Contacts+ Privacy Policy

Last Updated: May 23, 2018

Thank you for using Contacts+ !

Contacts+, provided to you by FullContact Inc. ("Contacts+", “we”, “us”, “our”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, process, and disclose your information, including Personal Data (as defined below), in conjunction with your access to and use of our Services, and it applies to all of the Services offered by Contacts+ and its affiliates including but not limited to all of our Apps, Sites, APIs (including exports), and Integrations. "Users" as defined in this Privacy Policy includes any user of our Services including individual End Users, organizational Clients, and Developers.

Capitalized terms not defined in this Privacy Policy have the meanings given in our Terms of Use located at www.contactspls.com/terms.

Specifically, we'll cover:

  1. Information We Collect
  2. How We Use Information
  3. How Information Is Shared
  4. Data Retention
  5. Third Party Websites
  6. Minors
  7. Data Protection
  8. Your Rights
  9. Your Rights Under the GDPR
  10. Changes to This Privacy Policy
  11. How to Contact Us

1. INFORMATION WE COLLECT

1.1 Types of Data We Collect

"Personal Data" means any data that allows someone to identify or contact an individual data subject, including, for example, name, address, telephone number, email address, as well as any other non-public information that is associated with or linked to any of the foregoing data. "Anonymous Data" means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

1.2 Information You Provide Us

1.3 Information We Receive From Your Use of Our Services

1.3.1 Your Contacts

We provide a variety of Services that enable you to effectively manage contact information that you provide to us as part of the Services (your "Contacts", also referred to as "End User Contact Data" in our Terms of Use located at www.contactspls.com/terms). Contacts typically contain information on individuals (or organizations) including names, email addresses, phone numbers, URLs, social handles, online identifiers, and physical addresses. Your Contacts may also contain additional information on individuals such as organizational affiliations, job titles, birthdays, key dates, age, gender, general location, relationships, skills, interests, preferences, notes, photos, tags and other categorizations. Depending on which Services you elect to use, Contacts may be collected in one or more of the following ways:

1.3.2 Relationship Information

We provide a variety of Services that enable you to effectively manage your relationships. Depending on which Services you elect to use, relationship information may be collected in one or more of the following ways:

1.3.3 Location Information

1.3.4 Usage and Device Information

We may collect the following information from the applications and devices you use to access our Services:

1.4 Information We Receive from Third Parties.

We may receive information that others provide about you when they use the Services (through Contacts provided to us as described above), or obtain information from other sources, including but not limited to public or licensed APIs (“Public Data”), and combine that with information we collect through the Services. We do not control, supervise, or respond for how the third parties providing your information process your Personal Data.

2. HOW WE USE INFORMATION

We use, store, and process information, including Personal Data, to provide, understand, improve, and develop our Services, create and maintain a trusted and safer environment, and comply with our legal obligations.

2.1 Provide, Maintain, and Support the Services

Using the information we collect, we are able to deliver the Services to you and honor our Terms of Use. For example, we may process your Contacts to provide you with the contact management features you select, including but not limited to Contact storage, backup, editing, synchronization, deduplication, search, tagging, sharing, and grouping.

Relationship information may be used for relationship management services including determining, classifying, and ranking relationships, as well as recommending communication actions, appointments, or new connections. Relationship information may also be used to improve certain contact management functions such as deduplication, tagging, and grouping.

We also need to use the information you provide (including Personal Data) to facilitate the creation of and secure your Account on our network, identify you as a user in our system, provide improved administration and quality of experience of our Site and Services, send email, call, or send SMS text messages to you to verify ownership of the email address or phone number provided when your Account was created, send you service, support or maintenance messages, updates, security alerts, and Account notifications. Your information may also be used for the detection and prevention of fraud, spam, abuse, and other harmful activity, and for any purpose you authorize at the time of collection.

Additionally, to provide you technical support, we may need to review your Account and the contents of your Account to identify, research, troubleshoot, and resolve any issues that you report to us or that we otherwise become aware of.

2.2 Improve, Personalize, and Develop the Services

We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys; and develop new features and services.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing

We may process your information (including Personal Data) for marketing purposes including profiling and offering you products or services that may be of interest to you (such as information about our Services or partner campaigns and other third party services). We may also administer referral programs, rewards, surveys, sweepstakes, contests, newsletters, or other promotional activities or events sponsored or managed by us or a third party partners. You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your Account.

