Privacy Policy

Showpad Privacy Policy – Showpad as Controller

3. For what purposes and under what legal grounds do we process your personal data?

Showpad may (be required to) process certain Personal Data for one or more of the following purposes:

1. Contract administration;
2. Supplier Management;
3. The use as administrator of the Product and Services / support;
4. The interaction with the Website / Product and Services towards Showpad;
5. Downloads from the Website;
6. Training and improvements;
7. Online Meetings;
8. Showpad Academy;
9. Showpad Marketplace;
10. Events/Webinars & registration;
11. Job applications;
12. Compliance with laws; law enforcement requests; protection of Showpad’s rights; Fraud;
13. Lead Generation;
14. Direct Marketing;
15. On-Site Physical access control;
16. Strategic company initiatives;
17. Business Intelligence;
18. Other purposes.

3.1 Contract administration

This purpose relates to the processing of Your Contact Details (e.g., first name, last name, address, email, telephone number), Your Professional Details (e.g., job title, company name, billing/financial information), Your respective user account details (e.g., actions, activities, profile information, account analytics), and/or E-signature information, to:

• negotiate, execute, renew, and/or manage a contract with You, including in respect of the Products and Services provided thereunder;
• process billing information and payments related thereto; and/or
• communicate with You in respect of the above (including sending legal and non-legal notifications) and other contract-related items.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this purpose is based upon the following legal grounds:

• “processing is necessary for the performance of a contract to which the data subject is party“ or “to take steps at the request of the data subject before entering into a contract”; and/or
• “processing is necessary for compliance with a legal obligation to which the controller is subject“ (e.g., retention of log files);
• “processing is necessary for the legitimate interests pursued by the controller” (e.g., retention of log files).

The Processing of this Personal Data is an absolute requirement, without which Showpad will not enter into a contract or negotiation with You, and even may mean that Your contract or negotiation may be suspended or terminated by Showpad.

Please be aware that Showpad may use an e-signature solution to obtain your approval of the proposed contract. Usage of such an e-signature solution shall be included under this purpose.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.2 Supplier Management

This purpose relates to the processing of Your Contact Details (e.g., first name, last name, address, email, telephone number), Your Professional Details (e.g., job title, company name, billing/financial information), and/or E-signature information, to:

• negotiate, execute, renew, and/or manage a contract with You;
• process billing information and payments related thereto; and/or
• communicate with You in respect of the above (including sending legal and non-legal notifications) and other contract-related items.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• “processing is necessary for the performance of a contract to which the data subject is party“ or “to take steps at the request of the data subject before entering into a contract”; and/or
• “processing is necessary for compliance with a legal obligation to which the controller is subject“;
• “processing is necessary for the legitimate interests pursued by the controller”.

The Processing of this Personal Data is an absolute requirement, without which Showpad will not enter into a contract with You.

Please be aware that Showpad may use an e-signature solution to obtain your approval of the proposed contract. Usage of such an e-signature solution shall be included under this purpose.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.3 The use as administrator of the Showpad Product and Services / Support to Showpad Product and Services

This purpose relates to You as an Administrator of the Products and Services, and the corresponding processing of Your Contact Details (e.g., first name, last name, address, email, telephone number), Your Professional Details (e.g., job title, company name, billing/financial information), Your respective user account details (e.g., actions & activities, profile information, account analytics, IP address, account preferences, uploaded content, device information, content shared and/or actions within the Products and Services related to You or as made available by You), to:

• set up and manage the administrator account of the Products and Services;
• Provide training to you.
• interact with You in respect of (the execution of) the Contract underlying the Products and Services;
• be able to provide support in respect of the Products and Services;
• manage and respond to Your questions (e.g., technical, commercial, or administrative); and/or
• manage and respond to Your tickets and requests for maintenance and support.

The Processing of this Personal Data is an absolute requirement. You not allowing us to process all or some of this Personal Data may mean that Showpad will not be able to provide You the Products and Services, as well as related support and troubleshooting.

