Reltio Privacy Policy

Effective Date: February 1, 2024

Reltio, Inc. (“Reltio,” “we,” “our” or “us”) values your privacy. In this Reltio Privacy Policy (“Policy”), we describe how we collect, secure, use, and share information that we obtain from and about customers, prospects and others (“you” or “your”) with whom we engage or identify in connection with our business (such as through our marketing, sales and partner channels).  This includes those entities or persons who visit our websites and/or social media presence, including via , or other websites that include a link to this Policy collectively, the “Sites”).  This Policy also describes such information we may obtain from entities or persons interacting with our products, services and applications made available through our Sites (collectively, the “Services”). It also describes your choices regarding use, access to and correction of such personal information that we may collect. Note that in this Policy we use the term “personal information” interchangeably with the term “personal data.” Reltio owns and operates the Services (or engages third parties to operate aspects of the Services on Reltio’s behalf).

Please read this Policy carefully and in conjunction with our Website Terms and Conditions, and ensure that you understand this Policy and such terms before you start to use our Services. This Policy does not apply to job applicants or Reltio personnel (see our Personnel Privacy Policy). By accessing and using the Services you acknowledge that you have read and understood the content of this Policy.  Accordingly, if you do not agree to the terms of this Policy, do not use the Services.

We reserve the right to update this Policy from time to time. If we make changes, we will revise the date at the top of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Policy whenever you access our Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

IF YOU ARE AN INDIVIDUAL LOCATED IN THE EEA OR THE U.K.: If you are an individual located in the European Economic Area (“EEA”) or the United Kingdom (“U.K.”), this entire Policy applies to you. However, please see the section titled EEA or U.K. Users below, which provides more information about which rights you have regarding the processing of your personal information.

IF YOU ARE A CALIFORNIA RESIDENT: If you are an individual resident of California, this entire Policy applies to you. However, please see the section titled California Users below, which will inform you in detail about our information collection practices and your specific rights.

IF YOU ARE A NEVADA RESIDENT: If you are an individual resident of Nevada, this entire Policy applies to you. However, please see the section titled Nevada Users below, which will also apply to you.

Who We Are and How to Contact Us

For the purposes of EEA data protection law, Reltio is the data controller.  Our address is Reltio, Inc. of 100 Marine Parkway, Suite 275, Redwood Shores, CA 94065, USA. If you have any questions, or want more details about how we use your personal information, you can contact us by emailing legalt@reltio.com or writing to us at 100 Marine Parkway, Suite 275, Redwood Shores, CA 94065, USA, Attn: Legal Department.

This Policy covers the Services found at the Sites and customer production sites. The Sites and customer production sites may contain links to other websites. 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. Please check these policies before you submit any personal information to these third party websites. We do not accept any responsibility or liability for the content of such sites or information practices of such third party websites.

We may collect information about you directly from you and from third parties, as well as automatically through your use of our Sites or Services.

Information We Collect Directly From You

We collect and process information you provide directly to us via the Sites. Personal information submitted through the Sites include the details you submit when you apply for a job with us, fill out a form, communicate with us via third party social media sites, request customer support, participate in a community or otherwise communicate with us. The types of information we may collect include your name, email address, company name, postal address, phone number and any other information you choose to provide. We may require company financial and billing information when contracting with us for services.

Information We Collect Automatically When You Use Our Services

We gather information about your use of the Sites through cookies. We may collect the following information through cookies on the Sites: standard web browser information including browser type, Internet Protocol address, pages viewed on the Reltio websites, and links clicked, date/time stamp, and/or clickstream data to analyse trends in the aggregate and administer the websites.

Information We Collect From Other Sources

We may also obtain personal information from other sources and combine that with the information we collect through our Services for the purposes described below, including lead generation.

We may collect and process information about you directly from you and from third parties, as well as automatically through your use of our Sites or Services.

