Last Updated: September 6, 2019
We provide a sales training platform that provides a performance-based and robust training solution for hotel and other industries (the “Training Services”).
For the purposes of the GDPR, SalesBoost is considered the data controller. This means that we are responsible for deciding how we use the information that we hold. We are a Delaware limited liability company registered in the United States with an office at SalesBoost, LLC, 5345 Towne Square Drive, Suite 145, Plano, Texas 75024 USA.
The GDPR applies to you if you reside in the European Economic Area (an “EEA Resident”).
This policy describes the types of information we may collect from you or that you may provide when you access or use the Site, the Training Services, the other SalesBoost Services or other features, functions, services products and our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies to information we collect or may collect:
- In accessing and using the Site.
- In creating an account and registering to use the Training Services and the other SalesBoost Services.
- In accessing and using the Training Services and the other SalesBoost Services.
- In e-mail, text and other electronic messages sent through or use of the Site, the Training Services and the other SalesBoost Services.
- When you interact with other users of the Training Services and the other SalesBoost Services.
- When you send any content through the Site, the Training Services or any of the other SalesBoost Services.
- Through services provided to us by third-party companies, agents or contractors.
It does not apply to information collected by:
- Us offline or through any other means, including on any other website operated by SalesBoost or any third party; or
- Any third party, including through any application or content (including advertising) that may be accessible from or on the Site, the Training Services or any of the other SalesBoost Services.
Minors under the Age of 18
None of the SalesBoost Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Site, the Training Services or the other SalesBoost Services. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on or through any of the SalesBoost Services or any of its features or register on the Site use any of the interactive or public comment features of any of the SalesBoost Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
Information We Collect About You and How We Collect It
We collect or may collect several types of information from and about mangers and other users of the Site, the Training Services and the other SalesBoost Services, including:
- Information by which you may be personally identified, including personal data such as your full name, e-mail address, phone number and street address (“personal data”);
- Financial and billing information, including bank account and credit card information;
- Analytics information;
- Information that is about you but individually does not identify you, such as IP address and date and time of visit;
- Information from your device, including contact information;
- Usage details and information, including how you communicate with other users of the Training Services and the other SalesBoost Services;
- Information contained in the comments and postings on or through any of the SalesBoost Services;
- Device, internet and mobile information such as the hardware model, operating system version, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number);
- Information that you provide by registering or filling in forms or applications on or through the Site. This includes information provided in connection with registering to access and use the Training Services and the other SalesBoost Services;
- When you report a problem with the Site, the Training Services or any of the other SalesBoost Services;
- Records and copies of your correspondence (including e-mail addresses), if you contact us;
- Details of transactions you carry out through the Site, the Training Services and any of the other SalesBoost Services; and/or
- Your search queries on or through any of SalesBoost Services.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through or use the Site, the Training Services and the other SalesBoost Services.
- From third parties, such as our customers, business partners and other third parties that provide us or you with certain services.
Certain web transactions may also involve you calling us or our calling you. Please be aware that we may monitor and in some cases record such calls for staff training or quality assurance purposes.
We take every reasonable step to limit the volume of your personal data that we process to what is reasonably necessary.
We do not Engage in Automated Decision-making without Human Intervention
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
Consequences of not providing Personal Data
You are not required to provide all personal data identified in this policy to use our Site or to interact with us offline, but we may not be able to provide the Training Services if you do not provide certain personal data. In addition, if you do not provide the personal data, we may not be able to respond to your requests or provide you with other important information.
Compliance with the Family Education Rights & Privacy Act (FERPA)
In the United States, the Family Educational Rights & Privacy Act, 20 U.S.C. § 1232(g), restricts the disclosure of personally identifiable information from a student’s education records, unless an exception applies. For U.S. users, SalesBoost’s data protection and privacy policies and practices comply with FERPA and other applicable federal and state education privacy laws.
SalesBoost maintains the confidentiality of FERPA-covered student data, and only uses this information to deliver and improve SalesBoost Services provided to schools and their students, as provided in SalesBoost’s agreements with schools. You may also have specific rights related to accessing and/or updating Your Personal Information when FERPA applies. For further information about FERPA compliance, or to access, modify, or remove any such data, please contact us email@example.com.
