Breadcrumbs.IO, Inc. PRIVACY NOTICE

Effective: July 12, 2020

1. Introduction and Scope

This Privacy Notice explains how Breadcrumbs.IO, Inc. (“Breadcrumbs“, “we,” “us,” “our“) collects, uses, discloses, and otherwise processes personal data in connection with our Services.  Our “Services” include all the services that we offer on our own behalf, including the Breadcrumbs platform and the websites that post or link to this Notice.  This Notice does not apply to services that we provide solely on behalf of a third party or the personal data or our privacy practices relating to job applicants, employees and other personnel.

2. Collection of Personal Data

When we use the term “personal data” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to you.

Where we collect personal data directly from you, we process this data subject to our legitimate interests (as described in Section 3 below), to fulfil our obligations under a contract we have with you, and occasionally to comply with our legal obligations or for public safety. Here, we are acting as a data controller.  Where we process personal data on behalf of our customers, we will only process the data as instructed by our clients to perform our obligations under the contract.  Here, we are acting as a data processor on behalf of our clients (the data controller).

A. Personal Information You Provide

We collect the following personal information you provide in connection with our Services:

  • Communications.  If you communicate with us through any paper or electronic form, we collect your contact information, such as your name, address, job title, email address and phone number, the content of the communication and the metadata associated with the communication.
  • Registration.  If you sign up to receive news or alerts from us or register for an account, we collect your contact information, communication preferences and information relevant to sales, such as details about past or scheduled meetings.
  • Verification and CRM Services.  If you register for an account or subscribe to our Services, we will collect your contact, registration and billing information, including your name, payment information, physical address, email address, username and password, and basic information about your profession and how you intend to use your CRM data.
  • Events, Surveys, and Promotions. If you fill out any forms relating to Breadcrumbs events, surveys, or promotions, we collect your contact and demographic information and any other information requested on the form.  
  • User Support.  If you contact our customer support or file a support claim with us, we collect information about your account, your use of the Services, information relating to your user support request and any other information you choose to provide. We may need additional information to fulfill your request or respond to your inquiry. 
  • Any other personal data you choose to share with us.

B. Information from Third Party Sources.  

We may receive personal data from our business partners and service providers and combine this information with other information we collect from or about you, including the following:

  • From Our Customers.  Our customers may give us access to their email CRM provider databases in connection with our Services, in which case we will collect the names, emails and other information provided to us by our customers.
  • Technology Service Providers.  Our technology service providers may provide us information in connection with their services, including our website operators, payment processors, marketing partners and validation and security providers.  The information may include contact information, demographic information, interests, information about your use of the Services, information about transactions completed in the Services and information about your interactions with our marketing campaigns.
  • Data Enrichment Providers.  To assist our customers, we may receive personal data from third parties who provide data enrichment services.  The specific categories of personal data depend on the customer’s needs, but typically including demographic and background data, and information about interests and purchasing histories.

C. Information we Collect Automatically.  

We use various technologies to collect information about the device or browser you use to navigate and use our Services, including:

  • Web Logs and Usage Data.  As is true of many websites and email communications, we gather certain information automatically and store it in log files.  This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data.  We use this data to analyze trends on our Services, manage and administer the content, for security and availability of the Services, improve the performance of the Services, and for fraud protection and to protect our rights and the rights and safety of individuals.  Additionally, we may collect a record of the videos and audio programs you have accessed on the service, including titles, authors, date, time, duration of the content and the duration of your watching or listening, which we use for our own internal analytics and to recommend other content you may find interesting.
  • Cookies and Other Data Collection Technologies.  We and our service providers use cookies, scripts and similar technologies to manage the Sites and to collect information about you and your use of our Sites.  These technologies help us to recognize you, customize or personalize your experience, advertise products or services to you and analyze the use of our Sites to make them more useful to you.  These technologies may also allow us to aggregate demographic and statistical data and provide this information to our service providers to facilitate their provision of services.  Most Internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences.  For information on how to do this, access the “help” menu on your Internet browser, or access http://www.aboutcookies.org/how-to-control-cookies. Please note, however, that disabling our cookies may result in your inability to take full advantage of all of the features of our Services.  
  • Google Analytics.  We use “Google Analytics” to collect information about your use of the Services.  Google Analytics collects information such as how often users access the Services, what pages they access when they do so and what other websites they used prior to using the Services.  We use the information we get from Google Analytics only to improve the Services.  To learn more about the use of data collection technologies by Google for analytics and to exercise choice regarding those technologies, please visit the Google Analytics Opt-Out browser add-on page.