Information We Collect Directly From You

We collect and process information you provide directly to us via the Sites. Personal information submitted through the Services include the details you submit when you apply for a job with us (which is governed by our Personnel Privacy Policy ), fill out a form, communicate with us via third-party social media sites (including the Sites) or our chatbot, request customer support, participate in a community or otherwise communicate with us. The types of information we may collect include your name, email address, company name, title, role, postal address, country, phone number, emergency contact information for certain events, dietary restrictions, and any other information you choose to provide to us. We may require and collect your company financial and billing information when contracting with us for Services.

Information We Collect Automatically When You Use Our Sites

We gather information about your use of the Sites through cookies. We may collect the following information through cookies on the Sites: standard web browser information, including browser type, Internet Protocol address, pages viewed on the Sites, and links clicked, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the Sites. Please also see the Cookies and Tracking Technologies section below.

Information We Collect From Other Sources

We may also obtain personal information about you from other sources (such as commercial third-party data feeds) and combine that with the information we collect through our Services for the purposes described below, including lead generation.

We use your personal information for the following purposes:

• To enable us to provide you with full access to the Services and Sites.
• To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, to fulfill your requests or orders, and for other customer service purposes.
• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experience while using the Sites or Services.
• For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about our Services or services from Reltio partners or other information we think may interest you.
• To better understand how users – such as you – access and use our Sites and Services, both on an aggregated and individualized basis, in order to improve our Sites and Services and respond to user desires and preferences, and for other research and analytical purposes.
• To send you technical notices, updates, security alerts and support and administrative messages.
• To derive operating and usage scores or ranks based on user profiles and data attributes across our platform which we can use as benchmarks and averages to measure where our services stand relative to our peers.
• Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests.
• Notify you about important changes to the Sites and Services, including changes or updates to our Policy.

Reltio and our partners use cookies or similar technologies to analyze trends, administer the Sites, track users’ movements around the Sites, and to gather demographic information about our user base as a whole.

We use the following types of cookies:

• Strictly necessary cookies: These are cookies that are required for the operation of our Sites and under our terms with you. They include, for example, cookies that make use of certain Services offered through the Sites.
• Analytical/performance cookies: They allow us to recognize and count the number of visitors and to see how visitors move around our Sites when they are using it. This helps us for our legitimate interests of improving the way our Sites work, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies: These are used to recognize you when you return to our Sites. This enables us, subject to your choices and preferences, to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region).
• Advertising cookies: These cookies record your visit to our Sites, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Sites and the advertising displayed on it more relevant to your interests. If you wish to opt out of interest-based advertising click here (or if located in the European Union click here). Please note you may continue to receive generic ads.

Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information, like ad impressions or clicks, and email open rates; (2) measure popularity of Services and associated advertising; and (3) access user cookies.

For more information regarding our cookies, including the precise cookies we use, please see the consent mechanism on the Sites or   (i.e., the pop-window that allows you to opt-out or opt-in to the placement of certain cookies).

Disabling Cookies

You can control and/or delete cookies as you wish – for details, see www.aboutcookies.org. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a website, including ours, and some services and functionalities may not work. You will not be able to opt-out of any cookies or other technologies that are “strictly necessary” for the Services. Where you have not set your permissions, we may also separately prompt you regarding our use of cookies on the Sites or Services.

You can find more information on https://www.reltio.com and her  about the individual cookies we use on our Sites. As a reminder, cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving your experience. Cookies and other technologies may also be used to measure visitors to the Sites and its overall performance, as well as assist us with marketing on other platforms. For a list of the cookies we use, please see this link (also made available here: https://tracker-detail-page.trustarc.com/#/?domain=2469&category=0&locale=en-us).

We may disclose your personal information as follows:

Service Providers

We may disclose your personal information with our contracted service providers who need access to such data to carry out work on our behalf. This includes companies providing the following services for our Sites: hosting, authentication, cyber security, reference checking, anti-fraud, advertising and marketing, subscription services and convention management services.  Without limiting the foregoing, Reltio may also disclose your personal information to confirm the quality of information provided.