Additionally, we may also use such Personal Data in order to interact with You as an administrator concerning the Products and Services (e.g., software updates, newsletter, product announcements, upcoming events related to the Products and Services,  etc.). You can manage Your preferences concerning such interactions through the mailing preference centre. Please follow the link in each such communication to enter the mailing preference centre. Bear in mind that changes in the mailing preference centre will not affect any communications we are required to make to You based on the above requirements.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this purpose is based upon the following legal grounds:

• “processing is necessary for the performance of a contract to which the data subject is party“ or “to take steps at the request of the data subject before entering into a contract”;
• “processing is necessary for compliance with a legal obligation to which the controller is subject“)(e.g., retention of log files; and/or
• “processing is necessary for the legitimate interests pursued by the controller”, and more specifically, the fact that a close interaction between the Administrator and Showpad as well as sufficient context in respect of support and troubleshooting, is necessary for the smooth working and operation of the Products and Services, in which situation the Administrator plays a crucial role.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.4 The interaction with the Website / Website applications / Showpad Product and Services towards Showpad 

In case You are making use of the Website, this purpose relates to the Processing of your:

• When interacting under an account: Your Contact Details (e.g., first name, last name, address, email, telephone number), Your Professional Details (e.g., job title, company name, billing/financial information), Your respective user account details (e.g., actions and activities, profile information, account preferences, uploaded content, content shared and/or actions within the Products and Services related to You or as made available by You)
• In all circumstances: IP address, the web page you visited before you came to the Website, information you search for on the Website, and Your interactions with the Website.

In case You, as an Administrator or User, are interacting with Showpad through the Products and Services (e.g., notifications of new features, providing feedback to Showpad, Net Promoter scoring (NPS), etc. ), Showpad will be acting as data Controller concerning Your Contact Details (e.g., first name, last name, email) as well as Your Interactions and feedback (e.g., Net Promoter Scoring (NPS)) for the purposes mentioned hereunder.

We do this to:

• enable You to enjoy the use of, and easily navigate the Website,  Website applications, and Showpad Products and Services;
• better understand Your needs and interests in respect of our Website and Showpad Products and Services;
• Train Showpad collaborators to allow for a better Interaction with You;
• Improve the Website as well as the Products and Services and the Showpad Organisation, (including in respect of functionality, user-friendliness, to better tailor it to Your needs, etc.;
• Showcase the possibilities of certain Showpad features of the Products and Services;  and/or
• Discuss Your feedback.

Be advised, however, that this purpose concerning the Showpad Products and Services only applies where Showpad is the Controller for the Personal Data being processed by the Showpad Products and Services.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• “processing is necessary for the performance of a contract to which the data subject is party“ or “to take steps at the request of the data subject before entering into a contract”; and/or
• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”; and/or
• “processing is necessary for the legitimate interests pursued by the controller”, and more specifically, the fact that such information (e.g., IP address) is required to operate certain functionality of the Website and Showpad Products and Services.

Also, we refer to our Cookie Policy (see below).

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.5 Downloads from the website

In case You are downloading content from the Website, this purpose relates to the Processing of Your Contact Details (e.g., first name, last name, address, email, telephone number) and Your Professional Details (e.g., job title, company name, billing/financial information) when such data is requested in the applicable form, as well as IP address, order to allow for downloads and/or access content on the Website.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”;
• “processing is necessary for the performance of a contract to which the data subject is party“ or “to take steps at the request of the data subject before entering into a contract” and more specifically to be able to deliver the requested download; and/or
• “processing is necessary for the legitimate interests pursued by the controller”, and more specifically, the fact that Showpad values and wishes to protect its intellectual property rights and/or trade secrets, which is a key asset to Showpad, for which Showpad needs to be able to at least know which persons receive such related information.

The Processing of this Personal Data is an absolute requirement. If You do not allow us to process all or some of this Personal Data, You may not be allowed access to the download in question.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.6 Training & improvements

Whenever You are Interacting with Showpad, this purpose relates to the processing of Your Contact Details (e.g., first name, last name, address, email, telephone number) and Your Professional Details (e.g., job title, company name, billing/financial information) when such data is requested in the applicable form, as well as Your Interactions and feedback (e.g., Net Promoter Scoring (NPS), including sound and/or video recordings of the conversation(s), demo(s) and/or presentations being the subject matter of that Interaction (“Recordings”) to:

• Train Showpad collaborators to allow for a better Interaction with You;
• Improve the Website as well as the Products and Services and the Showpad Organisation, including in respect of functionality, user-friendliness, to better tailor it to Your needs, etc.; and/or
• Discuss Your feedback.

