AICPA SOC 2 Last Updated: May 23, 2018  

 1. PURPOSE

6Sense Insights, Inc. and our affiliates and subsidiaries (collectively, “6sense” or “we”) respects and protects the privacy of its users and clients. Therefore, we would like to share with you the following practices that govern how we collect, use, share and protect the information you provide to us through our websites (each a “Site”) and other information we might collect regarding you and other individuals and companies. We also describe the choices we offer, including how you can opt-out, correct or remove the information we have collected about you. As used in this privacy policy, “Personal Information” means information that may be used to identify you personally, such as your name, street address, email or telephone number and any other information relating to an identified or identifiable natural person. The terms “6sense,” “we,” and “us” include 6sense Insights, Inc. and our affiliates and subsidiaries.  

2. PERSONAL INFORMATION WE COLLECT

The types of Personal Information 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 6sense and the requirements of applicable law. Some of the ways that 6sense may collect Personal Information include:
  • You may provide Personal Information directly to 6sense by completing contact forms on our Sites, participating in surveys, providing us information in connection with participation at events, or by emailing or calling us to request products, services, or information. Personal information collected via these activities could include, for example, first and last name, address, telephone number, email address, job position and company name.
  • You might also interact with us or other users on our Site or by posting a review or other materials on our Site, in which case we will collect the information you provide in such submissions, including any Personal Information. If you choose to submit content to any public area of the Site, such content will be considered “public” and will not be subject to the privacy protections set forth herein.
  •  We may also collect certain information automatically through our Sites or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile advertising identifiers, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type, operating system, Internet service provider, pages that you visit before and after using 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 Services, and other actions taken through use of the Services such as preferences.
  •  In addition, 6sense provides an analytics-based solution aimed at helping its subscriber clients (“Subscribers”) predict whether business prospects are likely to become customers of the Subscribers. We may receive data from 6sense Subscribers regarding their prospective customers, such as sales data, web data/site activity data and lead information that is governed by the Subscriber’s privacy policies (collectively, “Subscriber Provided Information”).
  • We also collect information through third party providers who gather such data from a variety of publicly available sources (“Publicly Identifiable Information”). Such information could include for example, company name, name and title of the company’s officers and certain company employees, business phone numbers, fax numbers, email addresses, social media data and similar information obtained from the internet or published by third parties regarding such business prospects.
  • We do not collect sensitive Personal Information (such as medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of an individual, but if we were to do so, we would require opt-in consent for the sharing of any sensitive personal information.
 

3. HOW WE USE PERSONAL INFORMATION

We acquire, hold, use, and Process Personal Information based on the legal grounds and for the legitimate business purposes outlined in this Policy.
  • To Provide Products, Services, or Information Requested: 6sense may use information about you to fulfil requests for products, services, or information, including information about potential or future services, including to:
  • Generally manage your information and accounts;
  • Respond to questions, comments, and other requests;
  • Provide access to certain areas, functionalities, and features of 6sense’s services;
  • Allow you to register for events.
  • Administrative Purposes: 6sense may use Personal Information about you for its administrative purposes, including to: Measure interest in 6sense’s services;  
  • Ensure internal quality control;
  • Communicate with you about your accounts and activities involving us and our services, and, in our discretion, changes to any of our policies;
  • Verify your identity or account and for informational and operational purposes, such as customer service or system maintenance;
  • Process payment for products or services purchased;
  • Process applications and transactions;
  • Comply with regulatory requirements, including collecting and using information relating to adverse effects you have experienced when using our products; Prevent potentially prohibited or illegal activities;
  • Enforce our Terms of Use.
  • Marketing 6sense Products and Services: Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties (other than Subscriber Provided Information), may receive periodic emails, newsletters, mailings, or phone calls from us with information on 6sense’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. You may contact us at any time at privacy@6sense.com to opt out of the use of your Personal Information for marketing purposes.
  • Research and Development: 6sense may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and services or develop new products and services. From time to time, 6sense may perform research (online and offline) via surveys. We may engage third-party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us provide better service by learning more about the needs and the quality of the products and services we provide, and for such other purposes as described in the survey information. The survey responses may be utilized to determine the effectiveness of our services, various types of communications, advertising campaigns, and/or promotional activities.
  • Anonymous and Aggregated Information. 6sense may use Personal Information and other information you provide to us or that we collect 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 6sense’s 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 Services. Anonymized or aggregated information is not Personal Information, and 6sense may use such information in a number of ways, including research, internal analysis, analytics, improvement of our services, and any other legally permissible purposes. We may share this information within 6sense and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
  • Information Submitted to 6sense. Unless different terms are included in an agreement You have with 6sense, You agree that 6sense is free to use the content of any communications submitted by you to us, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or services. 6sense will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to us will be published or otherwise used with your name on it; or (c) we are required to do so by law.
  • Subscriber Provided Information. 6sense may use Subscriber Provided Information to process data for our Subscribers and Publicly Identifiable Information to provide business-tobusiness contacts and enriched data to our Subscribers and for purposes of continuing to develop a robust solution. We limit our use of personal information to the information relevant for the purpose of our processing.  We further require any third party who acts as a processor on our behalf to limit their use of personal information received from us to the purposes for which such information was provided.
  • Posting and Sharing Content with Friends or Colleagues. 6sense may provide functionality that will allow you to post a review or forward or share certain content with a friend or colleague. 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 6sense or any other Third Parties for any other purpose.
  • Other Uses. 6sense may use Personal Information for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
  • We may display personal testimonials on our Websites and other endorsements. With your consent we may post your testimonial along with your name.  If you wish to update or delete your testimonial, please contact us at: privacy@6sense.com.
 

