SYSTEM PAL Services and Contact Data
If you believe personal information pertaining to you has been submitted to SYSTEM PAL by a Subscriber and you wish to exercise any rights you may have to access, correct, amend, or delete such data, please contact us at [email protected]
We will respond to your request as soon as reasonably practicable, but no later than thirty (30) calendar days after your written request.
How we May Use Subscriber Data (Excluding Contact Data)
Subaccount Users and Ownership of Contact Data
Upon subscribing to our Services, a Subscriber designates individual users who will be provided with access to SYSTEM PAL (a “subaccount user”). Each subaccount user maintains his or her own Contact Data and cannot access the Contact Data of another subaccount user; provided however, that a Subscriber ultimately owns and controls all Contact Data created by any subaccount user.
How Contact Data is Collected through the Use of Our Services
Through using our Services, a Subscriber collects Contact Data in various ways. Some examples include:
• manual entry of information to create a Contact’s basic profile in the CRM Software;
• contact capture tool that automatically populates a Contact’s basic profile in the CRM Software;
• device fingerprinting that monitors certain online behaviors of a Contact;
• IP address; and cookies.
Categories of Information Our Subscribers May Collect through the Use of Our Services
When utilizing our Services, a Subscriber may collect Contact Data about individuals, some of which may consist of personal information. Some examples include:
• Basic Profile Data. User id, foreign id, name, email address, personal and business phone numbers, fax numbers, birth date, status of Contact (active client, former client, cold call), gender, home and business mailing addresses (including city, state, zip code, country), job title, employer name, avatar, the internet service provider, URL. This generally constitutes a Contact’s basic profile with respect to our Services.
• Behavioral Data. Using device finger printing and other analytics (including IP address identification and cookies), SYSTEM PAL tracks Contact Data related to a Contact’s profile creation and certain Contact behaviors over time by collecting information such as:
o browser name, device operating system, computer platform, browser version, and browser plugins;
o device screen size, color profile, color depth; and pixel ratio;
o whether the device is cookieEnabled;
o language used on the device;
o Internet service provider or network name used when accessing the Subscriber’s website;
o number of visits to the Subscriber’s website;
o number of views of certain content on the Subscriber’s website;
o number of downloads from the Subscriber’s website;
o number of emails opened from the Subscriber;
o timestamps of visits to the Subscriber’s website; and
o duration a Contact remains on the Subscriber’s website.
In addition, a Subscriber can manually assign Contacts to email distribution lists and note whether the Contact has paid for services or products from the Subscriber. SYSTEM PAL also automatically tracks whether any emails to a Contact were undeliverable (including the error code and date of error) and the date that a profile is modified or removed from the CRM Software.
How our Subscribers May Use Contact Data
Subscribers may use Contact Data for various purposes, including marketing. For example, Subscribers may target marketing materials to Contacts, monitor their Contacts’ online behavior, and use scoring to determine when to engage the Contact to purchase the Subscriber’s products or services. Subscribers can also utilize SYSTEM PAL’s reporting functionality to determine the effectiveness of marketing campaigns initiated through SYSTEM PAL. Another feature permits Subscribers to use Contact Data to initiate direct communication with a Contact through SYSTEM PAL, including via VoIP calls, text message, email, and social media interactions.
How our Subscribers May Share Contact Data
or call (877) 794-8377and the Company will obtain the policy for you within 30 business days.
Service Enabled Tracking
A Subscriber may use our Services to collect certain information about individuals and their online activities through tracking technologies. This can provide a Subscriber with information regarding a Contact’s interactions with a Subscriber’s website, including clicking on advertisements, reading content and submitting communications. Subscribers are contractually required to comply with any legal requirements in using tracking technologies made available through our Services. For example, Subscribers must disclose the use of any tracking technologies in their respective privacy policies and seek consent from Contacts in certain circumstances. Below are a few different ways this technology may be implemented through SYSTEM PAL.
• Web Beacons
Through the use of web beacons, alone or in conjunction with cookies, a Subscriber can track information about a Contact’s usage of the Subscriber’s website and interaction with emails from the Subscriber. Web beacons are clear electronic images that can recognize certain types of information on a Contact’s computer, such as a description of a website tied to the web beacon. For example, a Subscriber may place web beacons in marketing emails that notify the Subscriber when you click on a link in the email that directs you to one of the Subscriber’s websites.
• Device Fingerprinting
A Subscriber may receive behavioral data about a Contact using web-based device fingerprinting. Device fingerprinting is the process of collecting information through a browser to perform device identification that indicates a device is unique. Through this process, a Subscriber can track a Contact’s device across the web. The Company stores Contact Data captured during this process on behalf of the Subscriber. A Subscriber may use this process for various marketing activities, such as real-time targeted marketing, campaign measurement, reaching Subscribers across devices, and limiting the number of accesses to a Subscriber’s services.
