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Global Privacy Policy

Last Updated: October 24, 2023

Your privacy is important to us. This privacy policy (the “Policy”) explains the personal data we process, how we process it, and for what purposes. It also describes your choices regarding use, access, and correction of your personal data.

ChurnZero and our affiliated companies (collectively, “ChurnZero” or “we” or “us” or “our”) offer a customer success software-as-a-service platform and the other services (the “Services”) which we market for commercial use to enterprises and their users worldwide as well as public-facing websites (e.g., www.churnzero.com) (“Websites” together with Services, the “Product”).

To ensure you are well informed of our practices, we recommend that you read the entire Policy. If you have any questions or concerns about our use of your personal data, please contact us at privacy@churnzero.com.

PERSONAL DATA WE COLLECT

ChurnZero collects data from you, through our interactions with you and through our Products for a variety of purposes described below, including to operate effectively and provide you with the best experiences with our Products. You provide some of this data directly, such as when you administer your business platform account, register for a ChurnZero event, or contact us for support. We get some of it by collecting data about your interactions, use, and experience with our Products and through communications with us.

We rely on a variety of legal reasons and permissions (sometimes called “Legal Bases”) to process data, including with your consent, a balancing of legitimate interests, necessity to enter into and perform contracts, and compliance with legal obligations, for a variety of purposes described below.

We also obtain data from third parties. We protect data obtained from third parties according to the practices described in this Policy, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time and include:

  • Services that make user-generated content from their service available to others, such as local business reviews or public social media posts.
  • Communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks.
  • Service providers that help us determine your device’s location.
  • Partners with which we offer co-branded services or engage in joint marketing activities.

If you represent a business that utilizes our software-as-a-service Products or are an end user of a Product supplied by your employer, please see the Products Provided by Your Organization section of this Policy to learn how we process your data.

You have choices when it comes to the technology you use and the data you share. When you are asked to provide personal data, you can decline. Many of our Products require some personal data to operate and provide you with a service. If you choose not to provide data required to operate and provide you with a Product or feature, you cannot use that Product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing Product you are using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use the data will not work for you.

The data we collect can include the following:

Name and contact data. Your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials. Passwords, password hints, and similar security information used for authentication and account access.

Interactions. Data about your use of the Products. In some cases, such as support requests, this is data you provide to make use of the Products. In other cases, such as error reports, this is data we generate. Interactions may include:

  • Device and usage data. Data about your device and the Product and features you use, including information about your hardware and software, how our Products perform, as well as your settings (g., IMEI number for phones).
  • Contacts and relationships. Data about your contacts and relationships if you use a Product to share information with others, manage contacts, communicate with others, or improve your productivity.
  • Location data. Data about your device’s location, which can be either precise or imprecise. For example, we collect location data using Global Navigation Satellite System (GNSS) (g., GPS) and data about nearby cell towers and Wi-Fi hotspots. Location can also be inferred from a device’s IP address or data in your account profile that indicates where it is located with less precision, such as at a city or postal code level.

Content. Content of your files and communications you input, upload, receive, create, and control within the Products.

The above examples of personal data are not intended to be exhaustive. The data we collect depends on the context of your interactions with us and the choices you make (such as browser privacy settings) in your use of our Products.

HOW WE USE PERSONAL DATA

We use the data we collect to:

  • Provide our Products, which includes updating, securing, and troubleshooting, as well as providing support. It also includes sharing data, when it is required to provide the Product or perform the transactions you request.
  • Improve and develop our Products.
  • Advertise and market to you, which includes sending promotional communications, targeting advertising, and presenting you relevant offers.

We also use the data to operate our business, which includes analyzing our performance, meeting our legal obligations, developing our workforce, and doing research. However, we have built in technological and procedural safeguards designed to either prevent certain data combinations where required by law or aggregate or anonymize such data so that it cannot be reidentified.

