Privacy Policy

This Privacy Policy was last updated on July 31, 2018.

Engagio, Inc. (“Engagio” or “we”) provides its account-based marketing services (“Services”) to its business customers (its “Business Partners”) through a SaaS offering, and provides information relating to those Services through its website at www.engagio.com and related pages and subdomains (the “Site”). This privacy policy describes Engagio’s collection, use, and disclosure of the information we collect from visitors to the Site, including personally identifiable data (“Personal Data”), as well as Engagio’s practices relating to information we may receive from our Business Partners in connection with our Services.

Please read this policy carefully to understand how we handle and treat your personal information.

What information do we collect?

We may collect and process the following personal information from you:

  • Information you provide to us: We collect personal information when you voluntarily provide us with such information in the course of using our website or Services. For example, when you register to use our Services, we will collect your name, email address, password and organization information. We also collect personal information from you when you subscribe to our newsletter, or respond to a survey. If you make an enquiry through our website, or contact us in any other way, we will keep a copy of your communications with us.
  • Information we collect when you do business with us: We may process your personal information when you do business with us – for example, as a customer or prospective customer, or as a vendor, supplier, consultant, or other third party. For example, we may hold your business contact information and financial account information (if any) and other communications you have with us for the purposes of maintaining our business relations with you.
  • Information we automatically collect: We may also collect certain technical information by automatic means when you visit our website, such as IP address, browser type and operating system, referring URLs, your use of our website, and other clickstream data. We collect this information automatically through the use of various technologies, such as cookies.
  • Personal information where we act as a data processor: We also process personal information on behalf of our Business Partners in the context of supporting our products and services. Where a Business Partner subscribes to our Services, they will be the ones who control what data is collected and stored on our systems. In such cases, we are data processors acting in accordance with the instructions of our Business Partners. You will need to refer to the privacy policies of our Business Partners to find out more about how such information is handled by them.  The terms of the data processing addendum (“DPA”) are hereby incorporated by reference and shall apply to the extent Engagio processes any personal information that is subject to the GDPR on behalf of its Business Partners.

By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Data to Engagio via the Site, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of Engagio and the authorized third parties referred to herein located in the United States.

What do we use your information for?

The personal information we collect from you may be used in one of the following ways:

  • To respond to your inquiries and requests
  • To provide you with site and service
  • To enhance the site and service
  • To provide you with information and access to resources that you have requested from us
  • To provide you with technical support (your information helps us to better respond to your individual needs)
  • For system administration and security
  • For general business purposes, including to improve customer service (your information helps us to more effectively respond to your customer service requests and support needs), to help us improve the content and functionality of our Services, to better understand our users, to protect against wrongdoing, to enforce our Terms of Service, and to generally manage our business
  • For recruitment purposes, where you apply for a job with us
  • To send periodic emails. The email address you provide for using the service, will only be used to send you information and updates pertaining to the service.

How do we protect your information?

Engagio takes reasonable and appropriate measures to protect the Personal Data provided via the Site 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 Site 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 Engagio via the Internet.

Do we use cookies?

Yes. Cookies are small files that a site or its service provider transfers to your computers hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.

We use cookies to understand and save your preferences for future visits, to advertise to you on other sites, and to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

You may refuse to accept cookies by activating the setting on your browser that allows you to refuse the setting of cookies. You can find information on popular browsers and how to adjust your cookie preferences at the following websites:

However, if you choose to disable cookies, you may be unable to access certain parts of our site and/or our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.

Do we disclose any information to outside parties?

We will only share your information with third parties in certain circumstances:

  • We engage certain trusted third parties to perform functions and provide services to us, including cloud hosting services, email service providers, and customer support providers. We will only share your personal information with third parties to the extent necessary to perform these functions, in accordance with the purposes set out in this Privacy Policy and applicable laws.
  • In the event of a corporate sale, merger, reorganization, dissolution, or similar event, your personal information may be sold, disposed of, transferred, or otherwise disclosed as part of that transaction.
  • We may also disclose information about you to third parties where we believe it necessary or appropriate under law, for example: (1) to protect or defend our rights, interests, or property or that of third parties; (2) to comply with legal process, judicial orders, or subpoenas; (3) to respond to requests from public or government authorities, including for national security and law enforcement purposes; (4) to prevent or investigate possible wrongdoing in connection with the Services or to enforce our Terms of Service; (5) to protect the vital interests of our users, customers, and other third parties.
  • We may use and share aggregated non-personal information with third parties for marketing, advertising, and analytics purposes.

