PRIVACY POLICY
Last Updated: OCTOBER 4, 2021
This Privacy Policy ("Privacy Policy") explains how information is collected, used and
disclosed by Slintel, LLC.,
a Delaware Limited Liability Company ("Slintel," “we,” or “us”), and applies to information
we collect when you use
or access our online or mobile websites (www.slintel.com), products, services or
applications (collectively, the
"Slintel Services"), or when you otherwise interact with us. We respect the privacy rights
of users and recognize
the importance of protecting information collected about you.
California Notice
of Collection of Personal Information:
Slintel collects and uses personal information
as described below under "Categories of Information We Collect, Use, and Disclose for
Business Purposes." To learn more about your California privacy rights, including your right
to opt out of the sale of your personal information, please scroll down to “California
Privacy Disclosures.”
Changes to This
Policy
We may change this Privacy Policy from time to time. If we make any changes, we will notify
you by revising the "Last Updated" date at the top of this Privacy Policy, and in some
cases, we may provide you with additional notice (such as adding a statement to our homepage
or sending you an email notification). We encourage you to review our Privacy Policy
whenever you access the Slintel Services to stay informed about our privacy practices. Your
use of any of the Slintel Services after the posting of such changes means you accept these
changes.
1. Information
Collected
Information You Provide to Us
We collect information you provide directly to
us.
-
For example, we collect information when you register with Slintel for an account,
create or modify your account, access and use the Slintel Services (including but not
limited to when you upload, download, or share data or other information), participate
in any interactive features of the Slintel Services, make a purchase, request customer
support, communicate with us via third party social media sites or otherwise communicate
with us.
-
The types of information we may collect directly from you include your name, username,
email address, postal address, phone number, preferences, employer’s name, job title,
transactional information (including services purchased or subscribed to and billing
address) as well as any contact or other information you choose to provide. We also
store data or other information that you upload or provide to the Slintel Services
("Content") in order to be able to provide you with the features and functionality of
the Slintel Services.
Information We Collect Automatically When You Use the Slintel Services
When you access or use the Slintel Services, we
may automatically collect information about you, including:
-
Usage Information: We monitor user activity in connection with the Slintel Services and
may collect information about the applications and features you use, the websites you
visit, the files you upload, download, share or access, and the Content you access and
use.
-
Log Information: We log information about access and use of the Slintel Services
including your Internet Protocol ("IP") address, access times, browser type and
language, Internet Service Provider ("ISP"), the Web pages that you visit, the Content
you use and the URL of the Web page you visited before navigating to the Slintel
Services.
-
Information Collected by Cookies and Other Tracking Technologies: We use various
technologies to collect information, which may include saving cookies to your computer
or mobile device (“Technologies”). Cookies are small data files stored on your hard
drive or in device memory that help us to improve the Slintel Services and your
experience, customize your experience and preferences, allow you to access and use the
Slintel Services without re-entering your login credentials, understand which areas and
features of the Slintel Services are most popular and count visits. We may also collect
information using web beacons (also known as "tracking pixels"). Web beacons are
electronic images (also called "gifs") that may be used in the Slintel Services or in
emails that help us to deliver cookies, count visits, understand usage and campaign
effectiveness and determine whether an email has been opened and acted upon. We may use
third party service providers to support our Services. Some of these service providers
may use cookies or similar technologies to receive, collect, and store information.
-
We use Technologies as follows:
-
Strictly Necessary. We use Technologies that are necessary to operate our Services. You
can set your browser to block or alert you about these cookies, but some parts of the
Site may then not work.
-
Performance. We may use Technologies to assess and improve the performance of our
Services, including to help us understand how our visitors use our Services.
-
Functional. We may use Technologies to offer you enhanced functionality when accessing
or using our Services. If you do not allow these Technologies, then some or all of these
services may not function properly.
-
Advertising. We may partner with third parties that use technologies such as cookies to
gather information about your activities on this site and other sites you visit in order
to provide you advertising based upon your browsing activities and interests.