When we process personal data about you, we do so with your consent and/or as required to provide the Products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests of ChurnZero. Specifically,

  • Provide our Products. We use data to operate our Products. For example, we process the documents you upload to enable you to retrieve, delete, edit, forward, or otherwise process it, at your direction as part of the service. Or, for example, we use data to contact you to inform you when a subscription is ending or discuss your account.
  • Product improvement. We use data to continually improve our Products, including adding new features or capabilities. For example, we use error reports to improve security features and usage data to determine what new features to prioritize.
  • Personalization. Our Products include personalized features, such as recommendations that enhance your productivity. These features use automated processes to tailor your Product experiences based on the data we have about you, such as synchronizing your settings on several devices.
  • Product activation. We use data—such as device and application type, location, and unique device, application, network, and subscription identifiers—to activate Products that require activation.
  • Product development. We use data to develop new Products. For example, we use data, often de-identified, to better understand our customers’ computing and productivity needs which can shape the development of new Products.
  • Customer support. We use data to troubleshoot and diagnose Product problems and provide other customer care and support services, including to help us provide, improve, and secure the quality of our Products, and training, and to investigate security incidents.
  • Help secure and troubleshoot. We use data to help secure and troubleshoot our Products. This includes using data to protect the security and safety of our Products and customers, detecting malware and malicious activities, troubleshooting performance and compatibility issues to help customers get the most out of their experiences. This may include using automated systems to detect security and safety issues.
  • Updates. We use data we collect to develop Product updates and security patches. For example, we may use information about your device’s capabilities, such as available memory, to provide you a software update or security patch. Updates and patches are intended to maximize your experience with our Products, help you protect the privacy and security of your data, provide new features, and evaluate whether your device is ready to process such updates.
  • Promotional communications. We use data we collect to deliver promotional communications. You can sign up for email subscriptions and choose whether you wish to receive promotional communications from ChurnZero by email, SMS, physical mail, and telephone. For information about managing your contact data, email subscriptions, and promotional communications, see the How to Access and Control Your Personal Data section of this Policy.
  • Advertising. ChurnZero does not use what you say in email, human-to-human chat, video calls, or voice mail, or your documents, photos, or other personal files to target ads to you. We use data we collect through our interactions with you, through some of our first-party products, services, apps, and web properties, and on third-party web properties, for advertising on our Websites and on third-party properties. We may use automated processes to help make advertising more relevant to you.
  • Transacting commerce. We use data to carry out your transactions with us. For example, we process payment information to provide customers with Product subscriptions and user accounts.
  • Reporting and business operations. We use data to analyze our operations and perform business intelligence. This enables us to make informed decisions and report on the performance of our business.
  • Protecting rights and property. We use data to detect and prevent fraud, resolve disputes, enforce agreements, protect our property, and activities that violate our rights and the rights of others. We may use automated processes for these purposes.
  • Legal compliance. We process data to comply with applicable law. For example, we use contact information and credentials to help customers exercise their data protection rights.
  • Research. With appropriate technical and organizational measures to safeguard individuals’ rights and freedoms, we use data to conduct research, including for public interest and scientific purposes.

For more information about how we process personal date, please review the Reasons We Share Personal Data section of this Policy. When we transfer personal data from the European Economic Area, we do so based on a variety of legal mechanisms, as described in the Where We Store and Process Personal Data section of this Policy.

REASONS WE SHARE PERSONAL DATA

We share your personal data with your consent or as necessary to complete any transaction or provide any Product you have requested or authorized. For example, we share your content with third parties when you tell us to do so, such as when you link a Product with another service. If you use a Product provided by an organization you are affiliated with, such as an employer, or use an email address provided by such organization to access ChurnZero Products, we share certain data, such as interaction data and diagnostic data to enable your organization to manage the Products. When you provide payment data to make a purchase, we will share payment data with banks and other entities that process payment transactions or provide other financial services, and for fraud prevention and credit risk reduction.

In addition, we share personal data among ChurnZero-controlled affiliates and subsidiaries. We also share personal data with vendors or agents working on our behalf for the purposes described in this Policy. For example, companies we have hired to provide customer service support or assist in protecting and securing our systems and services may need access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. We may also disclose personal data as part of a corporate transaction such as a merger or sale of assets. Finally, we will retain, access, transfer, disclose, and preserve personal data, including your content, when we have a good faith belief that doing so is necessary to do any of the following:

  • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
  • Protect our customers, for example, to prevent attempts to defraud users of our Products, or to help prevent the loss of life or serious injury of anyone.
  • Operate and maintain the security of our Products, including to prevent or stop an attack on our computer systems or networks.
  • Protect the rights or property of ChurnZero, including enforcing the terms governing the use of the Products—however, if we receive information indicating that someone is using our Products to traffic in stolen intellectual or physical property of ChurnZero, we will not inspect a customer’s private content ourselves, but we may refer the matter to law enforcement.

For more information about data we disclose in response to requests from law enforcement and other government agencies, please see our Government Response Policy.