We may also process your Contacts and relationship information to suggest people for you to invite to use our Services. When you have chosen to send a referral to another individual or organization, we may process your Contacts and relationship information to facilitate your referral invitations.

2.4 Combine Contacts Across Users

By selectively combining your Contacts and relationship information with information from other users we can provide you and other users with enhanced features and Services. Your Contacts may be combined with other Users’ Contacts, as well as Public Data and other publicly available information and information we receive from third parties, to build more complete contact records of individuals (“Completed Contact Data”). Completed Contact Data reside in our Database and may be processed for the purposes described in the remainder of this section.

Completed Contact Data may be used to provide you and other Users of our Services with enhanced deduplication. Deduplication is a service that cleans up Contacts by automatically merging duplicate Contact records. The deduplication service relies on making associations between different Contact elements. For example, you might have two Contacts for the same individual in your address book or in your Customer database or file: one Contact that contains just a first name and a phone number, and a second Contact that contains a full name and an email address only. In order to determine whether those two Contacts represent the same individual and should be merged, we look at the Completed Contact Data for that individual. If, in this example, both the phone number and the email address exist within Completed Contact Data for that individual, we may automatically merge (or suggest you to merge) your two Contacts.

In the above example, we may have learned of the linkage between the phone number and email address from publicly available sources. In other cases, we may have been able to infer the linkage or we may have learned the linkage from one or more other Users of our Services who have contributed a Contact that contains those two contact elements together. In this way you are benefiting from information that other Users of our Services have contributed to Completed Contact Data. Similarly, contributing your information to Completed Contact Data benefits other Users of our Services. Relationship information from you and other Users of our Services may also be used in providing enhanced deduplication. For example, the fact that two Contacts in your address book contain the same first name may increase the chances that those Contacts represent the same individual.

Your Contact information may also be combined with other Users of our Services data to provide contact enrichment. In contact enrichment, a User is able to match a Contact that they possess to our Completed Contact Data, and receive back a subset of the contact information from the relevant Completed Contact Data for that individual. For example, we may share an individual’s name to support features including but not limited to caller ID. We also may share public social handles to support Contact Enrichment. Certain professional information including but not limited to business emails, organizational affiliation and job title, that can be inferred or extracted from a business card or email signature, may also be shared. Finally, generalized demographic information such as age range and gender, affinities, unique pseudonymized identifiers,, as well as derived general location from a phone number or physical address, may also be shared. We will never share physical addresses, personal phone numbers, personal emails unless you have given us your specific and unequivocal permission to share that information or we have secured the information via pseudonymization (e.g., through cryptographic hashing). We will never share any of your private notes with any other User.

We also use Completed Contact Data to provide Contact Search, such as when an User of our Services wants to retrieve a set of Completed Contact Data based on a set of search criteria. With the exception of the shareable contact elements described above, all contact elements in a Completed Contact are considered private and are not shared with other Users of our Services . However, any contact element (including those private elements) may be used for lookup and matching purposes.

2.5 Creation of Anonymous Data

We may create Anonymous Data records from information by excluding certain private data in a manner that makes the data not personally identifiable. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in our sole discretion.

3. HOW INFORMATION IS SHARED

3.1 When You Consent, Agree or Direct Us to Share

You may authorize us to disclose your information to others, such as when you connect a third party application or website to access your Account, when you participate in promotional activities conducted by our partners or third parties or when you exercise consent as requested in the use of our Services.

3.2 Sharing between Users

To provide our Services, we may need to share certain information with other Users of our Services , as it is necessary for the adequate performance of the contract between you and us and for performance of certain features of our Services based on our legitimate interest. Examples include, but are not limited to, sharing information through our Teams products as well as information contributed to our Database for the purposes of improving the Services for both you and other End Users and Developers (as described in Section 2.4).

3.3 Compliance with Law, Responding to Legal Requests, Preventing Harm, and Protection of Yours or Our Rights

Regardless of any choices you make regarding your Personal Data (as described below), we may disclose Personal Data if it believes in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with applicable laws, including laws outside your country of residence; (c) to respond to requests from public and government authorities (including authorities outside your country of residence) or to respond to subpoenas or warrants; (d) to protect or defend our rights or our property of and/or that of you or other End Users or Developers; and/or (e) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or Terms of Use. In addition, under certain applicable laws, individuals may have the right to require that we disclose to them their information (including Personal Data) that we store in our Database. We will make such disclosures required by law, but we will not disclose you as the source of that information unless required by law.