-
Most web browsers are set to accept cookies by default. If you prefer, you can usually
choose to set your browser to remove or reject browser cookies or to prompt you before
accepting such a cookie. Please note that, if you choose to remove or reject browser
cookies, this could affect the availability or functionality of the Slintel Services.
Information We Collect for Our Users
-
Slintel provides customers of our subscription Services (“Users”) with business-level
contact information, including names, professional titles and emails (“Business Data”)
to help our business-to-business (“B2B”) customers engage with other businesses. We
maintain a core database of Business Data that is sourced via agreements with third
parties by publicly available sources (e.g., SEC website, company websites).
-
Slintel collects elements of Business Data in a number of ways, which include:
- Via agreements with third parties
- Scanning of publicly available sources
- User-uploaded information
- Inferences about your use of business technology based on the technologies used
by your employer.
- We do not include in the Business Data any information that you provide in connection
with your subscription to the Slintel Services—though we may receive similar information
from other sources, which may be included in Business Data.
2. Use of Information
We may use the information we collect about you for a variety of purposes, including to:
- Provide, operate, maintain and improve the Slintel Services;
- Enable you to access and use the Slintel Services, including collecting, uploading,
downloading, processing, storing and sharing content;/li>
- Send notifications and updates, including security alerts, technical notices, and
support messages;
- Provide and deliver the Slintel Services and features you request, process and complete
transactions, and send you related information, including purchase confirmations and
invoices;
- Provide support services, including responding to questions, requests for features, and
technical support;
- Send you communications about our Services, Slintel, or on behalf of our select
partners;
- Track and analyze usage statistics within the Slintel Services and for marketing or
advertising purposes;
- Personalize and improve the Slintel Services, and provide content, features, and/or
advertisements that match your interests and preferences or otherwise customize your
experience on the Slintel Services;
- Link or combine with other information we receive from third parties to help understand
your needs and provide you with better service;
- Enable you to communicate, collaborate, and share files with users you designate;
Investigate and prevent fraudulent transactions, unauthorized access to the Slintel
Services, and other illegal activities; and
- For other purposes about which we notify you upon collection of your personal
information.
Global Processing & Transfers
Slintel is a global business and it, or its service providers, may process, transfer, and
store information on servers located in a number of countries outside the European Economic
Area (EEA), including in the United States and India and other locations where we have
facilities or have engaged a service provider. Since we are committed to protecting your
information, we take steps to ensure that there are appropriate safeguards in place when we
transfer data and only transfer your data, subject to suitable safeguards being in place.
3. Sharing and Disclosure of Information
We will not share personal information about you that you provide in connection with your
registration or that we collect regarding your use of the Slintel Services or any Content
with any third parties except as described in this Privacy Policy or in connection with the
Slintel Services. For example, we may share personal information about you as follows:
- Vendors, Consultants and other Service Providers: We may share your information
with third party vendors, consultants and other service providers who are working on our
behalf and require access to your information to carry out that work, such as to process
billing, provide customer support, etc.
- Third-Party Applications: Certain aspects of the Slintel Services allow or
require you to connect with third party applications or services. In connection with
your use of any such third-party applications or services, such third parties may
receive information about you including your username and any Content you choose to use
in connection with those applications and services, and such third parties may contact
you directly as necessary. The Slintel Services may automatically collect and upload
certain data from such applications. This Privacy Policy does not apply to your use of
such third-party applications and services, and we are not responsible for how those
third parties collect, use and disclose your information and Content. We encourage you
to review the privacy policies of those third parties before connecting to or using
their applications or services to learn more about their information and privacy
practices.
- Compliance with Laws: We may disclose your information to a third party if (a) we
believe that disclosure is reasonably necessary to comply with any applicable law,
regulation, legal process or governmental request, (b) to enforce our agreements,
policies and Terms of Service, (c) to protect the security or integrity of the Slintel
Services, (d) to protect Slintel, our customers or the public from harm or illegal
activities, or (e) to respond to what we believe in good faith to be an emergency. We
also may be required to disclose an individual’s personal information in response to a
lawful request by public authorities, including to meet national security or law
enforcement requirements.
