Privacy Policy

Types of data collected

Among the types of Personal Data that e6data, Inc. collects, by itself or through third parties, are:

• Trackers and Usage Data
• Number of Users and session statistics
• City, and the latitude and longitude of that city
• Device and browser information
• Answers to questions, clicks, keypress events, motion sensor events, mouse movements, scroll position and touch events
• Contact details you submit through our forms, such as name, work email, company and role
• For visitors in the United States, identity attributes such as name, professional email address and professional profile, inferred by our visitor identification provider

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy, or by explanations displayed before the Data is collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this website. Unless specified otherwise, all Data requested is mandatory, and failure to provide it may make it impossible for e6data, Inc. to provide its services. Where e6data, Inc. states that some Data is not mandatory, Users are free not to provide it without consequence to the availability or functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact us.

Any use of Cookies, or of other Trackers, by e6data, Inc. or by the owners of third-party services used by e6data, Inc., serves the purpose of providing the Service required by the User, in addition to any other purposes described in this document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through this website.

Mode and place of processing the data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification or unauthorised destruction of the Data. Data processing is carried out using computers and IT-enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases the Data may be accessible to certain types of persons in charge, involved with the operation of this website (administration, sales, marketing, legal, system administration) or to external parties such as third-party technical service providers, mail carriers, hosting providers, IT companies and communications agencies, appointed where necessary as Data Processors by the Owner. An updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section below describing each processor.

Retention time

Unless specified otherwise in this document, Personal Data is processed and stored for as long as required by the purpose it was collected for. It may be retained longer to comply with applicable legal obligations, or based on the User's consent.

Purposes of processing

The Data concerning the User is collected to allow the Owner to:

• Provide and operate the Service, including hosting
• Comply with legal obligations
• Respond to enforcement requests
• Protect its rights and interests, or those of its Users or third parties
• Detect malicious or fraudulent activity
• Carry out analytics, advertising and conversion measurement, tag management, consent management, and customer messaging

Who processes your data

Personal Data is collected for the purposes above using the following services. Each entry names the recipient, what it receives, and where it processes the Data.

Website visitor identification

We use RB2B, a visitor identification service, on this website. For visitors browsing from the United States, RB2B attempts to match a visit to an individual person and may provide us with identity attributes such as a name, a professional email address and a professional profile, even where the visitor has not filled in a form. We use this to understand which companies and roles are researching e6data, and to follow up on business enquiries.

This processing is described in the Notice at collection below, where these attributes are treated as Identifiers. If you would prefer not to be identified in this way, you can opt out through your privacy choices, or by writing to privacy@e6data.com, and we will remove your record and suppress future identification.

Under US state privacy laws, our use of analytics and advertising services may constitute a Sale or Sharing of Personal Information, and involves Targeted Advertising. Users can control this at any time through your privacy choices.

e6data, Inc. uses Trackers. To learn more, Users may consult the Cookie Policy.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes.
• Provision of Data is necessary for the performance of an agreement with the User, or for any pre-contractual obligations thereof.
• Processing is necessary for compliance with a legal obligation to which the Owner is subject.
• Processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Owner.
• Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Personal Data collected for purposes related to the performance of a contract between the Owner and the User is retained until that contract has been fully performed. Personal Data collected for the purposes of the Owner's legitimate interests is retained as long as needed to fulfil those purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document, or by contacting the Owner.

The Owner may retain Personal Data for a longer period whenever the User has given consent to such processing, as long as that consent is not withdrawn, and may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon the order of an authority. Once the retention period expires, Personal Data is deleted. The right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

Your rights under the GDPR

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law:

• Withdraw their consent at any time, where they have previously given consent to the processing of their Personal Data.
• Object to the processing of their Data where the processing is carried out on a legal basis other than consent.
• Access their Data: to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
• Verify and seek rectification: to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data, in which case the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed.
• Receive their Data and have it transferred to another controller, in a structured, commonly used and machine-readable format and, where technically feasible, transmitted without hindrance.
• Lodge a complaint before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad, including to any international organisation governed by public international law or set up by two or more countries, and about the security measures taken by the Owner to safeguard their Data.