Unless described otherwise in this Policy, Reltio does not sell or share any of your personal information with third parties for their promotional or direct marketing purposes.

Business Partners

From time to time, Reltio may enter into agreements with a business partner to offer a product or service. If you participate in the service offering from Reltio and a business partner, Reltio may disclose your personal information with the business partner(s) to the extent necessary for the performance of a contract with you, to deliver the product or service. Business partners’ use of your personal information is governed by their privacy policies. You may choose to not participate or purchase the product or service if you do not wish to have your information disclosed in this manner.

Business Transfers

If we are acquired by or merged with another company, if substantially all of our assets or stock are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the personal information we have collected from you to the other company or as part of that proceeding.

Compelled Disclosure

Reltio reserves the right to use or disclose information, including personal information, if required by law or if Reltio reasonably believes that use or disclosure is necessary to protect Reltio rights and/or to comply with a judicial proceeding, court order, or legal process. In certain situations, Reltio may be required to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

If personal data is to be used in a way not previously disclosed or shared with external parties not covered in this Privacy Policy, you will be provided the opportunity to opt out.

We are required to state the lawful basis under which we process the personal information of our users from the EEA. Accordingly, the lawful basis on which we process your personal information is as follows:

Where your prior consent is required in order for us to process your personal information, for instance in relation to direct marketing in certain jurisdictions, we will obtain and rely on your consent in relation to the processing concerned; or

• Where the processing is necessary for a contract we have with you; or
• Where the processing is necessary for compliance with a legal obligation to which we are subject; or
• For the purposes of the legitimate interests pursued by us in promoting our business, providing our Services to you pursuant to our legal agreements with you, and in ensuring the security, accessibility and improvement of our Services and the development of new services.

Where permitted in our legitimate interest, or with your prior consent where required by law, we will use your personal information for marketing and to provide you with promotional update communications by email about our Services.

You can object to further marketing at any time by selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you by clicking here to remove yourself from the mailing list or contacting us at support@reltio.com.

We are located in the United States, and the personal information that we collect is stored on servers hosted by us or our authorized third-party service providers located in the United States and elsewhere. This means that your personal information will be collected, processed, and stored in the United States or other countries, which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region, such as the EU’s General Data Protection Regulation (“GDPR”).

By sending us personal information, you agree and consent to the processing of your personal information in the United States, which may not offer an equivalent level of protection to that required in other countries (particularly the European Union), and to the processing of that information by us on servers located in the United States, as described in this Policy.

We have implemented safeguards we believe are designed to ensure that the personal information we process remains protected in accordance with this Policy, including when processed internationally or by our third-party service providers and partners. The safeguards we may take in our discretion include, for instance, entering into specific agreements in connection with any onward transfers of personal information. We may implement other mechanisms and take similar appropriate safeguards with our third-party service providers and partners. Further details can be provided upon request.

Reltio 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 regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom (and Gibraltar) and Switzerland, as applicable to the United States in reliance on Data Privacy Framework. Reltio has certified to the Department of Commerce that it adheres to the Data Privacy Framework Principles with respect to such information. If there is any conflict between the terms of this Policy and the Data Privacy Framework Principles, such terms of the Data Privacy Framework Principles shall govern. To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/s/ and https://www.dataprivacyframework.gov/s/participant-search.

Reltio is responsible under the Data Privacy Framework for the processing of personal information it receives and subsequently transfers to a third party acting as an agent on our behalf. Reltio complies with the Data Privacy Framework Principles for all such onward transfers of personal information from the EU, the United Kingdom (and Gibraltar) and Switzerland, including the onward transfer liability provisions.

With respect to personal information we receive or transfer pursuant to the Data Privacy Framework, Reltio is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Reltio may be required to disclose your personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Reltio commits to referring unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. 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://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you. For complaints regarding the EU-U.S. DPF, the UK Extension to the EU-U.S DPF, and the Swiss-U.S. DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.

Reltio’s privacy practices we describe in this Policy also comply with the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure the protection of personal information transferred among participating APEC economies. More information about the APEC framework can be found here.

