Privacy Policy

Effective Date: May 16, 2023

Salas O’Brien, Inc. and its affiliates and subsidiaries (“Company,” “we,” “us” or “our”) recognize the importance of protecting the privacy of individuals. The following Privacy Notice (“Privacy Notice”) describes the way we handle personal information learned about you from your visits to Company’s websites, including Salasobrien.com and any other site where this Privacy Notice is posted (collectively, the “Site”).

PLEASE REVIEW THIS PRIVACY NOTICE CAREFULLY. By accessing the Site and/or submitting information to or through the Site, you accept the terms of this Privacy Notice and consent to our collection, use, disclosure and retention of your information as described in this Privacy Notice.

FOR CALIFORNIA RESIDENTS

If you are a resident of California, you may be afforded additional rights. Please see the sections below entitled, “Additional Information for California Residents” for more information on our collection of California resident personal information and how to exercise such rights.

INFORMATION WE COLLECT

Personal Information You Provide

You may provide us with personal information when you visit our Site, which may include:

Name
Address
Telephone number
Email address
Organization/company name

Additionally, we may collect any personal information you provide us in communications you send or provide when you contact us through any communications tools on the Site.

Information Collected Automatically

Certain information may automatically be collected by Company when you use the Site. This information may include:

IP address
Browser type
Type of operating system
Device type
Unique device identifier
Internet service provider
Language preference
Access times and dates
Approximate geographic location
Referring website addresses
User actions (e.g., page views)
Search queries

Cookies and Other Information Collection Tools

We use cookies and similar tracking technologies to track the activity on the Site and store certain information. Other tracking technologies we may use are beacons, tags, and scripts.

Cookies. A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Site or the functionality of some parts of our Site may be limited. We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for longer defined periods or until you or your browser erase them. Persistent cookies have varying durations that are dependent on their expiration date.

Web Beacons. Certain sections of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company to count users who have visited those pages or opened an email and to collect other website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Why do we use them? Cookies and other tracking technologies help us identify the effectiveness of account and marketing communications we send, improve the Site by providing us with information about which parts of the Site are most popular, what actions are taken by users and what content is viewed, enabling us to analyze technical and navigational information about the Site, and helping us to detect and prevent fraud. These tools use cookies to collect standard Internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of the Site (including IP address) is transmitted to our data collection tool service providers. This information is then used by us to evaluate visitors’ use of the Site and to compile statistical reports on website activity for Company. For example, we use Google Analytics to help analyze how users use the Site. If you would like to opt-out from the use of your information by Google analytics, you may use Google Analytics opt-out browser add-on designed for this purpose.

How do I control cookies? Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user’s computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Site.

HOW WE USE THE INFORMATION WE COLLECT

We may use the information we collect for any of the following purposes:

to provide the Site to you and to improve the Site;
to provide, operate, improve, and personalize the services we offer, and to give each user a more consistent and personalized experience when interacting with us;
to perform a contract with you or the organization with which you are affiliated;
to provide you with information about products and services that we may provide that we think may be of interest to you;
to provide you with updates or transactional information about our services that you or the organization with which you are affiliated may be using;
for customer service and/or support, security (including for authentication purposes), to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
for data analysis, identifying usage trends, and determining the effectiveness of our promotional campaigns;
to communicate with you;
to comply with applicable laws or respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process;
to enforce our rights, protect our property or protect the rights, property or safety of others; and
as needed to support external auditing, compliance and corporate governance functions.

We may create aggregate data sets using information we collect on the Site that are not identifiable to any individual. We may use and disclose such aggregate and de-identified data for any lawful purpose.

HOW WE SHARE INFORMATION

We may share personal information we collect in the following situations:

With Third Party Service Providers Performing Services on Our Behalf. We may share your personal information with our service providers to perform the functions for which we engage them. For example, we may use third parties to host the Site or assist us in providing functionality on the Site, provide analytics on the Site, provide marketing and advertising services for us, to send out emails on our behalf or process payments.
With Our Affiliates and Subsidiaries. We may share your information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures or companies under common control) for our internal business purposes.

