provide, maintain, and improve our Service to you;
notify you about changes to our Service;
allow you to participate in interactive features of our Service when you choose to do so;
provide customer support in relation to the Service;
gather analysis or valuable information so that we can improve our Service;
monitor the usage of our Service;
detect, prevent, and address security or other technical issues related to the Service;
answer your queries and contact requests;
for the purposes outlined in our Recruitment Portal Privacy Notice;
administer events and initiatives and facilitate your participation either as a participant or speaker;
administer, manage, and develop our business relationships;
internally train our personnel and improve our internal standards and practices; and
market to you and provide you with news, special offers and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you where we have your consent to do so. We may also use your Personal Data to contact you with marketing or promotional materials based on our legitimate interest in engaging in direct marketing. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

Our Service also collects and uses sales information, including at the employee level, to provide metrics and sales performance support. Accordingly, we collect and process information about sales performance at the employee or sales representative level on behalf of our clients, which is processed at both the individual sales performance level and at aggregate levels. This information is used by our clients pursuant to their own privacy policies and procedures to support key sales and other operational objectives, and in this context our clients are the data controllers of Personal Data processed as part of our Services.

We process Personal Data provided by prospective and existing Varicent clients in the course of doing business such as name, contact information, and other business details such as job title, employer, areas of business interest, and email correspondence. We also process audio and video information when meetings are recorded with consent of the company or individual being recorded. Such Personal Data may be processed and analyzed by third party service providers using software and algorithms to enhance our business relationships and exercise our legitimate interests to train personnel and improve our internal standards and practices. Examples of the foregoing include but are not limited to enabling automatic notetaking, deal tracking, evaluating the strengths of our interactions with our customers, the development of proposals and communications, and ensuring consistent messaging about our offerings. Individuals and companies who have provided consent can modify or withdraw it at any time by providing notice as provided in the “Contact Us” section below. If you are an existing customer of Varicent, the contents of our audio and video recordings shall be processed by us only for the purposes of managing and improving our business relationship with your specific account and training Varicent personnel related to your business. Such recordings are deemed to be Confidential Information under your Cloud Services Agreement external to the Cloud Service and any Customer Data located therein and shall be subject to further notice(s) we may provide to your company. Notwithstanding the foregoing, our call recording providers may use short, anonymized snippets of recordings from parties we speak with to train machine learning engines (ex. speech to text) within their product. We do not require external participants to call to consent to being recorded.

Varicent also frequently organizes and participates in events and initiatives. In such cases, this Privacy Policy applies to both participants and speakers, together with any other supplementary information or notices that are provided in relation to each event or initiative. During such activities we may process Personal Data such as business contact information, telephone number and/or location. Where a hospitality service is provided, we may process Personal Data such as dietary requirements or personal disabilities to the extent permitted by law. If the activity is recorded, we may also process pictures and videos of you. In such cases, this material may be used later by Varicent for further compatible purposes in accordance with the notices you receive at the location of recording. We may also obtain data such as attendee lists from third parties such as event organizers where the activity is sponsored by Varicent. In such cases, the privacy policy of those third parties to whom you provided your personal data will apply to you.

We may also collect Usage Data on how the Service is accessed and used. This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. Except to the extent otherwise outlined in a separate agreement with our business clients, we are the Data Controller of Usage Data.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are stored on your device and consist of two different types; session and persistent. Session cookies enable us to recognize your actions during the browsing session, are temporary and expire when you close your browser and are not stored beyond this. Persistent cookies remain stored on your device after you close your browser until they expire or when you delete them. Other tracking technologies are also used such as beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

Name	Cookie	Purpose
Cookie Settings	Consent, necessary analysis	This cookie allows us to remember the cookie settings Users have enabled on our site.
Google Analytics	Non-essential persistent cookies	These cookies are used to: give us insight into how people use our Service in order to help us improve the Service; and provide estimates of the number of visitors to our Service, including the source and patterns of the User traffic, in order to see how we can enhance your experience when visiting the Service. We will only use Google Analytics where we have your prior consent to do so, which can be given via the cookie banner on our Service.
Intercom	Non-essential persistent cookies	This cookie allows us to provide you with real-time support via a live chat service.

