This Privacy Policy describes how Sales Copilot, Inc (d/b/a HeySam) - (collectively “HeySam”, “we”, “us”, and “ours”) collects, stores, uses and discloses the following categories of personal data:
1. Customer Data: personal data (as defined in Section 1) that we collect, process and manage on behalf of our business customers (each, a “Customer”; collectively, “Customers”), as part of the HeySam products and services described on one or more applicable order forms (“Platform”).
We process such Customer Data on behalf of and under the instruction of the respective Customer, in accordance with our Data Processing Addendum with them. Accordingly, this Privacy Policy (which describes HeySam’s privacy and data processing practices) does not apply to the privacy and data processing practices of our Customers. To learn about the privacy policy and practices of our Customers, please contact them directly.
2. User Data: personal data concerning individuals acting on behalf of our Customers in respect of their engagement with HeySam, and users of the Platform on behalf of such Customers, e.g., the account administrators and users, billing contacts and authorized signatories on behalf of the Customer (collectively, “Users”); as well as the Customer’s business needs and preferences, as identified to us or recognized through our engagement with them;
3. Prospect Data: data relating to visitors of our website (www.heysam.ai), participants at our events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts with our website, online ads and content, emails, integrations or communications under our control (the “Sites”, and collectively with the Platform, the “Services”).
1. Customer Data: personal data (as defined in Section 1) that we collect, process and manage on behalf of our business customers (each, a “Customer”; collectively, “Customers”), as part of the HeySam products and services described on one or more applicable order forms (“Platform”).
We process such Customer Data on behalf of and under the instruction of the respective Customer, in accordance with our Data Processing Addendum with them. Accordingly, this Privacy Policy (which describes HeySam’s privacy and data processing practices) does not apply to the privacy and data processing practices of our Customers. To learn about the privacy policy and practices of our Customers, please contact them directly.
2. User Data: personal data concerning individuals acting on behalf of our Customers in respect of their engagement with HeySam, and users of the Platform on behalf of such Customers, e.g., the account administrators and users, billing contacts and authorized signatories on behalf of the Customer (collectively, “Users”); as well as the Customer’s business needs and preferences, as identified to us or recognized through our engagement with them;
3. Prospect Data: data relating to visitors of our website (www.heysam.ai), participants at our events, and any other prospective customer, user or partner (collectively, “Prospects”) who visits or otherwise interacts with our website, online ads and content, emails, integrations or communications under our control (the “Sites”, and collectively with the Platform, the “Services”).
Specifically, this Privacy Policy describes our practices regarding:
1. Data Collection & Processing
2. Data Uses
3. Data Location
4. Data Retention
5. Data Disclosure
6. Communications
7. Data Security
8. Data Subject Rights
9. Data Controller/Processor
10. Opt-Out of Sale/Sharing
11. Additional Notices & Contact Details
2. Data Uses
3. Data Location
4. Data Retention
5. Data Disclosure
6. Communications
7. Data Security
8. Data Subject Rights
9. Data Controller/Processor
10. Opt-Out of Sale/Sharing
11. Additional Notices & Contact Details
If you are a Customer, User or Prospect, please read this Privacy Policy carefully and make sure that you fully understand it.
Our Services are designed for businesses and are not intended for personal or household use. Accordingly, we treat all personal data covered by this Privacy Policy, including information about any visitors to our Sites, as pertaining to individuals acting as business representatives, rather than in their personal capacity.
You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us and avoid any interaction with us or with our Sites, or use our Services.
1. Data Collection & Processing
When we use the terms “personal data” or “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.Sometimes we collect personal data automatically when an individual interacts with our Services or Sites and sometimes we collect personal data directly from an individual. At times, we may collect personal data about an individual from other sources and third parties (such as our Customers and Service Providers), even before our first direct interaction. HeySam does not collect, use, or disclose sensitive personal data.
We may collect or generate the following types of personal data about individuals through the Services:
We may collect or generate the following types of personal data about individuals through the Services:
- Usage, login credentials, and device information concerning Users and Prospects (connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, log-in credentials to the Services, the cookies and pixels installed or utilized on their device, and inferred or presumed data generated from their use of the Services);
- Information concerning our Customers, Users and Prospects contact and business details such as name, email, phone number, position, workplace and related business insights, our communications with such individuals (correspondences, sensory information including call and video recordings, and transcriptions and analyses thereof), feedback and testimonials received, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement);
- Personal data contained in Customer Data which is provided by our Customers or processed on their behalf and under their instruction. This may include any of the types of personal data described above (with respect to Users or other individuals whose data is contained in the Customer Data), in accordance with our Data Processing Addendum with them.
