Privacy Policy

Privacy Policy

 

Effective date / date last updated: January 8, 2024

Emissary provides intelligence for enterprise sales, marketing and product teams (i.e., our business clients) that is sourced from a network of executive advisors from target accounts (i.e., Emissarys). This Privacy Policy describes how LeRoy Technologies, Inc., d/b/a Emissary (“Emissary,” “we”, “us” or “our”) processes personal information that we collect through our website at https://emissary.io/, our sales intelligence platform (Emissary Knowledge), and any other digital properties that we own or control and that posts or links to this Privacy Policy (collectively, the “Service”), as well as through our interviews with our executive advisors, our social media pages, our marketing activities and other activities described in this Privacy Policy. 

This Privacy Policy does not apply to information that we process on behalf of our business customers (such as businesses and other organizations) while providing our services to them, nor to the information that our business customers collect directly from executive advisors while using the Service. If you have questions regarding your personal information that we process on behalf of a business customer or would like to exercise any rights you may have with respect to such information, please direct your questions or requests to that business customer.

We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as representatives of the relevant business customers and not in their individual capacities. European users: If you are located in the European Economic Area (the “EEA”) or the United Kingdom (the “UK”), please read the Notice to European Users below in addition to this Privacy Policy for information about your personal information and your privacy rights.

Index

 

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, current and former professional title(s) and company name(s), job function(s), job start/end dates, and phone number.
  • Account data, such as the username and password that you may set to establish an online account with us, photograph or picture, target account information, links to your profiles on social networks, and any other information that you may add to your account profile.  
  • Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise. 
  • Research data, such as your responses to surveys and questionnaires that we might ask you to complete for research purposes related to the Service, your responses to interviews, and your calls with us or a business customer or an executive advisor, as applicable. Your calls may also be recorded for these purposes.
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
  • Payment data needed to complete transactions, including country of residence and other payment card information you submit to the Service to pay us or account information you provide to us to make payments to you.
  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

  • Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages you viewed, how long you spent on a page, the website you visited before browsing to the Service, navigation paths between pages, information about your activity on a page, access times and duration of access, and whether you have opened our emails or clicked links within them.
  • Communication interaction data, such as your interactions with our email or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails. 

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

  • provide and operate the Service and our business;
  • personalize the Service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
  • establish and maintain your user account;
  • communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
  • understand your needs and interests, and personalize your experience on the Service and our communications; and
  • provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information (including your responses to surveys and questionnaires and your call recordings with business clients or executive advisors, as applicable) for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

  • Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.  
  • Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section of our Cookie Notice. 

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
  • protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); 
  • audit our internal processes for compliance with legal and contractual requirements or our internal policies; 
  • enforce the terms and conditions that govern the Service; and 
  • prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.  

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.  

How we share your personal information

We may disclose your personal information to the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.  

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as information technology, customer support, email delivery, marketing, research and analytics). 

Business clients and Executive advisors. Certain of your personal information (e.g., limited contact data) may be shared with business clients or executive advisors in connection with an engagement service.

Payment processors. Any payment data is collected and processed directly by our payment processors, Veem and Tipalti. Veem may use your payment data in accordance with its privacy policy, https://www.veem.com/legal/#privacy-policy, and Tipalti may use your payment data in accordance with its privacy policy, https://tipalti.com/privacy/. 

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above. 

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations of or due diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Emissary (including, in connection with a bankruptcy or similar proceedings).

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights in the Notice to European Users below.

Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account. 

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.  

Cookies. For information about cookies employed by the Service and how to control them, see our Cookie Notice. 

Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track”. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Linked third-party platforms. If you choose to connect to the Service through a third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

Other sites and services

The Service may contain links to third party websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions, nor are they subject to this Privacy Policy. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfers

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.  

Users in Europe should read the important information provided in the Notice to European Users below about the transfer of personal information outside of Europe. 

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.

 

How to contact us

  • Email: support@emissary.com
  • Phone: (646) 776-0501

Notice to European users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies where we are processing the personal information of individuals located in the EEA or the UK (EEA and UK jurisdictions are together referred to as “Europe”) as a controller.

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from which they are either directly identified or can be identified.   

Controller. Emissary is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (including the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the How to contact us section above for our contact details.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:

Our Representative in the EU. Our EU representative appointed under the EU GDPR is [insert]. You can contact them:

  • By email to: datarequest@datarep.com (quoting <Emissary, Inc.> in the subject line
  • By postal mail to: DataRep, The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland 

Our Representative in the UK. Our UK representative appointed under the UK GDPR is [insert]. You can contact them:

  • By email to: datarequest@datarep.com (quoting <Emissary, Inc.> in the subject line
  • By postal mail to: DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdon 

Our legal bases for processing 

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use. 

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

  • Where we need to process your personal information to deliver our Service to you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).  

We have set out below, in a table format, the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see How we use your personal information above.

PurposeCategories of personal information involvedLegal basis
Service delivery and operations
  • Contact data
  • Account data
  • Communications data
  • Research data
  • Payment data
  • Compliance with Law. If we are legally obliged to respond to your request.
  • Legitimate Interests. In all other cases – our legitimate interests to develop and communicate about our organization.
Research and development 
  • Any and all data types relevant in the circumstances
  • Legitimate interest. We have legitimate interest in understanding what may be of interest to our customers, improving customer relationships and experience, delivering relevant content to our customers, measuring and understanding the effectiveness of the content we serve to customers.
Marketing
  • Contact data
  • Account data 
  • Communications data
  • Marketing data
  • Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose.
  • Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Security
  • Contact data
  • Device data
  • Online activity data
  • Compliance with Law.
  • Legitimate Interests. We have a legitimate interest in ensuring the ongoing security and proper operation of our Service and associated IT services, systems, and networks.
Compliance and protection
  • Any and all data types relevant in the circumstances
  • Compliance with Law.
  • Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
Further uses 
  • Any and all data types relevant in the circumstances
  • The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected. 
  • Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

 

Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.  

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 

When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects. We will let you know if that changes by updating this Privacy Policy.

Security. We have put in place procedures designed to deal with breaches of personal information. In the event of such breaches, we have procedures in place to work with applicable regulators. In addition, in certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal information.

Your rights

General. European data protection laws give you certain additional rights regarding your personal information. If you are located in Europe, you may ask us to take any of the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.
  • Correct. Update or correct inaccuracies in your personal information.
  • Delete. Delete your personal information where there is no lawful reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons that will be notified to you, if applicable, at the time of your request. 
  • Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Restrict. Restrict the processing of your personal information, if, (i) you want us to establish the personal information’s accuracy; (ii) where our use of the personal information is unlawful but you do not want us to erase it; (iii) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.
  • Object. Object to our processing of your personal information where we are relying on legitimate interests – you also have the right to object where we are processing your personal information for direct marketing purposes.
  • Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. 

Exercising These Rights. You may submit these requests by email to advisor-support@emissary.io or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. 

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence. 

  • For users in the EEA – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
  • For users in the UK – the contact information for the UK data protection regulator is below:

Data processing outside Europe  

We are a US-based company and many of our service providers, advisers, partners or other recipients of data are also based in the US. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the US. It may also be provided to recipients in other countries outside Europe.  

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it. 

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at advisor-support@emissary.io.

 

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