For avoidance of doubt, Recordings may be used internally at Showpad for training and coaching purposes of Showpad collaborators as well as for Showpad’s sales enablement purposes. Such Recordings may also be shared with the external participants in the Recording.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• The purpose as described above, excluding unsolicited customer feedback and Net Promoter Scoring (NPS), is based upon the legal ground where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”; and/or
• The purpose of unsolicited customer feedback and Net Promoter Scoring (NPS) is based upon the legal ground where “processing is necessary for the legitimate interests pursued by the controller”.

In case where consent applies, You represent that You are entitled to give consent to this Privacy Policy on behalf of Yourself as well as the other participants on Your side of the Interaction (e.g., in case of Recordings).

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.7 Online Meetings

We use Zoom to conduct online meetings, video conferences, and/or online training (hereinafter referred to as “Zoom Meetings”). “Zoom” is a service of Zoom Video Communications, Inc., which is based in the United States. When the Zoom meeting is or will be recorded, you may be informed via the Zoom functionality, which asks for your consent. We use recordings of Zoom meetings for the purpose of documentation and training (see further in our Privacy Policy). By participating in Zoom meetings, you consent to the collection, processing, and disclosure of information as described in this Privacy Policy.

As a result of participating in the Zoom Meeting, we may Process the following information:

• Personal Information: Your name, email address, and other information you provide when joining a Zoom meeting.
• Meeting Content: Any data, including video, audio, and chat content, generated during the Zoom meeting.
• Technical Information: Information about your device, network, and Zoom usage, including IP address, device information, and connection logs.

Apart from supporting any of the other purposes mentioned in the Privacy Policy, we use information processed during Zoom meetings for the following purposes:

• Meeting Facilitation: To facilitate and manage Zoom Meetings, including participant authentication and communication.
• Meeting Analytics: To analyse usage patterns, troubleshoot issues, and improve the quality of our Zoom meetings.
• Security: To ensure the security and integrity of Zoom meetings, including detecting and preventing unauthorised access or misuse.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”; and/or
• “processing is necessary for the performance of a contract to which the data subject is party“ or “to take steps at the request of the data subject before entering into a contract”; and/or
• “processing is necessary for the legitimate interests pursued by the controller”, e.g., in case there is no contractual relationship or negotiation thereto and more specifically the fact that Showpad is i) pursuing business development and/or expansion and maintenance of commercial relationships with customers as well as other third parties, and ii) ensuring business operations in general, handling files relating to Showpad’s core business with intervening third parties, maintaining good relationships with suppliers, working on business projects with third parties, etc.

The Processing of this Personal Data is an absolute requirement. If You do not allow us to process all or some of this Personal Data for this purpose may mean that You may not be allowed to participate in said Zoom Meeting.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.8 Showpad Academy

Whenever You are Participating in a training or certification program of Showpad, this purpose relates to the Processing of Your Contact Details (e.g., first name, last name, address, email, telephone number) and Your Professional Details (e.g., job title, company name, billing/financial information) when such data is requested in the applicable form, as well as any relevant data related to the course or program you are participating in, your progress and scoring in that course or program, and your validity of the received certifications and scoring.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”; and/or
• “processing is necessary for the performance of a contract to which the data subject is party“ or “to take steps at the request of the data subject before entering into a contract”; and/or
• “processing is necessary for the legitimate interests pursued by the controller”, and more specifically, the fact that Showpad values and wishes to protect its intellectual property rights and/or trade secrets, which is a key asset to Showpad, for which Showpad needs to be able to at least know which persons receive such related information.