You may now or in the future provide testimonials, pictures, audio and video recordings, text, data, information and other input or any other content linked, posted, and/or submitted by you or other users to be published or displayed (hereinafter, “posted“) on or through the Site or the Training Services, or transmitted to third parties or other users of, the Training Services or any of the other SalesBoost Services (collectively, “User Content“). Your User Content is posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Site, the Training Services or the other SalesBoost Services, with whom your User Content is shared. Therefore, we cannot and do not guarantee that your User Content will not be viewed, downloaded or shared by unauthorized persons.
The technologies we use for automatic data collection may include:
- Flash Cookies. Certain features of the Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on the Site. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit SalesBoost, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Do Not Track Policy
Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services. At present, no universally accepted standards exist on how companies should respond to do-not-track signals. In the event a final universally accepted standard is established, we will assess and provide an appropriate response to these signals.
Third-party Responsibilities and Services
The Service Providers may also transmit cookies to your computer or device, when you click on ads that appear on or through the Service. Also, if you click on a link to a third-party website, such third party may also transmit cookies to you. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any our Services, and those third parties may not honor “Do Not Track” requests you have set using your web browser.
Use of Remarketing with Google Adwords, Google Analytics and other Remarking and Analytic Services
We use or may use a variety of remarketing and analytic services including:
You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to, you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
DoubleClick: We may use Google Analytics and Google Adwords remarketing codes to log when users view specific pages or take specific actions on a website. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.
Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions on its website.
How We Use Your Information
- Where the use of your information is necessary for the performance of a contract we are about to enter into or have entered into with you or pursuant to which we are providing services to you or on your behalf;
- Where the use is necessary for the purposes of our legitimate interests (or those of a third party);
- Where we need to comply with a legal or regulatory obligation; or
- Where you have given your consent (which can be withdrawn at any time).
We use information that we collect about you or that you provide to us, including any personal data, for the following purposes:
- To provide you the Training Services and the other SalesBoost Services and the content and the other products and services that you request from us.
- To provide the Site and its contents to you.
- To process and complete transactions and send you related information, including the request for and the provision of the Training Services.
- To provide technical and other support to you.
- To send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers and events; and providing other news or information about us, our customers and our select partners.
- To enable Service Providers to perform certain responsibilities and provide certain services in connection with our business and operations.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to the Site, the Training Services and the other SalesBoost Services.
- To allow you to participate in interactive features on or through any of the SalesBoost Services.
- To enhance the safety and security of all of the SalesBoost Services.
- To verify your identity and prevent fraud or other unauthorized or illegal activity.
- To enable marketing, remarketing and targeted advertising and similar services from us or Service Providers, including direct and indirect marketing and on-line behavioral advertising regarding our own and third-party products and services that we believe may be of interest to you, including advertisement on third party websites.
- To perform targeted and other advertising on third party websites.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Some of the information that we collect automatically is statistical data and does not include personal data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Site, the Training Services and the other SalesBoost Services, and to deliver a better and more personalized service, including enabling us to:
- Estimate our audience size and better understand usage patterns.
- Store information about your preferences, enabling us to customize the Site according to your individual interests.
- Speed up your searches.
- Recognize you when you return to the Site.
Storage and Transfer of Your Information
We may store any data and other information that we collect (personal or otherwise) ourselves or in databases owned and maintained by us, our affiliates, agents or Service Providers. We do not, however, store your bank account and credit card information in our databases. Any such bank account and credit card information is stored and maintained by Authorize.Net and Recurly. If you pay by check, however, we will have a copy of the check.
If you access or use the Site, the Training Services or any of the other SalesBoost Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by SalesBoost and you. By allowing SalesBoost to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Site and view content faster.
Although users from all over the world may access the Site, the Training Services and the other SalesBoost Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
- To our subsidiaries and affiliates.
- To other users in your organization in connection with any of the Training Services or any of the other SalesBoost Services.
- To Service Providers, contractors and other third parties we use to support our business, including credit card and payment processors and marketing support.
- To a potential or actual buyer. assignee or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of SalesBoost’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by SalesBoost about customers and users of the Site is among the assets that may be or are actually transferred.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal data:
- To comply with any court order, law or legal process, including to respond to any government or regulatory request.
- To enforce or apply the Terms and other agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of SalesBoost, our customers or others.