Where you are located in the EEA, Switzerland and the United Kingdom, your Personal Data may be transferred to - and maintained on – our computers located outside of the EEA, Switzerland or the United Kingdom or to other recipients located in countries outside of the EEA, Switzerland and the United Kingdom which may not have data privacy laws equivalent to those in of the country in which you are located. By submitting your Personal Data to us, you consent to the transfer of your Personal Data to us, and the other recipients described in this Privacy Policy that are located in countries outside of the country in which you are located. You may withdraw your consent at any time. The withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal, nor the lawfulness of processing based on other legal bases.

Disclosures to Service Providers and Other Third Parties
We may share Personal Data with our third-party service providers that support our products and services, or other operational needs, as well as assist us in analyzing how our Service is used and assisting us in fulfilling the purposes outlined in this Privacy Policy. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose, pursuant to agreements entered into with Service Providers that comply with applicable data privacy laws, including, to the extent applicable, the GDPR”, the CCPA, and other laws that are similar, equivalent to, successors to, or that are intended to supplement the GDPR and CCPA. We may have liability to you in case of failure to comply with the law or this policy in handling onward transfer of your Information to third parties.

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

We may also share Personal Data with third parties to comply with legal obligations; when we believe in good faith that an applicable law requires it; at the request of governmental authorities or other third parties conducting an investigation; to detect and protect against fraud, or any technical or security vulnerabilities; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of our business, third parties, visitors to our websites, or the public. We may also share Personal Data with any person to whom we transfer any of our rights or obligations under any agreement, or in connection with a sale, merger, or consolidation of our business or other transfer of our assets, whether voluntarily or by operation of law, or who is otherwise deemed to be our successor or transferee.

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. We have implemented reasonable information security policies and technical and organizational procedures commensurate with the sensitivity of the information and commercially acceptable standards to protect your Personal Data. However, we cannot guarantee its absolute security. If we collect Personal Data as confidential information under the scope of a non-disclosure agreement with the company you represent, we will comply with the protective requirements under such agreement unless we have your permission to act otherwise.

The right to access, update or delete the Personal Data we have on you;
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
The right to object. You may have the right to object to our processing of your Personal Data in certain circumstances. You always have the right to object where we are processing your Personal Data for direct marketing purposes;
The right of restriction. You have the right to request that we restrict the processing of your Personal Data;
The right to data portability. You have the right to be provided with a copy of the Personal Data we have on you in a structured, machine-readable, and commonly used format;
The right to withdraw consent. You also have the right to withdraw your consent at any time where we have relied on your consent to process your Personal Data;
The right not to be subject to automated decision-making. You also have the right not to be subject to a decision based solely on automated processing of Personal Data, including profiling, which produces legal effects concerning you or similarly significantly affecting you.

Your Data Protection Rights Under Certain U.S. State Laws
This U.S. State Privacy Rights and Disclosure section addresses legal obligations and rights specified in the CCPA, and similar U.S. state laws. These obligations and rights apply to residents of certain U.S. State laws and to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a consumer, household, or device. It does not include deidentified or aggregate information, or public information lawfully available from governmental records.

Category of Personal Data

Sources from which Personal Data was collected or obtained

Purpose of collection

Categories of entities with which Personal Data was shared

Address and other identifiers – such as name, postal address, email address, account name, Social Security number, job title, job function, company, telephone number, driver’s license number, passport number, or other similar identifiers

Directly from you

From your employer

From other third parties, including clients, business contacts, data brokers and third-party sales software and systems

From publicly available information

To provide and operate the software and services

to contact you to discuss the services or products you receive from us

to respond to any questions or concerns you have raised

to deal with administrative matters such as invoicing, renewal or to audit performance management metrics and transactions

to perform services on our behalf, such as customer service, processing or fulfilling orders, and processing payments

to comply with applicable law, company policies or carry out related compliance checks and controls

to verify your identity or for other fraud and/or crime prevention

to debug errors in our systems

for marketing and advertising purposes

for internal research, analytics and development

Your employer

Professional advisers, including accountancy and legal firms, in order to provide us with advice;

Service providers, including to provide and support our data management, analytics, security, and storage systems;

Third party business partners to your employer.