The Processing of this Personal Data is an absolute requirement. If You do not allow us to process all or some of this Personal Data, You may not be allowed to participate in said trainings or certification programs.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.9 Showpad Marketplace

Whenever You are Interacting with the Showpad Marketplace, this purpose relates to the processing of Your Contact Details (e.g., first name, last name, address, email, telephone number) and Your Professional Details (e.g., job title, company name, billing/financial information) when such data is requested in the applicable form, in providing the requested services to You in respect of the Showpad Marketplace.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”; and/or
• “processing is necessary for the performance of a contract to which the data subject is party“ or “to take steps at the request of the data subject before entering into a contract”; and/or
• “processing is necessary for the legitimate interests pursued by the controller”, and more specifically, the fact that Showpad values and wishes to protect its intellectual property rights and/or trade secrets, which is a key asset to Showpad, for which Showpad needs to be able to at least know which persons receive such related information.

The Processing of this Personal Data is an absolute requirement. If You do not allow us to process all or some of this Personal Data, You may not be allowed access to the download in question.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.10 Events/webinars & registration

This purpose relates to the processing of Your Contact Details (e.g., first name, last name, address, email, telephone number), Your Professional Details (e.g., job title, company name, billing/financial information), as well as sound and/or video recordings made during such events, to:

• Process Your registration to the event as organised by Showpad (alone or jointly with another organiser) or organised by a third party on behalf of Showpad;
• Contacting you in respect to Your registration;
• Proceed with billing and payment of Your registration (if applicable);
• Invite You to similar events;
• Propose events to You which Showpad – in its reasonable opinion – may consider relevant or interesting to You;
• Sharing Your Personal Data with the other parties involved in the organisation of the event (including for lead management);
• Sharing Your Personal Data with other participants to the same event (e.g., concerning a participant list), however limited to first name, last name, job title, and company name; and/or
• Publish photo and/or video recordings of You participating at the event in related or relevant publications, the Website, and/or social media of the parties involved in the organisation of the event (including for educational, news, or promotional purposes, whether in print, electronic, or other media).

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”; and/or
• “processing is necessary for the performance of a contract to which the data subject is a party“ or “to take steps at the request of the data subject before entering into a contract”.

The Processing of this Personal Data is an absolute requirement in cases where You are engaging in or registering for an event. If You do not allow us to process all or some of this Personal Data, Showpad may not be able to register Your participation in the event, or Your registration may be suspended or terminated by Showpad.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.11 Job applications

Job application

In case You are responding to a job opening at Showpad, Showpad has otherwise received your CV or professional details (e.g., from a job agent), or where Your application has been retained by Showpad, this purpose relates to the processing of Your Contact Details (e.g., first name, last name, address, email, telephone number), Your Professional Details (e.g., job title, company name, CV), and Your respective user account details (e.g., actions and activities, profile information, account analytics, account preferences, uploaded content), to:

• Process(ed) Your job application; and/or
• Get in contact with You regarding Your job application and onboarding.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”;
• “processing is necessary for the performance of a contract to which the data subject is party“ or “to take steps at the request of the data subject before entering into a contract”; and/or
• “processing is necessary for the legitimate interests pursued by the controller”, including the fact that Showpad needs to be able to verify and/or cross-check Your claimed capabilities per Your application and to enter into contact with You.

The Processing of this Personal Data is an absolute requirement. If you do not allow us to process all or some of this Personal Data, Showpad may not be able to process or retain Your job application or verify Your claimed capabilities.

Additional questionnaires during Your job application

In addition to the above, during Your application process, You may be asked to participate in a questionnaire (e.g., in order for Showpad to become more aware with regard to diversity and inclusion). Any such questionnaires shall be used only for the purpose indicated in that questionnaire. Participation in such a questionnaire is on a voluntary basis only.

Participation in, or feedback provided in, such a questionnaire shall under no circumstances have any positive or negative impact on Your application. Where the personal data relating to such questionnaire would qualify as “sensitive personal” data as defined under article 9 GDPR, be advised that this personal data is treated with the utmost care and protection (e.g., strict need to know basis, strict internal usage, no divulging to third parties, etc.)

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Poli

3.12 Compliance with laws; Law enforcement requests; protection of Showpad’s rights; Fraud

This purpose may include, amongst others, the Processing of any such Personal Data to the extent that Showpad has a good faith belief such processing is reasonably necessary to: (a) comply with a law, regulation or compulsory legal request from a public or law enforcement authority; (b) national security; (c) protect the safety of any person from death or serious bodily injury; (d) prevent fraud or abuse; and, (e) as necessary to protect or enforce our legal rights and those of our collaborators as well as the integrity of our Products and Services.

