Privacy Policy (Salesloft)
Board International SA and its subsidiaries (“Board” or the “Data Controller”) are committed to protecting personal data and pay particular attention to the way in which this information is used and shared. This Privacy Policy is primarily aimed at informing you of what data Board may collect and how Board process personal data of the participants of the virtual meetings on the platform Salesloft (the “Platform”). Board processes personal data under the General Data Protection Regulation (“GDPR”), which came into force on 25 May 2018, the Swiss Federal Act on Data Protection, the Canadian Personal Information Protection and Electronic Documents Act, the Japan’s Act on the Protection of Personal Information, the Australian Privacy Act, the Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data Protection, and the Indian Information Technology Act, 2000 (the “Regulation”). These latter Regulation aim to guarantee that the personal data of physical persons is processed in compliance with the rights, fundamental freedoms and dignity of persons, with particular reference to confidentiality and personal identity. Board pays particular attention to the way in which personal information is used and shared and it is therefore important to inform you of the adopted privacy policy.
Processing of personal data means collection, recording, transcription, organisation, conservation, processing, alteration, selection, retrieval, comparison, use, disclosure, erasure, distribution, interconnection and any other processing which is useful in relation to the use of the Platform (the “Service”).
1. Personal data we collect
1.1 Board collects the personal information provided by users to attend meeting(s) on the Platform and provide related services (the “Service”).
- In particular, the personal data processed by Board includes, inter alia, the following data:
- name, surname, and job title or contact information including the e-mail address and telephone number;
- personal information such as address, postcode, country;
- one or more characteristic elements of his or her physical, cultural or social identity.
This information falls under the definition of personal data, i.e. any information concerning an identified or identifiable physical person (the “Data Subject”); identifiable refers to physical persons who can be identified, directly or indirectly, with particular reference to data such as the name, identification number, data concerning their location, an online ID or one or more characteristic elements of his or her physical, physiological, genetic, mental, economic, cultural or social identity (the “Personal Data”).
1.3 Board and its commercial partners or service providers (as it may be the case) may record audio and video in the course of the providing the Service only if all the users have provided their prior, explicit, and written consent. Photos and videos may be edited, copied, exhibited, published or distributed and the video may be transcribed in a writing form. Such recordings may be used for internal purposes such as training or service improvement, but only where the consent has been voluntarily given, and users have been fully informed of:
- the purpose of the recording;
- the recipients of the data;
- who can access the data;
- and the duration of the storage.
Recordings will not commence unless and until consent has been documented.
Users must be made aware that:
- participation is voluntary and not contingent on agreeing to the recording;
- they have the right to revoke consent at any time, and this will result in the immediate cessation of the recording.
2. Purposes of the processing
2.1 The Personal Data may be processed, for purposes linked to the provisions of the Service and, for example, to record and transcript the meeting, for the administrative management of the participation, for the execution of specific activities and for the sending of email referring to the Service.
2.2 The Personal Data provided by you may be processed also to provide online security for the Services, and to comply with the applicable laws, regulations, court orders, government, and law enforcement requests, to investigate security and privacy incidents, and to manage any customer disputes.
2.3 Photographic, audio, and video recordings will only be processed with valid written consent, and such consent must be obtained in advance and documented. These recordings may be used for internal training purposes, onboarding, and improving business relationships with existing or prospective customers, but only within the scope clearly disclosed to the Data Subject at the time of consent.
3. Methods of processing
3.1 Your Personal Data is collected by the parties set forth at clause 6 of this Privacy Policy, and the related processing is carried out using manual or computerised automated instruments with logics strictly linked to the purposes described above and, in any case, to guarantee the security and confidentiality of the Personal Data.
4. Legal basis of the processing of Personal Data and withdrawal of the consent
4.1 The provision of Personal Data (described in article 1) by you is absolutely optional and does not represent a legal requirement; however, in some cases, the provision of your Personal Data could be required to perform the activities related to the Service.
You may, at any time, revoke your authorization for the recording of video by notifying the Privacy Committee at the email address [email protected] in writing. Upon revocation, the recording or use of personal data shall no longer be permissible in connection with the use of Salesloft. Revocation of consent shall not affect the lawfulness of the data processing based on consent gave before its withdrawal, but it will prohibit further use.
5. Categories of persons to whom the Personal Data may be disclosed
5.1 The Personal Data collected for the purpose of the provision of the Service under clause 2 may be disclosed to companies performing activities which are strictly linked and instrumental to the provision of the Service, such as Salesloft, and Microsoft Teams. Such Personal Data may be transferred to associated companies and/or companies within the Board Group or third parties even located outside the European Union, where there are in place the appropriate safeguards (guarantee of an appropriate level of protection) set forth by the European Commission.
