Effective as of December 1st ,2023.
Our websites, products and services are designed for enterprise customers and their representatives. We do not offer products or services directly to individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant enterprise and not their individual capacities.
- Personal information we collect
- How we use your personal information
- How we share your personal information
- Your choices
- Other sites and services
- International data transfers
- How to contact us
- Notice to California residents
- Notice to Users in Europe and other countries outside the US
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.
- Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Private sources, such as data providers, social media platforms and data licensors.
- Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters who participate in our paid affiliate programs.
- Marketing partners, such as joint marketing partners and event co-sponsors.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
- Online activity data, such as pages you viewed, how long you spent on a page, the website you visited before browsing to the Service, navigation paths between pages, information about your activity on a page, access times and duration of access, and whether you have opened our emails or clicked links within them.
- Communication interaction data such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
- provide, operate and improve the Service and our business;
- communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
- administer and communicate with you about events or contests in which you participate;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you Company-related or other direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
How we share your personal information
- Service providers: Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, online chat functionality providers, email delivery, marketing, consumer research, and website analytics).
- Professional advisors: Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
- Authorities and others: Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
- Business transferees: Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of the business or assets of, or equity interests in, the Company or our affiliates (including, in connection with a bankruptcy or similar proceedings).
In this section, we describe the rights and choices available to all users. Users located in Europe can find information about their additional rights in the Notice to users in Europe and other countries outside the US section below, and users who are California residents can find information about their additional rights in the Notice to California residents section below.
- Opt-out of communications: You may opt-out of marketing-related emails and other direct marketing communications by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
- Cookies: For information about cookies employed by the Service and how to control them, see our Cookie Notice.
- Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
- Do Not Track: Some Internet browsers may be configured to send «Do Not Track» signals to the online services that you visit. We currently do not respond to «Do Not Track». To find out more about «Do Not Track,» please visit http://www.allaboutdnt.com.
- Declining to provide information: We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Other sites and services
We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
International data transfer
We are an international company and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users located in Europe or other countries outside the US should read the important information provided below about the transfer of personal information outside of Europe.
The Service is not intended for use by anyone under 16 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
How to contact us
Europe, Middle East & Africa
Asia, New Zealand, and Australia
Notice to California residents
This notice describes our collection, use and disclosure of personal information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to their personal information. For purposes of this notice, “personal information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA.
Your privacy rights
As a California resident, you have the following rights under the CCPA:
- Right to know: You can request information about the categories of personal information that we have collected; the categories of sources from which we collected personal information; the business or commercial purpose for collecting, sharing, and/or selling personal information; the categories of any personal information that we sold or disclosed for a business purpose; and the categories of any third parties with whom personal information was sold, shared, or disclosed for a business purpose.
- Right to access: You can request a copy of personal information that we have collected about you.
- Right to deletion: You can request that we delete personal information that we collected from you.
- Right to opt-out: If we “sell” or “share” your personal information as defined by the CCPA, you can opt-out of those disclosures.
- Right to correction: You can request that we correct inaccurate personal information that we have collected about you.
- Nondiscrimination: You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.
Note: The rights described above are not absolute, and, in certain cases, we may decline your request as permitted by law or where the laws in your state do not afford you these rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You can ask to appeal any denial of a request in the same manner through which you may submit one.
How to exercise your rights
You may submit requests to exercise your right to information/know, access, appeal, correction, or deletion by using the How to contact us section above or at https://5-56.eu/about-us/.
The rights described above are not absolute, and, in certain cases, we may decline your request as permitted by law or where the laws in your state do not afford you these rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. You can ask to appeal any denial of a request in the same manner through which you may submit one.
Verification of identity; authorized agents
We may need to verify your identity to process your information/know, access, deletion, and correction requests, and we reserve the right to confirm your residency. To verify your identity, we may require authentication into your Service account if you have one, provide personal identifiers we can match against information we may have collected from you previously, confirm your request using the email or telephone account stated in the request, provide government identification, or provide a declaration under penalty of perjury, where permitted by law.
Your authorized agent may make a request on your behalf. We will process your agent’s requests to exercise your rights to know, access, correction, or deletion upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to applicable state law, proof that you have given the agent permission to submit the request, or additional information.
The following describes our practices currently and during the past 12 months:
- Sharing and sales of personal information:
- Sharing: Our potential use of the interest-based advertising services described above may constitute “sharing” of your personal information (including identifiers and internet/network information described in the CCPA) with our advertising partners from which you have the right to opt-out. If we engage in such practices, you can request to opt-out of this sharing of your personal information by clicking the Do Not Sell or Share My Personal Information link in the footer of this webpage. Your request to opt-out will apply only to the browser and the device from which you submit the request.
- Sales: We do not otherwise “sell” personal information as defined by the CCPA. Although our Services are not intended for children under 16 years of age, we are required to inform you that we do not have actual knowledge that we have sold or shared the personal information of children under 16.
