Privacy Policy

EFFECTIVE DATE: May 8, 2023

  1. About DSG

Demand Science Group, LLC, and its subsidiaries and affiliates (collectively “DemandScience”, “DSG”, “we”, “us”, or “our”) provides an integrated platform serving the B2B market with a suite of products that help marketing organizations improve demand generation.  We provide our solutions, such as Klarity (“Products and Services”) to a wide range of B2B businesses globally leveraging our expertise across content syndication, ABM Display, and B2B Data. 

  1. Commitment to Privacy 

DSG respects privacy and are committed to protecting personal information, or information identifying a natural person (“Personal Data”).  In this Privacy Policy (“Policy”), we describe the types of Personal Data we collect; why we collect it; the lawful bases for doing so; how we collect Personal Data, use Personal Data, and disclose Personal Data; and any of your rights, including access to your Personal Data. 

  1. Application of This Policy

This Policy applies to the Personal Data we collect when you purchase or use any of our Products and Services, including visits to our website at demandscience.com (“Website”). 

This Policy also applies to Business Contact Information (“BCI”) that is readily available in the public domain, such as business name, first and last name, business telephone number, job titles, work e-mail addresses and location in which a business is located and an individual works.  BCI information is collected and maintained in our B2B database.  Affiliates offering our Products and Services that also determine the purposes and means of processing BCI Information are Leadiro UK Limited and DS Intelligence LLC. 

By purchasing or using our Products and Services, or reading this Policy, you agree that your Personal Data will be handled as described in this Policy. Your purchase or use of the Products and Services, and any dispute over privacy, is subject to this Policy and our applicable Terms of Use, including its applicable limitations on damages and the resolution of disputes. The Terms of Use are incorporated by reference into this Policy. 

By purchasing or using our Products and Services, or reading this Policy, you are deemed to have agreed to the provisions of this Policy, unless you are in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, in which case you are acknowledging that you have been provided this Policy. Without prejudice to your rights under applicable laws, this Policy is not contractual and does not form a part of your contract with DSG or its affiliates or subsidiaries. 

In addition, this Policy applies to Personal Data we collect or use about job applicants or employees who are California residents (“Job Applicant and Employee Data”). We collect, use, and disclose Job Applicant and Employee Data for different reasons than other Personal Data we may collect, use, or disclose. For more information about how we collect, use, or disclose Job Applicant and Employee Data, please scroll down to the section titled “Additional Information for Job Applicants and Employees About the CCPA”. If you would like more information, please contact us using the information in section “22. Contact Us” below.

  1. What Personal Data Do We Collect About You and Why?

Personal Data, as we use it in this Policy, means information that directly identifies you and therefore, can be associated with you. This includes, but is not limited to, your first and last name, and contact information such as your physical address, email address, Internet Protocol address (“IP address”) and phone number.  Personal Data may also include your professional or employment-related details and details regarding your interaction with our Website or email marketing. 

Personal Data We Collect Directly from You.

If you request a whitepaper or other specific content, subscribe to our newsletters, or complete the web form on the Contact Us page, we ask you to fill out a brief form that requests information such as your name, company, title, e-mail address, and telephone, as well as your areas of interest and of course the content of any message to us. Similarly, if you provide comments on any blog or community page we may host, you will need to log in – although you may do that via your social network account such as Facebook, Twitter, or LinkedIn. 

Of course, we collect information from you when you respond to an online or a telemarketing survey. 

Our Website may include social media features or widgets, such as the Facebook, YouTube, and Twitter buttons. These features may also collect your IP address, which pages you are visiting on our Website, and may set a cookie (see below) even if you do not ‘click’ on the social media widget. These features may also give you the option to post information about your activities on our Website to your social media profile page to share with others within your network. Your interactions with these widgets and any data they may collect even if you do not click on them are governed by the privacy policy of the company providing them. 

Personal Data We Receive from Information Readily Available in the Public Domain.

DSG affirmatively collects and receives BCI from various third-party sources, including our partners.  BCI is information pertaining to businesses and individuals that is readily available in the public domain, including but not limited to:  business name, first and last name, business telephone number, job titles, work e-mail addresses and location in which a business is located and an individual works. We collect this information to provide our Products and Services to our customers. 

Personal Data We Collect Automatically.

We may automatically collect the following information about your use of our Website through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; the length of time you visit our Website; and the referring Uniform Resource Locator (“URL”), or the webpage that led you to our Website. We also use cookies and other tracking mechanisms in emails that we send you. In the email context, these tools help us know whether you’ve opened our message and whether you have interacted with the content at all. We may combine this information with other information that we have collected about you, including, where applicable, your username, name, and other Personal Data. (Please see below at Section 9, “Our Use of Cookies and Other Tracking Mechanisms” for more information on these tools). We may also collect information about your interaction with emails sent using ReplyForce, such as when you open an email sent using ReplyForce or click a link included in an email sent using ReplyForce, through technologies such as embedded pixels and link wrappers.  We use this information to provide ReplyForce to ReplyForce Users.  (Please see below at Section 12, “If Your Information is Provided to ReplyForce by a ReplyForce User” for more information.) 

  1. How We Use Personal Data

We use Personal Data for the following purposes:  

To fulfill or meet the reason you provided the Personal Data. To communicate with you about your purchase or use of our Products and Services, to respond to your inquiries or request for information, and for other marketing and client service purposes. 

To tailor the content and information that we may send through development of your profile, to offer content customization, and personalized help and instructions, and to otherwise personalize your experiences while visiting our Website and to help connect you with others who may have Products or Services in which you’ve expressed an interest. 

