such sharing via the registration form. The use of your Personal Data by the Event Sponsors will be in accordance with their own privacy policies.

6.5. In the event of merger, sale, or change of control.

We may transfer or assign this Privacy Policy and any Personal Data to a third-party entity that acquires or is merged with as part of a merger, acquisition, sale, or other change of control.

6.6. Other Disclosures.
We may disclose Personal Data about you if is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our terms of use, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Salsify, our users, or the public.

Retention of Personal Data.

We reserve the right to retain any Personal Data as long as the Personal Data are needed to: (i) fulfill the purposes that are described in Section 5 (How we use the information we collect), and (ii) comply with applicable law.

When we no longer need to process or retain Personal Data, we will delete or anonymise this information, or, where that is not possible (e.g. because they were stored in backups), we will store them securely and place them beyond the scope of subsequent processing activity until it is possible to delete them.

Your Rights.

Depending where you are located, you may have certain legal rights over the personal data we process about you, subject to local privacy laws. These may include the right to:

Right of access: You may contact us to find out what information we hold about you.
Right of rectification and erasure: You may correct your data and ask for it to be erased.
Right to restrict processing. You may object to our carrying out of certain processing actions.
Right of portability: You may ask us to forward items of your personal data in electronic format to you.
Right to object to the processing of your personal data carried out on the basis of our legitimate interests. You may decide to stop receiving marketing communications from us at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in marketing emails that we send you or by contacting us.
Right not be subject to a decision based solely on automated processing, including profiling, which produces legal effects or otherwise significantly affects you. Salsify does not perform automated decision-making as part of the processing activities covered by this Privacy Policy.
Right to contact the relevant data protection authority regarding our collection and use of your personal data.
Finally, you have the right to specify your will with regard to the conservation, deletion and communication of your personal data after your death.

Please note that the exercise of these rights is not absolute and may be restricted on legal grounds, or on the grounds of legitimate interest (e.g. customer disputes).

You can exercise the applicable rights by contacting us using the contact details at the bottom of this Privacy Policy or by submitting your request through our request portal.

We will promptly review all such requests in accordance with applicable laws.

International data transfers

Salsify operates as a global business and may transfer, store, or process your Personal Data in a country outside your jurisdiction, including countries outside the European Economic Area (“EEA”), Switzerland and the United Kingdom (“UK”). Therefore, your Personal Data may be processed in countries or jurisdictions that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection.

However, we have implemented appropriate security measures to ensure that your Personal Data remains protected in accordance with this Privacy Policy. For example, if we transfer personal data from the EEA, Switzerland or UK to another country, such as the United States we will enter into “Standard Contractual Clauses” approved by the relevant authority or take other measures to provide an adequate level of data protection under EU, Swiss and UK law.

Data Security.

The security of Personal Data is important to us. We take appropriate technical and organisational measures that provide a level of security appropriate to the risk of processing your personal data We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and in storage. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security.

Children's Privacy.

Our Site is not intended for children under the age of 18. Accordingly, we do not intend to collect Personal Data from anyone we know to be under 18 years of age.

Contacting Us.

If you have any questions, comments or concerns regarding our privacy practices, please contact us using the following contact details depending on your geographic location:

If you reside in the USA:

Email us at to privacy@salsify.com

Write to us at 101 Federal St #2600, Boston, MA 02110, United States

If you reside in the European Economic Area, the United Kingdom and Switzerland:

Email us at DPO@Salsify.com.

Write to us at Legal Department, Alkemics, 7 RUE DE MADRID, 75008 PARIS, FRANCE.

Data Protection Officer : Justine de Saulieu

If you are residing in any other location:

Email us at privacy@salsify.com

Write to us at 101 Federal St #2600, Boston, MA 02110, United States

Notice of Collection and additional rights for California Residents.

If you are a California resident, the California Consumer Privacy Act, California Civil Code Sections 1798.83-1798.84 (“CCPA”) permits you to request information, no more than once per calendar year, regarding the disclosure of your Personal Data by Salsify to third parties, including for the third parties’ direct marketing purposes. Furthermore, California residents have the following rights with respect to Personal Data we may have collected about them:

(i) Requests to Know

You have the right to request that we disclose to you:

The categories of Personal Data we have collected about you;
The categories of Personal Data about you we have sold or disclosed for a business purpose;
The categories of sources from which we have collected Personal Data about you;
The business or commercial purposes for selling or collecting Personal Data about you;
The categories of Personal Data sold or shared about you, as well as the categories of third parties to whom the Personal Data was sold, by category of Personal Data for each party to whom Personal Data was sold;
The specific pieces of Personal Data collected; and
How long your Personal Data is retained.

You may submit a request to know via this form. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period

(ii) Requests to Delete or Correct

You have the right to request that we delete any Personal Data about you that we have collected, or correct Personal Data that we have about you that is inaccurate. Upon receiving a verified request to delete personal data, we will do so unless otherwise authorized by law. You may submit a request to delete Personal Data via this form.

(iii) Authorized Agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

(iv) Methods for Submitting Consumer Requests and Our Response to Requests

You may submit a request to know and requests to delete Personal Data about you via:

https://www.salsify.com/personal-data-request

via email at privacy@salsify.com

Write to us:

Salsify Inc.,

101 Federal Street, Suite 2600

Boston, MA 02110

Attn: Privacy Department

Upon receipt of a request, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose.

We will acknowledge the receipt of your request within ten (10) business days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 calendar days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. In order to protect your privacy and the security of Personal Data about you, we verify your request by asking for additional identifying information appropriate in the circumstances.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

(v) The Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights described above.

(vi) Selling and Sharing of Personal Data

Salsify may use your Personal Data for the purposes described in Section 4 of this Policy, and may share your Personal Data as further described in Section 5. of this Policy. California law places certain obligations on businesses that “sell” Personal Data to third parties or “share” Personal Data with third parties for “cross-context behavioral advertising” as those terms are defined under the CCPA. We do not “sell” or “share” the Personal Data covered by this Policy and have not done so in the twelve months prior to the effective date of this Policy. Consequently, we do not have a Do Not Sell My Info-functionality on the Site.

(viii) Sensitive Personal Data

Some Personal Data may be considered sensitive personal information under certain privacy laws, including the California Consumer Privacy Act (“CCPA”). Sensitive personal information may include, for example, government-issued identification number, information relating to a person's race or ethnic origin, political opinions or religious beliefs, physical or mental health or condition, sexual orientation, or trade union membership. It may include information about an individual's criminal offenses or convictions, as well as any other information deemed sensitive under applicable data protection laws.

The CPPA provides consumers with the “right to limit” the use of their sensitive personal information to certain business purposes. Salsify does not request sensitive personal information in connection with the use of its Sites.

(iv) How We Respond to Do Not Track Signals

Salsify does not track Site users over time and across third party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about an individual consumer's online activities over time and across third-party web sites or online services.