Details about the right to object

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner, or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Where Personal Data is processed for direct marketing purposes, Users can object at any time, free of charge and without providing any justification, and the Personal Data will no longer be processed for those purposes.

How to exercise these rights

Any request to exercise User rights can be directed to the Owner at privacy@e6data.com. Such requests are free of charge and will be answered as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data, or restriction of processing, will be communicated by the Owner to each recipient to whom the Personal Data has been disclosed, unless this proves impossible or involves disproportionate effort. At the User's request, the Owner will inform them about those recipients.

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy, and is provided by the business running this website and, where applicable, its parent, subsidiaries and affiliates. It applies to Users who are residents of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana, and for those Users it supersedes any other possibly divergent or conflicting provisions contained in this privacy policy.

Notice at collection

The following notice provides timely notice about the categories of Personal Information collected or disclosed in the past 12 months. While this categorisation is mainly based on California privacy laws, it is also a useful general guide for Users who are not California residents. For each category below, the retention period is the time necessary to fulfil the purpose; each is Sold or Shared, and used for Targeted Advertising.

Definitions of these concepts are set out in the Definitions and legal references section below.

Sources of the Personal Information we collect

We collect the categories of Personal Information above, either directly or indirectly, from you when you use this website. You provide Personal Information directly when you submit a request via any form on this website. You provide it indirectly when you navigate the website, as Personal Information about you is automatically observed and collected. We may also collect your Personal Information from third parties that work with us in connection with the Service or the functioning of this website, including our visitor identification provider.

Your privacy rights under US state laws

• The right to know and to access Personal Information: to request that we confirm whether we are processing your Personal Information, and to access it.
• The right to correct inaccurate Personal Information that we maintain about you.
• The right to request the deletion of your Personal Information.
• The right to obtain a copy of your Personal Information in a portable and usable format, where technically feasible.
• The right to opt out of the Sale of your Personal Information.
• The right to non-discrimination for exercising your privacy rights.

Additional rights for Users residing in California

• The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising.
• The right to request that we limit our use or disclosure of your Sensitive Personal Information to what is necessary to perform the services or provide the goods reasonably expected by an average consumer. Certain exceptions outlined in the law may apply.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana

• The right to opt out of the processing of your Personal Information for Targeted Advertising, or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
• The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Certain exceptions outlined in the law may apply.

Additional rights for Users residing in Utah

• The right to opt out of the processing of your Personal Information for Targeted Advertising.
• The right to opt out of the processing of your Sensitive Personal Information. Certain exceptions outlined in the law may apply.

How to exercise your rights

To exercise the rights described above, submit your request to us at privacy@e6data.com. For us to respond, we must be able to verify who you are: we will not respond to a request if we are unable to verify your identity and confirm that the Personal Information in our possession relates to you. You are not required to create an account with us to submit a request. Any Personal Information collected from you in connection with verification is used solely for verification, is not further disclosed, is not retained longer than necessary for that purpose, and is not used for unrelated purposes. If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

To opt out of Sale or Sharing and of Targeted Advertising, you can use your privacy choices on this website at any time. If you submit requests to opt out via a user-enabled global privacy control, such as the Global Privacy Control (GPC), you are free to do so and we will abide by such a request in a frictionless manner.

How and when we handle your request

We will respond to your request without undue delay, and in all cases within the timeframe required by applicable law. Should we need more time, we will explain why and how much more time we need. Should we deny your request, we will explain the reasons behind the denial; where applicable law provides for it, you may then contact the relevant authority to submit a complaint. We do not charge a fee to process or respond to your request unless the request is manifestly unfounded or excessive, or in other cases permitted by applicable law. In those cases we may charge a reasonable fee or refuse to act on the request, and will communicate our choice and the reasons for it.

Further information for Users in Brazil

This section integrates with and supplements the information contained in the rest of the privacy policy, and is provided by the entity running this website and, where applicable, its parent, subsidiaries and affiliates. It applies to all Users in Brazil according to the Lei Geral de Proteção de Dados (the LGPD), and for those Users it supersedes any other possibly divergent or conflicting information contained in this privacy policy. This part of the document uses the term "personal information" as defined in the LGPD.

