Privacy Policy

(“15Five,” “we” or “us”) is committed to protecting your (“you,” “user,” or “your”) privacy.  This “Privacy Policy” explains how 15Five collects, uses, and shares the personal information we collect from users of our website hosted at https://www.15five.com/, any other related sites operated by 15Five and all subdomains, subpages, and successor sites thereof (collectively, the “Website”), and/or the software applications and services made available on the Website (collectively, the “Services”).  By visiting the Website, (as defined below), accessing the Services, and/or described herein that authorize us to collect and process your information, you signify that you have read, understood and expressly consent to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy.  If you do not agree with the terms set out in this Privacy Policy, please do not visit the Website, check any of the boxes described herein, or use the Services; and please delete any cookies placed on your web browser and hard drive by the Website and/or the Services.

Please read the following carefully to understand our views and practices regarding our use of your personal data.

Service Agreements and Consent

Data that you consent to provide to us also will be governed by the agreement(s) between you and 15Five regarding your use of the Services (the “Service Agreements”).

We collect personal information about you from various sources to provide our Services to you, to analyze and improve our Services, and to communicate with you.  To help you understand how we use and share this information, this Privacy Policy describes our data privacy and confidentiality practices.

Information We Receive or Collect From You

The information about you that we receive and/or collect is used to improve the content of our Website and the quality of our Services, and no personally identifiable information is shared with or sold to other organizations for commercial purposes, except to provide products or services you have requested, and when we have your permission to do so.

You may give us data about you when you:

  1. set up an account with the Services, such as a user name and password;
  2. access or use the Website or the Services, such as, for example, identifying information such as your name, company name, information about the organization you represent, contact information, postal address, email address, billing address, Internet protocol (IP) address, or phone number (“Customer Information”);
  3. post any information on or through the Services;
  4. contact or correspond with us (for example via phone, email, or otherwise); or
  5. complete a survey about the use of the Website or the Services.

We may collect information about you such as:

  1. information about your use of the Website or the Services;
  2. certain technical information if you visit the Website, such as, for example, the type of device (and its unique device identifier) you use to access the Website and/or Services, the Internet protocol (IP) address used to connect your device to the Internet, your login information for the Services, browser type and version, time-zone setting, browser plug-in types and versions, operating system, mobile network information and platform, full Uniform Resource Locator (URL), clickstream to, through and from the Website and/or Services (including date and time), pages you viewed, page response time, download errors, length of visit to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page; or
  3. when you access our Services by or through a mobile device, we may receive or collect and store unique identification numbers associated with your device or our mobile application (including, for example, a Unique Device Identifier (UDID), Unique ID for Advertisers (IDFA), Google Ad ID, or Windows Advertising ID), device type, model and manufacturer, and mobile device operating system brand and model.

We may be given data about you, the organization you represent, or a third party such as:

  1. information the organization you represent provides to us when it registers with the Services; or
  2. information about you and the organization you represent from third party services that interoperate with the Services.

In some cases, provision of your information may be necessary to provide you with the Services. In these cases, if you fail to provide us with certain requested information, you may be unable to use the Services.

Purpose and Legal Basis for Processing your Data and the Customer Information

15Five has lawful bases to collect, use and share your Customer Information and any personal data we receive from, collect or maintain about you.  Lawful bases include: your consent (as provided for in this Privacy Policy, Cookie Policy (as defined below) and the Service Agreements); contract (where processing is necessary for the performance of a contract with you, such as the Service Agreements); obligation to comply with laws that apply to us; protection of the vital interests of a natural person, such as in the event of an emergency; and other legitimate interests including, but not limited to, where processing is necessary to:

  1. protect you or 15Five from threats (such as security threats or fraud);
  2. enable us to administer our business, such as for quality control and customer service;
  3. manage corporate transactions; and/or
  4. understand and improve our business and customer relationships generally.

Where we have a legal basis to use your personal data without consent, this Privacy Policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal data will be used.  Where consent is required for our use of your personal data as described above, you have the right to withdraw or decline your consent and cease your use of the Website and/or Services.  If you decide to withdraw your consent, such withdrawal will not affect the lawfulness of processing based on consent before such withdrawal.  Notwithstanding Customer Information you choose to allow other users of the Services to view and access, your Customer Information will be kept confidential and will be used to support your relationship with us.  Except as otherwise set forth in this Privacy Policy or the Services Agreements, we will not sell, rent, or lease to others your Customer Information or any other personal information we receive from, collect or maintain about you.