5.2 The Personal Data collected for the purposes listed at clause 2 may be transferred to third parties within the Board Group and/or other third parties (located inside or outside the European Union). The list of the third parties to whom your Personal Data has been disclosed may be requested to Board using the e-mail address set forth in clause 7.4.
6. Controller, Processors and Representatives
6.1 Data Controller or Controller refers to the physical or legal person, public authority, service or other body which, individually or with others, determines the purposes and means of the processing of Personal Data; where the purposes and means of such processing are determined by the European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by the European Union or Member State law.
6.2 The Controllers are Board International SA with registered office in Via Maestri Comacini 4, Chiasso, Ticino 6830, Switzerland, and the other companies in the Board Group which work autonomously and independently in the processing of Personal Data, in particular the following companies:
- Board (Australia) Pty. Ltd., with offices at Suite 22.03, Level 22, 111 Pacific Hwy, North Sydney, New South Wales Australia 2060;
- Board Belgium BV, with offices at Unit 2.29, The Office Operators, Leonardo Da Vincilaan 9, B-1930 Zaventem (Belgium);
- Board Benelux B.V., with offices at De Entree 232 – 4.07 1101 EE Amsterdam (The Netherlands);
- Board Canada, Ltd., with offices at 88 Queens Quay West Suite 2500 Toronto ON M5J 0B8;
- Board Intelligence Management France S.a.s., with offices at 2-4, rue Paul Cézanne, 75008 Paris (France);
- Board Deutschland GmbH, with offices at Hanauer Landstraße 176, 60314 Frankfurt am Main (Germany);
- Board Software (India) Private Limited, with offices at 1305, 13th Floor, Marathon Icon, Off. Ganpatrao Kadam Marg, Opp. Peninsula Corporate Park, Lower Parel-West, Mumbai, Maharashtra, 400013 (India);
- Board Italia S.r.l., with offices at Via Caduti di Marcinelle n. 5, 20134 Milan (Italy);
- Board Japan Inc, with offices at Marunouchi Kitaguchi Bldg., 1-6-5 Marunouchi, Chiyoda-ku, Tokyo 100-0005 (Japan);
- Board Scandinavian AB, with offices at Västra Trädgårdsgatan 15, 111 53 Stockholm (Sweden);
- Board M.I. IBERICA, S.L., with offices at Calle de Mendez Alvaro, 20 Madrid 28045 Spain;
- Board M.I.T. Limited, with offices at Penrose House, 67 Hightown Road, Banbury, Oxfordshire, OX16 9BE;
- Board Americas, Inc., with offices at 18 Tremont Street, 7th Floor Boston, MA 02108 (USA).
6.3 The Controllers appoint external Processors to achieve the purposes specified at clause 2. It is possible to request a complete list of external Processors by sending an e-mail to the e-mail address set forth at clause 7.4 of this policy.
6.4 Data Subjects may exercise their rights towards each Controller.
7. Rights of the data Subjects
7.1 You have the right, at any time, to obtain confirmation from the Controller as to whether or not Personal Data concerning you is being processed, to know its origin, purposes and methods of processing; you also have the right to request the updating, correction, integration, erasure, transformation into an anonymous form, the suspension of any data processed in violation of the relevant legislation, including those which are no longer necessary to pursue the purposes for which they were collected and/or subsequently processed.
7.2 You have the right to object, wholly or partially, to the processing of your Personal Data for legitimate reasons, even where this is still relevant for the purpose for which they were collected, and to the processing of your Personal Data for the purpose of commercial information or the sending or advertising materials or direct sales or for the execution of market research or commercial communication.
7.3 You have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and to transmit those data to another controller.
7.4 To exercise your rights or to revoke a previously given consent, please write to the specific e-mail address: [email protected]. The consent for recording must:
- Be given in advance of any recording,
- Be documented in writing,
- Clearly describe the purpose, recipients, access rights, and retention periods, and
- Be revocable at any time.
7.5 Please note that you also have the right to lodge a complaint with the competent supervisory authority.
8. Period for which the Personal Data is processed
8.1 Your Personal Data will be retained in hard copy and/or electronic/computerized/optical format for the time strictly necessary to meet the purposes indicated at clause 2, in compliance with the applicable laws and/or the contractual relationship. Board has defined the specific duration of the storage of the Personal Data for each type of Personal Data collected. At the end of such periods, Board will definitively erase your Personal Data.
9. Amendments
9.1 This Privacy Policy may be subject to amendments. Any substantial amendment to the collection or processing of recorded data will be communicated by Board via e-mail to all users, and renewed consent will be required if changes materially affect the processing conditions.
9.2. Board has implemented this policy to ensure strict compliance with data privacy standards and to protect the rights of individuals.
10. Contacts
For any information or request which relates to this Privacy Policy, please contact us (Board International, Via Maestri Comacini 4, Chiasso, Ticino 6830, Switzerland) at the e-mail address [email protected].