For the purposes of the California Consumer Privacy Act (“CCPA”), in the last 12 months, we may have collected the following categories of Personal Information, as defined in the CCPA: identifiers; customer record information; internet or other electronic network activity information; professional or employment-related information; geolocation data; commercial information; inferences; and audio, electronic, and visual information.
2. Data Uses
We use personal data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services, e.g., in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Customers, Users, Prospects, ourselves and our Services (“Legitimate Interests”).
If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing) (“Consent”), your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at privacy@heysam.ai.
Specifically, we use personal data for the following business and commercial purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing) (“Consent”), your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at privacy@heysam.ai.
Specifically, we use personal data for the following business and commercial purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):
Customer and User personal data
- To facilitate, operate, enhance, and provide our Services (Performance of Contract; Legitimate Interests);
- To provide technical support, troubleshooting, and customer service (Performance of Contract; Legitimate Interests);
- To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities to make our Services easier to use (Performance of Contract; Legitimate Interests);
- To deliver relevant advertising and marketing communications based on your preferences and interactions (Legitimate Interests; Consent);
- To facilitate, sponsor and offer certain events, contests and promotions (Legitimate Interests).
Customer, User and Prospect personal data
- To analyze service usage, optimize performance, and improve user experience, including through AI and machine learning (Legitimate Interests);
- To contact our Customers, Users and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (Performance of Contract; Legitimate Interests; Consent);
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity (Performance of Contract; Legitimate Interests; Legal Obligation);
- To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose (Legitimate Interests);
- To enforce our Terms and Conditions, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties (Legitimate Interests);
- To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards (Performance of Contract; Legitimate Interests; Legal Obligation);
- For any other lawful purpose, or other purpose that you consent to (Legal Obligation; Consent).
3. Data Location
We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States of America and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.
While privacy laws may vary between jurisdictions, HeySam is committed to protect personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
HeySam complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce and will be further liable in cases of onward transfers of your personal data to third parties (including our Service Providers).
HeySam 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) regarding the processing of personal data received from the European Union in reliance on the EU-U.S. DPF, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.
HeySam has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) regarding the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.
If there is any conflict between the terms in this policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern for personal data transferred under the DPF. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit www.dataprivacyframework.gov.
While privacy laws may vary between jurisdictions, HeySam is committed to protect personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.
HeySam complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce and will be further liable in cases of onward transfers of your personal data to third parties (including our Service Providers).
HeySam 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) regarding the processing of personal data received from the European Union in reliance on the EU-U.S. DPF, and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.
HeySam has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) regarding the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.
If there is any conflict between the terms in this policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern for personal data transferred under the DPF. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit www.dataprivacyframework.gov.
4. Data Retention
We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
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 the applicable legal requirements.
If you have any questions about our data retention policy, please contact us by e-mail at privacy@heysam.ai.
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 the applicable legal requirements.
If you have any questions about our data retention policy, please contact us by e-mail at privacy@heysam.ai.
5. Data disclosure
We disclose personal data in the following ways:
Service Providers:
We engage third-party service providers for:
- Infrastructure (hosting, servers, content delivery)
- Security and fraud prevention
- Analytics and performance monitoring
- Communication and marketing
- Payment processing
- Customer support and CRM
- Professional services (legal, financial, compliance) (collectively, “Service Providers“)
Our Service Providers may have access to personal information, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
Service Integrations:
You may choose to use a third-party service to integrate with our Services, for example in order to upload or retrieve personal data to or from the Services, or to enrich the data you have processed on either service or enhance your usage thereof (provided that such integration is supported by our Services). The provider of this integrated third-party service may receive certain relevant data about or from your account on the Services, or share certain relevant data from your account on the third-party provider’s service with our Services, depending on the nature and purpose of such integration. This could include your Customer Data and/or User Data. Note that we do not receive or store your passwords for any of these third-party services (but do typically require your API key in order to integrate with them).
Event Sponsors:
If you attend an event or webinar organized by us, or download or access an asset on our Sites related to such an event, webinar or other activity involving third-party sponsors or presenters, we may share your personal data with them. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your personal data will be subject to the sponsors’ privacy statements. If you do not wish for your personal data to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with Section 8 below;
Business Customers:
Our Customers have access to any personal data we process on their behalf in our capacity as a “processor” or a “service provider.”
Legal Compliance:
We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Protecting Rights and Safety:
We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of HeySam, any of our Users or Customers, or any members of the general public.