Please note that some of our Products include links to or otherwise enable you to access products of third parties whose privacy practices differ from those of ChurnZero. If you provide personal data to any of those products, your data is governed by their privacy policies.

HOW TO ACCESS AND CONTROL YOUR PERSONAL DATA

You can also make choices about the collection and use of your data by ChurnZero. You can control your personal data that we have obtained, and exercise your data protection rights, by contacting ChurnZero or using various tools we provide. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law. How you can access or control your personal data will also depend on which Products you use. For example, you can:

  • Control the use of your data for personalized advertising from ChurnZero by visiting our opt-out page.
  • Choose whether you wish to receive promotional emails, SMS messages, telephone calls, and postal mail from ChurnZero.
  • Access and clear some of your data through the ChurnZero Trust Center.

Not all personal data processed by ChurnZero can be accessed or controlled via the tools above. If you want to access or control personal data processed by us that is not available via the tools above or directly through the Products you use, you can always contact us at the address in the How to Contact Us section.

You can access and control your personal data that ChurnZero has obtained with tools we provide to you, which are described below, or by contacting us. For instance:

  • If we obtained your consent to use your personal data, you can withdraw that consent at any time.
  • You can request access to, erasure of, and updates to your personal data.
  • If you’d like to port your data elsewhere, you can utilize the tools available in the ChurnZero Trust Center or contact us for assistance.

You can also object to or restrict the use of your personal data by ChurnZero. For example, you can object at any time to our use of your personal data:

  • For direct marketing purposes.
  • Where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party.

You may have these rights under applicable laws, including the EU General Data Protection Regulation (GDPR), but we offer them regardless of your location. In some cases, your ability to access or control your personal data will be limited, as required or permitted by applicable law.

If your organization, such as your employer, provides you with access to and is administering your use of our Products, contact your organization to learn more about how to access and control your personal data.

Your communications preferences. You can choose whether you wish to receive promotional communications from ChurnZero by email, SMS, physical mail, and telephone. If you receive promotional email or SMS messages from us and would like to opt out, you can do so by following the directions in that message. You can also make choices about the receipt of promotional email, telephone calls, and postal mail by contacting us at the information in the How to Contact Us section of this Policy. These choices do not apply to mandatory service communications that are part of certain ChurnZero Products, programs, activities, or to surveys or other informational communications that have their own unsubscribe method.

Your advertising choices. To opt out of receiving personalized advertising from ChurnZero, visit our opt-out page. When you opt out, your preference is stored in a cookie that is specific to the web browser you are using. The opt-out cookie has an expiration date of five years. If you delete the cookies on your device, you need to opt out again.

Because the data used for interest-based advertising is also used for other required purposes (including providing our Products, analytics, and fraud detection), opting out of interest-based advertising does not stop that data collection. You will continue to get ads, although they may be less relevant to you.

You can opt out of receiving interest-based advertising from third parties we partner with by visiting their sites (see above). Many of these companies are also members of the NAI or DAA, which each provide a simple way to opt out of ad targeting from participating companies.

Browser-based controls. When you use a browser, you can control your personal data using certain features. For example:

  • Cookie controls. You can control the data stored by cookies and withdraw consent to cookies by using the browser-based cookie controls described in the Cookies and Similar Technology section of this Policy.
  • Browser controls for “Do Not Track.” Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not yet a common understanding of how to interpret the DNT signal, our Products do not currently respond to browser DNT signals. We continue to work with the online industry to define a common understanding of how to treat DNT signals. In the meantime, you can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving interest-based advertising from ChurnZero as described above.

COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small text files placed on your device to store data that can be recalled by a web server in the domain that placed the cookie, which can be used to uniquely identify your computer and contain other information as well. Certain cookies are placed by third parties acting on our behalf. We use cookies and similar technologies to store and honor your preferences and settings, enable you to sign-in, provide interest-based advertising, combat fraud, analyze how our Products perform, and fulfill other legitimate purposes described below. Our Websites also contain web beacons or other similar technologies, as described below.