3.4 Service Providers

We use a variety of third party service providers to help us provide our Services. These Service providers may be located anywhere worldwide in countries outside your country of residence. In particular, currently use service providers based in Europe, India, Asia Pacific and North and South America.

In order to facilitate payments for Services we provide, certain information as described above may be shared with the relevant payments service providers. This data sharing is necessary for the performance of the contract between you and us.

These service providers may have limited access to your information as necessary to perform these services on our behalf, and are contractually bound to protect and to use your information only for the purposes for which it was disclosed and consistent with this Privacy Policy.

We may need to share your information in order to deliver the Services to you and honor our Terms of Use.

3.5 Corporate Affiliates

To enable or support us in providing the Services, we may share your information including Personal Data, in compliance with local data privacy laws, within our corporate family of companies that are related by common ownership or control.

3.6 Social Media Platforms.

Where permissible according to applicable law we may use certain derivative Personal Data about you, such as a cryptographic hash of a personal email and share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our Sites or otherwise promote our Services.

The social media platforms with which we may share your Personal Data are not controlled or supervised by us. Therefore, any questions regarding how your social media platform service provider processes your Personal Data should be directed to such provider.

Please note that you may, at any time ask us to cease processing your Personal Data for these direct marketing purposes by sending an email to: privacy@contactspls.com.

3.7 Business Transfers.

If we undertake or are involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information, in connection with such transaction, or in preparation for or contemplation of such transaction (e.g., due diligence).

3.8 Aggregated and Anonymized Data.

We may also use and share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other Anonymized Data for any lawful purpose, including (but not limited to) regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

4. DATA RETENTION

We generally retain your information for as long as is necessary for the performance of the Services to you and our other Users and to comply with our legal obligations. This includes information that you have made available to our Database for the purposes of improving the Services for both you and other Users of our Services (as described in Section 2.4).

You may request that we delete your information and close your Account or you can delete your End User Contact Data and close your Account on your own. Please note that if you request the deletion of your information or if you delete your information:

5. THIRD PARTY WEBSITES

When you click on a link to any other website or location, you will leave our Site and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites, or the manner in which they collect, use and handle information or content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

6. MINORS

Our Services are not intended for or designed to attract anyone under the age of 18 ("Minors"). We don’t intentionally or knowingly collect personal information regarding Minors and our Terms of Use explicitly prohibit the use of our Services by Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data without such parent or guardian's consent, he or she should contact us. We will then delete such information from our Database.

7. DATA PROTECTION

7.1 Security

We are continuously implementing and updating appropriate technical and organizational measures to help protect your Personal Data against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your Personal Data are firewalls and data encryption, and information access controls. If you know or have reason to believe that your account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Account, please contact us following the instructions in the “Contact Us” section below.

7.2. Our International Operations and Data Transfers

To bring you our Services, we operate globally. We may transfer, store, and process your information within our family of companies or with service providers based in Europe, India, Asia and North America. Laws in these countries may differ from the laws applicable to your country of residence. For example, information collected within the European Economic Area (the “EEA”) may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy.

7.3 EU-US and Swiss-US Privacy Shield

We comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States, respectively. We have certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, we are subject to the authority of the Federal Trade Commission. If you have any questions or concerns relating to our Privacy Shield certification, contact us at: FullContact, Inc., Legal Department, 1755 Blake St., Suite #450 Denver, Colorado 80202, or via email: legal@contactspls.com. If we are not able to resolve your concern, you may also contact our designated Privacy Shield independent dispute resolution provider, JAMS. In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.

8. YOUR RIGHTS

8.1 Email Choices

We offer you choices regarding the collection, use, and sharing of your Personal Data. If you are a User of our Services , we may periodically send you free newsletters and emails that promote our Site or Services as well as products or services we think you may be interested in. When you receive such promotional newsletters or communications from us, you may indicate a preference to stop receiving them from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the email you receive or by contacting us directly. Despite your indicated email preferences, we may send you service related communication, including notices of any updates to our Terms of Use or Privacy Policy.

8.2 Access, Correction, and Deletion

We allow any data subject, including the End Users of our Services, to access, modify, and set permissions with respect to Personal Data that it holds about them. You and any data subject may access and make corrections and choices about your Personal Data by visiting our “Claim Profile” page (located at https://www.contactspls.com/help/sar.html).