We do not sell or trade your personal information to third parties.

Third Party Links

Occasionally, at our discretion, we may include or offer third party products or services on our website. If you access other websites using the links provided, the operators of these websites may collect information from you that will be used by them in accordance with their privacy policies. These third party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

CHILDREN UNDER THE AGE OF 13

Engagio does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Site. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Site without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Engagio through the Site, please contact us, and we will endeavor to delete that information from our databases.

Legal Basis for Processing Personal Information (for EEA visitors)

If you are an individual from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our or a third party’s legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).  In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the details at the end of this Privacy Policy.

International Transfers

If you are visiting our website or using our Services from outside the United States (U.S.), please be aware that you are sending personal information to the U.S. where our servers are located. The U.S. may not have data protection laws that are as comprehensive or protective as those in your country of residence. However, our collection, storage, and use of your personal information will at all times be in accordance with this Privacy Policy.

EU-U.S. Privacy Shield

For personal information that we receive from the European Union, Engagio, Inc (our registered company name) has certified its compliance with the EU-U.S. Privacy Shield as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from the EU countries. We have certified that we adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity & Purpose Limitation and Recourse, Enforcement & Liability when processing personal information from the EU in the U.S. If there is any conflict between the policies in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To access the Privacy Shield List and to find details of our certification, please visit: https://www.privacyshield.gov/

Engagio, Inc is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with regards to our compliance with the Privacy Shield.

Residents of the European Union who believe that their information has not been processed in compliance with the Privacy Shield Principles may raise their complaint in a number of ways:

(1) You can contact us directly using the contact details provided at the end of this Privacy Policy and we will respond to your complaint within 45 days of receipt:

(2) We have further committed to cooperate and comply with the panel of the European data protection authorities (DPAs) as our independent recourse mechanism in the resolution of your Privacy Shield complaint. If you are unsatisfied with the response you have received from us, or your complaint remains unresolved, you can contact your local DPA (contact details available here), and they will investigate your complaint free of charge.

(3) Further, your complaint may be referred to the U.S. Department of Commerce or the FTC for further investigation;

(4) If your complaint is not resolved through the above methods, a binding arbitration process may be available under the Privacy Shield in certain circumstances. To find out more about the Privacy Shield’s binding arbitration scheme, please see this article.

If we have received your personal information in the U.S. under the Privacy Shield, and subsequently transfer that information to a third party agent or service provider for processing, we will be responsible if our third party agent or service provider fails to process your personal information in compliance with the Privacy Shield Principles and this causes you harm.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information. You have the right to:

  •      to request access to a copy of the personal information we hold about you, or to request the correction, amendment, or deletion of such information;
  •      to object to, or request a restriction of, processing of your personal information;
  •      to request transfer of your personal information, to you or to a third party;
  •      to withdraw consent for further processing of your personal information (in cases where our use of your personal information is based on your consent);
  •      to lodge a complaint with a supervisory authority (though we encourage you to contact us first with any questions or concerns).

To make a request relating to the exercise of your data protection rights, please contact us using the contact details provided at the end of this Privacy Policy. We will consider and respond to your request in accordance with the Privacy Shield Principles and applicable laws.

Furthermore, we commit to giving you an opportunity to opt-out if your personal information is to be disclosed to any other independent third parties, or to be used for a purpose materially different from those that are set out in this Privacy Policy. Where sensitive personal information is involved, we will always obtain your express opt-in consent to do such things. If you otherwise wish to limit the use or disclosure of your personal information, please write to us at the contact details below.

You can also unsubscribe from our marketing communications at any time by following the instructions or unsubscribe mechanism in the email message itself.

Data Retention

We may retain your personal information as long as you continue to use the Services, have an account with us, or for as long as is necessary to fulfil the purposes outlined in the policy. You can ask to close your account by contacting us at the details above, and we will delete your personal information on request.

We may, however, retain personal information for an additional period as is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.

Changes to our Privacy Policy

Our business may change from time to time. As a result, at times it may be necessary for Engagio to make changes to this Privacy Policy. Engagio reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data through the Site. This Privacy Policy was last updated on the date indicated above. Your continued use or access to the Site and the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Contacting Engagio

To keep your Personal Data accurate, current, and complete, please contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Site.

Engagio, Inc.
101 S San Mateo Dr., Fl 4, San Mateo CA 94401
Email: privacy@engagio.com

Residents of the European Economic Area (EEA) may also contact our Data Protection Officer at dpo@engagio.com, or our EU Representative, VeraSafe, using this contact form.

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