Table of Contents
INTRODUCTION KEY DEFINITIONS INFORMATION WE COLLECT HOW WE USE YOUR PERSONAL DATA HOW WE DISCLOSE YOUR PERSONAL DATA DATA RETENTION HOW WE PROTECT YOUR PERSONAL DATA INTERNATIONAL TRANSFERS OF PERSONAL DATA PRIVACY RIGHTS AND CHOICES CONTACT INFORMATION
INTRODUCTION
This Privacy Policy explains how Semrush collects, uses, stores, discloses and otherwise processes the personal data we collect when you use and interact with our websites and apps that display or link to this Privacy Policy, register for an account and use our Services, visit our branded social media pages, register for, attend or take part in our events, webinars, or contests, participate in our academy or otherwise interact with us in person and/or by email, text message, instant messaging, telephonically, and by other electronic means. It also tells you about your rights and choices with respect to your personal data, and how you can contact us if you have any questions or concerns.
This Privacy Policy does not apply to our handling of personal data that we process on behalf of our business customers as a service provider or processor. Our processing of that information is governed by our agreement with our business customers.
Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, you should not use our website and the Services or otherwise provide us with your personal data. By using and/or accessing our website and the Services or otherwise providing us with your personal data, you acknowledge that you have read and understood this Privacy Policy. Your use of our websites and the Services is also governed by our Terms of Service.
This Privacy Policy is effective as of the date first set forth above. We may update this Privacy Policy from time to time. If we make changes, we will post the updated Privacy Policy on this page or another page that links to this page and change the date at the top of this webpage. We encourage you to look for updates and changes to this Privacy Policy by checking this date when you access our website. We will notify you of any modifications to this Privacy Policy that might materially affect the way we use or disclose your personal data prior to the change becoming effective by means of a message on this website, unless another type of notice is required by the applicable law. Your continued use of the website and our Services after we have posted changes to this Privacy Policy or notified you, if applicable, is deemed to be your acceptance of those changes.
KEY DEFINITIONS
“Affiliates“ means entities in our group who are listed in this Privacy Policy (please read the Affiliates section).
“European Data Protection Law” means the General Data Protection Regulation (EU) 2016/679 (GDPR) and applicable national legislation implementing the GDPR and, if applicable, the UK data Protection Act 2018 and the UK GDPR.
“Privacy Policy” refers to this Privacy Policy.
“SELL2EUROPE”, “we”, “us” and/or “our” refers to SELL2EUROPE and its Affiliates, unless specified otherwise.
“Services” refers to our Software as a Service professional service made available via our websites.
“You” and “your” refers to the individual to whom personal data covered by this Privacy Policy relates.
INFORMATION WE COLLECT
Some of our website’s functionality can be used without providing any personal data, though for using some features of the Services, personal data is required. We process three broad categories of personal data:
- Information provided directly by you;
- Information received from third parties; and
- Information collected automatically.
- Information Provided Directly by You
Account registration. If you register with the Services through our website at https://www.sell2europe.com/ , or through a separate subscription agreement with us, then as part of such registration we will ask you to provide certain personal data, including your name, your company name, your email address and password. If you create an account or log into the Services using third-party services, such as Google, Facebook or LinkedIn, we will receive your name and email address and/or phone number as permitted by your profile settings on the third-party service in order to authenticate you. The information we receive when you authenticate through a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in the relevant third-party services to understand what data may be disclosed to us or shared with our Services.
Communication with Semrush. We collect personal data that you voluntarily give us when you contact us with inquiries (including by filling out relevant forms on our websites), engage with our chat bot on the website, respond to one of our surveys, contact our customer support regarding a problem you are experiencing with the Services or otherwise contact us regarding the website or the Services.
Transactions. We collect details of transactions you carry out using the Services including information you provide to enable us to fulfill your orders, which may include financial information such as your credit card number. As a paying user of the Services, we will receive your payment transaction details (for example, your name, the amount paid and the date of payment).
Payment Information. We collect billing and other payment information (for example, if you sign up for a trial, a paid service or purchase a Third-Party Service), including payment method details, such as credit card number.
Additional Payment Information. You may choose to provide additional information such as your VAT, additional billing address or name of the entity that you represent.