HeySam Subsidiaries and Affiliated Companies:
Should HeySam undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. We may disclose personal data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.
For the avoidance of doubt, HeySam may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
For the purposes of the CCPA, in the past 12 months, we may have disclosed the following categories of Personal Information, as defined in the CCPA: identifiers; customer record information; internet or other electronic network activity information; professional or employment-related information; geolocation data; commercial information; inferences; and audio, electronic and visual information to Service Providers, partnerships, service integrations, for legal compliance, or to protect rights and safety. We may have disclosed identifiers and customer record information to event sponsors. We do so in pursuit of the business and commercial purposes described in Section 2 above.
For the avoidance of doubt, HeySam may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
For the purposes of the CCPA, in the past 12 months, we may have disclosed the following categories of Personal Information, as defined in the CCPA: identifiers; customer record information; internet or other electronic network activity information; professional or employment-related information; geolocation data; commercial information; inferences; and audio, electronic and visual information to Service Providers, partnerships, service integrations, for legal compliance, or to protect rights and safety. We may have disclosed identifiers and customer record information to event sponsors. We do so in pursuit of the business and commercial purposes described in Section 2 above.
6. Communications
We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications:
We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. You can manage most communication preferences in your profile settings, but you cannot opt out of essential service messages.
Promotional Communications:
We may send marketing messages about our offerings and updates through email, phone, or other channels. You can opt out of these communications at any time.
If you do not wish to receive such promotional communications, you may notify HeySam at any time by sending an e-mail to: privacy@heysam.ai, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
7. Data Security
We use industry-standard security measures to protect your personal data. However, no online service is completely secure. We cannot guarantee absolute protection against unauthorized access or misuse.
8. Data Subject Rights
Individuals have rights concerning their personal data. Please contact us by e-mail at: privacy@heysam.ai if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR), the Brazilian Data Protection Act (LGPD), the CCPA, or the Swiss Federal Act on Data Protection (FADP) . Such rights may include – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with HeySam, or to restrict or object to such personal data processing (including the right to direct us not to sell or share your personal data to third parties now or in the future, as described below), or to port such personal data, or the right to equal services and prices (e.g., freedom from discrimination) (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable. If you are an LGPD-protected individual, you also have the rights to confirmation of existence of processing; to request review of decisions made solely based on automatic decisions that affect your interests; to lodge a complaint with the supervisory authority and with consumer protection authorities in Brazil.
To the extent applicable to you, you may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.
Please note that when you or an authorized agent ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. If your request relates to personal data that may be processed on our Customer’s behalf, as their “data processor” or “service provider” (as further explained in Section 9 below), note that such Customer exclusively determines how such data is processed, as well as if and how your request should be handled – so we advise that you submit your request directly to them. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal data, or that such data is processed on behalf of one of our Customers, so that we may forward it to such Customer for their further handling. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request, or proof of request fulfillment).
We may redact from the data which we will make available to you, any personal data or confidential information related to others.
In compliance with the EU-U.S. DPF, and the UK Extension of the EU-U.S. DPP and the Swiss-U.S. DPF Principles, we commit to resolve complaints about our collection or use of your Personal Information. EEA, UK and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework compliance should submit inquiries to dpo@heysam.ai. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, HeySam, Inc. has further committed to cooperate with EU Data Protection Authorities (DPAs), the UK Information Commissioner Office (UK ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to independently address complaints that we have been unable to resolve.
Please note that under certain conditions, you can invoke a binding arbitration by delivering a notice to us via dpo@heysam.ai. Please also note that HeySam is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
To the extent applicable to you, you may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.
Please note that when you or an authorized agent ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. If your request relates to personal data that may be processed on our Customer’s behalf, as their “data processor” or “service provider” (as further explained in Section 9 below), note that such Customer exclusively determines how such data is processed, as well as if and how your request should be handled – so we advise that you submit your request directly to them. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal data, or that such data is processed on behalf of one of our Customers, so that we may forward it to such Customer for their further handling. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request, or proof of request fulfillment).
We may redact from the data which we will make available to you, any personal data or confidential information related to others.
In compliance with the EU-U.S. DPF, and the UK Extension of the EU-U.S. DPP and the Swiss-U.S. DPF Principles, we commit to resolve complaints about our collection or use of your Personal Information. EEA, UK and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework compliance should submit inquiries to dpo@heysam.ai. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, HeySam, Inc. has further committed to cooperate with EU Data Protection Authorities (DPAs), the UK Information Commissioner Office (UK ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to independently address complaints that we have been unable to resolve.
