Policy Version Date: May 25, 2018
CommercialTribe collects information under the direction of its Clients and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
CommercialTribe has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to the CommercialTribe’s Client (the data controller). If requested to remove data, we will respond within a reasonable timeframe.
We will retain personal data we process on behalf of our Clients for as long as needed to provide services to our Client. CommercialTribe will retain this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
1. Information Collected
We may collect personal identification information from Users and visitors to our Applications in a variety of ways, including, but not limited to, when Users visit our Applications, fill out a form, and in connection with the Service or the other activities, services, features or resources we make available on our Applications. When registered to use the Services through our Applications, we will require our customers to give us contact information which includes certain user personal information, such as name, company name, email address, location, and role or departmental organization, as well as the number of Users within the organization that will be using the Services. CommercialTribe also requires Users to submit video, audio, or presentation content where necessary to respond to activities or prompts from Clients. At the time you express interest in obtaining additional information about our Services, or when you register for the Services, we may also ask for additional information about you and your company, such as title, department name, or additional company information, such as number of employees and industry. Users and visitors can browse the public website without providing any personal information and individuals may always refuse to supply personally identification information at any time, except that it may prevent them from engaging in certain site-related activities, such as login and recording. Use of some CommercialTribe applications requires the collection of certain personal information, at a minimum name, email address, and company name, as well as User-submitted video content, should the User choose to use the Service.
We may collect non-personal identification information about Users and visitors to our Applications whenever they interact with our Applications or use our Services. Non-personal identification information may include the browser name, the type of computer and technical information about Users and visitors means of connection to our Applications, such as the operating system and the Internet service providers utilized and other similar information. We may combine this automatically collected log information with other information we collect about you. We do this to improve the functionality of the services that we offer you.
2. How We Use Collected Information
We use the information you provide to:
- Administer your account with us, deliver our Services, and customize the Services we provide to you.
- Respond to your inquiries or customer service requests.
- Enable you to record video or audio content, or submit presentation content, in response to prompts or activities.
- Send you service or promotional communications through email and notices in CommercialTribe.
- Deliver our Services by sharing information with third parties, if necessary. For example, to enable email communications to Users.
- Enable you to share your information and communicate with other Users.
In general, information (including personal information) you submit to us is used by us to provide you and others with the Services, to respond to requests that you make, to improve our Services and to better tailor the features, performance, and support of the Services. In addition, CommercialTribe uses the information that we collect to set up Services for individuals and their organizations. Submitted video, audio, or presentation content is used to create or respond to Client-issued prompts and activities. We may also use the information to contact customers to further discuss customer interest in our company, the Services that we provide, and to send information regarding our company or partners, such as promotions and events. User email addresses and any personal customer information will not be distributed or shared with any third parties other than CommercialTribe employees, consultants and representatives, except as otherwise provided below. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield (see Section 12 below), CommercialTribe is potentially liable. Furthermore, CommercialTribe is taking all commercially reasonable steps to comply with the GDPR enacted in May of 2018.
Users can opt out of being contacted by us, or receiving such information from us, at any time by updating your marketing email preferences, as indicated below or by contacting us at email@example.com. Separately, Users are also asked to provide an email address when registering for the Services, in order to receive a username and password. We may also email information regarding updates to the Services or CommercialTribe. Again, email will not be distributed or shared and Users can opt out of receiving any communication by updating your marketing email preferences at the time it is distributed, or at the time any User registers for the Services.
Except as we explicitly state at the time we request information, or as provided for in the CommercialTribe user agreement governing your use of the Services (the “SaaS Agreement”) or this Statement, we do not disclose to any third party the information provided. Any financial and billing information collected through the use of the Applications is used solely to check the qualifications of prospective customers and to bill for Services. This billing information is not used by CommercialTribe for marketing or promotional purposes.
