Legal & Privacy

Privacy Statement

Effective January 1, 2020

Salelytics values the privacy of our customers and any individual who accesses or uses the Salelytics website, products, and services (collectively, the “Services”). Your privacy is an important factor Salelytics considers in the development of each of our products and services. This Privacy Statement explains generally how we receive Personal Information about you, and what we do with that Personal Information once we have it.


What do we mean by “Personal Information”?

FFor us, “Personal Information” means information or data that relates to an identified or identifiable individual. “Sensitive Personal Information” is a subset of Personal Information and is data about children, financial information, health information (including PHI as defined by the Health Insurance Portability and Accountability Act), Social Security or other national identification number, racial or ethnic origin, political opinions, religious beliefs, trade union membership, sex life, criminal convictions, and precise geolocation data.


What type of Personal Information is collected?

We may collect data, including Personal Information, about you as you use services and interact with us. This information may include name, address, email address, IP address or phone number. If we link other data with your Personal Information, we will treat that linked data as Personal Information.

Please understand, in addition to collecting Personal Information, Salelytics may also gather information that does not personally identify you regarding your use of the Salelytics services (“Anonymous Information”). We may use the Anonymous Information we collect regarding your use of services to measure the effectiveness of our marketing efforts, for business to business sales and marketing, for improving the Services we offer to you, or to improve the Salelytics website. Generally, you will not be aware when we collect such Anonymous Information. It may be collected in various ways, such as through traffic data or direct surveys of our customers and may entail the use of, among other things, cookies, IP addresses, or other numeric codes used to identify the computer or other device used to access the Salelytics website.


How do we receive Personal Information about you?

We learn Personal Information about you when:

You give it to us directly (e.g., when you choose to contact us); If you are under 13, we don’t want your Personal Information, and you must not provide it to us. If you are a parent and believe your child who is under 13 has provided us with Personal Information without your express consent, please contact us to have your child’s information removed.

By providing your Personal Information, you opt-in and consent to its collection, use, disclosure, sharing, and transfer as described in this Privacy Statement.


What do we do with your Personal Information once we have it?

When you give us Personal Information, we will use it in the ways for which you’ve given us permission, or ways in which our clients who provided us the Personal Information instruct. Generally, we use your Personal Information to help us provide and improve our products and services for you and our clients with which you have a business relationship.

We may use the Personal Information to enforce our agreements with you, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that we comply with applicable laws and prevent or detect use or abuse of our services.

Salelytics may also use your Personal Information to create anonymous data records or aggregations of data, to perform statistical analyses and for other purposes, by omitting or removing information that makes the data personally identifiable to you.


How long will we retain Personal Information?

We will retain your Personal Information only as long as needed to fulfill the purposes for which it was collected or as required by law. Your information will be deleted, anonymized or pseudonymized once it is no longer needed to comply with our business requirements, legal obligations, resolve disputes, protect our assets, or enforce our agreements.


When do we share your Personal Information with others?

We will/may share your Personal Information with others:

  • When we have asked and received your permission to share it.
  • To follow the law whenever we receive requests about you from a government entity, or related to a lawsuit. We’ll notify you or our client from whom we received your Personal Information when we’re asked to hand over your Personal Information in this way unless we’re legally prohibited from doing so. When we receive requests like this, we’ll only release your Personal Information if we have a good faith belief the law requires us to do so. Nothing in this Statement is intended to limit any legal defenses or objections you may have to a third party’s request to disclose your Personal Information.
  • If our organizational structure or status changes (e.g., if we undergo a restructuring, are acquired, or go bankrupt), we may pass your Personal Information to a successor or affiliate.

How do we protect your Personal Information?

We are committed to protecting your Personal Information once we have it. We implement industry standard physical, administrative and technical security measures. If, despite these efforts, we learn of a security breach involving your Personal Information, when required by law or contractual obligations, we’ll notify you or our client so appropriate protective steps can be taken. Salelytics is not responsible for unauthorized access to such Personal Information by hackers or others that obtain access through illegal measures in the absence of negligence on the part of Salelytics.


How can you protect your Personal Information?

Electronic communication (e.g., email, online chat or instant messaging, etc.) you send to us may not be secure unless we advise you in advance that security measures will be in place prior to you transmitting the information. For this reason, we ask you do not send Personal Information such as financial information, social security numbers or passwords to us through unsecured electronic communication. Users should also take care with how they handle and disclose their Personal Information. Please refer to the Federal Trade Commission’s Web site at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information about how to protect yourself against identity theft.


How do you keep my healthcare information private?