Identity Verification. In some cases (for example if you request a refund) we may ask you to provide us information such as your billing information (name, transaction ID, last 4 digits of the credit card associated with the account, billing date, etc.), email address, login name, and if needed, information that verifies your identity, in accordance with applicable law.
Using our blog, requesting content or creating a Public Profile. If you use our blog, request content or would like to participate in our webinars or events, we may ask you to provide us with information such as your name, job title, your photo or other information. By posting any information on publicly accessible blogs or other areas of our websites you acknowledge and agree that the data you provide on our websites - including information provided to create your public profile (hereinafter “Public Profile”) - would be visible to any member of the public who accesses the websites. You can change the information in your Public Profile whenever you want.
Testimonials. We collect and display personal testimonials of satisfied customers and users on the Services in addition to other endorsements. With your consent, we may post your testimonial, along with your name, on the Services. If you wish to update or delete your testimonial, you can contact us at [agency@foxof.com].
Information Received From Third Parties We may combine personal data we receive from you with personal data we obtain from other sources, such as:
Our authorized resellers or distributors, for example, if you purchase access to the Services through one of these partners. The personal data we may receive includes business contact information, including mailing addresses, job titles, email addresses, and phone numbers. Other third parties, such as email campaigns, marketing partners, publicly-available sources and data providers. The personal data we may receive includes company information, location information, demographic information, and business contact information, including mailing addresses, job titles, email addresses, and phone numbers. We may use this information to enhance the information that we already maintain about you and to improve the accuracy of our records, in addition to other purposes described in this Privacy Policy. Information Collected Automatically Like many other commercial websites, we use certain technologies, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies, to automatically collect information that may contain personal data as you navigate our websites or use our Services or interact with communications we send to you, subject to your consent where required by applicable laws.
Device and Usage Data. When users come to our websites, we may track, collect, and aggregate information indicating, among other things, which pages of our websites were visited, the order in which they were visited, when they were visited, and which hyperlinks were clicked. We also collect information from the URLs from which you linked to our websites. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the websites. We may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.
Third-Party Widgets. Some of our Services contain widgets and social media features, such as the Facebook or LinkedIn button. You are the only person who decides if you would like to press this button and share your personal data with the respective third-party operators of widgets or social media. These widgets and features collect your IP address, the information about the page you are visiting during your use of the Services and may set a cookie to enable the feature to function properly. Widgets and social media features are either hosted by a third party or hosted directly within our Services. Your interactions with these features are governed by the privacy policy of the company providing it and we recommend that you read them prior to sharing your data with such third parties.
Cookies and Similar Technologies. Google Analytics. The Services use Google Analytics, a web analytics service of Google Ireland Limited (Google Building Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland). The use includes the “Universal Analytics” operating mode. This facilitates the assignment of data, sessions and interactions across several devices to a pseudonymous user ID and thus the analysis of a user’s activities across devices.
API YouTube. Semrush uses YouTube API Services. If you are using our Services, by agreeing to our Privacy Policy you hereby also certify that you have read and agree to YouTube’s General Terms of Service (https://www.youtube.com/t/terms ) and Google’s Privacy Policy (https://policies.google.com/privacy?hl=en) . In addition to normal procedure for deleting stored data, you can revoke access to your data via the Google security settings page at https://myaccount.google.com/permissions?pli=1 .
Google Maps API. Semrush uses Google Maps API Services. If you are using our Services, by agreeing to our Privacy Policy you hereby also certify that you have read and agree to Google Maps/Google Earth Additional Terms of Service at https://maps.google.com/help/terms_maps/; and Google Privacy Policy at https://www.google.com/policies/privacy/ . In addition to normal procedure for deleting stored data, you can revoke access to your data via the Google security settings page at https://myaccount.google.com/permissions?pli=1 .
Conversion Tags. If you reach our website via our partner’s Reference Link as described in our Affiliate program, we may use conversion tags, provided by Conversant LLC (“CJ Conversion Tags”), for the purposes of correct attribution of our partner’s marketing activity and the performance of our Affiliate program. You will receive the notice about our use of the Cookies and similar technologies during your first visit of our partner’s website including request for your consent with use of CJ Conversion Tags. You are the only person who decides if you would like to provide this permission, and you can revoke your permission any time by contacting us at [agency@foxof.com]. CJ Conversion Tags collect the following data relating to the order and/or the form completed on our website: unique order ID; quantity of each product purchased; price of each product purchased; currency of the transaction; discount amount (if any); coupon code used (if any); marketing channel the sale is attributed to and a last click timestamp; dynamic CJ event click token captured on landing page URL. The processing of such data is also subject to Conversant Privacy Policy. You can revoke your permission to process the data for the purposes described above by sending an e-mail to [agency@foxof.com].