Such disclosures shall always be limited to the Personal Data as required for the specific purpose of the recipient while taking into account the necessary provisions on confidentiality, integrity, availability, and security of the data involved.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• “processing is necessary for compliance with a legal obligation to which the controller is subject“;
• “processing is necessary to protect the vital interests of the data subject or of another natural person”; and/or
• “processing is necessary for the legitimate interests pursued by the controller”, and more specifically, the fact that Showpad itself needs to be able to mitigate risk of damages and liabilities that may result from any illegal actions by You.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.13 Lead Generation

This purpose relates to the processing of Your Contact Details (e.g., first name, last name, address, email, telephone number) and Your Professional Details (e.g., job title, company name) resulting from Personal Data:

• Publicly disclosed by You (e.g., website, LinkedIn, memberships, etc.):
• From interactions You have/had with Showpad;
• Obtained from third parties that are allowed to share such Personal Data with Showpad; or,
• From research performed by or under the instruction of Showpad to allow Showpad to qualify and process leads in Showpad’s CRM and/or BI tools.

3.14 Direct Marketing

This purpose relates to the processing of Your Contact Details (e.g., first name, last name, address, email, telephone number), Your Professional Details (e.g., job title, company name), to provide You with further information (and offers from us or partners of Showpad that Showpad believes You may find useful or interesting), including newsletters, marketing, events or promotional materials and other information on Products and Services offered by us or third parties.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy (e.g., lead generation).

To the extent that this is required per applicable Data Protection law (e.g., GDPR), before Showpad will directly contact You under this purpose, Showpad shall a) first seek Your consent (opt-in), or b) use other legal basis such as i) allowed under applicable legislation (e.g., soft opt-in under EU directive (2002/58/EC) or under guidance of such authority supervising such legislation, ii) where You were in a prior (pre-) contractual engagement with Showpad and Showpad wants to inform you of its own similar events or Showpad Products and Services, iii) where You have yourself initiated or requested a commercial response from Showpad, iv) etc.).

When sending direct marketing communications to You, Showpad shall ensure to do so in line with the applicable direct marketing legislation (e.g., EU directive (2002/58/EC), CAN-SPAM, etc.).

For avoidance of doubt, where applicable to You per applicable Data Protection law (e.g., GDPR), You shall have the right to object at any time to Processing of Your Personal Data for direct marketing purposes, in which case Your Personal Data shall no longer be processed for this purpose. In such a case, You may opt out of receiving such promotional messages from us at any time by following the instructions on those messages, or by contacting us at privacy@showpad.com.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”; and/or
• “processing is necessary for the legitimate interests pursued by the controller”, which, according to applicable Data Protection laws, may be an applicable legal ground for direct marketing and lead generation.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”; and/or
• “processing is necessary for the legitimate interests pursued by the controller”, which, according to applicable Data Protection laws, may be an applicable legal ground for direct marketing/ lead generation.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.15 On-Site physical access control

This purpose relates to the processing of Your Contact Details (e.g., first name, last name, email, telephone number), Your Professional Details (e.g., job title, company name), Your Showpad host details, as well as Your photo or video material (e.g., video doorbell) to:

• Allow you to gain physical access to Showpad premises;
• To manage Your physical access;
• To notify Your Showpad host of Your presence.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the legal ground that “processing is necessary for the legitimate interests pursued by the controller”, and more specifically the fact that Showpad itself needs to be able to comply with its information security certifications, to ensure the safety of its assets, collaborators and visitors, and to avoid unauthorised access to parts of the Showpad premises.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.16 Strategic Company initiatives

This purpose relates to the processing of Your Contact Details (e.g., first name, last name, address, email, telephone number), Your Professional Details (e.g., job title, company name, billing/financial information), Your respective user account details (e.g., actions and activities, profile information, account analytics), resulting from Personal Data:

• Publicly disclosed by You (e.g., website, LinkedIn, memberships, etc.):
• From interactions You have or had with Showpad;
• Obtained from third parties that are allowed to share such Personal Data with Showpad; or,
• From research performed by or under the instruction of Showpad to allow Showpad to perform analysis, and to determine Showpad’s customer strategy.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”; and/or
• “processing is necessary for the legitimate interests pursued by the controller”.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.17 Business Intelligence