For marketing purposes. For example, we may use your Personal Data, such as your email address or phone number, to send you content, surveys, news and newsletters, or to otherwise contact you about our Products and Services or information we think may interest you. We may also use automatically collected Personal Data to determine whether and how you have interacted with any email messages we have sent you. 

To provide our customers with access to a database of accurate business data records including BCI which enables them to promote their goods and services employing direct marketing to the right people (i.e., decision makers, influencers, champions) in other businesses, and to promote your business so it can be found when it is searched for by other businesses. 

To better understand how visitors access and use our Website, both on an aggregated and individualized basis, in order to improve our Website. For testing, research, analysis, and our development of our Products and Services. To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our Website users is among the assets transferred. 

If we would like to use your Personal Data for any purposes other than those described, we will obtain your prior consent unless there are other lawful bases for processing your Personal Data (please see below at Section 7). 

  1. How We Disclose Your Personal Data

We may disclose your Personal Data within DSG, and externally with third parties as discussed below.   

When we disclose your Personal Data, we enter into a contractually binding agreement with the recipient of the Personal Data which requires the recipient to comply with the European Union General Data Protection Regulation (“GDPR”), the UK GDPR, the Canadian Personal Data Protection and Electronic Documents Act (“PIPEDA”), as well as any implementing regulation thereof of any jurisdiction, and any applicable data privacy laws and regulations of the United States or any US state, Canada, or any other relevant jurisdictions.  

Internally, Within DSG. We may disclose your Personal Data internally, within DSG. This may involve disclosing your Personal Data outside of the EEA and the UK.  All DSG subsidiaries and affiliates have entered into an intra-company transfer agreement committing to compliance with the GDPR, UK GDPR, PIPEDA, as well all other applicable data privacy laws.   

Other Website Visitors. If you post a comment on the blog pages or any other public area of our Website, your comment and identity will be available to, and searchable by, all users of our Website. This does not apply to any personal data you provide in a Contact Us inquiry. 

Upon Your Request or Instruction. When you request content from us or we present you with an online or telemarketing survey, we will typically obtain your direction to disclose limited Personal Data between DSG subsidiaries or affiliates, or specified business customers. 

Service Providers. We may disclose the personal data we collect from you to third party vendors, service providers, sub-processors, contractors or agents who perform functions on our behalf. We only disclose Personal Data to our service providers for the purpose of performing services on our behalf. We require that these parties only process the Personal Data for limited and specified purposes consistent with this Policy. 

Customers and Partners. We may disclose your Personal Data with our customers and partners under lawful bases, including Consent and/or Legitimate Interest (please see Section 7, below).  We may disclose or make your Personal Data available to partners who provide services on our behalf, such as hosting third-party software we have purchased and integrated into our website. 

Business Transfers. If DSG or any of its subsidiaries or affiliates are acquired by or merged with another organization, if substantially all of our assets are transferred to another organization, or as part of a bankruptcy proceeding, we may transfer the personal data we have collected from you to the other organization. 

In Response to Legal Process. We also may disclose the Personal Data we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena. 

To Protect Us and Others. We also may disclose the Personal Data we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which we are involved. 

Other Purposes 

If we would like to disclose your Personal Data for any purposes other than those described, we will obtain your prior consent, unless there are other lawful bases for processing your Personal Data (please see Section 7, below). 

  1. Lawful Bases for Processing Personal Data

We process Personal Data in accordance with all applicable data privacy laws and regulations.  If you are located in the European Union or Switzerland, the GDPR applies.   

If you are located in the UK, the UK GDPR applies. Under either, there are six lawful bases for processing of Personal Data: 

Consent, Performance of a Contract, and Legitimate Interests are the three lawful bases that are most appropriate when we process Personal Data: 

Generally, Consent is the most appropriate lawful bases when: Individuals freely consent to our processing of their Personal Data after being fully informed (e.g., specific purposes, right to easily withdraw at any time).  

Generally, Performance of Contract is the most appropriate lawful bases when: Our Products and Services are purchased and used, we need to process Personal Data to fulfill our obligations under the written agreements.    

Generally, Legitimate Interests is the most appropriate lawful bases when: 

  1. Under our Business-to-Business (B2B) model, we only process BCI taken from the public domain (e.g., work e-mail addresses); 
  1. We provide BCI to help our customers promote their offerings to other businesses (i.e., B2B);  
  1. It is in the interest of the professionals whose BCI we process for us to maintain accurate information so that businesses can better reach the most relevant business contacts, thus promoting the legitimate interests of the individual and our customers; and 
  1. You always have the right to opt-out and restrict all further processing of your Personal Data.The controllers of our B2B databases are our subsidiary[ies] Leadiro UK Limited and DS Intelligence LLC. 
  1. How Long We Keep Your Personal Data

We typically only retain your Personal Data for the time necessary to realize our legitimate business purposes and to comply with the law. 

  1. Our Use of Cookies and Other Tracking Technologies

We and our third-party service providers use cookies and other tracking technologies to track information about your use of our Website. We may combine this information with other Personal Data we collect from you (and our third-party service providers may do so on our behalf). 

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies). 

What are Cookies and how do they benefit you?

Cookies are small text files that are placed on your computer or mobile device when you browse websites. 

Cookies are not actual programs or software. When you visit a website, it stores a snippet of text from your visit; the next time you visit, this text is retrieved by the website, and it enables the website to recognize you. Cookies can be used differently depending on the actual website visited. Cookies allow websites to store such things as user preferences. You can think of cookies as providing a “memory” for the website, enabling it to recognize a user and respond appropriately. Cookies on our Website do NOT store any personally identifiable information such as names, addresses, email addresses or phone numbers. 