As set forth above, if you email us, we may keep your message, email address, and contact information to respond to your message.

We employ Zuora, Inc as a payment intermediary service to receive payment from users of the Services, and do not request or store any of your financial information, such as your bank routing or account numbers, or your debit or credit card account numbers.

Following termination or deactivation of your account with the Services, we may retain information, including profile information and Customer Information, in order to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our rights under our agreements with you, for backup, audit or regulatory purposes, and for other actions permitted by law.  Otherwise, we will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which we originally collected it.  To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

We may share your Customer Information for marketing purposes but only with your express prior consent.  Those uses will be subject to such third party’s privacy policies.  Also, 15Five may share your Customer Information with third parties in aggregated and/or anonymized form.

Information gathering and usage

15Five uses collected information for the following general purposes: products and services provision, billing, identification and authentication, services improvement, contact, and research.

15Five may also use non-personally identifiable data submitted by users to create and provide new services, features or content.  For example, and without limitation, we may use data such as employee pulse trends rates to publish interesting observations for informational or marketing purposes.  15Five will aggregate and anonymize such data such that neither users nor the organizations users’ represent are identified.

15Five may internally perform statistical and other analysis on information we collect (including usage data, device data, referral data, and information from page tags) to analyze and measure user behavior and trends, to understand how people use our services, to monitor, troubleshoot and improve our services, and to create and provide new services, features or content.

Special Cases in which We Share Personal Information

We may share your information, including Customer Information and personal information, under the following circumstances:

  1. In order to investigate, prevent, or take action regarding illegal activities, suspected fraud, by lawful request of public authorities and national security or law enforcement requirements, situations involving potential threats to the physical safety of any person, violations of the Service Agreements, or as otherwise required by law. In such circumstances, you acknowledge 15Five may disclose such information to the extent necessary to comply with such legal requirement;
  2. 15Five is acquired by or merged with another company. In this event, 15Five will use reasonable efforts to notify you before information about you is transferred and becomes subject to a different privacy policy;
  3. Disclosures to subprocessors (as described in the DPA (as defined below)) and businesses with whom we are under common corporate control;
  4. In the event of an emergency if necessary to protect the safety of 15Five’s employees, agents, customers or any person. When your information is disclosed under this subparagraph, we may also disclose such information on a non-aggregated, non-anonymous basis;
  5. Disclosures to our service providers, business partners, suppliers, sub-contractors or agents who perform services for us, as well as our professional advisers (including our lawyers, bankers, auditors and insurers), and analytics and search engine providers that assist us in the improvement and optimization of the Website and/or Services; and/or
  6. 15Five may disclose aggregated and anonymized data to third parties for market research, trend research, academic research, benchmarking, forecasting, or any other purpose. In all such instances, we will not disclose any identifiable information about you, your respondents, or your company.  15Five may also analyze your usage patterns and the usage patterns of your respondents to improve or optimize our Services.

Cookies

A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser and stored on your computer’s hard drive.

Cookies are required to use the 15Five Services.

We use cookies to record current session information, but do not use permanent cookies.  You are required to log-in to your 15Five after a certain period of time has elapsed to protect you from others accidentally accessing your account contents.

We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Services, and to understand the demographics of our users, the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Services.  Please see 15Five’s “Cookie Policyhere, if you would like to learn more about 15Five’s use of cookies and types of data we collect through cookies.

Although we do our best to honor the privacy preferences of our users, we are not able to respond to Do Not Track signals from your browser at this time.

Data storage

15Five uses third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run 15Five.  Although 15Five owns the code, databases, and all rights to the 15Five application, you retain all rights to your data.