For Legal Purposes. We may share information that we collect from users as needed to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose personal information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share personal information as required to pursue available remedies or limit damages we may sustain.
Changes of Control. We may transfer or assign the information that we have collected from users in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

EMAIL MARKETING

You may opt out of receiving promotional e-mails and text messages from us by following the unsubscribe instructions provided in any such messages. Please note that if you opt out of receiving promotional messages from us, this does not impact other transactional and administrative messages which you will continue to receive (such as emails relating to billing and payment information or changes to this Privacy Notice).

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

The California Privacy Rights Act of 2020 (“CPRA”) requires businesses subject to the CPRA to make certain disclosures regarding the collection, use and disclosure of personal information and provides California residents with specific rights regarding their personal information. This section provides those disclosures and describes rights available to California residents, along with how to exercise those rights with respect to personal information held by us.

Collection, Use, and Disclosure of Personal Information

We have collected the following categories of personal information and used, disclosed, sold or shared such information in the twelve (12) months prior to the effective date of this U.S. Supplement:

Categories of Personal Information We Collected About California Consumers

Identifiers such as name, telephone number, postal address, organization/company name, unique personal identifier, online identifier, IP address, email address, or other similar identifiers
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an Internet website, application, or advertisement
Geolocation data, consisting of approximate location inferred from IP address

Categories of Personal Data Disclosed

We may disclose the categories of personal information identified above with the following categories of recipients:

With Third Party Service Providers Performing Services on Our Behalf. We may share your personal information with our service providers to perform the functions for which we engage them.
With our Affiliates and Subsidiaries. We may share your information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures or companies under common control) for our internal business purposes.
With Law Enforcement, Courts and Other Third Parties for Legal Purposes. We may share information as needed to enforce our rights, respond to a subpoena, regulation, legal process, governmental request or other legal or regulatory process.
To Successors in Interest. We may transfer or assign information that we have collected in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

We may disclose the following categories of personal information to website and data analytics providers. This disclosure may be considered a “sale” of personal information under the CPRA.

Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an Internet website, application, or advertisement
Geolocation data, consisting of approximate location inferred from IP address

Categories of Sources from which We Collect Personal Information

We collect the personal information described above from or through the following categories of sources:

From you directly and indirectly, including when you access/visit the Site, purchase our products, use our products, request a demo of our products or sign up for a free trial, create an account with us, sign up to receive our newsletters and/or marketing communications, sign up for our webinars/events/forums or contact us, or provide us with information at trade shows and other in-person events; and
From third parties, including from individuals making a referral and from our service providers who provide analytics services to help us understand the activity on the Site.

Business or Commercial Purposes for Collecting and Disclosing Personal Information

We collect and disclose the personal information described above for a variety of business purposes including:

to provide the Site to you and to improve the Site;
to provide, operate, improve, and personalize the services we offer, and to give each user a more consistent and personalized experience when interacting with us;
to perform a contract with you or the organization with which you are affiliated;
to provide you with information about products and services that we may provide that we think may be of interest to you;
to provide you with updates about our services and with transactional information;
for customer service and/or support, security (including for authentication purposes), to detect fraud or illegal activities, and for archival and backup purposes in connection with the provision of the Site;
for analytics purposes;
to communicate with you;
to comply with applicable laws or respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process;
to enforce our rights, protect our property or protect the rights, property or safety of others; and
as needed to support external auditing, compliance and corporate governance functions.

We will retain the personal information described above for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable laws or regulation.

California Residents’ Personal Information Rights

The CPRA provides California residents with specific rights regarding their personal information. The below describes such rights and how you may exercise such rights.