Salelytics is required by law to maintain the privacy of “protected health information.” Please follow this link to Salelytics’s HIPAA Privacy Notice.


What about cookies and other tracking technology?

A cookie is a small file, typically of letters and numbers, downloaded onto a device when the user accesses certain websites. Cookies can make the web more useful by storing information about your preferences for a particular website or a service. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer.

Cookies are typically classified as either session Cookies or persistent Cookies depending on whether they expire at the end of a browser session (from when a user opens the browser window to when they exit the browser) or they can be stored for longer.

  • Session Cookies – allow websites to link the actions of a user during a browser session. They may be used for a variety of purposes such as remembering what a user has put in their shopping basket as they browse around a site. They could also be used for security when a user is accessing internet banking or to facilitate use of webmail. These session Cookies expire after a browser session, so would not be stored longer term. For this reason, session Cookies may sometimes be considered less privacy intrusive than persistent Cookies.
  • Persistent Cookies – are stored on a user’s device in between browser sessions which allows the preferences or actions of the user across a site (or in some cases across different websites) to be remembered. Persistent Cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising.

Salelytics uses cookies or other similar tracking technologies to provide you with better Services.

Most browsers are initially set to accept Cookies. You may configure your browser to accept all Cookies, reject all Cookies, or notify you when a Cookie is set. You can manage your own Cookies preferences by using your browser settings: each browser is different, so check the “Help” menu of your browser to learn how to change your Cookie preferences or delete them. If you prefer, you can set your browser to refuse Cookies. You block Cookies by activating the setting on your browser which allows you to refuse the setting of all or some Cookies.


How do you handle my “Do Not Track” browser settings?

Salelytics does not track the non-Salelytics website activity of any internet user with Do Not Track browser settings engaged.


Does Salelytics use any other tracking technology?

Salelytics employs a software technology called transparent images to help us better manage content on our site by informing us what content is effective. We use extremely small, transparent images with a unique identifier, similar in function to cookies, used to track the online movements of Web users. The main difference between the two is transparent images are invisible on the page and are very small, about the size of the period at the end of this sentence. In some instances, transparent images are tied to users’ personally identifiable information. In particular, we use transparent images in our HTML-based e-mails to let us know which e-mails have been opened by the recipients. This allows us to gauge the effectiveness of certain communications. Users may opt out of these e-mails by replying to the unsubscribe link at the end of the e-mail message.


How does Salelytics ensure compliance with legal obligations?

In connection with the Services, and if applicable, you and Salelytics shall at all times ensure compliance with any privacy and data protection laws including those in the United States (including but not limited to the Gramm-Leach-Bliley Financial Services Modernization Act, the Health Insurance Portability and Accountability Act and the Fair Credit Reporting Act.


What if we change this Privacy Statement?

We may need to change this Statement and our notices. The updates will be posted online. If the changes are substantive, we will announce the update through Salelytics’s websites. Your continued use of the product or service after the effective date of such changes constitutes your acceptance of such changes. To make your review more convenient, we will post an effective date at the top of the page.


How to Contact Us?

If you want to make a correction to your Personal Information, or you have any questions about our privacy statement, please contact the legal department at via this link.

You may also reach us by emailing Privacy-Request@salelytics.com, or by mail, we can be contacted at:

Allison K. Gagnon, Director, Contract Management

Legal Department

1111 E. South River Street

Appleton, WI. 54915

Salelytics Code of Ethical Business Conduct

This Code of Ethical Business Conduct (“Code”) is intended as an overview of Salelytics guiding principles and not as a restatement of Salelytics policies and procedures.

Salelytics reputation as an ethical company is essential to our success. Our reputation needs to be managed and developed with the same care we extend to our clients. In carrying out the business of Salelytics, we deal with clients, vendors, community leaders, the press and the general public. It is essential all of our dealings be legal and above reproach, and must not, in any way, compromise Salelytics interests, its policies or its reputation for the highest standards of business ethics.

We believe Salelytics directors, officers and employees should disclose any activity that may have the appearance of being unethical. In so doing, not only can we take appropriate disciplinary or legal action, but we may be able to take steps to prevent the situation that gives rise to the questioned activity.

Merely operating within the law is just the beginning of the ethical conduct we insist upon and expect. The following is a broad statement of Salelytics expectations regarding legal and ethical conduct. This statement is intended to be interpreted in the spirit of its intent and not literally, as it is virtually impossible to address every situation or condition that may arise.

