Purpose and Scope:
Transparency/Notice – Types of Personal Data We Collect and How We Use It
The types of Personal Data we may collect (directly from you or from third-party sources) and our privacy practices depend on the nature of the relationship you have with SnapLogic and the requirements of applicable law. Some of the ways that Snaplogic may collect Personal Data include:
- You may provide Personal Data directly to SnapLogic through interacting with the Site or Services or requesting information.
- As you navigate the Site or the Services, certain passive Personal Data may also be collected about your visit, including through cookies and similar technologies as described below.
We will strive to collect only that Personal Data which is relevant for the purposes of operating the Site and the Services. Below are the ways we collect Personal Data and how we use it.
Types of Personal Data We Collect:
SnapLogic collects information, including Personal Data, from and regarding its current, prospective and former customers, users and visitors (collectively “Individuals”).
- Personal Data You Provide Directly to Us. When you use the Services or register for a Services account with SnapLogic, or when interacting with the Site, responding to surveys, requesting information or contracting us directly, we may ask you to provide some or all of the following types of information:
- Account Creation. We may collect Personal Data from you to create a Services account, such as your name, job title, email address, phone number, username, information and other Personal Data requested at the time which you register for an account with either the Site or the Services.
- Use of the Site or Services. When you access or otherwise use the Site or the Services, we may collect Personal Data from you.
- Communications with Us. We may collect Personal Data from you such as email address, phone number or mailing address when you choose to request information about our Services, request to receive customer or technical support, or otherwise communicate with us.
- Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Data. All Personal Data collected from your participation in our surveys is provided by you voluntarily.
- Automatic Data Collection. We may collect certain Personal Data automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, MAC address, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Site or the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Site and the Services, and other actions taken through use of the Site or Services such as preferences.
- Personal Data from Other Sources. We may receive Personal Data about you from other sources, including through third-party services and organizations to supplement information provided by you. Information we collect through third-party accounts may include your name, your email, your user name, location, birth date, job title/position in your organization, business address and your profile picture. This supplemental information allows us to verify information that you have provided to SnapLogic and to enhance our ability to provide you with information about our business, Site and Services, including new services that may be of interest to you.
How SnapLogic Uses Your Personal Data:
We acquire, hold, use, and share your information, including Personal Data, for a variety of business purposes, including:
- Providing Services or Information Requested. Snaplogic may use information about you to fulfill requests for Services or information, including to:
- Manage Individual information and Site accounts;
- Respond to questions, comments, and other requests;
- Contact you to answer requests for support;
- Allow you to register for events.
- Administrative Purposes. SnapLogic may use Personal Data about you for its administrative purposes, including to:
- Measure interest in SnapLogic’s Services;
- Develop new Services;
- Verify Individual identity;
- Communicate about changes to any SnapLogic policy;
- Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management;
- Prevent potentially prohibited or illegal activities;
- Enforce our Terms.
- Marketing SnapLogic Products and Services. SnapLogic may use your information, including Personal Data to provide you with materials about offers and Services that may be of interest to you. SnapLogic may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- For other purposes disclosed at the time that you provide Personal Data; or
- Otherwise with your consent.
- Anonymous and Aggregated Information Use. SnapLogic may use Personal Data and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access SnapLogic’s Site and Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including
- the measurement of visitors’ interest in and use of various portions or features of the Site or Services;
- research, internal analysis, analytics, and any other legally permissible purposes;
- shared with third-parties their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
- Research and Development. SnapLogic may use Personal Data alone or in the aggregate with information obtained from other sources, to
- help us to optimally deliver our existing Services,
- better understand and serve the users of the Services,
- conduct research on customer demographics, interests and behavior; and
- develop new Services.
This research may be compiled and analyzed alone or on an aggregate basis, and SnapLogic may share the aggregate data with its current affiliates and vendors for lawful purposes.
- Sharing Content with Friends or Colleagues. SnapLogic’s Site and Services may offer various tools and functionalities that allow you to share content and collaborate with others. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Site or Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request but will not be collected or otherwise used by SnapLogic or any other third-parties for any other purpose.
- Other Uses. SnapLogic may use Personal Data for which we have a legitimate interest, such as direct marketing, individual or market research, fraud prevention, disclosure to our affiliated organizations and network and information security. We may also use your Personal Data where such use is necessary to provide the Site or Services, to comply with our legal obligations or for any other purpose disclosed to you at the time you provide Personal Data or with your consent.
Third-Party Websites and Social Media Platforms.
The Services may contain links to other websites and other websites may reference or link to our Site Services. These other domains, websites and applications are not controlled by us, and SnapLogic does not endorse or make any representations about third-party websites, applications or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
SnapLogic’s Site may include publicly accessible blogs. The Site may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site Services. You should be aware that Personal Data which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Data provided by you may be viewed and used by third parties for any number of purposes.