For more details see: https://www.allaboutcookies.org/ 

Our cookies help us: 

We do NOT use cookies to: 

What information is kept by the cookie? 

A cookie will typically hold: 

Granting Us Permission to Use Cookies

If the settings on the browser you are using to view our Website (Internet Explorer, Google Chrome, Mozilla Firefox, etc.) are set up to allow cookies, we take this, and your continued use of our Website, to mean that you accept and consent to our use of cookies. Should you wish to remove or not use cookies from our Website you can disable cookies through ‘Internet Options’ on your browser menu at any time, however, please be aware that doing so will probably mean that our Website may not work as well as you would expect. 

Our use of cookies falls into a few categories such as: 

More about Our Cookies

Website function cookies, such as session or preference cookies: 

Session cookies 

Persistent cookies 

We use cookies to make our Website function including:

Third-party functions 

Our Website, like most websites, includes functionality provided by third parties. A common example is an embedded YouTube or Vimeo video. Disabling these cookies is likely to break the functions offered by these third parties. 

Social Media Website Cookies 

To facilitate easy sharing or liking of content on social network platforms such Facebook and Twitter, we have included sharing buttons on our Website. The privacy implications on this will vary from social media network to social media network and will be dependent on the privacy settings you have chosen on these networks. 

Third Party Analytics: Anonymous Visitor & Behavior Statistics Cookies  

We use automated devices and applications, such as Google Analytics, to evaluate usage of our Website. We use these tools to help us improve our Website, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not disclose your Personal Data to these third parties and we do not receive your personal data from these third parties.  Unless you explicitly give us your information by filling in a form or calling us, all data that analytics programs collect is stored anonymously where we only see totals and not specific individual data. To opt-out of the collection of this demographic information from Google Analytics Demographics and Interest Reporting, you can use the Google Analytics Opt-out Browser Add-on. 

Examples include:

These statistics help us make our Website as user-friendly as possible, to ensure a good experience for all visitors. 

We use:

AdRoll Advertising

As you browse our Website, advertising Cookies will be placed on your computer or mobile device so that we can understand your interests. Our display advertising partner, AdRoll, then enables us to present you with retargeting advertising on other websites based on your previous interaction with our Website. The techniques our partners employ do NOT collect personal information such as your name, email address, postal address, or telephone number. You can visit this page to opt-out of AdRoll’s and their partner’s targeted advertising. 

Turning Cookies Off

You can switch cookies off by adjusting your internet browser settings to stop accepting cookies.  

Please be aware though that turning off cookies will impair the performance of many websites and not just ours. 

Local Storage Objects. We may use Flash Local Storage Objects (“Flash LSOs”) to store your website preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete, or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page, choose “Global Storage Settings Panel” and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO. 

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Website to, among other things, track the activities of Website visitors, help us manage content, and compile statistics about Website usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded. 

  1. If You Use Klarity By DemandScience

This section provides additional information about how DS Intelligence LLC may collect, use, and disclose information about individuals who use Klarity.  For purposes of this section, “we,” “us,” and “our” refers to DS Intelligence LLC, and individuals who use Klarity as “Klarity Users.” This section describes how we may collect, use, and disclose information about Klarity Users only when they are using Klarity. Other sections of this Privacy Policy describe how Klarity Users’ information may be collected, used, or disclosed when visiting the Website or using other Products or Services, or if your BCI may be collected for inclusion in our B2B databases. 

How and Why We May Collect Personal Data About Klarity Users

We collect the following categories of personal data about Klarity Users, for the purposes stated in the chart.  We may have done this in the past 12 months.  Klarity Users’ BCI is included in our database, and our use and disclosure of that BCI is described above in Sections 4, “What Personal Data Do We Collect About You”; 5, “How We Use Personal Data”; and 6, “How We Disclose Your Personal Data”. 

Category of personal dataExamplesPurpose of collection and use
IdentifiersName, username and password, mailing address, physical address, email address, telephone number, device ID, company, IP address ·      Communicate with you 
·      Provide and enhance Klarity 
·      Detect and prevent fraud 
·      Update our database of business contact information 
·      Market, advertise, or promote Klarity or our other products and services 
·      Comply with legal and regulatory obligations 
California Consumer Records Law informationName, username and password, mailing address, physical address, email address, telephone number, employment·      Communicate with you 
·      Provide and enhance Klarity 
·      Detect and prevent fraud 
·      Update our database of business contact information 
·      Market, advertise, or promote Klarity or our other products and services 
Comply with legal and regulatory obligations 
Commercial informationUse of Klarity by DemandScience, interest in using or purchasing other products and service we may offer·      Communicate with you 
·      Provide and enhance Klarity 
·      Detect and prevent fraud 
·      Market, advertise, or promote Klarity or our other products and services 
Comply with legal and regulatory obligations 
Internet or other electronic network activityBrowsing history, clickstream data, browser and operating system type, navigation paths, data/time stamps, cookie identifiers, and other information about device characteristics and how you interact with ReplyForce by DemandScience·      Communicate with you 
·      Provide and enhance Klarity 
·      Detect and prevent fraud 
·      Market, advertise, or promote Klarity or our other products and services 
Comply with legal and regulatory obligations 
Geolocation dataDevice location, geolocation, IP address·      Provide and enhance Klarity 
·      Detect and prevent fraud 
Comply with legal and regulatory obligations 
Professional or employment-related informationOccupation, title, employer, business mailing address, business email address, business telephone number·      Communicate with you
·      Provide and enhance Klarity by DemandScience
·      Detect and prevent fraud
·      Update our database of business contact information
·      Market, advertise, or promote Klarity by DemandScience or our other products and services
Comply with legal and regulatory obligations
Mailbox informationEmails you have sent or received·      Provide and enhance Klarity 
Comply with legal and regulatory obligations 

Additional Information for Klarity Users Located in Europe

We are required to identify the basis for Klarity to process your personal data, if you are located in the European Economic Area or the United Kingdom. 

