Effective Date: October 1, 2023

This Privacy Policy describes Rocket Media GmbH’s service “salesfox” information collection and use practices. This Privacy Policy refers to Rocket Media GmbH’s service salesfox as “we,” “us,” or “our,” and refers to the reader as “you” or “user.” If you access or use our website Salesfox.io, web applications, our mobile applications, and/or any of our other sites, products, or services that link to this Privacy Policy (“Services”), you consent to our collection and use of your information as described in this Privacy Policy, including that your information may be transferred to and stored in the United States. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE THE SERVICES.

Salesfox is subject to the regulatory and enforcement authority of the Swiss Federation Law.

The Information We Collect and How We Collect it

To provide the Services, we need to know certain information about you and other users with whom you interact. The types of information we collect depends on how you use the Services. Several categories of information are collected from you, as described below.

A. Information Provided by You

Information that you may provide to us includes, but is not limited to:

• Name
• Email addresses
• Work title
• Profile picture

For example, we may collect information from you when you:

• Log in or create an account
• Create or edit your user profile
• Complete an online form
• Register for a promotion
• Request certain features (e.g., newsletters, demos, and other products)
• Contact customer support
• Provide a user testimonial

You may also choose to provide the following:

• Content. We also store files or other information that you upload or connect to the Services from third-party cloud storage in order to be able to provide you with the features and functionality of the Services.
• Third-party Account Information. When you use a third-party account to sign in to the Services, you provide us with the user ID associated with the third-party system (e.g., Cloud Storage, Identity Management System, etc) that you use. If you sign in with or otherwise connect your account to the Services, you authorize us to collect, store, and use in accordance with this Privacy Policy any and all information available to us through the User Interface and Application Programming Interface, including without limitation any information that you have made public in connection with your account, information that the third-party system shares with us, or information that is disclosed as being shared during the sign-in process. Please see your third-party system’s privacy policy and help center for more information about how they share information when you choose to connect your account.

The decision to provide us with information is optional; however, if you elect not to provide certain information, you may not be able to access certain content or features available through the Services.

B. Information That Is Collected Automatically

We may automatically collect certain information about your use of the Services, including when you use our websites or apps without logging in.Device and Usage information. We may collect information about: (i) the computers or devices (including mobile devices) you use to access the Services; and (ii) how you use the Services. Examples of the information that we may automatically collect and analyze include, but are not limited to:

• IP Address, a.k.a. internet protocol address (your point of access to the Internet). IP address can reveal a web user’s general location (city/state/country).
• Location Information, such as the geo-location of your device. If you use our mobile apps, you will be asked to give the apps access to your mobile device’s geolocation data. If you grant such permission, we may collect information about your precise geolocation information (i.e., your real-time geographic location), and may use that information to customize the Services with location-based information and features. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can withhold permission to access that data or you should be able to turn off the GPS or other location-tracking functions on your device by visiting settings or privacy settings or settings for location services;
• Unique Device Identifiers, such as MAC Address, IDFA, IDFV, IMEI, and Advertising IDs;
• Device Attributes, such as browser types, browser language, and operating system;
• Usage Data, such as information related to the ways in which you interact with the Services, such as: web log data, referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information.

As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

Cookies and Related Technologies. We use “cookies” and other “tracking” technologies for a variety of purposes. The technologies we may use include, but are not limited to: (i) browser cookies; (ii) web beacons; (iii) tracking pixels; and (iv) local shared objects (“flash cookies”). Our uses of cookies and related technologies include, but are not limited to: storing your username; analyzing usage of the Services by collecting the device/usage information discussed above; and customizing the Services. As we adopt additional technologies, we may also gather additional information through other methods.

Cookie Choices. Many browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Services. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.

C. Information from Other Sources

We may obtain information about you from other sources such as marketers, partners, affiliates (e.g. entities under common ownership or control with Salesfox), researchers, and others where they are legally permitted to share such information with us. For example, if you register for Salesfox on another website or use a website that facilitates your activity on Salesfox, that website may provide information about you and your transactions to us.

How We Use the Information We Collect

In general we use the information we collect to provide and administer the Services. More specifically, we might use the information we collect to:

• Provide you with the services and products you have requested, such as to create reports of activity associated with any particular Learning Path;
• Send you notifications of activity through different channels, such as email or push notifications;
• Notify you about new features, products, and special events;
• Provide you with newsletters or marketing communications about our products and services as well as third party products and services we think may be of interest to you;
• Personalize and deliver content on the Services;
• Test changes and develop new features, products and services;
• Generate and review data and reports describing our user base and usage patterns;
• Analyze the accuracy, effectiveness, usability, or popularity of the Services and perform research;
• Resolve disputes and troubleshoot the Services

We may combine information that we collect or receive through the Services with information we obtain from other sources and use it as described in this Privacy Policy.

