Platform Privacy Policy

XANT – Platform Privacy Policy

 

Last updated: April 21, 2021

 

  1. Scope

 

  1. What Personal Information Do We Collect from or about You?

 

  1. How Do We Use Your Personal Information?

 

  1. With Whom Do We Share Your Personal Information?

 

  1. Cookies

 

  1. Where Do We Store Your Personal Information?

 

  1. How Do We Keep Your Personal Information Safe?

 

  1. How Long Do We Keep Your Personal Information?

 

  1. European Privacy Rights

 

  1. International Data Transfers

 

  1. Information for California Residents

 

  1. Where Can You Find Changes to this Policy?

 

  1. What about the Privacy of Users Who Are 13 and Under?

 

  1. Contact Us

 

 

  1. Scope

 

XANT, Inc. (“XANT,” “we,” “our” and/or “us”) is committed to protecting your privacy as described in this Platform Privacy Policy (the “Policy”).  This Policy describes how we use and share Personal Information collected through our cloud-based software platform (the “Platform”), which we make available to our business customers (the “Customers”).

 

The Platform synchronizes with a Customer’s Customer Relationship Management (“CRM”) platform(s) to pull Personal Information from the Customer’s CRM platform (“Customer Data”).  When collecting and processing Customer Data on behalf of and on instructions from a Customer to provide the Platform, XANT acts as a processor of the Customer, who is the data controller.  For more information, including on how to exercise your rights to your Personal Information, please refer to the privacy policy of the Customer who submitted your Personal Information to the Platform.

 

XANT also may process Personal Information as a controller when it collects Personal Information about your use of the Platform, when it combines Customer Data with Personal Information gathered from other Customers and vendors, and when it processes Personal Information of business contacts in connection with its customer, partner, and vendor relationships.  This Policy describes XANT’s data processing activities as a controller.

 

As used in this Policy, “Personal Information” means information relating to an identified or identifiable individual.

 

This Policy does not apply to any Personal Information collected through our website (https://www.insidesales.com (the “Site”)) or the XANT web applications and related services provided through the Site.  Such Personal Information is subject to our Website Privacy Policy.

 

  1. What Personal Information Do We Collect from or about You?

 

Information Collected via Automated Means

 

  • Platform Usage Information. We will collect and process information regarding your use of the Platform via cookies and similar technologies.  Such information may include your: number of unique logins, operating system, internet protocol address, source type, session duration, information about the server environment, OS type/version, CPU type/version, browser type/version, operating system type/version, device type/version, or such other similar information about your user configuration or operation of the Platform. We also collect Personal Information from emails and phone calls we process, such as email addresses and phone numbers.

 

  • Customer Data. We may collect Personal Information from a Customer’s CRM via standard application programming interface connectors. Our customers determine which Personal Information to provide us, and such information may include: first name, last name, postal address, email address, telephone number, mobile telephone number, business contact information, title, company.

 

Information Collected from Other Sources

 

  • Social Media Account Login. You can log in to the customer support area of our Platform using third-party sign-in services, such as Facebook Connect or an Open ID provider.  These services will take steps to authenticate your identity and may provide you the option to share certain Personal Information with us.

 

  • Third-Party Providers. We may obtain Personal Information about you from public records or from third parties.  Such Personal Information may include professional characteristics, such as contact information, job title, or employer information.

 

  • Customer, Vendor, and Partner Relationships. Through our customer, vendor, and partner relationships, we may receive Personal Information of employees and other individuals who are contact persons at our Customers, vendors, and partners, such as contact details and other information relevant to the applicable business relationship.

 

  1. How Do We Use Your Personal Information?

 

We may use your Personal Information:

 

  • To operate, maintain, debug, improve, and enhance our Platform;
  • To (i) determine which configurations or practices optimize the performance of the Platform; and (ii) identify, understand, and anticipate performance issues and the environmental factors that affect them;
  • To develop new features, products, and services;
  • For machine learning and analytics purposes;
  • To identify characteristics relating to sales leads and prospects, including sales activity, title, and email and phone response characteristics, which may be used to forecast sales leads’ and prospects’ propensities (e.g., likeliness to engage with vendors);
  • To understand how our users configure and use our Platform;
  • To verify the accuracy of Personal Information processed through our Platform;
  • In a de-identified and aggregated form for analytics purposes;
  • To find and prevent fraud and to respond to trust and safety issues that may arise;
  • For compliance purposes, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
  • To anonymize your Personal Information.