Generally, we process your personal data based upon our legitimate interest in doing so, for example to manage Klarity or to detect and prevent fraud.  If you submit your personal data to make an inquiry or to communicate with us, our basis for processing your personal data is consent.  When you submit your personal data to sign up to use Klarity, our basis for processing your personal data is necessity to contract.  See Section 7, “Lawful Bases for Processing Personal Data,” for more information about our basis for adding your personal data that is BCI to our database. 

If you have questions, please contact us using the information in Section 20, “Contact Us”.

Where We May Collect Personal Data About Klarity Users From

We may have collected personal data about Klarity Users from the following sources: 

Category of sourcesCategory of personal data
From you
We may collect personal data from you when you sign up to use Klarity by DemandScience, when you provide your information in a web form on Klarity by DemandScience, or when you otherwise communicate with us.
·      Identifiers
·      California Consumer Records Law information
·      Internet or other electronic network activity
·      Geolocation data
Professional or employment-related information
Automatically
We may collect personal data from you automatically.  See Section 9, “Our Use of Cookies and Other Tracking Technologies” for more information.
·      Internet or other electronic network activity
Geolocation data

Why We May Disclose Personal Data About Klarity Users And To Whom

e disclose personal data of Klarity Users as follows, and we may have done so in the past 12 months:

Category of Third Party Recipient and Purpose of DisclosureCategory of personal data
Service providers
We may engage third parties to perform certain functions on our behalf.  To do so, we may disclose personal data to our third-party business partners and service providers in order to maintain and operate Klarity and provide, improve, and personalize Klarity, including to fulfill requests for Klarity, and for other technical and processing functions, such as sending e-mails on our behalf and technical support.  We may also disclose personal data to service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal, or fraudulent activity or other threats and for legal compliance purposes or pursuant to legal process.
·      Identifiers 
·      California Consumer Records Law information 
·      Commercial information 
·      Internet or other electronic network activity 
Professional or employment-related information 
Professional Services Firms
We may disclose personal data about Klarity Users to professional services firms that help us comply with our legal and regulatory obligations and establish, enforce, and otherwise exercise our rights and defend against claims, including, for example, auditors, law firms, and consultants.
·      Identifiers
·      California Consumer Records Law information
·      Commercial information
·      Internet or other electronic network activity
·      Geolocation data
Professional or employment-related information
Parents, Affiliates, and Subsidiaries
DSG is the ultimate parent entity of DS Intelligence LLC and other companies that make up the DemandScience family.  We may disclose personal data about Klarity Users to other companies within the DemandScience family, in order to provide Klarity or our other products and services.  When we disclose personal data about Klarity Users to other companies within the DemandScience family, their collection, use, and disclosure of that personal data is subject to this Privacy Statement.  When we disclose business contact information about Klarity Users to include in our database as B2B Participants, the collection, use, and disclosure of that personal data is as described in Sections 4, “What Personal Data Do We Collect About You”; 5, “How We Use Personal Data”; and 6, “How We Disclose Your Personal Data”.
·      Identifiers
·      California Consumer Records Law information
·      Commercial information
·      Internet or other electronic network activity
·      Geolocation data
Professional or employment-related information
Government Entities
We may disclose personal data about Klarity Users to Government Entities and law enforcement officials, for various reasons, including as required by law or regulation.
·      Identifiers 
·      California Consumer Records Law information 
·      Commercial information 
·      Internet or other electronic network activity 
·      Geolocation data 
Professional or employment-related information 
Merger and Acquisition Activity
We may disclose personal data about Klarity Users to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment, or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and performing the proposed transaction.
·      Identifiers
·      California Consumer Records Law information
·      Commercial information
·      Internet or other electronic network activity
·      Geolocation data
Professional or employment-related information

To opt out of Klarity please email [email protected].

  1. If You Use ReplyForce

This section provides additional information about how DS Data Management LLC may collect, use, and disclose information about individuals who use ReplyForce.  For purposes of this section, “we,” “us,” and “our” refers to DS Data Management LLC, and individuals who use ReplyForce as “ReplyForce Users.” This section describes how we may collect, use, and disclose information about ReplyForce Users only when they are using ReplyForce. Other sections of this Privacy Policy describe how ReplyForce Users’ information may be collected, used, or disclosed when visiting the Website or using other Products or Services, or if your BCI may be collected for inclusion in our B2B databases. 

How and Why We May Collect Personal Data About ReplyForce Users 

We collect the following categories of personal data about ReplyForce Users, for the purposes stated in the chart.  We may have done this in the past 12 months.  ReplyForce Users’ BCI in our database, and our use and disclosure of that BCI is described in Sections 4, “What Personal Data Do We Collect About You”; 5, “How We Use Personal Data”; and 6, “How We Disclose Your Personal Data”. 