Our use of cookies and similar technologies. ChurnZero uses cookies and similar technologies for several purposes, depending on the context or product, including:

  • Storing your preferences and settings. We use cookies to store your preferences and settings on your device, and to enhance your experiences. For example, depending on your settings, allowing the Websites to be presented in your preferred language. Or, by way of further example, if you opt out of interest-based advertising, we store your opt-out preference in a cookie on your device. Similarly, in scenarios where we obtain your consent to place cookies on your device, we store your choice in a cookie.
  • Sign-in and authentication. We use cookies to authenticate you. When you sign-in to our Products, we store a unique ID number, and the time you signed in, in an encrypted cookie on your device. This cookie allows you to navigate the Products without having to sign in again.
  • Security. We use cookies to process information that helps us secure our Products, as well as detect fraud and abuse.
  • Social media. Some of our Websites include social media cookies, including those that enable users who are signed in to the social media service to share content via that service.
  • Feedback. ChurnZero uses cookies to enable you to provide feedback on a Website.
  • Interest-based advertising. We use cookies to collect data about your online activity and identify your interests so that we can provide advertising that is most relevant to you. You can opt out of receiving interest-based advertising from us as described in the How to Access and Control Your Personal Data section of this privacy statement.
  • Showing advertising. ChurnZero uses cookies to record how many visitors have clicked on an advertisement and to record which advertisements you have seen, for example, so you do not see the same one repeatedly.
  • Analytics. We use first- and third-party cookies and other identifiers to gather usage and performance data. For example, we use cookies to count the number of unique visitors to a web page or service and to develop other statistics about the operations of our Products.
  • Performance. ChurnZero uses cookies to understand and improve how our Products perform. For example, we use cookies to gather data that helps with load balancing; this helps us keep our Websites up and running.

Where required, we obtain your consent prior to placing or using optional cookies that are not (i) strictly necessary to provide the Website; or (ii) for the purpose of facilitating communications.

For a list of the cookies and other similar technology on our Products and how to control cookie placement, including service providers acting on our behalf, please visit our Cookie Policy.

PRODUCTS PROVIDED BY YOUR ORGANIZATION

ChurnZero Products offered to and designed primarily for use by organizations and developers include:

  • Our software-as-a-service customer success platform, referred to as Subscription Service in the Subscription Terms for which an organization (our customer) contracts with ChurnZero for the Subscription Service.
  • Professional Service as referred to in the Subscription Terms, such as onboarding services, data migration services, data science services, or services to supplement existing features in the Subscription Service.

ChurnZero’s processing of your personal data in connection with that Product is governed by a contract between ChurnZero and your organization. ChurnZero processes your personal data to provide the Product to your organization and you, and in some cases for our business operations related to providing the Product as described in this Policy. In the event of a conflict between this Policy and the terms of any agreement(s) between a customer and ChurnZero for Subscription Service Products, the terms of those agreement(s) will control.

If your organization provides you with access to ChurnZero Products, your use of the Products is subject to your organization’s policies, if any. You should direct your privacy inquiries, including any requests to exercise your data protection rights, to your organization’s administrator. When you use social features in the Products, other users in your network may see some of your activity. To learn more about the social features and other functionality, please review documentation or help content specific to the ChurnZero Product. ChurnZero is not responsible for the privacy or security practices of our customers, which may differ from those set forth in this privacy statement.

As mentioned above, if you have questions about our processing of your personal data in connection with providing Products to your organization, please contact your organization. If you have questions about our business operations in connection with providing Products to your organization as provided in the Subscription Terms, please contact ChurnZero as described in the How to Contact Us section. You can also learn more about our Subscription Service Products’ features and settings, including choices that impact your privacy or your end users’ privacy, in Product documentation.

CHILDREN’S PERSONAL INFORMATION

We do not knowingly collect any personal data from children under the age of 16. If you are under the age of 16, please do not submit any personal data through our Products. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal data through the Products without their permission. If you have reason to believe that a child under the age of 16 has provided personal data to us through the Products, please contact us at privacy@churnzero.com, and we will use commercially reasonable efforts to delete that information.

OTHER IMPORTANT PRIVACY INFORMATION

Below you will find additional privacy information, such as how we secure your data, where we process your data, and how long we retain your data.

Security of personal data. ChurnZero is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. For example, we store the personal data you provide on computer systems that have limited access and are in controlled facilities. When we transmit highly confidential data (such as access credentials) over the internet, we protect it through the use of encryption. ChurnZero complies with applicable data protection laws, including applicable security breach notification laws.

Where we store and process personal data. Personal data collected by ChurnZero may be stored and processed in your region, in the United States, and in any other country where ChurnZero or its affiliates, subsidiaries, or service providers operate facilities. Typically, the primary storage location is in the customer’s region or in the United States, often with a backup to a data center in another region. The storage location(s) are chosen to operate efficiently, to improve performance, and to create redundancies to protect the data in the event of an outage or other problem. We take steps to process the data that we collect according to this Policy’s provisions and the requirements of applicable law.