- Business Transfers: We may share or transfer your information in connection with,
or during negotiations of, any merger, sale of company assets, financing, or acquisition
of all or a portion of our business to another company.
- Aggregated or Anonymized Data: We may also share aggregated or anonymized
information that does not directly identify you with third parties.
- Business Data: We display business-level contact information within profiles to
subscribers of the Slintel Service.
4. Security
While no service is completely secure, Slintel takes reasonable measures to help protect
information from unauthorized disclosure. While we make every effort to help ensure the
integrity and security of our network and systems, we cannot guarantee our security
measures.
5. Your Choices
a) Account Information & Retention.
For subscribers to the Slintel Services, you may update, correct or delete information about
you at any time by
logging into your online account and modifying your information or by emailing us at [email protected]. We will
retain your personal information for the period necessary to fulfill the purposes outlined
in this Privacy Policy.
If you wish to deactivate your account, please email us at [email protected], but note that we may
retain certain
information as required or permitted by law. We may also retain cached or archived copies of
information subject to
our data retention policies.
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 to comply with our legal
obligations, resolve disputes and enforce our agreements.
b) Promotional and Newsletter Communications
You may opt in to receive promotional and
newsletter emails from Slintel by following the opt-in instructions provided at the time of
account creation or instructions provided through the Services. If you do not opt in, we may
still send you non-promotional communications, such as security alerts and notices related
to your access to or use of the Slintel Services or those about your online account or our
ongoing business relations.
c) Business Contact Information
Slintel is committed to compliance with all
applicable privacy laws & regulations. If you prefer to withdraw from gaining the
business benefits of being listed on our website and in our database, then you can request
deletion of your profile and removal from our databases. If you make this choice, all
information contained in your profile will be removed and your profile will become
unavailable in our products.
Please send requests for deletion of your profile from your email address to
[email protected] .
6. Links to Third Party Websites
We may include links to third-party websites from the Slintel Services. When you click on a
link to a third-party website, your activity and use on the linked website is governed by
that website’s policies, not by those of Slintel. We encourage you to visit their websites
and review their privacy and user policies.
7. Our Policy Toward Children
The Slintel Services are not directed to individuals under 13. We do not knowingly collect
personal information from children under 13. If you become aware that a child has provided
us with personal information, please contact us at [email protected] . If we become aware
that a child under 13 has provided us with personal information, we will take steps to
delete such information.
8. California Privacy Disclosures
If you are a California resident, please review the following
additional privacy disclosures under the California Consumer Privacy Act ("CCPA"):
a) HOW TO EXERCISE YOUR LEGAL RIGHTS
You have the right to understand how we collect, use,
disclose and may sell your personal information, to access your information, to request
that we delete certain information, and to not be discriminated against for exercising
your privacy rights.
Your Rights.If you are a California resident, you have the right to:
- Access. You may request, up to two times each year, that we disclose to you the
categories and/or the specific pieces of personal information that we collect, use,
disclose, and may sell.
- Delete. You can request that we delete the personal information that we collected
from you. Once we receive and verify your request, we will delete your personal
information from our records. We are not required to delete information if we need to
use it for the following:
- Completing a transaction or contract with you.
- Detecting security interests, protecting against malicious, deceptive, fraudulent,
or illegal activity, or prosecuting people responsible for that activity.
- Debugging our products to identify and repair errors to our Services.
- Exercising, and allowing others to exercise, free speech, or other legal rights.
- Internal uses that align with your expectations.
- Complying with a legal requirement.
- Other internal and lawful uses consistent with the reasons you provided the
information.
- Opt-Out of Sale of Personal Information. As more fully explained below, Slintel
sells personal information collected in its database to its customers. You can request
that we do not sell your personal information.