In the event of any conflict between the Code and the certificate of incorporation or bylaws of the Company, including, without limitation, provisions related to business opportunities presented to members of the Board of Directors, the provisions set forth in the certificate of incorporation or bylaws, as applicable, shall control.

Business Conduct:

Each director and officer should be aware of the ethical practices of each of the people he or she manages. We must maintain an attitude within Salelytics unethical actions or the appearance of unethical actions are not acceptable. This Code cannot and is not intended to cover every applicable law or provide answers to all questions that might arise; for that we must rely on each person’s good sense of what is right, including a sense of when it is proper to seek guidance from others on the appropriate course of conduct.

Conflict of Interest:

All directors, officers and employees of Salelytics are expected to avoid any activity, investment, interest or association which interferes with or is reasonably likely to interfere with the independent exercise of his or her judgment when it is related to Salelytics interests. Directors, officers and employees of Salelytics have a duty of loyalty to Salelytics, and must therefore avoid any actual or apparent conflict of interest with Salelytics.

It is impossible to cover every possible conflict of interest, and at times it will not be easy to distinguish between proper and improper activity. However, the most common conflicts are:

  • Having a financial interest, directly or indirectly, in any supplier, client or competitor of Salelytics. All interests of 1% or greater in a supplier, client or competitor should be fully disclosed.
  • Engaging in a business transaction on behalf of Salelytics with a relative by blood or marriage, or with a firm where such relative is an officer or representative, without prior full disclosure and written clearance.
  • Accepting any money, gifts of other than nominal value, unusual hospitality, loans or any other preferential treatment from any supplier, client or competitor of Salelytics.

In short, we cannot be influenced by improper personal considerations which might consciously or unconsciously affect our judgment regarding the best interests of Salelytics. If a director, officer or employee becomes aware of an actual or apparent conflict of interest, he or she should discuss it with the appropriate manager and disclose it to Salelytics General Counsel.

Corporate Opportunities:

No director, officer or employee of Salelytics may:

  • Take for himself or herself personally any business opportunity discovered through the use of Salelytics property, information or position;
  • Use Salelytics property, information or position for personal gain; or
  • Compete with Salelytics.

Employees, officers and directors owe a duty to Salelytics to advance its legitimate interests when the opportunity to do so arises.

Information About Competitors:

As a business that competes in the marketplace, we seek economic knowledge about our competitors. However, Salelytics officers, directors and employees shall not engage in illegal or improper acts to acquire a competitor’s trade secrets or customer lists. In addition, we will not hire a competitor’s employees for the purpose of obtaining confidential information about the competitor.

Confidentiality:

All directors, officers and employees should maintain the confidentiality of information entrusted to them by Salelytics, its business partners, suppliers, clients or others related to Salelytics business. Such information must not be disclosed to others, except when disclosure is authorized by Salelytics or legally mandated. Confidential information includes all nonpublic information that might be of use to competitors, or harmful to Salelytics or its clients if disclosed.

Dealing with Suppliers and Clients:

Salelytics overall view regarding its relations with vendors and clients is simple. They must be treated as Salelytics expects to be treated – with fairness.

Salelytics strives to ensure it does not have or contribute to adverse human rights impacts (including modern slavery or human trafficking) within its business or through its supply chains. There is an ongoing commitment to engage only those suppliers that uphold the same principles as Salelytics. In the event suppliers fail to take steps to cease or prevent adverse human rights impacts, Salelytics will reconsider its business relationships with those suppliers.

Contributions to Political Parties, Candidates or Government Officials:

Salelytics policy is precise and specific. Contributions by a corporation to political parties or candidates involving federal offices in the United States are expressly forbidden by Federal law. Salelytics obeys the law. In addition, while political contributions to parties or candidates may be legal in some states and in some foreign countries, no Salelytics corporate funds may be used for such purposes without the express prior approval of the President of Salelytics. Salelytics is an active participant in the democratic process at the national, state and local levels within the parameters of the law. Salelytics also encourages all employees to participate in our political system by voting, speaking out on public issues, and becoming active in civic and political activities. It is important, however, that directors, officers and employees clearly distinguish their personal view from those of Salelytics, unless specifically authorized by Salelytics to speak on Salelytics behalf.

Payments to Government Personnel:

The U.S. Foreign Corrupt Practices Act prohibits giving anything of value, directly or indirectly, to officials of foreign governments or foreign political candidates in order to obtain or retain business. It is strictly prohibited to make illegal payments to government officials of any country.