- Sensitive personal information: We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the CCPA.
- Deidentification: We do not attempt to reidentify deidentified information derived from personal information, except for the purpose of testing whether our deidentification processes comply with applicable law.
- Retention: The criteria for deciding how long to retain personal information is generally based on whether such a period is sufficient to fulfill the purposes for which we collected it as described in this notice, including complying with our legal obligations.
Data Categories and Disclosures
|Statutory category/personal information we collect
|Categories of third parties to whom we disclose the personal information for a business purpose
|California Customer Records (as defined in California Civil Code §1798.80)
|Internet or Network Information
|Professional or Employment Information
|Protected Classification Characteristics
May be included or revealed in:
Notice to Users in Europe and Other Countries Outside the US
Where this Notice applies: The information provided in this «Notice to users in Europe and other countries outside the US» section applies only where (i) we are processing the personal information of individuals located in the EEA, the UK (EEA and UK jurisdictions are together referred to as «Europe»), or another country as a controller, and (ii) the laws related to the processing of personal information of such jurisdiction apply directly to us. For the avoidance of doubt, this section does not constitute our submission to the jurisdiction of any such laws around the world, and this section only applies to the extent the data protection or data privacy laws of a particular jurisdiction outside of the United States apply directly to our processing of your personal information.
Our legal bases for processing
In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a «legal basis» for that use.
- Contractual Necessity: Where we need to process your personal information to deliver our Services to you (including our Site).
- Legitimate Interests: Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
- Compliance with Law: Where we need to comply with a legal or regulatory obligation.
- Consent: Where we have your specific consent to carry out the processing for the Purpose in question.
We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these. Purposes and the data types involved, see How we use your personal information above.
|Categories of personal information involved
|Service delivery and operations
|Research and development
|Any and all data types relevant in the circumstances
|Legitimate interest. We have legitimate interest in understanding what may be of interest to our customers, improving customer relationships and experience, delivering relevant content to our customers, measuring and understanding the effectiveness of the content we serve to customers.
|Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
|Compliance and protection
|Any and all data types relevant in the circumstances
|Compliance with Law. Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through cooperation with authorities. We and any relevant third parties may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety
|Any and all data types relevant in the circumstances
|The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
No obligation to provide personal information. You do not have to provide personal information to us. However where we need to process your personal information either to comply with applicable law or to deliver our Services to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Services to you. We will notify you if this is the case at the time.
Security. We have put in place procedures designed to deal with breaches of personal information. In the event of such breaches, we have procedures in place to work with applicable regulators. In addition, in certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal information.
General: Applicable data protection laws may give you certain rights regarding your personal information. If you are located in Europe or other countries outside the US where such rights apply, you may ask us to take any of the following actions in relation to your personal information that we hold:
- Access: Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct: Update or correct inaccuracies in your personal information.
- Delete: Delete your personal information where there is no lawful reason for us continuing to store or process it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal information to comply with local law. Note that we may not always be able to comply with your request for specific legal reasons that will be notified to you, if applicable, at the time of your request.
- Portability: Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Restrict: Restrict the processing of your personal information if:
- (i) you want us to establish the personal information’s accuracy;
- (ii) where our use of the personal information is unlawful but you do not want us to erase it;
- (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.
- Object: Object to our processing of your personal information where we are relying on legitimate interests (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.
- Withdraw Consent: When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
Exercising These Rights. You may submit these requests by using the How to contact us section above. We may request specific information from you to help us confirm your identity and process your request.
Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information). If we reject any request you may make (whether in whole or in part), we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We try to respond to all legitimate requests within a month. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
- For users in the European Economic Area: The contact information for the data protection regulator in your place of residence can be found here.
- For users in the UK: The contact information for the UK data protection regulator is below:
The Information Commissioner’s Office
Water Lane, Wycliffe House
Wilmslow – Cheshire SK9 5AF
Tel. +44 303 123 1113
Data Processing outside of your home country
We are an international company, and many of our service providers, advisers, partners, or other recipients of data are also based in the US and elsewhere around the world. This means that, if you use the Services, your personal information may be accessed and processed in the US or elsewhere around the world.
It is important to note that the recipient jurisdiction may not be subject to an ‘adequacy decision’ under applicable laws (e.g., GDPR) – basically, this means that the recipient jurisdiction’s legal regime is not considered by relevant legal bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by your home jurisdiction (e.g., Europe) laws.
Where we share your personal information with third parties who are based outside your home country, we try to ensure a similar degree of protection is afforded to it in accordance with applicable privacy laws by making sure one of the following mechanisms is implemented:
- Transfers to territories with an adequacy decision: We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the relevant legal authority (e.g., the European Commission or UK Government).
- Transfers to territories without an adequacy decision:
- We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the US, see above).
- However, in these cases:
- We may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in your home country – for example, standard-form contracts approved by relevant authorities for this purpose; or
- In limited circumstances, we may rely on an exception, or ‘derogation,’ which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of your home country.