Control, Email and Opt-Out

You have control over your Customer Information and other personal information related to your use of the Services.  Accordingly, you may access, review, add, rectify, modify, correct, delete or update your Customer Information or other personal information at any time.  You have the right to ask us not to collect, use, process or disclose your Customer Information in any of the manners described herein.  Exercising this ability to opt-out will affect your user experience.  You can notify us of your intention to halt the collection, use, processing, or disclosure of your Customer Information at any time by contacting us at privacy@15five.com.  Some personal information is automatically collected via the use of data analytics tools.  If you object to such collection, your only choice is not to access the Website and/or Services.

If you receive one or more emails from us, it means one of two things: (i) you provided us with your ; or (ii) you provided us your email address so that we could contact you.  If you believe you received an email from us in error, please contact us immediately at .

If you consented to receiving marketing communications from us by opting-in where indicated on or through the Website and/or the Services and subsequently desire to withdraw such consent, we provide you with the opportunity to opt-out of receiving marketing communications from us at any point in time.  If you wish to cease receiving marketing emails and other communications from us, you can opt-out by contacting us at privacy@15five.com or by changing the setting in your Services account.

In addition to the above rights of access, correction, rectification, amendment or deletion, if you live in the EEA or Switzerland (as defined below), subject to applicable law, you may have some or all of the following rights with respect to your personal information:

  1. to restrict processing of your personal data if the data is inaccurate, the processing is unlawful or we no longer need it for the purpose for which we hold it;
  2. to transmit your data (as provided by you, directly or otherwise collected by us by virtue of your use of the Services) in machine-readable format to you or to a third party when we justify our processing on the basis of your consent or the performance of a contract with you;
  3. to withdraw your consent to our processing of your personal data (where that processing is based on your consent);
  4. to obtain or see a copy of the appropriate safeguards under which your personal data is transferred to a third country or international organization;
  5. to object, at any time, to the processing of your personal information, on legitimate grounds, except if otherwise permitted by applicable law;
  6. to erase your personal data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed); and
  7. to file a complaint with your local supervisory authority for data protection.

You can exercise the above rights by: (i) email sent to privacy@15five.com; or (ii) mail sent to 15Five at: 3053 Fillmore St., #279, San Francisco, CA 94123.  If you establish a membership account with the Services, .

The personal data processed in connection with your use of the Services is necessary in order for you to maintain an account to use the Services.  Accordingly, if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed to facilitate your use of the Services, you may not be able to use the Services as you did before, or at all.  The foregoing does not include your right to object to direct marketing, which can be exercised at any time without restriction.  Please allow .

Please note the rights mentioned above do not extend to non-personal data.  Please also note it may be necessary to retain your personal data for the purposes of assessing and verifying data that is submitted to and/or held within the Services, and to manage the Services; your rights under applicable law may be limited accordingly.

Keeping information safe

15Five cares about the security of your information and uses commercially reasonable physical, technical and organizational measures designed to protect against the loss, misuse and alteration of and preserve the integrity and security of all information we collect and that we share with our service providers; however, no security system is impenetrable and we cannot guarantee the security of our systems 100%.  In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

While we strive to protect your data from unauthorized use or disclosure, 15Five does not warrant or guarantee the security of the data that you provide to us; any transmission is at your own risk.

You are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services.  In order to protect you and your data, we may suspend your use of the Website and/or Services without notice, pending an investigation, if any breach of security is suspected.

Within 15Five, only authorized 15Five personnel have access to personal information.  Such personnel have been informed by 15Five of their obligation to preserve the confidentiality of such personal information.  15Five’s employees who have access to such personal information may use it only in accordance with the principles set out in the Privacy Policy and applicable legislation and regulation.  Depending on the nature of the personal information, it may be stored in the offices of 15Five or in various computer systems of 15Five or of its service suppliers, or in storage installations of 15Five or of its service suppliers.

Links to third-party websites and services 

For your convenience, our website and Services may provide links to third-party websites or services that are not governed by this Privacy Policy.  To the extent that any linked third-party websites or services you visit are not owned or controlled by 15Five, we are not responsible for those websites’ or services’ content or information practices.  We encourage you to review the privacy policies of any site or service before providing any personal information.