Unique and online identifiers – such as IP address, device IDs, or other similar identifiers

Directly from you

From your employer

To provide and operate the software and services

to comply with applicable law, company policies or carry out related compliance checks and controls

to verify your identity or for other fraud and/or crime prevention

to debug errors in our systems

for marketing and advertising purposes

for internal research, analytics and development

Service providers, including to provide and support our data management, analytics, security, and storage systems;

Financial information

Directly from you

From your employer

From other third parties, including clients, business contacts and third-party sales software and systems

To provide and operate the software and services

to contact you to discuss the services or products you receive from us

to respond to any questions or concerns you have raised

to deal with administrative matters such as invoicing, renewal or to audit performance management metrics and transactions

to perform services on our behalf, such as customer service, processing or fulfilling orders, and processing payments

to comply with applicable law, company policies or carry out related compliance checks and controls

to verify your identity or for other fraud and/or crime prevention

to debug errors in our systems

for marketing and advertising purposes

for internal research, analytics and development

Your employer

Professional advisers, including accountancy and legal firms, in order to provide us with advice;

Service providers, including to provide and support our data management, analytics, security, and storage systems;

Third party business partners to your employer.

Commercial information – such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

Directly from you

From your employer

From other third parties, including clients, business contacts and third-party sales software and systems

From publicly available information

To provide and operate the software and services

to contact you to discuss the services or products you receive from us

to respond to any questions or concerns you have raised

to deal with administrative matters such as invoicing, renewal or to audit performance management metrics and transactions

to perform services on our behalf, such as customer service, processing or fulfilling orders, and processing payments

for marketing and advertising purposes

for internal research, analytics, and development

Your employer

Professional advisers, including accountancy and legal firms, in order to provide us with advice;

Service providers, including to provide and support our data management, analytics, security, and storage systems;

Third party business partners to your employer.

Education or other professional information Directly from you

From your employer

From other third parties

From publicly available information

To provide and operate the software and services

for marketing and advertising purposes

for internal research, analytics and development

Your employer

Professional advisers, including accountancy and legal firms, in order to provide us with advice;

Service providers, including to provide and support our data management, analytics, security, and storage systems;

Third party business partners to your employer.

Geolocation Information

Directly from you

From your employer

To provide and operate the software and services

to verify your identity or for other fraud and/or crime prevention;

Service providers, including to provide and support our data management, analytics, security, and storage systems;

Inferences drawn from CCPA PI – such as individual profiles, preferences, characteristics, behaviors

Directly from you

From your employer

From other third parties

From publicly available information

To provide and operate the software and services

for marketing and advertising purposes

for internal research, analytics, and development

Your employer

Professional advisers, including accountancy and legal firms, in order to provide us with advice;

Service providers, including to provide and support our data management, analytics, security, and storage systems;

Third party business partners to your employer.

Your Right to Request the Deletion of Personal Data and Other Rights
Depending on the jurisdiction you reside in; you may be able to exercise rights similar to those outlined in Section 10. Upon your request, we will delete the Personal Data we have collected about you, except for situations when that information is necessary for us to: provide you with a product or service that you requested; perform a contract we entered into with you; maintain the functionality or security of our systems; comply with or exercise rights provided by the law; or use the information internally in ways that are compatible with the context in which you provided the information to us, or that are reasonably aligned with your expectations based on your relationship with us.

For requests for access or deletion of Personal Data Varicent collects and processes directly as a Data Controller, we will first acknowledge receipt of your request. We will provide a substantive response to your request as soon as we can, generally within 30 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances as allowed by applicable law. If we expect your request is going to take us longer than normal to fulfill, we’ll let you know.

Varicent complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Varicent has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Varicent has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Varicent commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in United States, the European Union, the United Kingdom, and/or Switzerland (as applicable). If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

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Why Varicent

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Sales Performance Management

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High-Tech

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