We and our partners may use other cookies and similar technologies to gather information about the use of our websites and the Services, and for other business purposes as disclosed in our Cookie Policy. For more information on our use of cookies and similar technologies, and your choices with respect to such use, please refer to our Cookie Policy.
HOW WE USE YOUR INFORMATION
We use the personal data we collect, described above, as follows:
- To provide the Services and related support, process transactions, manage your user account and respond to your requests. This is necessary to perform the contract we are about to enter into or have entered into with you.
- To the extent permitted by applicable law, and for certain legitimate interests, including:
If we have not entered into a contract with you, to operate and administer our websites, to provide you with content you access and request (e.g., to download content from our websites), and to respond to your requests for our Services (including sharing your personal data with our resellers as necessary to respond to your request for the Services in an efficient manner and facilitate the sale of our Services, as described in the ‘How We Share Your Personal Data’ section below); To manage our relationship with you, which includes sending administrative information to you, for example, information regarding the website and changes to our terms, conditions, and policies, information on our own products and services that may be of interest to you and responding to your requests or communicating with you; To analyze your preferences, interests and behavior (such as your usage of and interactions with our websites and Services) to identify insights, trends and correlations. This enables us to improve your experience with our Services by providing you with more relevant content and service offerings and helps us improve our Services (including our Service’s functionality, product features, and user-friendliness) and develop new products and services. For other internal business purposes, such as data analysis, benchmarking, audits, conducting research, analysis, studies or surveys and identifying usage trends. To prevent fraud or criminal activities, misuse of our products or services and ensure the security of our IT systems, architecture and networks; To (a) comply with legal obligations and legal process; (b) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (c) enforce our Terms of Service; (d) protect our operations; (e) protect our rights, privacy, safety of property, and/or that of you or others; and (f) allow us to pursue available remedies or limit the damages that we may sustain. If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfill your request, to keep basic data to identify you and prevent further unwanted processing. For marketing and advertising, including sending you updates and information about our new products and services, upcoming events or other promotions or news, including by email or push notification, as permitted by law.
Where required by law we will only send you marketing information if you consent to us doing so at the time you provide us your personal data. Otherwise it is in our legitimate business interests to send such information. You may opt-out of our marketing communications as described in the “Opt-out of marketing communications” section below.
We engage our advertising partners, including third party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information (including the automatically-collected data described above) about your interactions over time across our Services, our communications, and other online services, and use that information to serve online ads that they think will interest you. Where required by law we will undertake such advertising activities on the basis of your consent, otherwise it is in our legitimate business interests to undertake such activities. Please refer to our Cookie Policy. for more information.
HOW WE DISCLOSE YOUR PERSONAL DATA
SELL2EUROPE will not sell, rent, lease or otherwise provide your personal data to others, except in order to provide you with the products and services you request and as further described below, or with your permission or as required by applicable law.
Service Providers. We may engage other companies and people to perform tasks on our behalf - meaning they are helping us provide our Services. In particular, we use third party providers of payment processing, fraud prevention, and risk assessment, hosting and other information technology services, email communication and customer support services, analytics and data providers, marketing, advertising and investor relations. Following our instructions, these parties may process your personal data in the course of providing the relevant services to us.
Affiliates. We may disclose your data to our affiliates for administrative purposes; to help provide our Services (such as providing engineering services), and related customer support or to conduct sales and marketing activities on our behalf. For example, if you request information about a company or a service from a SELL2EUROPE, then we may pass your personal data relevant to such request onto another SELL2EUROPE to enable them to appropriately respond to your request.
Resellers or Distributors, Affiliates or Other Third Parties. When you request Services from us or inquire about the Services, we may share your personal data such as name, last name and email address with our authorized resellers distributors, Affiliates and other third parties as necessary to respond to your request for our Services in an efficient manner and facilitate the sale of our Services and for those third parties’ own marketing services. These third parties will process your personal data as separate data controllers/businesses and in accordance with their privacy policies. Please refer to the privacy policy of the applicable reseller for information on the reseller’s privacy practices.