Notice to California Residents

The California Consumer Privacy Act of 2018 (the “CCPA”) provides certain rights to California residents regarding their personal information.  A California resident has the right to request that 15Five disclose certain information, including: (1) the categories of personal information it has collected about that California resident, (2) the categories of sources from which the personal information is collected, (3) the business or commercial purpose for collecting or selling the personal information, (4) the categories of third parties with whom 15Five shares personal information, (5) the specific pieces of personal information it has collected about that resident, and (6) the categories of personal information that 15Five has sold about that resident and the categories of third parties to whom that information was sold.  A California resident has the right to request that 15Five delete their personal information.  A California resident also has a right to “opt-out” of the sale of that resident’s personal information.  Finally, a California resident has the right not to be discriminated against for exercising their privacy rights under the CCPA; provided, however, that the CCPA does not prohibit 15Five from offering financial incentives, different prices, rates, levels or qualities of goods or services for the collection of personal information if that price or difference is directly related to the value provided by the consumer’s data.  You will be notified of any Privacy Policy changes:

  • On our Privacy Policy page

You can change your Personal Information:

  • By emailing us at privacy@15five.com

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses.  If applicable, this information could include the categories of customer information and the names and addresses of those businesses with which we shared that information for the immediately prior calendar year (e.g., requests made in 2020 will receive information regarding 2019 sharing activities).  To obtain this information, please send an email message to privacy@15Five.com with “Shine the Light Request” on the subject line and in the body of your message.  We will provide the requested information to you at your e-mail address in response.  Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

Pursuant to California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Compliant Assistance Unit of the Division of Consumer Services for the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

Notice to Non-U.S. Data Subjects

You understand and acknowledge in connection with our provision of the Services, we are a data processor and not a controller (as such terms are defined under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data).  In the event you are a user of the Services, the data processing addendum referenced in the Services Agreements, by and between you and 15Five, applies to the personally identifiable information of non-U.S. data subjects shared by you (the “DPA”).

Please be aware your Customer Information and personal information may be collected, managed, transferred to, processed, and stored or accessed in a country different other than your country of residence.  Also, we may allow our service providers or assistance providers, who may be located outside of your country of residence, to access your personal information.  In addition, we may make other disclosures of your personal information outside of your country of residence, for example, in the event we receive a legal or regulatory request from a foreign law enforcement body.  We will always take steps designed to ensure any transfer of such information to entities based outside your country of residence is carefully managed to protect your rights and interests by implementing appropriate safeguards to protect your personal information.  Data protection laws in any such country (including laws governing the terms of the notice issued to you at the time of collection of Customer Information and personal information) may be different from those laws of your country of residence.  By visiting the Website, and accessing and using the Services, you consent to the transfer of your information, including Customer Information, to such country(ies) as are set forth in this Privacy Policy.

From time to time, personal information we collect from data subjects in the European Economic Area or Switzerland (“EEA or Switzerland”) may be transferred to, stored, processed or accessed by, us and other entities who may be based outside of the EEA or Switzerland, for example, the United States.  Also, we may allow our subprocessors, who may be located outside the EEA or Switzerland, to access your personal data.  We will exercise commercially reasonable steps designed to ensure any transfer of such information to entities based outside the EEA or Switzerland is carefully managed to protect your rights and interests by implementing appropriate safeguards to protect your personal information.  Your personal data may be transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the Swiss government.

Where there is no adequacy decision by the European Commission in respect of a country (to the extent that they are outside the EEA or Switzerland), which means it is not deemed to provide an adequate level of protection to your personal data, we will exercise commercially reasonable efforts designed to ensure your personal data receives an adequate level of protection.

If you would like to find out more about these safeguards in respect of processing your personal data and the means by which you can obtain a copy of them, please contact us at privacy@15five.com

Children’s Privacy

15Five’s website and services are intended for use strictly by adults.  We do not knowingly solicit or collect personal information from children under the age of sixteen.  If we learn that any personal information has been collected from a child under sixteen (16), we will delete the information as soon as possible.  If you believe that we might have collected information from a child under 18, please contact us at privacy@15five.com.

Changes

15Five may periodically update this policy.  We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your 15Five primary account holder account or by placing a prominent notice on our site.

Questions

Any questions about this Privacy Policy should be addressed to privacy@15five.com or by mail at:

3053 Fillmore St., #279, San Francisco, CA 94123

 

This Privacy Policy was last modified on October 7, 2021.