Users of the Services will be using the Applications to host data and information, some of which may be private or proprietary and may contain personal information about individuals that relate to identified or identifiable individuals (“User Data”). As used herein the term “User Data” also includes Personal Data as defined under GDPR. This includes Username, email address, role/hierarchy information, and self-submitted video/audio and presentation content, where applicable. CommercialTribe will not review, share, distribute, print, or reference any such User Data except as provided in the CommercialTribe SaaS Agreement, or as may be required by law. We or our third-party service providers may view or access User Data only in connection with providing the Services on our behalf and for the purpose of resolving a problem, support issue, or suspected violation of the SaaS Agreement, or as may be required by law. This includes data processing by authorized third parties as part of the SpotLight© service. Users are responsible for maintaining the confidentiality and security of their user registration and password, as CommercialTribe has no access to user passwords.
Information provided by Users and visitors to the Applications is logged to help diagnose technical problems, and to administer our Applications in order to constantly improve the quality of the Service. We may also track and analyze non-identifying and aggregate usage and volume statistical information from our visitors and Users, and we may provide such information to third parties that assist us for these purposes. We may directly collect analytics data, or use third-party analytics tools and services, to help us measure traffic and usage trends for the Services. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Services. We collect and use this analytics information in aggregate form such that it cannot reasonably be manipulated to identify any particular individual User.
3. How We Protect Your Information
We adopt commercially reasonable and appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of User Data and your personal information, username, password, transaction information, and data stored on our Applications. When our Applications are accessed using any currently supported browser, Secure Socket Layer (SSL) technology protects information using both server authentication and data encryption during transmission of User Data. If at any time you have questions about the security of your personal information, you can contact us at firstname.lastname@example.org.
4. Disclosure of Personal Information
Except as otherwise stated in this Statement, we do not disclose to or share your personal information with third parties, unless you ask or authorize us to do so. We do not sell, rent or otherwise provide your personally identifiable information to any third parties for marketing purposes.
We may provide your personal information to third-party service providers and suppliers who work on behalf of or with us to provide you with some of the services and features of the Services and to help us communicate with our Users (for example, in the submission of e-mail communications on our behalf and the providing of customer service). However, these service providers and suppliers do not have any independent right to use this information except to help us provide the Services, and are subject to the same data security and privacy terms as internal practices. Email addresses and names are provided to a third-party transactional email service to communicate with Users, and this service can be suspended at any time within the user profile or by request to email@example.com.
In the event we undergo a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information will likely be among the assets transferred. You acknowledge that such transfers may occur and that any acquirer of CommercialTribe or its assets may continue to use your personal information as set forth in this Statement. You hereby consent to CommercialTribe sharing your personal information under the above circumstances.
In certain situations, CommercialTribe may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. 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.
The United States Federal Trade Commission has jurisdiction to investigate and to bring enforcement actions for claims against CommercialTribe regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy, including the EU-US Privacy Shield.
5. Updating Your Information
Upon request, CommercialTribe will provide you with information about whether we hold or process any of your personal information on behalf of a third party. To request this information please contact us at firstname.lastname@example.org.
Users may update or change their registration information by editing their User Profile, by logging in to your User Account at www.commercialtribe.net with your username and password or by logging into the CT Coach application. Additionally, Users may update personal information, have registration information deleted, or discontinue a User Account by emailing us at email@example.com. We will respond to your request within a reasonable timeframe.
We will retain your information only for as long as your account is active or as needed to provide you services. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
6. Tracking Technologies
We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based on your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union by clicking here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Our website offers publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
9. Social Media Features
Our website includes Social Media Features, such as the Facebook Like button, and Widgets, such as the Share This button or interactive mini-programs that run on our website. These Features may collect your Internet protocol address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.
10. Use of CommercialTribe Screen Recording
Use of CommercialTribe’s Screen Recording functionality allows a user to selectively record applications, desktops, or other tools open on their computer. It is the responsibility of the user to ensure that any information not related to the recording, confidential or otherwise, is not visible on the recording. CommercialTribe can only capture the screen that the user authorizes for recording, and cannot edit content once it is recorded. However, the user can, at any time, re-record, reject, or otherwise delete a screen recording to fully remove that video from the platform, or request this deletion from CommercialTribe at firstname.lastname@example.org.