We transfer personal data from the European Economic Area, the United Kingdom, and Switzerland to other countries, some of which have not yet been determined by the European Commission to have an adequate level of data protection. For example, their laws may not guarantee you the same rights, or there may not be a privacy supervisory authority there that is capable of addressing your complaints. When we engage in such transfers, we use a variety of legal mechanisms, including contracts such as the standard contractual clauses published by the European Commission under Commission Implementing Decision 2021/914, to help protect your rights and enable these protections to travel with your data. To learn more about the European Commission’s decisions on the adequacy of the protection of personal data in the countries where ChurnZero processes personal data, see this article on the European Commission website.

ChurnZero complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. We have also certified to the U.S. Department of Commerce that we adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit the U.S. Department of Commerce’s Data Privacy Framework website.

If you have a question or complaint related to participation by ChurnZero in the DPF Frameworks, we encourage you to contact us via the information contained in the How to Contact Us section of this Policy. For any complaints related to the DPF Frameworks that ChurnZero cannot resolve directly, we have chosen to cooperate with the relevant EU Data Protection Authority, or a panel established by the European data protection authorities, for resolving disputes with EU individuals, the UK Information Commissioner (for UK individuals), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) for resolving disputes with Swiss individuals. Please contact us if you would like us to direct you to your data protection authority contacts. As further explained in the DPF Principles, binding arbitration is available to address residual complaints not resolved by other means. ChurnZero is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Data retention. ChurnZero retains personal data for as long as necessary to provide the Products and fulfill the transactions you have requested, or for other legitimate purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. Because these needs can vary for different data types, the context of our interactions with you or your use of Products, actual retention periods can vary significantly. Other criteria used to determine the retention periods include: (i) sensitive personal data typically is retained for a shorter period; or (ii) where we are subject to a legal, contractual, or similar obligation to retain or delete personal data.

Artificial Intelligence. ChurnZero leverages the power of artificial intelligence (AI) in many features of our Products, including by incorporating generative AI features. The collection and use of personal data in developing and deploying AI features is consistent with the commitments outlined in this Policy, and Product-specific details about AI usage can be find out by reviewing the Product documentation.

U.S. State Data Privacy. If you are a U.S. resident, we process your personal data in accordance with applicable U.S. state data privacy laws, including the California Consumer Privacy Act (CCPA). Please also see our U.S. State Data Privacy Laws Notice for additional information about the data we collect, process, share and disclose, and your rights under applicable U.S. state data privacy laws.

Other Applicable Data Privacy Locations. Please see our Supplemental Privacy Terms for Certain Regions to see how ChurnZero protects your personal data in certain locations where we do business other than the United States and EEA.

CHANGES TO THIS PRIVACY STATEMENT

We update this Policy when necessary to provide greater transparency or in response to:

  • Feedback from customers, regulators, industry, or other stakeholders.
  • Changes in our Products.
  • Changes in our data processing activities or policies.
  • Changes in applicable laws and regulations.

When we post changes to this Policy, we will revise the “last updated” date at the top of the Policy and, depending on the nature and amount of changed content, we may describe the changes. If there are material changes to the statement, such as a change to the purposes of processing of personal data that is not consistent with the purpose for which it was originally collected, we will notify you either by prominently posting a notice of such changes before they take effect or by directly sending you a notification. We encourage you to periodically review this Policy to learn how ChurnZero is protecting your information.

HOW TO CONTACT US

If you have a privacy concern, complaint, or question for our Data Protection Officer or privacy team, please contact us by emailing privacy@churnzero.com. We will respond to questions or concerns as required by law and within a period no longer than 30 days. You can also raise a concern or lodge a complaint with a data protection authority or other official with jurisdiction.

When ChurnZero is a controller, unless otherwise stated, ChurnZero Inc. is the data controller for personal data we collect through the Products subject to this Policy. Our address is:

Postal Address:

ChurnZero, Inc.

Attn: Data Protection Officer

717 D Street, NW, 2nd Floor

Washington, DC 20004
Telephone: (888) 258-4999
Email: privacy@churnzero.com

If you would like to exercise your rights under applicable data privacy law, you may contact ChurnZero at the address above.

 

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