4. REASONS WE SHARE PERSONAL INFORMATION

We may share your information as described in this Policy or with your permission.  We Use Vendors and Service Providers. We may share your information (including Publicly Identifiable Information and Subscriber Information when permitted by our Subscribers) with third party contractors, partners, vendors and providers engaged by 6sense to perform functions on our behalf or on behalf of our Subscribers for business purposes, including hosting or enriching data as part of our processing services. These companies will have access to your Personal Information only to perform their functions and may not use it for any other purpose.
  • Business Partners. 6sense may share Personal Information with our business partners, affiliates, and for our affiliates’ internal business purposes or to provide you with a product or service that you have requested. 6sense may also provide Personal Information 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 6sense’s. 6sense requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which 6sense provided it to them.
  • Sharing with Subscribers. We may share Publicly Identifiable Information collected and processed by us on behalf of our Subscribers with our Subscribers. All use by our Subscribers will be in accordance with their privacy policies.
  • Interest-Based Advertising and Third Party Marketing. Through our Sites, 6sense may allow third-party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with third-party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-6sense related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable, or otherwise of interest to you. If you prefer that we do not share your Personal Information with third-party advertising partners, you may opt-out as described in Section 5 of our policy, below.
  • Disclosures to Protect Us or Others (e.g., As Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, 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 6sense policies or contracts; (v) to collect amounts owed to 6sense; (vi) 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 (vii) 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 so that they may identify users in connection with their investigation of the unauthorized activities.
  • Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. Should such an event occur, 6sense will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Policy in effect at the time such Personal Information was collected.
 

5. YOUR DATA RIGHTS

  • Opt-Out. You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to 6sense’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by sending an email to privacy@6sense.com. Note that if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on third-party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
  • Accessing, Updating or Deleting Personal Information. You have the right to access your Personal Information in order to correct, amend, update or delete information that is inaccurate or to request that we no longer use your Personal Information. If you have any questions or concerns regarding 6sense’s collection, use or disclosure of your Personal Information or if you wish to change, amend, delete or review your Personal Information, please send a letter or email with your request and current contact information to 6sense at:
 

6sense Insights, Inc.

47 Lusk St.

San Francisco, CA 94107

Or Email: privacy@6sense.com

  We will use reasonable efforts to respond to your requests as soon as practicable. When updating your personal information, we may ask you to verify your identity before we can act on your request. IMPORTANT NOTE:  Subscribers may provide data to us for processing and 6sense data providers may collect information from the web that is not supplied directly by you to 6sense.  If you desire to correct, amend or delete personal information that was provided to us by such Third Parties (and not directly by you), you may contact us at privacy@6sense.com to access, correct or remove your information from our files. However, we also recommend that you contact the third-party website operators to whom you have provided such information under such Third-Parties’ privacy policies. Please note that because searches conducted by third-party data aggregators may involve millions of new and old web pages every day, information about you may be acquired again by 6sense through third party aggregators. The best way to avoid having your information found by a search engine is to contact the operator of the website that contains the original source(s) of the information and ask for the operator to remove the displayed information from the web. In addition, with respect to any personal data provided about you to us by our Subscribers, you should contact the applicable company to whom you provided the data (as the data provider) should you desire to correct, amend or delete such personal information.
  • Email and Telephone Communications. If you receive an unwanted promotional email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain communications regarding 6sense and our services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Service or this Policy).  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 our Site is not designed to respond to “do not track” requests from browsers.