Reltio also enters into Data Processing Agreements or Standard Contractual Clauses with our customers, as required to comply with applicable laws.

Individuals who have registered to use our Services and others who access our Sites, including individuals in the EEA and the United Kingdom, have rights in relation to their personal information which we process on behalf of our customers. You may attempt to exercise your rights by emailing us at legal@reltio.com. We will respond to your request within a reasonable timeframe.

All individuals who access our Sites or Services have the right to:

• Request access to your personal information.
• Request that any incorrect personal information about you that we are processing be rectified.
• Request that we erase the personal information concerned.
• Withdraw your consent at any time where we are processing personal information relating to you on the basis of your prior consent to that processing, after which we shall stop the processing concerned.

Lodge a formal complaint with the Information Commissioner in the United Kingdom (or your local EEA supervisory authority if you live outside the UK) if you have a complaint about any processing of your personal information being conducted by us.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Data Privacy Framework website, EEA, UK and Swiss citizens may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Individuals in the EEA have the right to request that we temporarily or permanently stop processing some or all of your personal information.

Reltio acknowledges that you have the right to access your personal information. For data stored in the Reltio Cloud, we have no direct relationship with the individuals whose personal information we process. An individual who seeks access, or who seeks to correct, amend, restrict, object, or delete inaccurate personal information located in the Reltio Cloud and contacts Reltio, will be routed to the appropriate Reltio customer (i.e. the data controller) to address the request. If requested to remove personal information, we will respond within a reasonable timeframe and route the request to the appropriate Reltio customer for processing.

Social Media and Joint Controllership for Individuals in the EEA

Sometimes, Reltio acts as a ‘joint controller’ with certain third parties, namely certain social media sites. When Reltio and a partner act as joint controllers, you (as a “data subject”) may exercise your rights against Reltio and/or the third party. For a list of our joint controller relationships, please contact us at legal@reltio.com.

Facebook

In order to market our Services and stay in touch with users, we maintain a Facebook page and use Facebook Pixel (“Facebook Products”). With respect to our use of these Facebook Products, we are jointly responsible with Facebook Ireland for the processing activities (“Joint Processing”):

Facebook Ireland Ltd.,

4 Grand Canal Square, Grand Canal Harbor

Dublin 2, Ireland

Information about the personal data that Facebook collects from you, as well as how and why Facebook processes it, can be found at https://www.facebook.com/about/privacy. Reltio and Facebook have entered into an agreement in order to determine the respective responsibilities for compliance with our obligations in connection with the Joint Processing within the meaning of the GDPR. This joint controller agreement, which sets out the reciprocal obligations, is available here.

Please note that Facebook Ireland is responsible for enabling data subjects’ rights under Articles 15-20 of the GDPR with regard to the personal data stored by Facebook Ireland in connection with the Joint Processing, as further described in Facebook’s privacy policy. To exercise your rights, please go to your Facebook settings or contact Facebook as set forth in its privacy policy.

Please note that some processing by Facebook Ireland Ltd. will also take place in the United States by Facebook Inc.

Representative in the U.K.

Pursuant to Article 27 of the UK GDPR, Reltio, Inc. has appointed Steve Debenham as its UK GDPR representative in the UK. You can contact Mr. Debenham regarding matters pertaining to the UK GDPR by: legal@reltio.com

We will retain personal information we process on behalf of you for as long as we believe we need to provide Services to you and we may retain such information for a further period after this time as necessary and relevant to our legitimate interests, any agreement with you, and in accordance with applicable legal obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to enforce the relevant terms of agreement or to identify, issue or resolve legal proceedings.

We may retain a record of your stated objection to the processing of your personal information, including in respect of an objection to receiving marketing communications, for the sole legitimate purpose of ensuring that we can continue to respect your wishes and not contact you further, during the term of your objection.

We take reasonable steps, including physical, technical and organizational measures, to protect your personal information from unauthorized access and against unlawful processing, accidental loss, destruction and damage. Unfortunately, the transmission of information via the internet is not completely secure. We cannot guarantee the security of your personal information submitted to us.