Category of personal data Examples Purpose of collection and use 
Identifiers Name, username and password, mailing address, physical address, email address, telephone number, device ID, company, IP address ·      Communicate with you 
·      Provide and enhance ReplyForce
·      Detect and prevent fraud
·      Update our database of business contact information
·      Market, advertise, or promote ReplyForce or our other products and services
·      Comply with legal and regulatory obligations
California Consumer Records Law information Name, username and password, mailing address, physical address, email address, telephone number, employment ·      Communicate with you 
·      Provide and enhance ReplyForce
·      Detect and prevent fraud
·      Update our database of business contact information
·      Market, advertise, or promote ReplyForce or our other products and services
·      Comply with legal and regulatory obligations
Commercial information Use of ReplyForce, interest in using or purchasing other products and service we may offer ·      Communicate with you 
·      Provide and enhance ReplyForce
·      Detect and prevent fraud
·      Update our database of business contact information
·      Market, advertise, or promote ReplyForce or our other products and services
·      Comply with legal and regulatory obligations
Internet or other electronic network activity Browsing history, clickstream data, browser and operating system type, navigation paths, data/time stamps, cookie identifiers, and other information about device characteristics and how you interact with ReplyForce ·      Communicate with you 
·      Provide and enhance ReplyForce
·      Detect and prevent fraud
·      Update our database of business contact information
·      Market, advertise, or promote ReplyForce or our other products and services
·      Comply with legal and regulatory obligations
Geolocation data Device location, geolocation, IP address ·      Provide and enhance ReplyForce
·      Detect and prevent fraud
·      Comply with legal and regulatory obligations
Professional or employment-related information Occupation, title, employer, business mailing address, business email address, business telephone number ·      Communicate with you 
·      Provide and enhance ReplyForce
·      Detect and prevent fraud
·      Update our database of business contact information
·      Market, advertise, or promote ReplyForce or our other products and services
·      Comply with legal and regulatory obligations
Mailbox information Emails you have sent or received ·      Provide and enhance ReplyForce
·      Comply with legal and regulatory obligations

Additional Information for ReplyForce Users Located in Europe 

We are required to identify the basis for ReplyForce to process your personal data, if you are located in the European Economic Area or the United Kingdom. 

Generally, we process your personal data based upon our legitimate interest in doing so, for example to manage ReplyForce or to detect and prevent fraud.  If you submit your personal data to make an inquiry or to communicate with us, our basis for processing your personal data is consent.  When you submit your personal data to sign up to use ReplyForce, our basis for processing your personal data is necessity to contract.  See Section 7, “Lawful Bases for Processing Personal Data,” for more information about our basis for adding your personal data that is BCI to our database. 

If you have questions, please contact us using the information in Section 22, “Contact Us”. 

Where We May Collect Personal Data About ReplyForce Users From 

We may have collected personal data about ReplyForce Users from the following sources: 

Category of sources Category of personal data 
From you 
We may collect personal data from you when you sign up to use ReplyForce, when you provide your information in a web form on ReplyForce, or when you otherwise communicate with us about ReplyForce. 
·      Identifiers
·      California Consumer Records Law information
·      Internet or other electronic network activity
·      Geolocation data 
·      Professional or employment-related information 
Automatically 
We may collect personal data from you automatically when, logged in, you visit ReplyForce, as you load ReplyForce, or as you interact with ReplyForce.  See Section 9, “Our Use of Cookies and Other Tracking Technologies” for more infomration. 
·      Internet or other electronic network activity
·      Geolocation data 
From your email provider 
Using ReplyForce requires you to connect it to your professional email mailbox in Exchange Online or Google Workspaces.  We will have access to your mailbox and we may collect your personal data as part of providing you with ReplyForce.  We do not access the content of messages in your mailbox. 
·      Identifiers
·      California Consumer Records Law information
·      Internet or other electronic network activity
·      Geolocation data 
·      Mailbox Information

Why We May Disclose Personal Data About ReplyForce Users And To Whom  

We disclose personal data of ReplyForce Users as follows, and we may have done so in the past 12 months: 

Category of Third Party Recipient and Purpose of Disclosure Category of personal data 
Service providers 
We may engage third parties to perform certain functions on our behalf.  To do so, we may disclose personal data to our third-party business partners and service providers in order to maintain and operate ReplyForce and provide, improve, and personalize ReplyForce, including to fulfill requests for ReplyForce, and for other technical and processing functions, such as sending e-mails on our behalf and technical support.  We may also disclose personal data to service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal, or fraudulent activity or other threats and for legal compliance purposes or pursuant to legal process. 
·      Identifiers
·      California Consumer Records Law information
·      Commercial information 
·      Internet or other electronic network activity
·      Professional or employment-related information 
·      Mailbox information 
Professional Services Firms 
We may disclose personal data about ReplyForce Users to professional services firms that help us comply with our legal and regulatory obligations and establish, enforce, and otherwise exercise our rights and defend against claims, including, for example, auditors, law firms, and consultants. 
·      Identifiers
·      California Consumer Records Law information
·      Commercial information 
·      Internet or other electronic network activity
·      Geolocation data 
·      Professional or employment-related information
·      Mailbox information 
Parents, Affiliates, and Subsidiaries 
Demand Science Group, LLC is the parent entity of our group of companies that make up the DemandScience family.  We may disclose personal data about ReplyForce Users to other companies within the DemandScience family, in order to provide ReplyForce or our other products and services.  When we disclose personal data about ReplyForce Users to other companies within the DemandScience family, their collection, use, and disclosure of that personal data is subject to this Privacy Statement.  When we disclose business contact information about ReplyForce Users to include in our database as B2B Participants, the collection, use, and disclosure of that personal data is as described in Section 4, “What Personal Data Do We Collect About You”; 5, “How We Use Personal Data”; and 6, “How We Disclose Your Personal Data”. 
·      Identifiers
·      California Consumer Records Law information
·      Commercial information 
·      Internet or other electronic network activity
·      Geolocation data 
·      Professional or employment-related information
·      Mailbox information 
Government Entities 
We may disclose personal data about ReplyForce Users to Government Entities and law enforcement officials, for various reasons, including as required by law or regulation. 
·      Identifiers
·      California Consumer Records Law information
·      Commercial information 
·      Internet or other electronic network activity
·      Geolocation data 
·      Professional or employment-related information
·      Mailbox information 
Merger and Acquisition Activity 
We may disclose personal data about ReplyForce Users to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment, or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and performing the proposed transaction. 
·      Identifiers
·      California Consumer Records Law information
·      Commercial information 
·      Internet or other electronic network activity
·      Geolocation data 
·      Professional or employment-related information
·      Mailbox information 