Please note that under certain conditions, you can invoke a binding arbitration by delivering a notice to us via dpo@heysam.ai. Please also note that HeySam is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
9. Data Controller / Processor
Certain data protection laws and regulations, such as the EU GDPR, UK GDPR, Brazilian Data Protection Act, and the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
HeySam is the “data controller” of Prospect Data. With respect to such data, we assume the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.
HeySam is the “data processor” of Customer Data, which we process on behalf of our Customer (who is the “data controller” of such data); and our Service Providers who process such Customer Data on our behalf are the “sub-processors” of such data.
HeySam is both a “data controller” and “data processor” of User Data. Such data is processed by HeySam for its own purposes (as described in Section 2 above), as an independent ‘controller’; whilst those certain portions of it which are included in Customer Data will be processed by us on our Customer’s behalf, as a ‘processor’.
Accordingly, HeySam processes Customer Data strictly in accordance with our Customer’s reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such Customer.
Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the Customer, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.
HeySam is the “data controller” of Prospect Data. With respect to such data, we assume the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.
HeySam is the “data processor” of Customer Data, which we process on behalf of our Customer (who is the “data controller” of such data); and our Service Providers who process such Customer Data on our behalf are the “sub-processors” of such data.
HeySam is both a “data controller” and “data processor” of User Data. Such data is processed by HeySam for its own purposes (as described in Section 2 above), as an independent ‘controller’; whilst those certain portions of it which are included in Customer Data will be processed by us on our Customer’s behalf, as a ‘processor’.
Accordingly, HeySam processes Customer Data strictly in accordance with our Customer’s reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such Customer.
Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the Customer, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.
10. Opt-Out of Sale / Sharing
Some cookie-based sharing may be considered a "sale" under US privacy laws. We share this data for the purposes described in Section 2.
For the purposes of the CCPA, in the last 12 months we may have “sold” or “shared” Internet or other electronic network activity information, Geolocation data, Commercial information, and Inferences with our analytics and advertising Service Providers. HeySam has not knowingly sold or shared the personal information of individuals under the age of 16.You may opt out of all Cookies that may result in a “sale” and/or “sharing” of your personal information in the following ways:
For the purposes of the CCPA, in the last 12 months we may have “sold” or “shared” Internet or other electronic network activity information, Geolocation data, Commercial information, and Inferences with our analytics and advertising Service Providers. HeySam has not knowingly sold or shared the personal information of individuals under the age of 16.You may opt out of all Cookies that may result in a “sale” and/or “sharing” of your personal information in the following ways:
- Click the “Your Privacy Choices” button (available in our website’s footer), move the toggle switch next to “Share or Sale of Personal Information” to grey (disabled), then click the “Confirm my Choices” button.
- Please note: If you visit us from a different device or browser, or clear cookies, then you need to return to this screen to re-select your preferences.
Set the Global Privacy Control (GPC) for each participating browser system that you use to opt out of the use of third-party Advertising or other cookies (instructions on how to download and use GPC are available here).
11. Additional Notices & Contact Details
Updates and Amendments:
We may update this Privacy Policy. We'll notify you of material changes that affect your rights. Changes take effect when published.
External Links:
Our Services may link to other websites. This Privacy Policy only covers our Services. Review other sites' privacy policies when visiting them.
Children:
Our Services are not designed to attract children under the age of 16. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at privacy@heysam.ai.
Data Protection Officer:
HeySam has appointed Mr. Manuel Napoli, as our Data Protection Officer (DPO), for monitoring and advising on HeySam’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your Privacy, or if you wish to make a complaint about how your personal data is being processed by HeySam, you can contact privacy@heysam.ai.
EU and UK Representative:
Dp-Dock GmbH has been designated as HeySam’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Dp-Doc has also been designated as HeySam’s representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. You can reach out to them at
For EU: DP-Dock GmbH, Attn: [SALES COPILOT, INC], Ballindamm 39, 20095 Hamburg,Germany
For UK: DP Data Protection Services UK Ltd., Attn: [SALES COPILOT, INC], 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom
www.dp-dock.com
heysam@gdpr-rep.com
For EU: DP-Dock GmbH, Attn: [SALES COPILOT, INC], Ballindamm 39, 20095 Hamburg,Germany
For UK: DP Data Protection Services UK Ltd., Attn: [SALES COPILOT, INC], 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom
www.dp-dock.com
heysam@gdpr-rep.com
Contacting Us:
If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact HeySam’s support at privacy@heysam.ai.