3. Purposes for Using Personal Data

We use the personal data we collect to:

  • To develop, maintain, improve and operate the Services, including our lead scoring and email validation services.
  • To personalize your user experience.
  • To communicate with you to provide technical or administrative support.
  • To conduct, manage and grow our organization.
  • To analyze, research and investigate the use of our Services.
  • To prevent, investigate and provide notice of fraud, unlawful or criminal activity, unauthorized access to or use of personal information, the Services or our data systems, and to meet legal, regulatory, judicial and institutional policy obligations.
  • To investigate and resolve disputes and security issues and to enforce our Terms of Use.
  • For any other lawful, legitimate business purpose.

We retain personal data for as long as is necessary for the purposes set out in this Section, unless a longer period is required under applicable law or is needed to resolve disputes or protect our legal rights.

4. Sharing and Disclosure of Personal Data

We may share your personal data in the following ways:

  • Service Providers. We share personal data with our service providers who perform services on our behalf, such as technology support providers, email communications providers, analytics providers, data storage providers, web hosting providers, developers, market research providers and our advertising partners.
  • Legal Obligations and Rights. We may disclose personal data to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental or law enforcement officials or private parties, including in response to subpoenas, search warrants or court orders.
  • Business Transactions or Reorganizations. We may disclose personal data if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change.
  • Within Breadcrumbs.  We may transfer personal data to our subsidiaries or affiliates for the business and operational purposes as described in the section above.
  • At Your Request.  We may disclose personal information about you to certain other third parties at your direction.

5. Children’s Personal Data

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 16.  If you are under the age of 16, please do not use our Services or otherwise provide us with any personal data either directly or by other means. If you are our customer, please do not provide us with the personal data of children under the age of 16.  If a child under the age of 16 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by or is about a child under the age of 16, we will promptly delete that personal data.

6. Online Privacy Choices

A. Online Advertising.  

We support the self-regulatory principles of the Digital Advertising Alliance (“DAA”). We work with advertisers, advertising networks, advertising servers, and analytics companies (“Ad Partners”) that use data collection technologies to understand how our Services are being used and to analyze your location and browsing history in order to deliver advertising relevant to your interests, as well as to provide advertising-related insights such as reporting, attribution, analytics, and market research.  These advertisements may appear on our Services or other websites or services, including through social media networks.  These Ad Partners may be able to associate devices across third party websites or services over time and link various devices used by the same individual.  

For more information about how Ad Partners use the information collected by these technologies and your options for restricting cookies placed by some of these Ad Partners, please visit the DAA’s opt-out page.  The DAA’s opt-outs are device- and browser-specific and may not work on all devices.  If you choose to opt-out through the DAA’s tools it does not mean you will cease to see advertising. Rather, the ads you see will be based on the website you are visiting and not your interests.

You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android).  You may also be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.

B. Privacy Preferences.

You have some choices regarding how we use your personal data, including the following:

  • How to Control Your Email Communications Preferences.  You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications.  You may not opt-out of Service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
  • Accessing, Modifying or Deleting Your Personal Data.  If you have any questions about reviewing, modifying, or deleting your personal data, you can contact us directly at privacy@Breadcrumbs.io.  We may not be able to modify or delete your data in all circumstances.

7. Third Party Websites

Our Services may include links to third-party websites, plug-ins and applications.  Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal data practices of third-party websites and online services or the practices of other third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices. 

8. Changes to this Privacy Notice

We will update this Privacy Notice from time to time.  If we make any changes to this Notice, we will post the revised Notice to this webpage and update the “Effective” date above.  If we make material changes to this Privacy Notice, we will notify you by email to your registered email address, by prominent posting on this website or our online services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided

9. Contact Us

If you have any questions about this Notice or our processing of personal data, please contact us by email at privacy@Breadcrumbs.com or by postal mail at:

Breadcrumbs Inc. 

Attn: Privacy Team

2 Mint Plaza, # 404

San Francisco, CA 94103