Social networking websites. Where permissible according to applicable law or with your consent where required by law, we may use certain limited personal data about you, such as your email address, to hash it and to share it with social network websites, such as Facebook, LinkedIn or Google, to generate leads, drive traffic to our websites or otherwise promote our products or Services. The social network websites with which we may share your personal data are not controlled or supervised by us. Therefore, any questions regarding how your social network websites service provider processes your personal data should be directed to such provider.
Business Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of a service to another provider, your personal data and other information may be transferred to a successor or affiliate as part of that transaction.
Legal Requirements. We may share your personal data so that we can comply with a legal obligation to which we are subject, protect and defend the rights or property of Semrush, act in urgent circumstances to protect your personal safety or that of the public, or protect Semrush against legal liability. For example, where we are obliged to share your personal data with regulatory bodies which govern our work and services; government departments such as law enforcement, courts orders; financial institutions; external auditors; etc.
DATA RETENTION
We retain your personal data for as long as reasonably necessary to provide the Services and fulfil the transactions you have requested, complying with our legal obligations or for other legitimate business purposes, such as maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. After the applicable retention period has elapsed, your personal data will be anonymized or deleted.
HOW WE PROTECT YOUR PERSONAL DATA
We have implemented physical, technical, and administrative security measures designed to protect the confidentiality of personal data we process. The Internet, however, cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any personal data you provide to us. It is your responsibility to protect the security of your login information.
If you know or suspect that your personal data have been lost, stolen, misappropriated, or otherwise compromised, or in case of any actual or suspected unauthorized use of your Semrush account, please immediately contact us by email at privacy@semrush.com .
INTERNATIONAL TRANSFERS OF PERSONAL DATA
SEMrush Inc. is based in the United States and other members of our group are based in countries outside the EEA or the UK (please read the Affiliates section above for more information). If you are accessing our websites and the Services from the EEA, the UK or other regions with laws governing data collection and use, please note that in connection with our business and for administrative, management and legal purposes, we may transfer your personal data from the country where you reside to SEMrush Inc. in the United States and to other members of our group in the jurisdictions in which our affiliates are established and to our service providers in the United States. These countries may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located.
Where we transfer your personal data as described above, we will take steps to ensure that your personal data receives adequate security protection where it is processed and your rights continue to be protected pursuant to the applicable data protection law, including through the use of Standard Contractual Clauses approved by the European Commission. In some cases, transfers of your personal data to us is necessary to perform the agreement we have entered into, or are about to enter into, with you. If you would like to receive more information on the safeguards that we implement as described above, please contact us as indicated below.
PRIVACY RIGHTS AND CHOICES
Opt-out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the “Contact Information” section below. You may continue to receive Services-related and other non-marketing emails.
Online tracking opt-out. You can opt out of third-party cookies as described in our Cookie Policy.
Personal data requests. We offer you choices that affect how we handle the personal data that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal data:
Information about how we have collected and used personal data. We have made this information available to you without having to request it by including it in this Privacy Policy.
Access to a copy of the personal data that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
Correction of personal data that is inaccurate or out of date.
Deletion of personal data that we no longer need to provide the Services or for other lawful purposes.
Opt out of the sharing or processing of your personal data for targeted advertising purposes. To exercise this right, you can visit the “Do Not Sell or Share My Personal Information” link in the footer of our website.
Additional rights, such as to object to and request that we restrict our use of personal data, and where applicable, you may withdraw your consent.
To make a request, please email us or write to us as provided in the “Contact Information” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.
You may also access, review, modify and delete your account profile information by going to your account and editing your information.
Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “Contact Information” section below. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.
CONTACT INFORMATION
SELL2EUROPE are the entities responsible for the processing of your personal data under this Privacy Policy (as joint controllers, where provided under applicable law).
If you have any questions or concerns regarding SELL2EUROPE’s Privacy Policy or use of personal data, or if you want to exercise your rights regarding your personal data, please contact us by email at our designated request address at [agency@foxof.com] or by regular mail to:
FOXOF-Entreprises Inc. 455 rue Notre-Dame Est, Suite 313, Montréal, Québec, H2Y 1C9 CANADA Attention: General Counsel