Human Resources Data
SnapLogic collects Personal Data from prospective and former employees and contractors both in the United States and wherever we have employees abroad, which in Europe includes the United Kingdom (“Human Resources Data” or “HR Data”). We use HR Data in order to hire, pay and provide salary and benefits to our employees, and retain such information as required by applicable law.
Information We Share
SnapLogic is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third-parties without further notice to you, as set forth below:
- We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers (processors) to whom we entrust Personal Data include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) customer service activities; and (iv) in connection with the provision of the Services. SnapLogic has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
- Business Partners. SnapLogic may share Personal Data with our business partners for our and their internal business purposes or to provide you with a product or service that you have requested. SnapLogic may also provide Personal Data to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with SnapLogic. SnapLogic requires our business partners to agree in writing to maintain the confidentiality and security of Personal Data they maintain on our behalf and not to use it for any purpose other than the purpose for which SnapLogic provided them.
- Displaying to Other Users. The content you post on the Services may be displayed on the Services. Other users of the Services may be able to see some information about you, such as your name if you submit a review. We are not responsible for privacy practices of the other users who will view and use the posted information.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Data, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) to enforce SnapLogic policies or contracts; (v) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.
Supplemental Privacy Provisions for Residents of the EEA and Switzerland
In 2018, the European Union published European Union Regulation 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR) requires us as a data controller of the Site and related Services to provide additional and/or different information about our data processing practices to data subjects resident in the European Economic Area (EEA). Switzerland has similar provisions.
Legal Basis of Processing
- Contractual and Legal Basis for HR Data: The collection of Personal Data for HR purposes from employees outside of the United States, including those in the United Kingdom, is necessary on various bases or grounds, such as in fulfillment of the employment contract between employee and employer, and there are also legal requirements to preserve employee records.
- Legitimate Interests for Non-HR Data: When we collect minimal Personal Data from you so that you can establish an account on the Site and we can communicate with you, or enable you to register for events via the Site, or in situations where SnapLogic needs to process your Personal Data to comply with applicable laws (as a U.S.-based company, SnapLogic is subject to U.S. laws and must comply with them), or to provide good customer support services, we rely on the “legitimate interests” basis for such Personal Data processing under Art. 6(1)(f) of the GDPR, and with respect to support services, usually a contractual basis as well. In these cases, we will ensure that your privacy and other fundamental interests do not override our legitimate interests.
- Legitimate Interests for HR Data: The collection of Personal Data for HR purposes from employees in the United Kingdom and generally is also to fulfill legal obligations such as tax and social welfare requirements regarding employees, and is a legitimate interest and also of SnapLogic, the data controller, and in many instances necessary to comply with a legal obligation.
- Consent: SnapLogic relies on your opt-in consent with respect to cookies that are not strictly necessary and for any direct marketing emails or purely promotional use of your Personal Data, per Article 6(1)(a) of the GDPR; we have taken steps to meet obligations under GDPR.
Data Transfers and Privacy Shield
International Data Transfers. All Personal Data collected via or by SnapLogic may be stored in the European Economic Area, Switzerland, United States or elsewhere, in the cloud, on our servers or the servers of our service providers. Your Personal Data may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to SnapLogic, you agree to the transfer to and storage of your Personal Data in these locations, subject to the protections set forth below. Where required by law, international transfers of Personal Data will be supported by an adequacy mechanism.
Privacy Shield. SnapLogic participates in and has certified its compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. SnapLogic is committed to subjecting all Personal Data received from European Union (EU) member countries and Switzerland, in reliance on the Privacy Shield Frameworks, to the Frameworks’ applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov.
SnapLogic is responsible for the processing of Personal Data it receives under the Privacy Shield Frameworks, and for subsequent transfers to any third parties who may act as agents on its behalf. SnapLogic complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU and Switzerland, including its onward transfer liability provisions, as follows:
- Whenever your Personal Data is transferred outside the European Economic Area (EEA) or Switzerland, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
- Where we use service providers based outside the EEA or Switzerland, we may transfer to them Personal Data of EU or Swiss residents if they are part of the Privacy Shield Frameworks which requires them to provide similar protection to Personal Data shared between the Europe and the US.
- In addition, SnapLogic is obligated to ensure adequate protection of such Personal Data in any onward transfer, and therefore has entered into and will continue to enter into appropriate data processing and data transfer agreements based on language approved by the European Commission pursuant to Article 46(5) of the GDPR, such as the Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC), which are available upon request at email@example.com.