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. The legal bases are:

• Your consent to the relevant processing activities.
• Compliance with a legal or regulatory obligation that lies with us.
• The carrying out of public policies provided in laws or regulations, or based on contracts, agreements and similar legal instruments.
• Studies conducted by research entities, preferably carried out on anonymised personal information.
• The carrying out of a contract and its preliminary procedures, where you are a party to that contract.
• The exercising of our rights in judicial, administrative or arbitration procedures.
• Protection or physical safety of yourself or a third party.
• The protection of health, in procedures carried out by health entities or professionals.
• Our legitimate interests, provided that your fundamental rights and liberties do not prevail over those interests.
• Credit protection.

Categories of personal information processed, and why

To find out what categories of your personal information are processed and why, read the sections titled Who processes your data and Purposes of processing in this document.

Your Brazilian privacy rights

• Obtain confirmation of the existence of processing activities on your personal information.
• Access your personal information.
• Have incomplete, inaccurate or outdated personal information rectified.
• Obtain the anonymisation, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD.
• Obtain information on the possibility to provide or deny your consent, and the consequences thereof.
• Obtain information about the third parties with whom we share your personal information.
• Obtain, upon express request, the portability of your personal information to another service or product provider, except for anonymised information, and provided that our commercial and industrial secrets are safeguarded.
• Obtain the deletion of your personal information being processed, if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply.
• Revoke your consent at any time.
• Lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies.
• Oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law.
• Request clear and adequate information regarding the criteria and procedures used for an automated decision.
• Request the review of decisions made solely on the basis of automated processing of your personal information which affect your interests, including decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against or otherwise suffer any detriment if you exercise your rights.

How to file your request, and how we respond

You can file your express request to exercise your rights free of charge, at any time, at privacy@e6data.com, or via your legal representative. We will strive to respond promptly. Should it be impossible for us to do so, we will communicate the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your request. Where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your request, if we are in a position to do so.

If you file an access or processing confirmation request, please specify whether you would like your personal information delivered in electronic or printed form, and whether you want us to answer immediately in a simplified fashion, or to provide a complete disclosure instead. In the latter case, we will respond within 15 days of your request, providing all the information on the origin of your personal information, confirmation of whether records exist, any criteria used for the processing, and the purposes of the processing, while safeguarding our commercial and industrial secrets.

If you file a rectification, deletion, anonymisation or blocking request, we will immediately communicate your request to other parties with whom we have shared your personal information so that they can also comply, except where such communication is proven impossible or involves disproportionate effort on our side.

Transfer of personal information outside of Brazil

We are allowed to transfer your personal information outside Brazilian territory where the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies; where it is necessary to protect your life or physical security or those of a third party; where it is authorised by the ANPD; where it results from a commitment undertaken in an international cooperation agreement; where it is necessary for the execution of a public policy or legal attribution of public service; or where it is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

Additional information about data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in court, or in the stages leading to possible legal action arising from improper use of this website or the related Services. The User declares to be aware that the Owner may be required to reveal Personal Data upon request of public authorities.

Additional information about the User's Personal Data

In addition to the information contained in this privacy policy, e6data, Inc. may provide the User with additional and contextual information concerning particular Services, or the collection and processing of Personal Data, upon request.

System logs and maintenance

For operation and maintenance purposes, this website and any third-party services may collect files that record interaction with it (system logs), or use other Personal Data such as the IP address for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time, using the contact details at the top of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and, where technically and legally feasible, by sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top. Should the changes affect processing activities performed on the basis of the User's consent, the Owner will collect new consent from the User where required.

Definitions and legal references

Legal information

This privacy statement has been prepared based on provisions of multiple legislations. This privacy policy relates solely to e6data, Inc., unless stated otherwise within this document.

Contact

For any question about this policy, or to exercise any of the rights described above, contact e6data, Inc. at privacy@e6data.com, or write to 355 Bryant Street, Suite 403, San Francisco, CA 94107, USA.