To opt out of Klarity please email [email protected].

  1. If Your Information is Provided to ReplyForce By a ReplyForce User 

A ReplyForce User can provide contact information for other individuals as part of the ReplyForce User’s use of ReplyForce.  ReplyForce handles personal data of those individuals only as directed by the ReplyForce User supplying the personal data.  This Privacy Statement does not explain how those individuals’ personal data is collected, used, or disclosed.  You should ask the ReplyForce User who supplies the personal data for their use in ReplyForce to explain their privacy practices surrounding the collection, use, and disclosure of that personal data. 

In addition, when emails are sent using ReplyForce, a pixel is embedded in the email that can determine whether the email was opened or not, and links contained in an email sent using ReplyForce are wrapped in a link to our servers, which will redirect you to the ultimate site.  We use the information generated through those pixels and link wrappers to help ReplyForce Users understand how individuals interact with emails sent using ReplyForce.  This Privacy Statement does not otherwise explain how that personal data is collected, used, or disclosed.  You should ask the ReplyForce User to explain their privacy practices surrounding the collection, use, and disclosure of that personal data. 

  1. Third-Party Links

Our Website may contain links to third-party websites and social media. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

  1. User Generated Content

We invite you to post content on our Website and provide responses to our blog, including your comments, pictures, and any other information that you would like to be available on our Website. If you post content to our Website, all of the information that you post will be available to all visitors to our Website. If you post your own content on our Website, your posting may become public and we cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy. 

  1. Security of My Personal Data
  1. Third Party Links

Our Website may contain links to third-party websites and social media. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites. 

  1. Security of My Personal Data

We have implemented technical and organizational measures to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security. 

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. 

  1. Access to My Personal Data

Consistent with applicable laws or regulations, we make good faith efforts to provide you with access to your Personal Data and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. 

Consistent with applicable laws or regulations, you may modify Personal Data that you have submitted, or that we have obtained from other sources by contacting us and requesting a copy of whatever identifiable information you have provided to us. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Website for a period of time 

  1. What Choices Do I Have Regarding Use of My Personal Data?

We may send periodic solicitations or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Based on the requirements of data privacy laws (e.g., GDPR), it can take up to 30 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any services you have requested or received from us.

  1. Children’s Privacy

Our Website is not intended for children under the age of 16.

We do not knowingly collect information from children.  In the event that we learn that we have collected personal on the Website from a child under age 16, we will delete that information promptly. If you believe that we might have any information from a child under 16, please contact us at [email protected].

  1. Visiting our Website from Outside the United States

If you are visiting our Website from outside the United States, please be aware that your information will typically be transferred to, stored, and processed in the United States, United Kingdom, Ireland, Philippines, New Zealand, Australia and France where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. Please be assured that we seek to take reasonable steps to ensure that your Personal Data is protected regardless of where we hold it.

  1. Visiting to Our Website from the European Economic Area (EEA) and the United Kingdom (UK)

The Lawful Basis for Processing Personal Data of EEA and UK Residents

When we collect information about you through our Websites, our emails, surveys, and so forth, the lawful basis on which we process your Personal Data is performance of a contract between us, namely, to provide you with the content, to help connect you with relevant vendors, and other information in response to your request. 

To the extent that we transfer Personal Data from any legal entity we may have in the EEA or UK to a jurisdiction outside the EEA or UK that has not been adduced by the European Commission as providing adequate data protections, we will ensure that such Personal Data is safeguarded through appropriate contractual terms, and technical and organizational measures. 

Rights for EEA and UK Residents

In addition, if you are a resident of the EEA or the UK, you have the right to: 

Find out if we use your Personal Data, to access your Personal Data, and receive copies of your Personal Data. 

Withdraw any express consent that you have provided to the processing of your Personal Data at any time without penalty. 

Access your Personal Data and have it corrected or amended if it is inaccurate or incomplete. 

Obtain a transferable copy of some of your Personal Data which can be transferred to another provider when the Personal Data was processed based on your consent. 

If you believe your Personal Data is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Data, you also have the right to request that we restrict the processing of your Personal Data pending our investigation and/or verification of your claim.  

Request your Personal Data be deleted or restricted under certain circumstances. For example, if we are processing your Personal Data on the lawful basis of your consent and have no other lawful basis to process such, you may request your personal data be deleted when you withdraw your consent. 

If you wish to exercise any of these rights or raise a complaint on how we have handled your Personal Data, please first contact us at the Contact Us details below.  If you wish to make a complaint with a supervisory authority, their contact information may be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en (if in the European Union) or https://ico.org.uk/make-a-complaint/ (if in the UK). 