Choices About How We Use and Disclose Your Personal Data
We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your personal data:
- Promotional Offers from SalesBoost. If you do not wish to have your e-mail address/contact information used by SalesBoost to promote our own or third parties’ products or services, you can opt-out through the unsubscribe mechanism at the bottom of the applicable email. This opt out does not apply to information provided to SalesBoost as a result of a service or product purchase, warranty registration, product service experience or other transactions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe’s Preference Manager at http://preferences-mgr.truste.com.
Our Legal Bases for Handling Your Personal Data
GDPR and the laws in some other jurisdictions require companies to tell you about the legal bases that they rely on to use or disclose your personal data. To the extent that those laws apply, we rely on the following legal grounds to process your personal data:
- Performance of a contract: In most cases, we collect and use your personal data and other information to meet our obligations under a contract to which you are a party or pursuant to which we are providing services to you or on your behalf. For example, when you use the Training Services, the Site, or the other SalesBoost Services, we will use your personal data to respond to your requests and to provide you with these services.
- Legitimate interests: We may use your personal data information for our legitimate interests on the grounds that it furthers our legitimate interests in commercial activities (but only to the extent that such interests are overridden by the interests or fundamental rights and freedoms of the affected individuals) including:
- Analyzing and improving the Training Services, the Site and the other SalesBoost Services and our business
- Providing the services in connection with the Training Services
- Legal compliance: We may use and disclose personal data in certain ways to comply with our legal obligations under European or Member State law or other applicable law.
- Consent: To the extent required by law, and in certain other cases, we handle personal data on the basis of implied or express consent.
Accessing and Correcting Your Information
You may change, correct or delete any personal data that you have provided to us through your user profile. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may also retain an archived copy of your records as required by law or for legitimate business purposes.
If you delete your User Content from any of the SalesBoost Services (including any User Content stored in the cloud), copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other users of the Servers or the Site. Proper access and use of information provided on or through any of the SalesBoost Services, including User Content, are governed by the Terms.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to firstname.lastname@example.org or write to us at: SalesBoost, LLC, 5345 Towne Square Drive, Suite 145, Plano, TX 75024 USA.
European Privacy Rights for EEA Residents
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your personal data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal data. You can also exercise the right by contacting us directly.
If you are an EEA Resident and GDPR applies and we hold your personal data in our capacity as a controller, you may request that we:
- Provide access to and/or a copy of certain personal data (including, in some cases, in portable form);
- Prevent the processing of your personal data for direct-marketing purposes (including any direct marketing processing based on profiling);
- Update personal data that is out of date or incorrect;
- Delete certain personal data which we are holding about you; provided that the personal data is not required by us for (i) compliance with a legal obligation under European or Member State law or other applicable law or (ii) the establishment, exercise or defense of a legal claim;
- Object to our processing of personal data;
- Restrict the way that we process and disclose certain of your information except to the extent that processing is required (i) to comply with a legal obligation under European Member State law or applicable law or (ii) for the establishment, exercise or defense of legal claims;
- Transfer your personal data to a third party to the extent that this is technically feasible; and
- Honor a revocation of your consent for the processing of your personal data (without retroactive effect).
We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include information that we need to keep processing for our legitimate interests or to comply with a legal obligation. We may request you provide us with additional information to confirm your identity before responding to your request. You have the right to lodge a complaint with the authorities applicable to your situation, though we invite you to contact us with any concern, as we would be happy to try to resolve it directly.
If you are an EEA Resident in France, you also have the right to set guidelines for the retention and communication of your personal data after your death.
If you reside in a jurisdiction other than the European Economic Area, you may also have similar rights to the above. Please contact us at email@example.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.
You can exercise any of these rights by contacting us at by e-mail at firstname.lastname@example.org or by mail at SalesBoost, LLC, 5345 Towne Square Drive, Suite 145, Plano, Texas 75024 USA.
How Long We Store Your Personal Data
We will only retain your personal data, in a form which permits us to identify you, for as long as necessary to fulfil the purposes we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
We understand that the security of your personal data is important. We provide reasonable administrative, technical, and physical security controls to protect your personal data. However, despite our efforts, no security controls are 100% effective and SalesBoost cannot ensure or warrant the security of your personal data. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to and use of certain parts of the Site, the Training Services and/or the other SalesBoost Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of any of the SalesBoost Services. The information you share in public areas may be viewed by any user of the Site.
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