This purpose relates to the processing of Your Contact Details (e.g., first name, last name, address, email, telephone number), Your Professional Details (e.g., job title, company name, billing/financial information), Your respective user account details (e.g., actions and activities, profile information, account analytics), resulting from Personal Data:

• Publicly disclosed by You (e.g., website, LinkedIn, memberships, etc.):
• From interactions You have/had with Showpad;
• Obtained from third parties that are allowed to share such Personal Data with Showpad; or,
• From research performed by or under the instruction of Showpad to allow Showpad to perform analysis, and to improve upon business intelligence.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the following legal grounds:

• where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”; and/or
• “processing is necessary for the legitimate interests pursued by the controller”.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

3.18 Other Purposes

With your consent

Showpad Processes Personal Data about You where you have given us consent to do so for a specific reason not addressed within this Privacy Policy. For example, we may publish testimonials, case studies, featured customer stories, etc., where You have consented thereto.

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the legal ground where the data subject “has given consent to the processing of his or her Personal Data for one or more specific purposes”.

As a legitimate interest

Showpad may Process additional information or enrich Personal Data that Showpad Processes for the purposes stated in this Privacy Policy, with Personal Data that:

• Has been publicly disclosed by You (e.g., website, LinkedIn, memberships, etc.):
• Results from interactions You have or had with Showpad;
• Is obtained from third parties that are allowed to share such Personal Data with Showpad; or,
• Results from research performed by (or under the instruction of) Showpad,

To the extent required to inform You per applicable Data Protection law, Processing of Personal Data for this Purpose is based upon the legal ground that “processing is necessary for the legitimate interests pursued by the controller”.

Be aware that this purpose is in addition to and leaves unharmed any other purpose as per this Privacy Policy.

4. Which parties may receive Personal Data from us?

Showpad may share Your Personal Data with its (as well as its affiliates’):

• Employees and collaborators in respect of the purposes described in this Privacy Policy;
• Third-party technology and service providers in respect of their services as used for the purposes described in this Privacy Policy;
• Showpad investors are represented on the Showpad Board of Directors to the extent related to services and strategic advice being offered by these investors to Showpad.
• Third-party maintenance and support recipients (including related service or technology providers);
• Showpad Partners, including in respect of i) offers of partners of Showpad, which Showpad, in its reasonable opinion, may believe to be of interest to You, and ii) Showpad Marketplace partners;
• Other third parties to the extent Showpad has a good faith belief that such disclosure is reasonably necessary to: (a) comply with a law, regulation or compulsory legal request from a public or law enforcement authority; (b) national security; (c) protect the safety of any person from death or serious bodily injury; (d) prevent fraud or abuse; and, (e) as necessary to protect or enforce our legal rights and those of our collaborators as well as the integrity of our Products and Services.

Such disclosures shall always be limited to the Personal Data as required for the specific purpose of the recipient while taking into account the necessary provisions on confidentiality, integrity, availability, and security of the data involved.

For avoidance of doubt, Showpad does not sell or otherwise commercialise the Personal Data.

To the extent required as per applicable Data Protection law, Showpad shall remain responsible for ensuring that such export occurs in a legally compliant way, as well as that the performance of the Sub-processors Showpad has engaged remains in line with the applicable data protection law.

5. Do We transfer Personal Data to third countries?

Showpad transfers Personal Data if and when required by:

• Its and its affiliates’ employees and collaborators;
• Third-party technology and service providers as used for the purposes described in this Privacy Policy;
• Third-party maintenance and support recipients (including related service and technology providers);
• Showpad Partners, including in respect of i) offers of partners of Showpad, which Showpad, in its reasonable opinion, may believe to be of interest to You and ii) Showpad Marketplace partners;
• Other third parties to the extent Showpad has good faith belief that such disclosure is reasonably necessary to: (a) comply with a law, regulation or compulsory legal request from a public or law enforcement authority; (b) national security; (c) protect the safety of any person from death or serious bodily injury; (d) prevent fraud or abuse; and, (e) as necessary to protect or enforce our legal rights and those of our collaborators as well as the integrity of our Products and Services.