In addition, the U.S. government has a number of laws and regulations regarding business gratuities which may be accepted by U.S. government personnel. The promise, offer or delivery to an official or employee of the U.S. government of a gift, favor or other gratuity in violation of these rules would not only violate Company policy but could also be a criminal offense. State and local governments, as well as foreign governments, may have similar rules.

Accuracy of Salelytics Records:

All official records showing the conduct of Salelytics business must be accurate and complete in all material respects. All those involved in the preparation of such materials should consider the accuracy of the records of critical importance, and should understand Salelytics does not maintain, nor does it countenance, any off-the-books funds for any purposes. It is the policy of Salelytics to fully and fairly disclose the financial condition of Salelytics in compliance with applicable accounting principles, laws, rules and regulations. All books and records of Salelytics shall be kept in such a way as to fully and fairly reflect all Salelytics transactions in accordance with generally accepted accounting principles.

There must be full, fair, accurate, timely and understandable disclosure in reports and documents filed with governmental agencies and in other public communications made by Salelytics, as well as in documents prepared for our equity and debt holders.

Retention of Records:

Disposal or destruction of Salelytics records and files should comply with company policy. In addition, when litigation or a government investigation is pending or imminent, relevant records must not knowingly be destroyed until the matter is closed.

Insider Information:

Federal law and the Securities and Exchange Commission’s regulations prohibit the use of “inside” (i.e., material nonpublic) information when trading in Salelytics securities. The Insider Trading and Securities Fraud Enforcement Act of 1988 imposes significant criminal and civil penalties for insider trading.

Examples of such information include, if applicable, possible acquisitions, mergers, stock splits, dividends, earnings, new contracts, new products or discoveries, major management changes, expansion plans, data which may be proprietary, or data which has not yet been disclosed to the investment public and other important corporate developments. As a result of these regulations, Salelytics personnel should follow the Salelytics Anti-Corruption Policy located on Salelytics intranet.

Dealings with Clients:

Salelytics business is built upon the principle of effective, courteous management of client contacts. Salelytics treats all clients and their consumers with dignity and respect.

Equal Opportunity:

Salelytics employees have been, and will continue to be, the key to our success. Salelytics strongly supports and recognizes its responsibility to provide equal employment opportunities to all qualified individuals. Salelytics places a high value on diversity. Salelytics strongly believes all people are unique and valuable, and should be respected for their individual abilities.

In support of this goal, Salelytics has established a company policy regarding discrimination or harassment on the basis of race, gender, age, color, religion, disability status, veteran status, sexual orientation, marital status or ethnic, national or any other characteristic protected by law. This policy applies to all personnel relationships, including but not limited to: promotions, transfers, training, job assignments, job stations, hours of work, rates of pay, working conditions, terminations, and all terms and conditions of employment.

Legal Conduct and Compliance with this Code:

Salelytics policy is that all of its directors, officers and employees shall conduct business on behalf of Salelytics in full compliance with the laws of the many jurisdictions in which Salelytics may conduct business. Accordingly, the provisions of the present Code are not intended as a substitute for applicable national laws and regulations and the scope of the Code’s application shall be limited to the extent incompatible with such laws and regulations. Under the laws of certain countries in which the Company has a presence, legal conduct and compliance with this Code may require further adaptations and directors, officers and employees should refer to the appropriate country annex that addresses such matters.

Any director, officer or employee who acquires knowledge of a violation of a law or this Code, or has cause to believe that a law or this Code has been violated, must immediately report this situation to the legal department, the President, Chief Operating Officer, or Vice President of Human Resources. If you wish to remain anonymous, you may report a violation of this Code by (a) calling the Telephone Hotline at 833-613-0412; (b) emailing Salelytics@GetInTouch.com; or (c) visiting www.InTouchWebsite.com/Salelytics. The Telephone Hotline and the email address are monitored by an independent company and are available 24 hours a day every day.

Any employee who ignores or violates any of Salelytics ethical standards, and any manager who penalizes a subordinate for trying to follow these ethical standards, will be subject to corrective action. However, it is not the threat of discipline that should govern your actions. Salelytics expects you to share its belief that a dedicated commitment to ethical behavior is the right thing to do and is good business.

Violations of this Code will result in disciplinary action that may include termination, referral for criminal prosecution and reimbursement to Salelytics for any losses or damages resulting from the violation. As with all matters involving investigations of violations and discipline, principles of fairness and dignity will be applied pursuant to the procedures developed and used by Salelytics Employee Relations Department.

Waivers:

Any waivers of this Code for directors or executive officers must be approved by the Executive Leadership team and must be promptly disclosed (with reasons for the waiver) as required by applicable law and our contractual requirements.

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