To exercise the rights described above, please submit a
verifiable consumer request to us by:
- Contacting us at [email protected]
- Mailing us at:
Slintel, LLC
Attn: Privacy
450 Mission Street,
Suite 201 San Francisco, CA, 94105,
(415) 212-9225
You can exercise your rights yourself or you can alternatively designate an authorized agent
to exercise these rights on your behalf. Only you or a person registered with the California
Secretary of State that you authorize to act on your behalf may make a verifiable consumer
request related to your personal information. Please note that to protect your Personal
Information, we will verify your identity by a method appropriate to the type of request you
are making. We may also request that your authorized agent have written permission from you
to make requests on your behalf, and we may also need to verify your authorized agent's
identity to protect your Personal Information.
We cannot respond to your request or provide you with personal information if we cannot
verify your identity or authority to make the request and confirm the personal information
relates to you.
We will not discriminate against you for exercising any of your CCPA rights.
b) CATEGORIES OF INFORMATION WE COLLECT,
USE, AND DISCLOSE FOR BUSINESS PURPOSES
As described above, we have collected the categories of
personal information listed below in the last 12 months. We receive this information
from you, your device, your use of the Services, third parties (like the other services
you have connected to your account and, in the case of Public Profile information, data
brokers), and as otherwise described in this policy. We use and disclose these
categories of information for the business purposes described in the Use of Information
and Sharing and Disclosure of Information sections, respectively. The categories are:
- identifiers, like your
name or username, business email address, business title, company, location,
business phone number, IP address, account ID, cookie ID, and other similar
identifiers.
- Commercial Information,
including your payment information and records of the Services or devices you
purchased, obtained.
- Internet or other
electronic network activity information, such as the usage data we receive
when you access or use our Services. This includes information about your
interactions with the Services and about the devices and computers you use to access
the Services.
- Other information that you
provide, including account information such as your biography, company or country.
- Professional or
Employment-Related Information, such as your work history.
- Inferences drawn from
any of the above.
c) HOW DOES SLINTEL COLLECT YOUR DATA ?
Slintel receives data directly and indirectly. You directly
provide Slintel with data when you:
- Register online or place an order for any of our services
- Provide feedback via email
- Use or view our website via your browser’s cookies
- Use our platform
Slintel may also receive your data indirectly from the
following sources:
- Via agreements with third parties
- Scanning of publicly available sources
- User-uploaded information
- Inferences about your use of business technology based on the technology used by
your employer.
d) HOW WILL SLINTEL USE YOUR DATA?
Personal Information Disclosed for Business Purposes
We may disclose your personal information to a third party for a business purpose. When we disclose personal
information for a business purpose, we enter a contract that describes the purpose and requires the recipient to
both keep that personal information confidential and not use it for any purpose except performing the contract.
In the preceding twelve (12) months, we have disclosed the following categories of personal information for a
business purpose:
- Identifiers: like your name or username, business email address, business title, company,
location, business phone number, IP address, account ID, cookie ID, and other similar identifiers.
- Commercial Information: Information related to purchases that you might make in connection with
our Services.
- Internet or other electronic network activity information: Limited information about your use of
the internet collected via web analytics.
- Examples: browsing and/or search history regarding sites visited before or after using Slintel
Services, the type of operating system used to connect to our Services, interactions with our
Services or our advertisements, browser type, internet service provider, the date and time of
your visit, the amount of time you spend on each page, information about the links you click and
pages you view within the services, and your preferences when you use the Services.
- Geolocation Data: Information about where your computer or device is approximately located when
you use the Services.
- Professional or Employment-Related Information: Information related to your employment, including
current job title, and work history.
- Inferences Drawn from the Above Information: Information we can determine or estimate about you
based on information we collect about you.
- Examples: Purchase preferences, potential future purchase behavior.
We disclose your personal information for a business purpose to the following
categories of third parties:
- Service providers
- Third parties to whom you or your agents authorize us to disclose your personal information in
connection with the products or services we provide to you
- Aggregators (such as analytics services)
e) Disclosure and Sale of Personal Information and the Right to
Opt-Out
We sell personal information collected for our database to our customers. This
database may contain information about consumers’ business personas including name, employer, job title, email
address, phone number, office address, and work or educational history. This information is sold to Slintel’s
business customers for business purposes.