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. If you have any questions about the security of your personal information, you can contact us at security@reltio.com.

Our Sites and Services are not designed for children under 16 and we do not target our Services to children. If we discover that a child under 16 has provided us with personal information, we will delete such information from our systems.

We use social media plug-ins (e.g., Facebook, LinkedIn, Instagram, YouTube, and Twitter). These features may collect your IP address and/or other information as set forth in each social platform’s privacy policy, which page you are visiting on our Sites or Services, and may set a cookie to enable the feature to function properly. Reltio also has a presence on some social media platforms, including Facebook, LinkedIn, Instagram, YouTube, Twitter and others. Through our accounts on social medial platforms, we may in some instances collect personal information when you interact with the Reltio accounts or otherwise communicate with us through those accounts. Any information that you post on social media is governed by each social platform’s privacy notices, and any personal information that we collect via our social media accounts will be processed in accordance with this Policy.

This California Users section (“CCPA Notice”) supplements the information contained in the Policy and applies solely to all visitors, users, and others who reside in the State of California (“Consumers”). We have created this CCPA Notice in order to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”).

Categories of Information We Collect

Our Services collect “personal information,” as that term is defined in CCPA: information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or device. In particular, within the last twelve (12) months, we have collected the following categories of personal information from Consumers:

• Identifiers, such as a real name, unique personal identifier, online identifier, IP address, email address, or account name
• Personal information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e)), such as a name, signature or telephone number
• Protected classification characteristics under California or federal law, such as age, ancestry and national origin, genetic information, marital status, race, religion or gender
• Commercial information, such as records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
• Biometric Information, such as a fingerprint or faceprint
• Internet or other similar network activity, such as browsing history or information on a Consumer’s interaction with a website or application
• Geolocation data, such as physical location
• Sensory Data, such as a photograph, or a video or audio recording
• Professional or employment-related information
• Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)
• Inferences drawn from other personal information, such as profile information reflecting a person’s preferences
• Sensitive Personal Information

We may also collect the following information, which does not fall within the definition of “personal information” that we use in the Policy:

• Publicly available information from government records.
• Deidentified or aggregated Consumer information.
• Certain other information that is already regulated by other laws or regulations.

As explained in more detail here, we obtain the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, when you sign up on the Services. This includes the following categories of personal information:
  • Identifiers
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • Other personal information
• Indirectly. For example, from observing your actions on our Services, including by the use of cookies or from third parties. This includes the following categories of personal information:
  • Internet or other similar network activity
  • Inferences drawn from other personal information
  • Geolocation data
• By observing Consumers’ behavior through their activity on the Services. This includes the following categories of personal information:
  • Internet or other similar network activity
  • Inferences drawn from other personal information

Use of Personal Information

We may use, or disclose the personal information (as defined by CCPA) we or our service providers collect for one or more of the following business purposes:

Reltio will not collect additional categories of personal information (including sensitive personal information) or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Reltio does not collect protected classifications characteristics under California or federal law, such as biometric information, sensory data, professional or employment-related information, or non-public education information.

Disclosure of Your Personal Information

Reltio may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the services for us.

As explained in more detail above, we share your personal information with certain categories of third parties who assist us in providing our Services.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Reltio has disclosed the following categories of personal information for a business purpose:

• Identifiers
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
• Internet or other similar network activity
• Geolocation data
• Inferences drawn from other personal information
• Other personal information as may be necessary

In addition to disclosures required by law or order, we disclose your personal information for a business purpose to the following categories of service providers or third parties:

• Companies that do things to help us provide the Services: hosting service providers, user engagement and email service providers, certain analytics providers, payment service providers, communication tools, identity verification providers, reservation deposit providers;
• Professional service providers, such as auditors, lawyers, consultants, accountants and insurers.

