Effective Date: August 1, 2020
Content Square SAS (“Content Square“, “we“, “our” or “us“) develops and provides customer experience analytics services.
Such services allow our customers to recreate a web or app session showing their end-users’ interactions on their website or mobile app, to gain meaningful insights into such interactions, and use them to create exceptional experiences.
We provide such services through the Content Square website (available at www.contentsquare.com, “Site”), and the Content Square platform available therein (“Platform”; and collectively – “Services”).
We respect the privacy of our Site visitors (“Visitors”), our customers and their personnel (“Customer”; and collectively - “you”), as well as our Customer’s end-users (“End-Users”), and are strongly committed to making our practices regarding their personal data transparent and fair.
- Data Collection
- Data Uses
- Data Location and Retention
- Data Sharing
- Cookies and Tracking Technologies
- Data Security
- Data Subject Rights
- Children’s Privacy
- Data Controller/Processor
- Additional Notices
You are not legally required to provide us with any Personal Data (defined below), but without it we will not be able to provide you with the full range of Services or with the best user experience when using our Services.
1. Data Collection
We collect Personal Data regarding our Visitors and Customers. We also collect Personal Data of other individuals, on our Customers’ behalf as they use our Services. Such data is typically collected and generated through the Visitor’s or Customer’s interaction with or use of our Site, Platform or Services, directly from such Visitor or Customer, from our Customers regarding their End-Users, or from other third parties.
In the below, we specify categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data”) we collect through our Services:
1.1 Data Collection via the Content Square Site, Platform and other means
Data Collected or Generated
When you visit, interact with or use our Site or Platform, we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of third-party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).
Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser type, locale and language settings, the cookies and pixels installed on such device, session logging, heatmaps and scrolls, screen resolution, ISP, referring or exit pages, and date/time stamps, and the activity (clicks, browsing, zooms and other interactions) of Visitors and Customers in connection with our Site or Platform.
Data Received from Customers or Visitors
Data Received from Third Parties
We may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from business partners or services provides, and through the use of tools and channels commonly used to connect between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn.
1.2 Data Collection via Customer’s use of the Content Square Services
Customers may use our Services and in doing so transfer End-User data to our cloud-based Services, and analyze such data via our Services. This includes:
a. Technical information and aggregated usage data, which may contain the End-User's type and version of operation system, usage length, phone model, country, screens visited in the Customer’s site, touch gestures performed in the site or mobile application, scrolling activity and any other actions the End-User may have performed during their use of the Customer’s website or mobile application;
b. End-User's partially-hashed IP address.
c. “cookies”, anonymous identifiers and other tracking technologies (see as detailed in Section 5 below)
Except for the foregoing, and, unless otherwise agreed with Content Square in writing, Customers are not to provide Content Square with any Personal Data regarding their End-Users. In particular, Customers must refrain, and are contractually prohibited from providing Content Square with any Personal Data of children under the age of 16; any health, financial, or insurance data; or other data which is subject to specific regulatory or statutory protection regimes (including "special categories" of data under the EU GDPR).
It is each Customer’s sole responsibility to mask the fields and HTML in its website or application which may include Personal Data, to take into account the sensitivity of the applicable End-User data which may be made available by Customer’s End-Users in any such field or webpage, and the nature of our Services. The End-User data will be available to Content Square for the duration of the determined retention period.
If you choose to provide us with any Personal Data regarding your End-Users, you must receive the End-User's explicit consent for such use.
Unless specifically requested by Customer, our Services will not store the End-User's full IP address, or any keyboard strokes by the End-User. The Services do not track the End-User's activity across applications/services that do not use the Services and will not collect any passwords entered to unlock the End-User's device.
2. Data Uses
We use Personal Data as necessary for the performance of our Site, Platform and Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and sales offerings, understanding how our Site, Platform and Services are used, optimizing our marketing and advertising services, customer service and support operations, and protecting and securing our Visitors, our Customers, ourselves and our Services.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
Specifically, we use Personal Data for the following purposes:
2.1 Data collected via the Content Square Site and Platform
a. To authenticate the identity of our Customers, and to allow them access to our Platform and Services;
b. To provide our Visitors and Customers with assistance and support;
c. To manage and deliver advertisements more effectively, including contextual, behavioral, and interests-based advertising based on the Visitor’s or Customer’s activity, preferences or other data available to us or to our business partners, including for retargeting purposes;
d. To create audience-related insights for optimizing ad performance;
e. To contact our Visitors and Customers with general or personalized messages and communications, as further described under Section 6 below;
f. to facilitate, sponsor and offer certain events and promotions;
g. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
h. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
i. To comply with any applicable laws and regulations.