6. COOKIES, PIXEL TAGS/WEB BEACONS AND ANALYTICS INFORMATION.

We, as well as Third Parties that provide content, advertising, or other functionality on our Sites, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices.
  • Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. These pixel tags or web beacons work in conjunction with cookies to let us know what portions of our Website are of interest to our visitors, help us provide you with tailored information from our website, and are used for purposes of enhancing our products and developing derivative product and/or service offerings.
  • Social Media Widgets. Our Sites include social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Websites. Your interactions with these features are governed by the privacy policy of the company providing it. 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 Information provided by you may be viewed and used by third parties for any number of purposes.
  • Analytics and Internet-Based Advertisers. 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 Information. For more information about Google Analytics, please visit  http://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. We may have similar arrangements with internet-based advertisers that might display ads when you visit our Website. These companies may collect personal and other information about your visits to this and other sites, to provide ads about products and services that might be of interest to you. The privacy policies and practices of these third party providers will govern their use and collection of this information.  Our uses of such Technologies fall into the following general categories:
  • Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our sites, services, applications, and tools. This includes technologies that allow you access to our sites, services, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as shoppingcarts, saved search, or similar functions;
  • Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our websites, applications, services, and tools, including as part of our analytic practices to help us understand how our visitors use our websites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;
  • Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our sites, services, applications, or tools. This may include identifying you when you sign into our sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our sites;
  • Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt-out of certain mobile ads via their device settings.

 7. OTHER RIGHTS AND IMPORTANT INFORMATION

  •  Security Measures. We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Our security program includes administrative, technical and physical safeguards appropriate for our size and resources and the types of information that we process. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure and you acknowledge that we are not responsible for any intercepted information sent via the internet. By using our Sites or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Sites. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
  • Retention. 6sense retains the Personal Information we process on behalf of our Subscribers for as long as needed to provide services to our Subscriber or as necessary to fulfill the purpose(s) for which it was collected. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
  • Data Transfers. All Personal Information collected via or by 6sense may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to 6sense, you consent to the storage of your Personal Information in these locations.
  • Human Resources Data. With regard to Personal Information that 6sense receives in connection with the employment relationship, 6sense will use such Personal Information only for employment-related purposes. If 6sense intends to use this Personal Information for any other purpose, 6sense will notify the Individual and provide an opportunity to opt out of such uses.
  • Children’s Privacy. We do not knowingly collect, maintain, or use Personal Information from children under 13 (and in certain jurisdictions under the age of 16) years of age, and no part of the Site is directed to children under the age of 13 (and in certain jurisdictions under the age of 16). If you learn that your child has provided us with Personal Information without your consent, you may alert us at privacy@6sense.com. If we learn that we have collected any Personal Information 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.
  • International Users. By using the Site, 6sense will transfer data to the United States. By choosing to visit the Site or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of California and the adjudication of any disputes arising in connection with 6sense or the Site will be in accordance with the Terms. If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and Processing globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
  • Adherence to EU-U.S and Swiss-U.S. Privacy Shield Frameworks. 6sense complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from European Union and Switzerland to the United States, respectively. 6sense has certified to the Department of Commerce that we adhere to the Privacy Shield Principles, including principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.commerce.gov/privacyshield.
  • 6sense adherence to the EU-US and Swiss-Us Privacy Shield Frameworks also applies to our wholly-owned subsidiary, ZenIQ, Inc., which is also covered under this policy.
In compliance with the EU-US and Swiss-US Privacy Shield Principles, 6sense commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact 6sense at: privacy@6sense.com; or at 6sense Insights Inc., 47 Lusk St., San Francisco, California, 94107. With respect to onward transfers of data subject to the EU-US and Swiss-US Privacy Shield, we remain liable for processing such transfers in accordance with the EU-US and Swiss-US Privacy Shield Principles. 6sense has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EUprivacyshield/foreuconsumers for more information or to file a complaint. With respect to our compliance with applicable privacy laws and regulations 6sense may be subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.  You may also have a right, under certain conditions, to invoke binding arbitration under Privacy Shield; for additional information, see https://www.privacyshield.gov/article?id=ANNEXIintroduction. The FTC has jurisdiction over 6sense’s compliance with the Privacy Shield.
  • Revision to the Privacy Policy. 6sense may change this Privacy Policy by posting an updated or revised Privacy Policy on our Website. Please check this Privacy Policy periodically so that you will remain up-to-date. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.
  • New Uses of Personal Information. Additionally, before we use Personal Information 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 Information is otherwise required by law or contract, 6sense will endeavor to comply with the law or contract.
  •  California Privacy Rights. California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information, disclosed to those parties. 6sense does not share Personal Information with Third Parties for their own marketing purposes.
 

SUPERSEDED DOCUMENTS

 
Title (Effective Date)
 6sense Privacy Policy                          Prior Effective Date: April 12, 2017
 Updated 6sense Privacy Policy            Current Effective Date: May 23, 2018