Your Rights and Choices

The CCPA provides Consumers with specific rights regarding their personal information, provided that we are able to verify their identities as explained below. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive your request and verify your identity (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request and verify your identity (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) under certain circumstances, for example to:

1. Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another Consumer to exercise that Consumer’s right of free speech, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Enable solely internal uses that are reasonably aligned with Consumer expectations based on your relationship with us.
7. Comply with a legal obligation.
8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Correction

You have the right to have corrected any inaccurate personal information that we have collected and retain.

Exercising Access, Data Portability, and Deletion Rights

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may submit a verifiable Consumer request related to your personal information. You may also make a verifiable Consumer request on behalf of your minor child.

An authorized agent is a natural person or a business entity registered with the Secretary of State that a Consumer has authorized to act on his or her behalf. When a Consumer uses an authorized agent to submit a request to know or a request to delete, we may require that the Consumer provide the authorized agent written permission to do so and verify their own identity directly with us, unless the Consumer has provided the authorized agent with a valid power of attorney. We may deny a request from an agent that does not submit proof that they have been authorized by the Consumer to act on his or her behalf.

To exercise the access, data portability, correction, and/or deletion rights described above, please submit a verifiable Consumer request to us by either:

Phone:  833-977-7720

Email:  legal@reltio.com

You may only make a verifiable Consumer request for access or data portability twice within a twelve (12) month period. The verifiable Consumer request must:

• Provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm that the identified personal information relates to you.

Submitting a verifiable Consumer request does not require you to register with us. Please note that the methods for verification are set forth in the CCPA, which also requires us to consider a number of factors, such as type, sensitivity and value of the personal information or risk of harm posed by unauthorized access or deletion, on a case-by-case basis.

We will only use personal information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.

We will deliver our written response by mail or electronically, at your option (as indicated in the Consumer request).

Any disclosures we provide will only cover the twelve (12) month period preceding our receipt of the verifiable Consumer’s request. If applicable, our response we provide will also explain the reasons we cannot comply with a request. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Sell and Share; Non-Discrimination

Under the CCPA, “personal information” includes information that is not necessarily directly tied to an individual’s identity but may be associated with a device. This includes identifiers such as IP addresses, web cookies, web beacons, and mobile Ad IDs. In many cases, these types of information do not directly identify you, but they are unique identifiers that could be linked to you and therefore covered by the CCPA. The term “sell” is broadly defined to include not just selling in exchange for money, but also disclosing personal information (including information that does not directly identify an individual as described above) in exchange for anything of value, which is not limited to the exchange of money. Under the CCPA’s broad definition of “sell,” which includes even the common flow of information in the digital analytics and advertising ecosystem, Reltio does “sell” personal information. Like most companies that operate websites, Reltio uses online analytics to measure the ways users engage with our Services and to provide targeted marketing. These analytics, in turn, inform how we perform online advertising.  As such, Reltio “shares” (as defined by CCPA) your personal information for cross-contextual behavioral advertising.  In order to provide these analytics and facilitate online advertising, we use third-parties that collect device identifiers and place tags, cookies, beacons, and similar tracking mechanisms on our digital properties and on third-party digital properties as set forth in our Cookie Notice link.  You may opt-out of our “selling” and “sharing” by accessing the cookie settings,   or by contacting us.

We will not discriminate against you in a manner prohibited by the CCPA because you exercise your CCPA rights. While you may request to delete your personal information under CCPA, such deletions may affect our ability to offer the Services to you.

Do Not Track and GPC

We may tracks users’ use of the Services, but do not track users across third-party websites. We will respond to browser Do Not Track (DNT) signals. For more information on DNT settings generally, please visit https://allaboutdnt.com.  We will honor the global privacy control signal.

We do not sell your personal information within the scope of, and according to the defined meaning of, a “sale” under NRS 603A.

For questions regarding this Policy or the information practices of the Sites or Services please contact Reltio Customer Care at legal@reltio.com.

You can also send an inquiry to:

Reltio Customer Care
100 Marine Parkway, Suite 275
Redwood Shores, CA 94065, USA