Aggregated or De-Identified Data – We may aggregate and/or de-identify the information we collect to limit or prevent identification of any particular user or device. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

How We Share Information

We do not rent, sell, or share your information with third parties except as described in this Privacy Policy. We may share your information with the following types of recipients and for the following purposes:

• Corporate Account Users. If you are an authorized user of an account and the account is owned by your employer, then the information you provide to the Services may become accessible to some or all the users of that employer.
• Other Users. If you invite other users to access, use, or edit content you create through the Services (for example, if you invite others to view a Certification, Huddle, or Document), we will make such content available to the individuals you invite.
• Service Providers. We may share your information with third parties that we refer to as service providers to assist us in providing services to you. For example, we might use these third parties to provide search technology, authentication systems, fraud detection, and customer support. Our contracts with service providers contain terms governing their use of your data.
• Safety, Security, and Compliance with Law. We may share your information when we believe in good faith that such sharing is reasonably necessary to investigate, prevent, or take action regarding possible illegal activities or to comply with legal process (e.g. a subpoena). We may also share your information in situations involving potential threats to the physical safety of any person, violations of this Privacy Policy or our user agreements or terms; or to respond to the claims of violation of the rights of third parties and/or to protect the rights, property and safety of Salesfox, our employees, users, or the public. This may involve the sharing of your information with law enforcement, government agencies, courts, and/or other organizations. Note that we may be required to share an individual’s personal data in response to a lawful request by public authorities in order to accommodate national security or law enforcement requirements.
• Business Transactions. As we develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets or the assets disclosed in connection with the due diligence for any such transaction. If Salesfox is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our websites of any change in ownership or uses of your information, as well as any choices you may have regarding your information.
• Consent. We may share your information in other ways and for new purposes if you have asked us to do so or have consented to such sharing. For example, we post customer testimonials on our Services that may identify you if we have received your consent.
• Liability. Pursuant to the Data Privacy Framework, Salesfox remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.

Online Analytics

We may use third-party web analytics services on our Services, such as those of Google Analytics and Heap. These providers use cookie-related technologies (described in the “Information that is Collected Automatically” section above) to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser, and you may also use Heap’s opt out.

Data Retention, Accessing Your Information, and Closing Your Account

Data Retention. We will retain your information for as long as your account is active or as necessary for legitimate business purposes.

Reviewing and Updating Your Account:

We acknowledge the individual’s right to access their personal data. We offer you the ability to access, review and change information associated with your account (such as your profile information, password, billing information, and user preferences) by logging into the Services and visiting your Profile. You can also make a request to modify information that cannot be amended or deleted through the Services by contacting us using the contact information below in Section 11. We will take reasonable steps to permit you to modify or delete information that is inaccurate or incomplete, in accordance with applicable laws.

Closing Your Account

If you wish to close your account, please visit your account settings. Upon your request, we will close your account, and delete your contact information from our active databases. You may also request to close your account by emailing us at the contact information provided below in Section 11. Your account will be closed as soon as reasonably possible based on your account activity and in accordance with applicable law. However, please note that even after you close your account, we may retain and use certain of your information (such as information regarding transactions made through our Services) where permitted by law to prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our user agreements and terms, and comply with legal requirements. If you have shared content or information through our Services with other users, such content or information may still be available to those other users if they have not also deleted it or closed their accounts.

Information We Collect & Process on Behalf of Subscribers. When our subscribers use our Services, we may process and store personal information on their behalf as a data processor. For example, in Salesfox Exercises when a subscriber (or the subscriber’s authorized users) upload documents, we will act primarily as a data processor and process such information on the subscriber’s behalf and in accordance with their instructions. In those instances, the subscriber as the data controller, is responsible for most aspects of the collection and use of the information. If you have any questions or concerns about how personal information is handled in these cases, you may wish to contact the subscriber directly, or refer to their privacy policies.

Email and Direct Marketing Choices

We provide opt-out information in all commercial email messages we send via an “unsubscribe” link. We reserve the right to send one message confirming your opt-out from a messaging program. Please note that it may take us some time to process your requests consistent with applicable law. You do not have the ability to opt-out of transactional or relationship messages (e.g., account notifications) that we send if you are a registered user of our Services or if you have engaged in transactions with us. To opt out of other direct marketing from us, please contact us using the email below in Section 11.

How We Protect Your Information

We employ physical, electronic, and managerial procedures to safeguard and help prevent unauthorized access to your information. We choose these safeguards based on the sensitivity of the information that we collect, process and store and the current state of technology. Although we take measures to safeguard against unauthorized disclosures of information, the Internet and the Services are not 100% secure so we cannot assure you that information we collect or store will be protected from all unauthorized access and thereby used in a manner that is inconsistent with this Privacy Policy.

Linked Sites and Services

Our Services may contain links to third-party websites or apps. Your use of a third party site or app may result in the collection, processing, or sharing of information about you, depending on the site or app. We are not responsible for the content or privacy practices of other websites or services which may be linked on our services. We do not endorse or make any representations about third-party websites or services. The information you choose to provide, or that is collected by these third parties, is not covered by our Privacy Policy. We strongly encourage you to read such third parties’ privacy policies.

Users From Outside the United States

By using the Services, you acknowledge that your information may be transferred to our affiliates and facilities, in the United States or elsewhere, and to the facilities of those third parties with whom we share it as described in this Privacy Policy.

Salesfox Inc. 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. Salesfox Inc. 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. Salesfox Inc. 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.

We offer EU, UK, and Swiss individuals whose personal information has been transferred to us the opportunity to choose whether the personal information it has received is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us using the contact information below in Section 11.

In compliance with the Data Privacy Framework Principles, Salesfox commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Data Privacy Framework. European Union, United Kingdom, and Swiss individuals with Data Privacy Framework inquiries or complaints should first contact us using the contact information below in Section 11.

Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy from time to time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Our use of the information we collect is subject to the Privacy Policy in effect at the time such information is used. If we make any material changes to this Privacy Policy, we will post the changes here and may notify you by email or other means before the change takes effect. Please review changes carefully. Your continued use of our Services following the posting of changes to this Privacy Policy will mean you consent to and accept those changes.

How to Contact Us

If you have any questions or suggestions regarding our Privacy Policy or practices, you may contact us at contact at salesfox.io or via postal mail at Rocket Media GmbH, Salesfox, Hardstrasse 51, 8424 Embrach, Switzerland