With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, SnapLogic is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, SnapLogic may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Independent Recourse Mechanism. As a US-based company that self-certifies compliance under the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, SnapLogic is required to name an independent recourse mechanism available to investigate unresolved complaints, including a system of alternative dispute resolution (ADR) by such mechanism, which is available at no cost to you. We have designated JAMS as our ADR provider to assist in resolving disputes under the Privacy Shield Frameworks up to the point of any final arbitration. If you are a consumer based in the European Union or Switzerland and wish to open a case, you can do so at https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim. However, if the claim relates to human resources data transferred from the EU, Switzerland or UK, we will cooperate and comply with the EU, UK or Swiss data protection authorities (DPAs) in connection therewith.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Opt-Out (Right to Restrict Processing):
You have the right to opt-out of certain uses and disclosures of your Personal Data. Where you have consented to SnapLogic’s use of your Personal Data, you may withdraw that consent at any time and opt-out to further use by contacting firstname.lastname@example.org. Even if you opt-out, we may still collect and use non-Personal Data regarding your activities on our Sites.
Direct Mail, Email and Outbound Telemarketing.
Individuals who provide us with Personal Data, or whose Personal Data we obtain from third parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on SnapLogic’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to you by following the instructions above.
Email and Telephone Communications
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law
“Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
Rights of Access, Rectification, Erasure and Restriction
If you believe that SnapLogic may be processing your Personal Data, but one of our customers is the Data Controller under applicable laws, please contact the entity that you interact with directly to exercise any of the rights listed above.
Although SnapLogic makes good faith efforts to provide Individuals with access to their Personal Data, there may be circumstances in which SnapLogic is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If SnapLogic determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, SnapLogic will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Data.
SnapLogic takes reasonable steps to protect the Personal Data provided via the Site and Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to SnapLogic via the Internet. If you have any questions about the security of your personal information, you can contact us at email@example.com.
We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.
The Site and Services are not directed to children under 13 (and in certain jurisdictions under the age of 16) years of age, and SnapLogic does not knowingly collect Personally Identifiable Information from children under 13 (and in certain jurisdictions under the age of 16) years of age. SnapLogic urges parents to instruct their children never to give out their real names, addresses, or phone numbers, without parental permission, when online. If you learn that your child has provided us with Personal Data without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected any Personal Data from children under 13 (and in certain jurisdictions under the age of 16), we will promptly take steps to delete such information and terminate the child’s account.
Redress/Compliance and Accountability:
1825 S. Grant St
San Mateo, CA 94402
We will address your concerns and attempt to resolve any privacy issues in a timely manner.
Other Terms and Conditions:
Your access to and use of the Site is subject to the Terms of Service at www.SnapLogic.com/terms-of-use.
- New Uses of Personal Data. Additionally, before we use Personal Data for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Data is otherwise required by law or contract, SnapLogic will endeavor to comply with the law or contract.
What are cookies?
A cookie is a small software file stored on your computer or mobile device when you visit a website.
Cookies set by the Site owner (SnapLogic) are referred to as “first party” cookies. Cookies set by parties other than the Site owner (but with the owner’s permission) are called “third party” cookies. These cookies are generally associated with a software vendor that provides services to SnapLogic. The parties that set third-party cookies can recognize your computer both when it visits the SnapLogic website and also when it visits certain other websites.
SnapLogic uses first and third-party cookies for several reasons. Some cookies are necessary for the operation of the SnapLogic Site: we refer to these as “essential cookies.” Other cookies enable us to track online behavior of our users, both individually and in aggregate. We use this information to better understand, improve and optimize the website experience for our users.
We utilize session cookies, which allow us to uniquely identify your browser while you are logged in and to process your online transactions. Session cookies disappear from your computer when the web browser is closed or computer is turned off. Session cookies are required for site operation. We also utilize persistent cookies to make it easier to log into and use the Site and Services. Persistent cookies remain on computers after the web browser is closed or the computer is turned off.
These cookies provide information that is used to the help us understand how our website is being used, to measure the effectiveness of marketing campaigns, and to help customize the website for you.
Information gathered from third-party cookies and from your browser can include:
- IP address
- Device identifiers (see below for more information)
- Web browser information
- Hardware and software information
- Page view statistics
- Browsing history
- Usage information
- Location information
- Time of access
Third-parties retain this data for varying periods of time.
Other Tracking Technologies
Web Beacons/Clear Gifs
Cookies are not the only way to recognize or track visitors to a website. We also use web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Site. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning. We may also embed clear gifs in email messages to track user responses.
This information is processed by us to provide reporting and improvement about the Site.
When you access the Service by or through a mobile device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a unique device identifier (“UDID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by SnapLogic. A device identifier may convey information to us about how you browse and use the Site. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
Device identifiers are processed by us to provide information about Site usage and improve the operation of the Site.
How can I control cookies?
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences.
Analytics Information and Interest-Based Advertising.
Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. This analytics data is not tied to any Personal Data. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
How often will you update this Cookie Statement?
Where can I get further information?