For a Subscriber utilizing the Services from the EU, prior to the collection of any service enabled tracking information about a Contact, such Contact will be prompted by Subscriber to provide consent. If the Contact does not provide consent, no cookies, web beacons, or other tracking devices will be permitted to be used for such individual.
Methods of Subscriber-Contact Communications Facilitated by Company
Through the Services, a Subscriber may interact with Contacts through email, text message, VoIP calls, and social media, as described below. The Company has no control over the timing, method, or substance of any such communications that are transmitted as a result of a Subscriber’s use of the Services. With respect to any Subscriber-contact communications, Subscribers are contractually required to comply with the Telephone Consumer Protection Act, Federal Trade Commission’s (FTC) Telemarketing Sales Rule (including compliance with the Do Not Call Registry), any other telemarketing regulations, rules, or laws, Canadian “anti-spam” law, and any other federal or state laws that apply to the Subscriber’s use of any communication mechanism provided through SYSTEM PAL. If you believe a Subscriber has your Contact Data and may have utilized it in violation of such a law, please contact us at [email protected]
or call (877) 794-8377to submit a complaint against the Subscriber and we will work with the Subscriber to resolve the issue and provide you with a response. We will investigate and respond to your complaint as soon as reasonably practicable, but no later than thirty (30) calendar days after your written request.
A Subscriber may interact with Contacts through individual or group emails sent through SYSTEM PAL using Contact Data and distribution list specifications.
A Subscriber may interact with Contacts through text messages sent through SYSTEM PAL.
Social Media Interactions
Browser Do-Not-Track Signals
The Company’s policy regarding ‘do-not-track’ signals is available here http://www.systempal.com.
Your Contact Data, Your Choice
The Subscriber’s use of the Services requires the transmission of Contact Data. If a Subscriber (or a subaccount user) no longer wishes to use the Services, the Subscriber (or subaccount user) can decline to transmit additional Contact Data to the CRM Software. For any Contact Data provided prior to the cessation of the Services, the Subscriber may have access to and be provided a copy of all Contact Data maintained by the Subscriber; however, a subaccount user shall not be provided with access or a copy of such Contact Data, unless the Subscriber provides its written permission. If a Subscriber requests that the Services are terminated with respect to certain Contact Data, the Company will honor that request. However the Company retains records as described under Data Retention below.
The Company will not intentionally collect or maintain any information on a Subscriber’s behalf regarding a Contact’s medical or health condition, race or ethnic origin, political opinions, religious or philosophical beliefs or other sensitive information. In addition, the Company requires that its Subscribers will not intentionally collect or maintain such information while utilizing the Services.
Children’s Online Privacy Protection
The Services are not designed for or directed to children under the age of 18. The Company contractually prohibits its Subscribers from intentionally collecting or maintaining Contact Data about anyone under the age of 18. If you are a parent who believes a Subscriber has collected information regarding your child under age 18, please contact us at [email protected]
or call (877) 794-8377to request deletion of such Contact Data from the Subscriber’s records. We will respond to your request as soon as reasonably practicable, but no later than 5 calendar days after your request.
The Company reserves the right to use or disclose Contact Data if required by law or if we reasonably believe it is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process.
When using our Services, a Subscriber is required to offer its Contacts a choice in how the Subscriber communicates with them. For example, a Subscriber’s marketing emails are auto-filled to provide language required to comply with laws such as CAN-SPAM. Contacts can manage their receipt of marketing and non-transactional communications from a Subscriber by clicking on the “unsubscribe” link at the bottom of the applicable message.
Correcting and Updating Subscriber Information
Subscribers may update or change their registration information by editing their user or organization record. To update a user profile, please log in to the applicable Services with your username and password and edit your user settings or send your request to [email protected]
or call (877) 794-8377. To update an organization’s information, please send your request to [email protected]
or call (877) 794-8377. To update billing information or to discontinue your account, please contact us at [email protected]
or call (877) 794-8377. Requests to access, change, or delete your information will be handled within 30 days.
The Company retains the Contact Data we receive only for a reasonable duration. As the case may be, we retain the Contact Data for as long as needed to provide our Services, comply with our legal obligations, resolve disputes, establish legal defenses, conduct audits, use for business purposes, and enforce our Subscription Agreements.
The Company implements administrative, technical, and physical safeguards to help protect personal information we obtain against loss, theft, and misuse, as well as unauthorized access, disclosure, alteration, and destruction. While we follow generally accepted standards to protect information submitted to us, including the use of secure socket layer (SSL) technology, no method of storage or transmission is 100% secure. Subscribers are solely responsible for protecting their passwords, limiting access to their computers, and signing out of our Services after their sessions. If a Subscriber believes that its Contact Data is no longer secure, please notify us immediately at [email protected]
or call (877) 794-8377.
System Pal, LLC
12430 Tesson Ferry Rd. Suite 129
St. Louis, Missouri
Effective Date: Friday, July 29, 2016