11. Consent to International Transfer
CommercialTribe primarily stores User Data and data it collects about Users and visitors to the Applications in the United States of America. If you are outside of the United States, please be aware that the United States may have different laws concerning the privacy of personal information than your country of residence and may not provide the same level of data protection as the laws of your country. By submitting personal information to us, you are consenting to the collection, storage, and processing of that information in the United States and to any country to which we may transfer your information for the purposes described in this Statement, except in the case of data transfers from the EEA, which are covered under the US-EU Privacy Shield Framework.
12. EU-U.S. Privacy Shield
EU-U.S. Privacy Shield and SWISS-U.S. Privacy Shield
CommercialTribe participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. CommercialTribe is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on the Privacy Shield Frameworks, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.
CommercialTribe is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. CommercialTribe complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, CommercialTribe is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, CommercialTribe may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
13. GDPR Compliance
CommercialTribe maintains compliance with GDPR regulations, matching or exceeding requirements and industry standards for security and privacy.
Limited Personal Data Collection
CommercialTribe only collects the Personal Data and User Data necessary for account management and platform functionality. The information collected is limited to basic, non-sensitive information about Users, including first and last name, business email address, location, and role within their organization’s hierarchy.
All relationships between CommercialTribe and Users is through organization-level contracts. Demonstrating consent from a user (the data subject) is the responsibility of the CommercialTribe client organization (the data controller).
14. Security, Data Modification, and Retention
CommercialTribe utilizes industry-leading security standards to ensure User Data is kept safe. Access to User Data is limited to Users, their direct managers, and specially designated CT customer success managers.
All system resources are patched in real-time, with automated security and software updates. System code is internally and externally reviewed, including manual tests and reviews, automated scans, and a suite of annual penetration tests. We do not warrant perfect security and we do not provide any guarantee that your User Data or any other information you provide will remain secure.
Data Modification, Portability, and Removal
A User or organization may modify their Personal Data within the CommercialTribe platform. If unable to do so, they may also request changes from CommercialTribe support.
A User or organization may at any time request removal of Personal Data. Generally, contractual obligations require CommercialTribe to disclose when a contracted User requests account deletion. If such a clause is not in place, CommercialTribe will generally consult with the User’s organization and complete deletion within 30 days of the request.
A User or organization may at any time request any or all of their Personal Data.
All data requests must reach email@example.com, and based on the situation will be processed within 30 days.
CommercialTribe will retain personal data on behalf of each customer only for as long as is required to provide services to that customer and in any event, for so long as it is required by law. As we process Personal Data on behalf of clients, we may retain information for the periods requested by the client or delete information as the client’s request. We will review retention periods periodically, and if appropriate, we may pseudonymize or anonymize data held for longer periods.
15. Changes to This Statement
CommercialTribe has the discretion to update this Statement at any time. When we do, we will revise the updated date at the bottom of this page and we will notify you by means of a notice posted on this website when the change becomes effective. We encourage Users to frequently check this page for any changes to stay informed about how we collect, store and use your personal information and User Data. You acknowledge and agree that it is your responsibility to review this Statement periodically and become aware of modifications.
By using this Site or the Services, you signify your acceptance of this Statement. Your continued use of the Site or the Services following the posting of changes to this Statement will be deemed your acceptance of those changes. You may view this Statement at any time on http://www.commercialtribe.com/privacy and within any CommercialTribe application, with a link to the Statement at any point when CommercialTribe collects or uses your personal information.
16. Use of the Mobile Application
We use mobile analytics software to allow us to better understand the functionality of our mobile apps on your mobile device. In addition to information we collect on our Applications, when you use our mobile apps we may also collect your city, device model and version, OS version, network availability, usage, bandwidth your subscription service credentials, and such other relevant information.