  1. California Residents

California “Shine The Light” law

Pursuant to California’s “Shine The Light” law (California Civil Code § 1798.83), California residents are entitled to request, once a year and free of charge, certain information regarding what types of their Personal Data may be disclosed to third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under this law, a business is to either provide California customers certain information upon request or permit California customers to opt-out of this type of disclosure.  You may request this information by contacting us at [email protected] and indicate in the e-mail subject line, “California Shine The Light Request.”  Please include your mailing address, state of residence and e-mail address with your request. 

The California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act, gives California residents enhanced rights with respect to their Personal Data that is collected by businesses. 

First, California residents may opt-out of having their Personal Data sold to other persons or parties. 

Second, California residents have a right to know:

What specific pieces of information a business has about the resident;

Categories of Personal Data it has collected about the resident;

Categories of sources from which the Personal Data is collected;

Categories of Personal Data that the business sold, shared, or disclosed for a business purpose about the resident;

Categories of third parties to whom the Personal Data was sold, shared, or disclosed for a business purpose; and

The business or commercial purpose for collecting, selling, or sharing Personal Data. 

Third, California residents can request that the Personal Data a business has collected from them be deleted from the business’s systems and records, subject to certain exceptions. 

Fourth, California residents can request that inaccurate Personal Data a business maintains about them be corrected.  

DSG is covered under the CCPA as we collect and process the Personal Data of California residents.  This Policy provides the required notices to California residents.  The CCPA also prohibits covered businesses from providing discriminatory treatment to California residents if they exercise their rights under the Act. 

DSG may sell or share Personal Data of California residents. You can request to opt-out of the sale or sharing of your Personal Data at any time by completing the online form (available at https://demandscience.com/ccpa/) or by sending us an e-mail at [email protected].  Under the CCPA, we have 15 days after receipt to implement a request to opt-out. The CCPA requires us to state that we do not have actual knowledge that we have sold or shared the Personal Data of California residents under 16 years of age. 

To make a “request to know,” “request to delete,” or “request to correct” your Personal Data, send us an e-mail at [email protected] . (Please put “Request to Know,” “Request to Delete,” or “Request to Correct” in the subject heading of your email.)  You may also submit these requests via  Do Not Sell My Personal Information or by mailing your request to address in the United States to: 

Demand Science Group, LLC 

Data Protection Officer 

222 Rosewood Drive 

Danvers, MA 01923 

We will honor these requests for individuals in the United States whether or not you would qualify as a California resident under the CCPA. 

We will confirm receipt of your request to know, delete, or correct within 10 days along with a description of what steps we will take to verify and respond.  We must provide the requested information or delete your Personal Data within 45 days of receipt of your request but can use an additional 45 days, but we will let you know additional time is needed. 

When contacting us, we may ask you to provide certain, limited Personal Data, such as your name, e-mail address and/or username to verify your request and to match with our records and systems.  We will not retain this Personal Data or use it for any other purpose.  Residents of other states may also have similar rights to request information about or delete their Personal Data.  To inquire about exercising these rights, please contact us at [email protected]

Additional Information for Job Applicants and Employees About the CCPA 

This subsection contains information about how we may collect, use, and disclose the Personal Data about California residents related to any job application or employment with us. This subsection does not contain information about how we may collect, use, and disclose Personal Data about California residents not related to any job application or employment with us, which is described in the remainder of this Policy.  This subsection does not apply to non-California residents. 

For example, if you are a California resident and apply for a job with us through the Careers page on our Website, the Policy outside of this subsection explains how we may collect, use, or disclose the Personal Data we collect or generate about you as you browse or navigate our website. This subsection explains how we may collect, use, or disclose the Personal Data you submit by clicking “Submit Application” on our Website to apply for a job. 

In the proceeding 12 months, we may have collected the following categories of information about job applicants and employees who are California residents: 

Category of Personal DataExamplesPurpose of Collection and Use
IdentifiersName, address, email address, phone number, social security number, online identifier·      Communicate with job applicants and employees
·      Make employment and compensation decisions
Comply with applicable law
California Consumer Records law informationName, social security number, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, other financial information, medical information, health insurance information·      Communicate with job applicants and employees
·      Make employment and compensation decisions
 
·     Provide employee benefits and compensation
Comply with applicable law
Characteristics of protected classifications under California or federal lawGender, race, ethnicity, veteran status, disability status, sexual orientation, national origin, criminal records· Comply with applicable law
Financial informationBank account information· Provide employee benefits and compensation
Internet or other electronic network activityNetwork activity, network connections, IP address· Detect and prevent fraud and malicious activity
· Ensure network and information security and compliance with our IT and data privacy and security policies
· Comply with applicable law
Geolocation informationIP geolocation· Detect and prevent fraud and malicious activity
· Ensure network and information security and compliance with our IT and data privacy security policies
· Comply with applicable law
Audiovisual informationRecording of calls or meetings, headshots, sales presentations· Record keeping of meetings as business records
· Make employment and compensation decisions
Professional or employment-related informationJob titles, compensation, professional experience, employment history, references, education, degrees· Make employment and compensation decisions
Education informationEducational institutions attended, dates of attendance, degrees granted· Make employment and compensation decisions
Inference informationInferences about a job applicant’s or employee’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes· Make employment and compensation decisions
· Comply with applicable law
Sensitive personal information·      Social Security number, driver’s license number, passport number, or state-issued identification card number
·      Racial or ethnic origin
Health information for purposes of ADA reasonable accommodations
· Comply with applicable law

We may have collected Personal Data about job applicants or employees from the following sources:

Category of SourcesCategory of Personal Data about Job Applicants and Employees
Through job applications and the application and hiring process
We may collect Personal Data about job applicants and employees through job applications and related application materials that they submit to us.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Audiovisual information
· Professional or employment-related information · Education information
· Sensitive personal information (racial or ethnic origin, health information)
From employees
We may collect Personal Data from employees as part of the onboarding process and continued employment process. We may also collect additional Personal Data automatically from employees as they use our information and communication systems.
· Identifiers
· California Consumer Records Law information
· Financial information
· Information or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Inference information
· Sensitive personal information (Social Security number, driver’s license number, passport number, or state-issued identification card number, health information)
Third party suppliers
We may collect Personal Data about job applicants or employees through third-party suppliers, which may be Service Providers under the CCPA or not. We use these third-party suppliers to conduct background checks, source application information (such as when an individual applies for a position through LinkedIn), or to identify potential candidates who may be a good fit to work with us (such as outside recruitment agencies)
· Identifiers
· California Consumer Records law information
· Professional or employment-related information
· Education information
· Inference information
Other third parties
We may collect Personal Data about job applicants or employees through other third parties, such as through reference calls during the hiring process or communicating with other entities to track and maintain appropriate records of education, training, and development activities, or from healthcare providers, as necessary to make hiring, employment, and promotion decisions.
· Identifiers
· California Consumer Records law information
· Professional or employment-related information
· Education information
· Inference information

We have sold Personal Data of California residents within the past 12 months. However, we do not sell or share the Personal Data related to and collected through any job application or employment with us described in this section, and we have not done so in the past 12 months. For more information about how we sell Personal Data of California residents, please navigate in this Policy to the section titled “California Consumer Privacy Act (CCPA)“. 

The CCPA requires us to state that we do not have actual knowledge that we have sold or shared Personal Data of job applicants or employees under 16 years of age. We do not have employees under 18 years of age. 

We disclose Personal Data of job applicants and employees as follows, and we may have done so in the past 12 months: 

Category of Third Party Recipient And Purpose Of DisclosureCategory of Personal Data about Job Applicants and Employees
Service providers
We engage third-party service providers to perform a variety of services on our behalf, which may mean that we have to disclose Personal Data about job applicants and employees to these third parties. For example, we may disclose Personal Data to a payroll provider in order to process payroll, or to a SaaS provider to provide software used by employees to fulfill their job duties and discharge their responsibilities. When we disclose Personal Data in this way, we put in place appropriate measures to make sure that our service providers keep the Personal Data confidential and secure.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Audiovisual information
· Geolocation information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal information
Financial institutions
We may disclose Personal Data about employees to financial institutions in order to pay employee compensation.
· Identifiers
· Financial information
· Professional or employment-related information
Benefit plans
We may disclose Personal Data about employees or their dependents to our benefits providers in order to provide benefits to our employees and their dependents, such as health, dental, and disability insurance.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Inference information
· Sensitive personal information (racial or ethnic origin)
Professional Services Firms
We may disclose Personal Data about job applicants or employees to professional services firms that help us comply with our legal and regulatory obligations and establish, enforce, and otherwise exercise our rights and defend against claims, including, for example, auditors, law firms, and consultants.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal information
Parents, Affiliates, and Subsidiaries
Demand Science Group, LLC is the parent entity of our group of companies that make up the DemandScience family. We may disclose Personal Data about job applicants or employees to other companies within the DemandScience family, in order to make employment or hiring decisions, to provide employ benefits and compensation, or to otherwise manage and operate the DemandScience family of companies. When we disclose Personal Data about job applicants or employees to other companies within the DemandScience family, their collection, use, and disclosure of that Personal Data is subject to this Policy.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal information
Government Entities
We may disclose Personal Data about job applicants and employees to Government Entities and law enforcement officials, for various reasons, including as required by law or regulation or to confirm or verify a California resident’s right to work in the United States.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Audiovisual information
· Geolocation information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal information
Merger and Acquisition Activity
We may disclose Personal Data about job applicants or employees to third parties in connection with the proposed or actual financing, insuring, sale, securitization, assignment, or other disposal of all or part of our business or assets (including accounts) for the purposes of evaluating and performing the proposed transaction.
· Identifiers
· California Consumer Records law information
· Characteristics of protected classifications under California or federal law
· Financial information
· Internet or other electronic network activity
· Geolocation information
· Audiovisual information
· Professional or employment-related information
· Education information
· Inference information
· Sensitive personal information

The CCPA requires us to state that we do not use or disclose sensitive personal information about job applicants or employees for purposes other than to perform the services reasonably expected by an average job applicant or employee who applies for a job or is employed by us; to prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted Personal Data; to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those reasonable for those actions; or to collect or process sensitive personal information where such collection or processing is for the purpose of inferring characteristics about a job applicant.

CCPA Consumer Request Rights Metrics

As described in this Policy, California residents have the opportunity to access, delete, and correct the Personal Data that we maintain about them. DSG presently is compiling metrics required by the CCPA for consumer requests made under the CCPA for calendar year 2022 and will update this Policy to provide those metrics by July 1, 2023.  If you would like information about our metrics for calendar year 2021, please contact us using the information in section 22, “Contact Us”. 

  1. Contact Us

If you have questions regarding this Policy, or would like to report a potential privacy or security incident or vulnerability or otherwise make a complaint, please contact us:

Call us at 1-888-845-3020; or e-mail us at [email protected]; or write us at:

Demand Science Group, LLC
Data Protection Officer
222 Rosewood Drive
Danvers, MA 01923

  1. Changes to This Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Website, at https://demandscience.com/privacy-policy/