Please note however that, if you request that we delete your Personal Data, we will not do so to protect your rights and freedoms because, if we do, another user may later upload your contact information and we will not have a record that you requested that your contact information be deleted. Instead of deleting your End User Contact Data from the our Database, we will retain it but flag it, restrict any further processing and not use or share it with any third parties. Finally, we provide you with the ability to export your Personal Data, End User Contact Data or Completed Contact Data from some of our Services at any time using industry standard formats.

Further information for data subjects can be found at https://www.contactspls.com/privacy_notice.html.

8.3 California Privacy Rights

California law permits users and customers who are California residents to request and obtain from us, once a year, free of charge, a list of the third parties to whom we have disclosed their Personal Data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Data disclosed to those third parties. See the “Contact Us” section below for where to send such requests.

9. YOUR RIGHTS UNDER THE GDPR

In the Use of our Services we mainly act as data processor and, in some cases, we may act as data controller when we determine the purposes and means of the processing of Personal Data.

EEA residents may exercise any of the rights described in this section by using the applicable functionality in our Services or by contacting us directly. If you reside outside of the European Union, you may have similar rights under your local laws. Please note that we may ask you to verify your identity before taking action on your request.

9.1 Purposes and Legal Basis for Processing. The purposes for processing are described in detail in Section 2 ("HOW WE USE INFORMATION"). In the Use of our Services when we act as data controller the legal basis for processing is as follows:

Provide and Maintain the Services (Section 2.1): This enables us to deliver the Services to you and honor our Terms of Use in the performance of a contract.

Improve, Personalize, and Develop the Services (Section 2.2): This use is based on our Legitimate Interest in improving our services for you and other users.

Provide, Personalize, Measure, and Improve our Advertising and Marketing (Section 2.3): This use is based on our Legitimate Interest in marketing our Services.

Combine Contacts and Relationship Information Across Users (Section 2.4): This use is necessary to deliver certain Services to you and is based on our your explicit Consent.

Creation of Anonymous Data (Section 2.5): This use is based on our Legitimate Interests to improve and market our Services.

9.2 Categories of Recipients of Data. Recipients of data are detailed in Section 3 ("HOW INFORMATION IS SHARED").

9.3 Rectification of Inaccurate or Incomplete Information. You have the right to ask us to correct inaccurate or incomplete Personal Data concerning you (and which you cannot update yourself within your Account).

9.4 Data Access and Portability. In some jurisdictions, applicable law may entitle you to request copies of your Personal Data held by us. You may also be entitled to request copies of Personal Data that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

9.5 Withdrawing Consent and Restriction of Processing. Where you have provided your consent to the processing of your Personal Data by us you may easily withdraw your consent at any time specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your Personal Data, in particular where (i) you contest the accuracy of your Personal Data; (ii) the processing is unlawful and you oppose the erasure of your Personal Data; (iii) we no longer need your Personal Data for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 9.2.6 below (“Objection to Processing”) and pending the verification whether the legitimate grounds of Contacts+ override your own.

9.6 Objection to Processing. In some jurisdictions, applicable law may entitle you to require us not to process your Personal Data for certain specific purposes, where such processing is based on legitimate interest. If you object to such processing we will no longer process your Personal Data for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise, or defence of legal claims.

Where your Personal Data is processed for direct marketing purposes, you may, at any time, ask us to cease processing your Personal Data for these direct marketing purposes by sending an email to: privacy@contactspls.com.

9.7 Lodging Complaints. You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities. If you are a EEA resident, you have the right to file a complaint with your applicable data protection authority.

10. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an email to the last email address associated with your Account, and/or by prominently posting notice of the changes on our Site. If any changes materially affect the manner in which we use or disclose Personal Data, we will provide advance notice of the change by email to the last email address associated with your Account, and/or by prominently posting notice of the changes on our Site. Continued use of our Site or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes

11. HOW TO CONTACT US

If you have any questions or complaints about this Privacy Policy, please contact us at: privacy@contactspls.com

Data Protection Officer (DPO):
Hector Rodriguez, CIPP/E
privacy@contactspls.com

Organization:
FullContact Inc. (a Delaware Company)
1755 Blake St., Suite #450 Denver, Colorado 80202
+1-888-330-6943