We do not sell the personal information that we receive from users as part of their registration or in
connection with their uses of the Slintel Services. We do not and will not knowingly sell Personal Information
of minors who are younger than 16.
If you would like to opt-out of the sale of your data, please click here: Do Not Sell My Personal Information
We make Business Data available to our customers on a subscription basis. Our customers are sales and marketing
teams in B2B companies that are looking to establish a connection with potential buyers to gauge interest in
their offerings. In the past twelve (12) months, we’ve sold the following categories of personal information in
the Business Data to our customers:
- Identifiers, like your name or username, business email address, business title, company, location,
business phone number, IP address, account ID, cookie ID, and other similar identifiers.
- Commercial Information: Information related to purchases that you might make in connection with our
Services.
- Electronic, visual, or similar information, such as your profile photo or other photos.
- Professional or Employment-Related Information: Information related to your employment, including
current job title, and work history.
- Inferences drawn from any of the above: Information we can determine or estimate about you based on
information we collect about you.
- Examples: Purchase preferences, potential future purchase behavior.
Slintel does not disclose, sell, collect, retain, or share sensitive personal
information (which is personal information that is not publicly available like your Social Security number,
driver’s license number, or medical history). For clarity, the identified categories of Business Data that are
disclosed and/or sold by Slintel LLC include only business contact information in the context of an employee’s role
with their employer. Slintel does not sell the personal information of consumers under 16 years of age.
9. Privacy Notice for Individuals in the EEA
a) Information about Processing of Personal Data
- Purpose of and Legal Basis for Processing: Personal information is processed in different ways
and with
different bases depending on your use of the Slintel Services:
- consent;
- as necessary for the performance of our agreement to provide Slintel Services;
- as necessary for legal compliance with an obligation; and
- proportional to our legitimate interests in providing the Services where such interests do not
override
your fundamental rights and freedoms related to data privacy.
- Legitimate Interests of Slintel:
- Slintel has a legitimate interest to collect and analyze B2B contact information. This has a
limited impact on the privacy of individuals because the Business Data is related to a person’s
role on behalf of a business.
- Categories of Personal Data Collected: As described above, we collect the following categories of
personal data:
- Identifiers, like your name or username, business email address, business title, company,
location, business phone number, IP address, account ID, cookie ID, and other similar
identifiers.
- Commercial Information, including your payment information and records of the Services or
devices you purchased, obtained.
- Internet or other electronic network activity information, such as the usage data we
receive when you access or use our Services. This includes information about your interactions
with the Services and about the devices and computers you use to access the Services.
- Other information that you provide, including account information such as your biography,
company or country.
- Professional or Employment-Related Information, such as your work history.
- Inferences drawn from any of the above.
- Recipients or Categories of Recipients that Receive Personal Data:
- Customers
- Service Providers
- Processors
- Third Parties
- Any Transfers of Data to Countries Outside of the EEA: Slintel provides its services from the
United States and India.
b) What Are Your Data Protection Rights?
- Right to Access: You have the right to request that Slintel provide you a copy of your personal
data.
- Right to Correct/Erase: You have the right to request that Slintel correct or erase any of your
personal data that you feel is inaccurate.
- Right to Restrict Processing: You have the right to request that Slintel restrict, or limit, the
processing of your personal data, consistent with legal requirements.
- Right to Object to Processing: You have the right to object to Slintel’s processing of your
personal data, consistent with legal requirements.
- Right to Data Portability: You have the right to request that Slintel transfer the data that it
has collected about you to another organization, or directly to you, consistent with legal requirements.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights,
please contact us at our email: [email protected]
Should you wish to report a complaint or if you feel that Slintel has not addressed your concern in a
satisfactory manner, you may contact your supervisory authority. Contact details for data protection authorities
are available here.
10. Contacting Us
Any questions about this Privacy Policy should be addressed to [email protected] We may also be contacted at:
Slintel, LLC
Attn: Privacy
450 Mission Street,
Suite 201 San Francisco, CA, 94105,
(415) 212-9225
.