Effective Date: May 25, 2018

Entities: Demandbase, Inc. (“Demandbase”).

Adherence to Privacy Shield Principles: Demandbase has applied for and adheres to the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland as to personal data submitted by Demandbase customers or collected by Demandbase through its products and services. Demandbase is committed to subjecting all personal data received from the EU and Switzerland, in reliance on the Privacy Shield Principles, to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access and recourse, enforcement, and liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification (once granted), please visit https://www.privacyshield.gov/list. In some cases, Demandbase may also process EU personal data received from customers or Partner Sites via other means, such as data processing agreements including the EU Standard Contractual Clauses.

Personal Data Processing under Privacy Shield: Demandbase has a comprehensive ABM Platform that helps its customers better reach their current and potential B2B customers. Demandbase products include advertising, when instructed on behalf of its customers or when data is provided to Demandbase, and data analytics. Demandbase customers typically provide Demandbase with information about their business customers and prospects, employees, and contact details of the foregoing types of data subjects. Through its services, Demandbase also receives personal information, such as online identifiers and IP address.

Demandbase’s Purposes for Processing Personal Data: Demandbase uses the personal information to provide and strengthen its services for customers. As part of its services, Demandbase may access personal data, use it to provide customer service, monitor and analyze trends, understand activity and usage, and use it to provide its customers with improved products and services. Demandbase may also share information with customers and partners based upon visits to their site. Demandbase may combine this personal data with non-personal data to help companies better understand their business prospects and customers and their interests as well as reach them through Demandbase’s advertising solutions.

Privacy Inquiries and Complaints: If you are a resident of the European Economic Area (“EEA”) and your country participates in Privacy Shield, then you may contact us with any privacy inquiries or complaints in scope of this notice to privacy[at]demandbase.com or via mail to:

Demandbase, Inc.
Attn: Privacy
680 Folsom Street, Suite 400
San Francisco, CA 94107 USA

In the event that Demandbase does not respond to your complaint in a timely manner or your complaint is not satisfactorily addressed, Demandbase has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to JAMS, an alternative dispute resolution provider located in the United States. In such case, you may visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint free of charge.

JAMS
EU-US Privacy Shield
3800 Howard Hughes Parkway, 11th Floor
Las Vegas, NV 89169
U.S.A.

If neither Demandbase nor JAMS resolve your complaint, under certain limited conditions, you may be able to invoke binding arbitration. Prior to initiating such arbitration, you must be a resident of an EEA country participating in the Privacy Shield and take the following steps: (1) contact Demandbase and afford us the opportunity to resolve the issue; (2) seek assistance from https://www.jamsadr.com/eu-us-privacy-shield; and (3) contact the US Department of Commerce (either directly or through a European Supervisory Authority) and afford the Department of Commerce time to attempt to resolve your inquiry. If you choose to invoke binding arbitration, then each party will be responsible for its own attorney’s fees. Under the Privacy Shield, the arbitrator(s) may only impose individual-specific, non-monetary, equitable relief to remedy any violation of the Privacy Shield Principles with respect to you.

Choice and Means to Limit Use and Disclosure of Personal Data: If you are a resident of an EEA country participating in Privacy Shield, then you have the right to access your data and limit its use and disclosure. Demandbase makes available an opt-out to its cookie-based tracking via the Digital Advertising Alliance’s WebChoices tool. For additional requests and means to limit use and disclosure, you may visit our Privacy Policy or contact privacy@demandbase.com.

Third Parties With Whom We Share Personal Data: Demandbase uses third party service providers to carry out our services, provide support, such as technical assistance, analytics, data storage and hosting, database monitoring, and payment processing. These third parties may access, process, or store personal data while providing their services on our instructions. Demandbase has contracts with these third parties restricting their rights to access, use, and disclose personal data. Demandbase complies with the Privacy Shield Principles for all onward transfers of personal data from the EEA and Switzerland, and may be held liable if both: (i) these third parties process personal data inconsistent with the Privacy Shield Principles and (ii) Demandbase is found responsible for the event giving rise to the damage.

Subject to FTC Jurisdiction: Demandbase is subject to the regulatory and enforcement powers of the Federal Trade Commission.

Legal Disclosure: Demandbase may be legally compelled to disclose personal data to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.