We send push notifications from time to time in order to update you about events or promotions. If you no longer wish to receive such communications, you may turn them off at the device level. We may link information we store within the analytics software to personal information you submit within the Applications or in connection with our Services, including the mobile app.
17. Contact Us
If you have any questions or suggestions regarding this Statement please contact us by sending us an e-mail to firstname.lastname@example.org or by contacting us at:
1331 17th St., Suite 400
Denver, CO 80202
18. Your Consent
By using our Applications or our Services, you consent to this Statement.
19. List of Third Parties
Unaffiliated Parties and Partners
The following is a list of unaffiliated third parties with whom we may share data or which may engage in processing:
|Amazon Web Services (AWS)
||Vendor- We use the service Amazon Web Services by Amazon Web Services, Inc. for the purpose of hosting all of the data provided by you, including User Data and Personal Data.
||Vendor- We use the service Google Cloud by Google LLC for the purpose of hosting all of the data provided by you, including User Data and Personal Data.
||Vendor- We use the service MongoDB Atlas by MongoDB, Inc. for the purpose of hosting all of the data provided by you, including User Data and Personal Data.
||Vendor- We use the service Intercom by Intercom, Inc. to provide support services, which service includes access to User Data and Personal Data.
||Vendor- We use the service ZenDesk Support by ZenDesk, Inc. to provide support services, which service includes access to User Data and Personal Data.
||Vendor- We use the service Intercom by FullStory, Inc. to provide support services, which service includes access to User Data and Personal Data.
||Vendor- We use the service Intercom by FullContact, Inc. to provide username and image lookup services, which service includes access to User Data and Personal Data.
||Vendor- We use the service Dropbox by Dropbox, Inc. for the purpose of hosting all of the data provided by you, including User Data and Personal Data for ad-hoc reporting.
||Vendor- We use the service SendGrid by SendGrid, Inc. for the purpose of sending email communications, which service includes access to User Data and Personal Data.
||Vendor- We use the service HubSpot by HubSpot, Inc. for the purpose of storing lead and customer contact data and sending email communications, which service includes access to User Data and Personal Data.
||Vendor- We use the service Salesforce CRM by Salesforce.com, Inc. for the purpose of storing lead and customer contact data and sales information, which data and information also include your User Data and Personal Data.
||Vendor- We use the service Analytics by Google, Inc. for the purpose of storing and analyzing website visitor and marketing campaign performance data, which data and information also include your User Data and Personal Data.
||Vendor- We use the service Adwords by Google, Inc. for the purpose of digital advertising on the Google ad network, and storing and analyzing advertising campaign performance data, which service includes access to User Data and Personal Data.
||Vendor- We use the service PushWoosh by PushWoosh, Inc. for the purpose of sending mobile push notifications, which service includes access to User Data and Personal Data.
||Vendor- We use the service Adroll by Adroll, Inc. for the purpose of displaying retargeting digital advertisements on the Adroll display network, which service includes access to User Data and Personal Data.
||Vendor- We use the service New Relic by New Relic, Inc. for the purpose of providing support services and ensuring platform stability, which service includes access to User Data and Personal Data.
||Vendor- We use Slack by Slack, Inc. for the purpose of providing internal communications when providing support services, which service includes access to User Data and Personal Data.
||Vendor- We use Google Drive by Google, Inc. for the purpose of providing support services and ad-hoc reporting, which service and reporting include access to User Data and Personal Data.
||Vendor- We use Sentry by Sentry, Inc. for the purpose of providing mobile crash analytics, which analytics service includes access to User Data and Personal Data.
||Vendor- We use Chart.io by Chart.io, Inc. for the purpose of hosting all of your data (including User Data and Personal Data) provided for ad-hoc reporting, which service includes access to User Data and Personal Data.
||Vendor- We use iTunes Connect by Apple, Inc. for the purpose of providing test flight (beta) access to mobile applications, which service includes access to User Data and Personal Data.