Such disclosures shall always be limited to the Personal Data as required for the specific purpose of the recipient while taking into account the necessary provisions on confidentiality, integrity, availability and security of the data involved.

In the current set-up of the Showpad organisation, such export of Personal Data shall occur.

To the extent required as per applicable Data Protection law, where such export occurs, Showpad shall ensure that such transfer occurs under the necessary legal provisions as required by the applicable legislation.

To the extent data is being internationally (re)transferred, Showpad shall ensure that such (re)transfer occurs under such instruments as allowed per the applicable regulation and providing for an adequate level of protection of Your Personal Data (e.g., adequacy decision of the EU commission, binding corporate rules, EU standard contractual clauses, …).

Showpad is responsible for ensuring a secure and compliant transfer. Showpad shall remain liable if its agent processes such personal information in a manner inconsistent with applicable rules, unless Showpad proves that it is not responsible for the event giving rise to the damage.

6. What rights do You have?

In all circumstances, You have the right to:

• Obtain access to and/or rectification of Your Personal Data as processed by Showpad; and
• Request to receive Your Personal Data in a format at the discretion of Showpad (e.g., Excel, CSV file, …), that allows for the data portability of such data to a similar service;

Where such right is entrusted to You by an Applicable Data Protection Law, You have the right to:

• Withdraw Your consent for processing of Your Personal Data (be advised that such leaves unharmed and does not affect the prior lawful processing of Your Personal Data, or the continuation of processing of (part of) Your Personal Data as allowed under an applicable legal ground (see A3)).
• The restriction of processing of Your Personal Data (e.g., article 18 GDPR) and/or right to object to the processing of Your Personal Data (e.g, article 21 GDPR).

7. How to exercise Your rights?

To exercise Your rights as set forth under A6, please contact privacy@showpad.com or use the means available to you under your user account (to the extent offered by Showpad).

Exercising Your rights can occur by Yourself or through an agent, under the conditions of the following paragraphs and by providing sufficient and verifiable written proof that such agent is acting on Your behalf.

In exercising Your rights under this section, You shall provide proof of Your identity to the satisfaction of Showpad by either identification through Your respective user account (to the extent possible), or by providing a copy of an official government issued document (e.g., ID Card, driver’s license, etc.) and Your telephone number (so we can verbally interact with You to confirm and verify). Such proof is essential to: i) verify the validity of Your request, ii) to safeguard the security of Your Personal Data, and, iii) to avoid unauthorised disclosures. Please be aware that without such proof, we may not be able to proceed with Your request.

Where we are communicating with You (e.g., newsletter, product announcements, upcoming events, etc.) You can manage Your preferences concerning such communications through the mailing preference centre. Please follow the link in each such communication to enter the mailing preference centre.

8. How do we respond to your requests?

Upon receipt of a request we strive to respond to your request without undue delay and in any event within one month of receipt of the request which period we may extend by two further months where necessary, taking into account the complexity and number of requests.

Requests whereby the requestor’s identity cannot be verified, which are unduly repetitive, or, create a substantial, articulable and unreasonable risk to the security of the Personal Data may be discarded by Showpad in whole or in part.

Response to your request shall be provided by electronic means only.

Exercising Your rights under this Privacy Policy:

• leaves unharmed and does not affect the prior lawful processing of Your Personal Data, or the continuation of processing of (part of) Your Personal Data as allowed under an applicable legal ground (see A3.)
• shall not lead to unjustified pricing discriminatory treatment by Showpad towards You (e.g. unjustified denying goods or services, unjustified charging different prices compared to the same product in the same version, unjustified providing different quality compared to the same product in the same version).

Be advised however that:

• Use of the Product and Services, or the processing for the Purposes under this Privacy Policy, may be impeded or even rendered impossible in absence of a complete data set;
• Erasure of Your Personal Information may be exercised by Showpad through the actual deletion of Your Personal data, anonymizing Your Personal Data and/or aggregating Your Personal Data.

9. Retention of Your Personal Data?

Showpad retains Your Personal Data (i) as long as Your Personal Data is relevant for the purpose, (ii) for the duration of any retention period that is required by law, or (iii) the end of the period in which litigation or investigations might arise. After such period, Showpad either deletes or anonymizes the Personal Data.