Right to Know

You have the right to request that we disclose what personal information we collect, use, disclose, sell or share. Specifically, you may request that we disclose to you the following:

The categories of personal information we have collected about you.
The categories of sources from which the personal information is collected.
The business or commercial purpose for collecting, selling or sharing personal information.
The categories of third parties with whom we disclose personal information.
The specific pieces of personal information we have collected about you.

You may also request that we disclose to you:

The categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each third party to whom the personal information was sold or shared.
The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

Right to Request Deletion

You have the right to request that we delete any personal information about you which we have collected from you. If it is necessary for us to maintain your personal information for certain purposes, we are not required to comply with your deletion request. If we determine that we will not delete your personal information when you request us to do so, we will inform you and tell you why we are not deleting it.

Right to Opt-Out of Sale or Sharing of Personal Information

We do not sell your personal information for monetary consideration. However, if you visit our Site we may use third-party cookies for website analytics and digital advertising purposes. The collection of data through certain third-party cookies for our analytics and digital advertising purposes may be considered a “sale” and “sharing” of personal information under the CPRA. To opt-out of having your information sold and shared with third-party website analytics providers or third party digital services providers for this purpose, visit our “Do Not Sell or Share My Personal Information” cookie consent management tool.

Right to Correct Inaccurate Personal Information

You have the right to request a business that maintains inaccurate personal information about you to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

Right to Limit Use and Disclosure of Sensitive Personal Information

We do not collect your sensitive personal information.

No Discrimination

You have the right not to be discriminated against because you exercised any of your aforementioned rights.

To exercise the rights described above, you must submit a verifiable request to us. You can do so by calling us at 877.725.2755 or by submitting a request online at salasobrien.com/contact. To submit a verifiable request, you will be asked to provide certain information to help us verify your identity. The information we ask you to provide to initiate a request may differ depending upon the type of request, the type, sensitivity and value of the personal information that is the subject of the request, and the risk of harm to you that may occur as a result of unauthorized access or deletion, among other factors.

You may designate an authorized agent to make a request on your behalf by providing the agent with signed written permission to do so.

If we cannot verify your identity or authority to make the request, we will not be able to comply with your request. We will inform you if we cannot verify your identity or authority. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.

Personal Information of Minors

We do not have actual knowledge that we sell or share personal information about minors under the age of 16.

CALIFORNIA “SHINE THE LIGHT” LAW

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please use our “Contact us” form at https://salasobrien.com/contact/.

LINKS TO EXTERNAL WEBSITES / ONLINE SERVICES

Our Site may contain links to third-party websites and/or online services. Access to and use of such third party websites and/or online services is governed by the privacy policies of those third parties – not this Privacy Notice. We are not responsible for the information practices of such third party websites and/or online services.

Some aspects of the Site may allow you to interface with our social media pages, such as Facebook, Twitter and LinkedIn. We will attempt to identify these aspects of the Site to you, for example, by identifying them with the applicable third-party logos or trade names. Information you post, share or otherwise submit to those social media services is subject to the privacy policies of those third party social media services.

SECURITY

We use reasonable security measures designed to protect against unauthorized intrusion to the Site and the access, use, or disclosure of personal information. However, the security of information transmitted through the Internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of data. In order to protect us, you, and your data, we may suspend your use of the Site, without notice if any breach of security is suspected.

DO NOT TRACK

Our Site does not currently take any action when it receives a Do Not Track request. Do Not Track is a privacy preference that you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For details, including how to turn on Do Not Track, visit www.donottrack.us.

CHILDREN

We do not knowingly collect or maintain personal information from any person under the age of thirteen. No parts of our Site are directed to or designed to attract anyone under the age of thirteen.

CONTACT INFORMATION; QUESTIONS AND CHANGES IN INFORMATION

If you have any questions regarding this Privacy Notice or to request changes to your personal information, please use our “Contact us” form at https://salasobrien.com/contact/.

NOTIFICATION OF CHANGES

Any changes to our Privacy Notice will be posted to this page so users are always aware of the information we collect and how we use it. Accordingly, please refer back to this Privacy Notice frequently as it may change.