 

Our Use of European Personal Information

 

If you are located in the European Economic Area or the United Kingdom (together “Europe”), we only process your Personal Information as data controllers when we have a valid legal basis to do so, including when:

 

  • You have consented to the use of your Personal Information.

 

  • Compliance with a Legal Obligation. We have a legal obligation to use your Personal Information.  For example, we may use your Personal Information to comply with tax and accounting obligations.

 

  • We need your Personal Information to provide you with requested services (e.g., to respond to your inquiries).

 

  • Legitimate Interests. We may have a legitimate interest in using your Personal Information.  In particular, we have a legitimate interest in using your Personal Information to develop, expand, and improve our Platform.  We only rely on our legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

 

  1. With Whom Do We Share Personal Information?

 

We will share Personal Information with third parties as described in this Policy.

 

  • We may share Personal Information with our affiliates and subsidiaries for any purposes listed in this Policy.

 

  • Service Providers. We may share Personal Information with third parties for the provision of services on our behalf, such as website and data hosting services, IT support services, or relating to facilitating feedback on our services.  These service providers are authorized to use Personal Information to perform their services to us.

 

  • We may share Personal Information with partners to assist us in the improvement and optimization of the Platform or understanding patterns of usage and behavior. We may provide Personal Information to businesses who are offering services in partnership with XANT, to the extent required to develop and operate such services.

 

  • Legal Process or Law Enforcement. We may be required by law enforcement or judicial authorities to provide Personal Information to the appropriate governmental authorities.  If your Personal Information is subject to European Union or United Kingdom data protection laws, we will make such disclosures only to the extent permitted under those laws.

 

  • Business Transfers. We may transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

 

  1. Cookies

 

Our Platform uses cookies and/or other similar technologies such as device-IDs, in-App codes, pixel tags, or web beacons to collect and store certain information (collectively, “Cookies”).  Most web browsers automatically accept Cookies, but if you prefer, you can change your browser settings to prevent that.  Please review your web browser’s “Help” file to learn the proper way to modify your Cookies settings.  However, you may not be able to take full advantage of our Platform if you do so.  Please read our Cookie Policy to learn more about our use of Cookies on our Platform.

 

  1. Where Do We Store Your Personal Information?

 

Your Personal Information is stored in a repository that contains both structured and unstructured data.  This repository is architected according to rigorous data engineering protocols designed for raw data storage, data staging, and data mart aggregation, and it leverages industry-leading cloud services, such as AWS and Azure.

 

  1. How Do We Keep Your Personal Information Safe?

 

We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal Information we maintain.  However, as no electronic transmission or storage of Personal Information can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Information.

 

  1. How Long Do We Keep Your Personal Information?

 

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you once your Personal Information is no longer necessary for the purposes for which we process it unless we are required by law to keep your Personal Information for a longer period.  In principle, we will retain your Personal Information for as long as needed to operate the Platform.  When determining the specific retention period, we consider various criteria, such as the type of service provided, the mandatory retention periods provided by law, and any applicable statutes of limitations.

 

  1. European Privacy Rights

 

If you are located in Europe, you may have the following privacy rights:

 

  • You may request access to the Personal Information we maintain about you, update, and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the Personal Information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. You also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place.

 

  • You may withdraw any consent you previously provided to us regarding the processing of your Personal Information, at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing conducted before your withdrawal of your consent.

 

If you want to exercise these rights, please direct your query to our Customer with whom you interact directly. You can also contact us at privacy@xant.ai, and we may refer your request to the concerned Customer if appropriate.  Before fulfilling your request, we may ask you to provide reasonable information to verify your identity.  Please note that there are exceptions and limitations to each of these rights, subject to local law requirements.

While any changes that you make to your Personal Information pursuant to this section will be reflected in active user databases instantly or within a reasonable period, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, to the extent permitted under applicable law.

 

  1. Information for California Residents

 

This Section 10 applies only to users of our Platform who are California residents.  As used in this section, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended, or superseded from time to time (“CCPA”).