10. What security measures do we use?

Showpad has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate: (a) the pseudonymisation and encryption of personal data; (b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; (c) the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.

Showpad shall thereto take into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons.

The whole Showpad Information security program is managed by the Showpad Information Security Team.

11. What is our policy towards minors and children?

The Showpad Products and Services, as well as the activities of Showpad are intended for a commercial application in a professional environment. Showpad is not knowingly or intentionally targeting children under the age of 18 year.

If a parent or guardian becomes aware that his or her child has provided Personal Data that is processed by Showpad without their consent, he or she should contact Showpad at privacy@showpad.com. If we become aware that a child has provided us with Personal Data, Showpad will take the reasonable and necessary steps to have that Personal Data irrevocably removed.

12. Do we employ automated decision making?

Showpad does not use the Personal Data You have provided hereunder for any automated decision-making processes or techniques which create or deny rights to You.

13. Do we sell Your Personal Data to third parties?

Showpad only processes Your Personal Data as per this Privacy Policy, Showpad does not sell, trade or otherwise commercialise Your Personal Data.

14. Are we processing PCI data?

Showpad does NOT process any payment card information (PCI). Any payment card operations and information is controlled and processed directly and solely by a third-party provider.

15. Where to log a complaint?

In case You have a complaint about the way Showpad is processing Personal Data, You can contact us directly at privacy@showpad.com, and we will review Your complaint and determine if we can help You to resolve it. Upon receipt of a complaint, we strive to respond to your request without undue delay and in any event within one month of receipt of the complaint, which period we may extend by two further months where necessary, taking into account the complexity and number of complaints.

If You have an unresolved complaint, You have the right subject to your applicable Data Protection law to complain with the competent “data protection authority”. Information on the competent data protection authority and the way to lodge a complaint can be found here (or the URL as updated by the European Commission).

Showpad NV, located in Belgium, acts as a so-called:

• “main establishment” in the EEA under GDPR. As a result, the Competent Data Protection Authority for Showpad NV is the Belgian DPA (Drukpersstraat 35, 1000 Brussel / +32 (0)2 274 48 00 / contact@apd-gba.be/ https://www.dataprotectionauthority.be/).
• “representative“ in line with section 27 GDPR for and on behalf of Showpad, Inc.

16. reCaptcha

“Google reCAPTCHA” (hereinafter “reCAPTCHA”) is implemented on our websites.

This service is provided by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).

We use reCAPTCHA on our websites to prevent various types of data processing abuse attempts (e.g., phishing). reCAPTCHA analyzes various information of the respective visitor (e.g., IP address, mouse movements of the user, length of stay on the website). By using reCAPTCHA, data is transferred to Google, which is used to determine whether the visitor is a human being or a (spam) bot.

The data processing is based on Art. 6 para. 1 lit. f GDPR. The website operator has a legitimate interest in protecting its web offers against abusive automated spying, against spam, as well as protecting third parties against such attacks. You can read which data is collected by Google and what this data is used for at https://policies.google.com/privacy. You can read the terms of use for Google services and products at https://policies.google.com/terms.

17. Who can I contact if I require more information?

Showpad NV, located in Belgium, acts as the so-called representative in line with section 27 GDPR for and on behalf of Showpad Inc.

Showpad has appointed a data protection officer for the whole Showpad Group who can be contacted at “Office of the Data Protection Officer – Showpad NV – Moutstraat 62 – 9000 Gent (Belgium) or privacy@showpad.com”

18. Showpad inc. – Data Privacy Framework (DPF) statement

Showpad Inc. complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce. Showpad, Inc., has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) concerning the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.

If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) Program and to view our certification, please visit https://www.dataprivacyframework.gov/

In compliance with the EU-U.S. DPF, Showpad, Inc., commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF. Data subjects have such a right, if and to the extent applicable, to binding arbitration under the principles of ANNEX-I-introduction.

Where and to the extent applicable, the Federal Trade Commission has jurisdiction over Showpad, Inc.‘s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF).

Showpad, Inc.’s further transfer of personal data is subject to section 5 of this Privacy Policy.