2.2 Data collected via Customer’s use of the Content Square Services
a. To facilitate, operate, and provide our Services;
b. To further develop, customize and improve the Services and general user experience, based on common or personal preferences, experiences and difficulties;
c. To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
d. To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
e. To comply with any applicable laws and regulations.
3. Data Location and Retention
Data Location: Your Personal Data may be maintained, processed and stored by our authorized affiliates and Service Providers (defined below) in the United States of America (U.S.), the State of Israel, France, UK and other jurisdictions, including the European Union, as necessary for the proper delivery of our Services, or as may be required by law.
Content Square has offices in Israel, which offers an adequate level of protection for the Personal Data of EU Member State residents.
Data Retention: We retain Visitors’ and Customers’ Personal Data for as long as reasonably necessary in order to maintain and expand our relationship with them and to provide them with our Services.
We retain our Customer personnel’s Account Data in accordance with the instructions of their organization (our Customer), or for as long as their account is active, and we have not been notified otherwise, or as long as we consider necessary for the purposes described herein.
We will also retain your Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.
Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at email@example.com.
4. Data Sharing
Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that it is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own, namely - hosting, data analytics, consulting, development, support, marketing and advertising, data and cybersecurity, payment processing, user engagement, e-mail distribution and monitoring, text messaging and session recording; as well as our business, legal and financial advisors (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
Currently, we use the Service Providers listed at https://contentsquare.com/privacy-center/subprocessors/ as sub-processors as part of the services provided to our customers.
Sharing Personal Data with our Customers: We may share the Personal Data (including Account Data) of our Customer’s personnel, and Personal Data of our Customer’s End-Users, with such Customer. Content Square is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of the Customer, that itself acts as the “Data Controller” of such data (as further described in Section 10 below).
Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Content Square, any of our Customers or their End-Users, or any members of the general public.
For the avoidance of doubt, Content Square may share your Personal Data in additional manners, such as pursuant to your explicit approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
5. Cookies and Tracking Technologies
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies that help us provide, secure and improve our Services, personalize your experience and monitor the performance of our activities and campaigns.
A cookie is a small text file that is placed, for example, to collect data about activity on our Site and Platform. Some cookies and other similar technologies serve to recall Personal Data, such as an IP address, that was previously indicated by the Visitor.
A list of the cookies we use can be found here: https://contentsquare.com/privacy-center/cookie-policy/
Service Communications: We may contact Customers with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-reset notices, etc. We may also send you notifications, messages and other updates. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
Notifications and Promotional Communications: We may also contact Visitors and Customers with promotional messages (such as newsletters, special offers and sales, new product announcements, etc.) or any other information we think they will find valuable. We may provide such notices through any of the contacts means available to us (e.g. phone or e-mail), through the Services, or through our marketing campaigns on any other sites.
If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to DSR@contentsquare.com, changing your communications preferences in your account, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
7. Data Security
In order to protect your Personal Data held with us and our Service Providers, we use industry-standard physical, procedural and electronic security measures. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.
8. Data Subject Rights
8.1 Data collected via the Content Square Site and Platform (Visitors & Customers)
If you wish to exercise your rights under any applicable law (including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA)), such as the right to request access to, and rectification or erasure of your Personal Data held with Content Square, or to restrict or object to such Personal Data’s processing, or to port such Personal Data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at DSR@contentsquare.com.
Please note that once you contact us by e-mail regarding your data subject rights, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
8.2 Data collected via the Content Square Services (Customer End-Users)
If an End-User would like to make any requests or queries regarding Personal Data which we process on our Customer’s behalf, we encourage them to contact such Customer directly. Should such requests or queries be made to Content Square instead, we may forward them to the Customer we believe to be relevant.
9. Children’s Privacy
Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will prohibit and attempt to block such use and will make reasonable efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at DSR@contentsquare.com.
10. Data Controller/Processor
Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller” (under the CCPA, the “business”), who determines the purposes and means of processing; and the “Data Processor” (under the CCPA, the ’service provider”), who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
If and End-User would like to make any requests or queries regarding Personal Data (see Section 8) we process on our Customer’s behalf, please contact such Customer directly.
11. Additional Notices
Questions, Concerns or Complaints: If you have any comments or questions about this Policy or if you have any concerns regarding your Personal Data, please contact Content Square’s appointed DPO at firstname.lastname@example.org.
Content Square SAS been designated as Content Square’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Content Square may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please send an email to email@example.com, or by postal mail to 3/5 boulevard de la Madeleine, 75001 Paris, France. If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.