 

Collection of Personal Information

 

We have listed below the Personal Information we may have collected, disclosed for a business purpose, or used for business or commercial purposes from California residents in the preceding twelve (12) months since this Policy was last updated.  We may also collect information about you from other sources, including third parties from whom we purchase Personal Information, and from publicly available information.  Such information includes identifiers, personal characteristics, professional information, geolocation information, educational information, commercial information, internet activity, and inferences derived from Personal Information.

 

We do not sell Personal Information.  However, we may share any of the above listed Personal Information with third parties or allow them to collect Personal Information on our behalf for “business purposes” as defined by the CCPA, including for maintaining and operating services, securing data, and marketing.

 

Use of Personal Information

 

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes as described in Sections 2 through 6 of this Policy.

 

Disclosure of Personal Information

 

As set forth in Section 4 of this Policy, we may share your Personal Information with the categories of third parties listed below:

 

  1. Affiliates and/or subsidiaries
  2. Service providers, agents, and/or subcontractors
  • Analytics and search engine providers

 

Right to Know and Access

 

You may submit a verifiable request for information regarding the: (i) categories of Personal Information collected, sold, or disclosed by us; (ii) purposes for which categories of Personal Information are collected or sold by us; (iii) categories of sources from which we collect Personal Information; (iv) categories of third parties with whom we disclosed or sold Personal Information; and (v) specific pieces of Personal Information we have collected about you during the past twelve (12) months.

 

Right to Delete

 

Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

 

Verification

 

Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity considering the information requested and pursuant to relevant CCPA requirements, limitations, and regulations.  To verify your access or deletion request, we will contact you through the contact information we have associated with you and may require that you verify your identity before we take action on your request.

 

Authorizing an Agent

 

To authorize an agent to make a request to know or delete on your behalf, please email us at privacy@xant.ai.

 

Right to Equal Service and Price

 

You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

 

Shine the Light

 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits California consumers to request certain information regarding XANT’s disclosure of Personal Information to third parties for their direct marketing purposes.  To make such a request, please send an email to privacy@xant.ai.

 

Requests

 

You can make requests related to your California privacy rights here. You may also make such requests by calling (866) 203-2740.

 

We do not accept or process requests through other means (e.g., fax, social media, email addresses, etc.).

 

When you make a request, we may ask you to provide verification information, such as your name, email, or phone number.  We will review the information provided, and we may request additional information via email or other means designed to ensure we are interacting with the correct individual as described above.

 

  1. International Data Transfers

 

We may transfer your Personal Information to the United States (“U.S.”), and to our affiliates, subsidiaries, service providers, and partners who may be located in the U.S. or in other jurisdictions worldwide. Laws governing data collection and use in those countries may differ from the laws applicable in your jurisdiction.  When we transfer your Personal Information outside of your jurisdiction, we take steps to comply with applicable data protection law, and in particular, legal requirements regarding adequate protection for data transfers.

 

If you are located in Europe, we will comply with applicable data protection laws when transferring your Personal Information outside of Europe.  We may transfer your Personal Information to countries which have been found to provide adequate protection according to the competent authorities (such as the European Commission), use contractual protections for the transfer of Personal Information, or transfer to recipients who have adopted Binding Corporate Rules. For more information about how we transfer Personal Information outside of Europe, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us as specified below.

 

  1. Where Can You Find Changes to this Policy?

 

We will post any adjustments to the Policy on this page, and the revised version will be effective when it is posted.  If we materially change the ways in which we use or share Personal Information previously collected from you through our Platform, we will notify you through our Platform, by email, or other means prior to the change becoming effective.

 

 

Privacy of Users Age 13 and Under.

 

If you are under the age of 13, you do not have permission to use our Platform.  We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age, and no parts of our Platform are directed to children.  If you learn that a child has provided us with Personal Information in violation of this Policy, you may alert us at privacy@xant.ai.

 

  1. Contact Us

 

The entity responsible for the processing of your Personal Information is XANT, Inc.  If you have questions about this Policy, or you would like to exercise your privacy rights as described in this Policy, please email us at privacy@xant.ai or write to us at:

 

XANT, Inc.
401 CONGRESS AVE, SUITE 2650
AUSTIN, TX 78701