Diffbot Privacy Statement for EEU Residents

See also: Diffbot’s Terms of Use, Diffbot’s Privacy Policy and Cookie Policy

Diffbot understands that you care about how information about you is used. This Privacy Policy (the “Policy”) explains how we process personal information, including information pertaining to business people (“Business Information”) and all other types of personal information through our online services (the “Services”), website, and web applications and tools (collectively with the Services, the “Sites”); how we maintain, use, and share that information; and how you can manage the way information about you is handled.

“Diffbot” for purposes of this Privacy Policy includes Diffbot Technologies Corp, a Delaware corporation, doing business in California.

For individuals residing in the EEA, the UK, or Switzerland, please review section titled: ‘Users in the European Economic Area (EEA), the UK, and Switzerland’ below to find out more information.

For residents of the State of California, please click here to find out more about your rights under the California Consumer Privacy Act of 2018 (“CCPA”).

I. Introduction

This brief summary of certain information in this Policy is intended to help you quickly understand who Diffbot is, how you can opt-out of our knowledge graph, and the potential outcomes of remaining in our knowledge graph.

Diffbot aggregates business contact and similar information related to individuals when they are working in their professional or employment capacity, and uses this information to create professional profiles of individuals and profiles of businesses. We provide this information to our Subscribers, who are businesses trying to reach business professionals for their own business-to-business sales, marketing, market intelligence research, and recruiting activities.

You can opt out of our knowledge graph by submitting an access request or claiming your professional profile and updating your profile information. Email us, our contact information is listed under the “Contact Us” section at the end of this Policy. By remaining in our knowledge graph, you may be contacted by our Subscribers when they are conducting their business-to-business sales, marketing, and market intelligence research, or recruiting activities. Communications you receive from our Subscribers may be relevant to your profession or employment role, but we cannot guarantee that you will find such communications to be relevant or of interest to you.

II. How we Collect Information

A. Where does Diffbot get the Business Information for its Profiles? Diffbot creates profiles of business people and companies, which we call “Professional Profiles” and “Organization Profiles,” respectively. Once we have collected Business Information about a person or company, we may combine multiple data points regarding a single person or company into a Professional or Organization Profile. The resulting Graph of Professional and Organization Profiles (the “Graph”) is then made available to the users of the Site and our Subscribers and strategic partners. Business Information that may be provided in a Professional Profile includes name, email address including business and/or other email addresses (including “freemails” such as Gmail, Yahoo, Hotmail, etc.), job title and department, phone number (general or direct business numbers, faxes, and/or mobile numbers), company name, postal address of company and business-related postal address of the person, employment history, and education history. Organization Profiles may also include links to articles by, about, or quoting an individual, and links to an individual’s social media profiles. Diffbot obtains the data for its Organization Profiles in several ways, including: Our search technology scans the web and gathers publicly-available information. We license business contact information from other companies. Diffbot also makes certain limited Business Information from its Professional Profiles publicly available on our Site as a preview of the Profiles available via our web graph (“Graph”). The categories of Business Information that may be made available in the Graph include past or current name, company, company headquarters telephone number, office address, job title, and/or education information.

B. Subscriber Information Subscriber Information Collected. Diffbot may collect the following information from or regarding its Subscribers: (1) personal contact information regarding users of the Services (“User Information”); (2) information uploaded or otherwise provided to our system by a user of the Services (“Uploaded Information”); (3) usage logs regarding the use of the Site and Services, including logins and other actions taken, time stamps, IP address, and other usage data (“Usage Logs”); and (4) any other information from or relating to users of our Services (“Related Information”) (collectively, “Subscriber Information”).

Certain users may be provided access to the Site through a company’s license agreement. Such company may require that one or more users have global rights to access any and all information of every user that has access through that company’s Diffbot account. Questions or concerns regarding the rights of other individuals in your company to access your information should be addressed to your company.

Use of Subscriber Information. Subscriber Information may be used for Diffbot’s legitimate business interests in connection with a Subscriber or its users’ use of the Site, including to respond to user inquiries and fulfill user requests, complete transactions, provide Subscriber service, send administrative information, and to personalize user experience with the Site. We may use Subscriber Information to better understand our users in general and to test, develop, improve, and enhance our Services and Site. We may use Subscriber Information to contact Subscribers or its users in the future about services, promotions, opportunities, and other general information about Diffbot. We may use Subscriber Information to investigate and prosecute potential breaches of Diffbot’s security or license agreements. Diffbot will not disclose Subscriber Information to any third party except in connection with a legitimate use as set forth in this Policy, in connection with a bona fide legal dispute to which such information is relevant, in response to valid, compulsory legal process, in response to a valid data subject request where required by applicable law, or as otherwise required by law. Diffbot will, whenever possible, obtain confidentiality agreements from any service provider to whom Subscriber Information is disclosed and ensure any recipient service providers are committed to employing appropriate technological security measures.

Diffbot employs reasonable security and back-up procedures to protect Subscriber Information. However, in the unlikely event there is a loss or corruption of Subscriber Information, Diffbot is not responsible or liable for such loss or corruption. We encourage our users to retain copies of all Uploaded Information on their own system.

C. How else does Diffbot Collect Information?

Information submitted through our Sites. Visitors to our Site may choose to submit their name, email address, phone number, and/or other information so that they can learn more about our Services, register to take part in a Diffbot-sponsored event, participate in a survey, contest, or sweepstakes, or apply to Diffbot’s open job positions, among other things. By accessing, using, and/or submitting information through the Site, including by filling out forms on our website, regardless of whether the form is ultimately submitted, a user of the Site consents to the practices described in this Policy with regard to the information collected about them. If you do not agree with this Policy, you should not submit any information through our Site and you must delete all cookies from your browser cache after visiting the Site and refrain from visiting or using the Site.

Managing Professional Profiles. Diffbot allows any person to claim their Professional Profile and to update the information listed about them in their Professional Profile. We use the information submitted to update a Professional Profile solely for purposes of verifying such person’s identity, updating their Professional Profile information, and honoring such person’s privacy preferences. For additional information, see the “Your Choices” section below.

Use of our Services. In order to use certain Diffbot Services, users may be required to register. From time to time, we may use a user’s email address to send information about our products and services. Recipients are provided with an opportunity to opt out of receiving such emails. We may also communicate with users regarding their use of our Services or Site, including changes to this Policy. A more detailed description of how we may collect and use Subscriber information can be found in the “Subscriber Information Collected” section above.

Providing information to our Subscribers. We receive information about our Subscribers’ end-users from or on behalf of our Subscribers. Because of the nature of our Services, this information may contain any type of data, but typically includes name, contact information, and company information, such as company name. We may also collect data automatically through use of our Services, as described in the “Cookies and Similar Technologies” section below. Any information provided through a website, application, or service on which a Subscriber uses our Services is subject to the Subscriber’s privacy policy and applicable terms. When we provide our Services to a Subscriber, we generally act as a “data processor,” and the Subscriber is considered to be the “data controller,” as further described in the “When Diffbot is a Controller” and “When Diffbot is a Processor” sections below.

Referring a friend. If a user invites a friend to join Diffbot, we will ask for such friend’s name and email address, and we will automatically send such friend a one-time email inviting them to visit the Site.

Purchasing our products and Services. Purchasers of our online subscription-based Services may need to provide credit card or other payment information. We will use that information solely for the purpose of fulfilling the purchase request. Our payment processor, Stripe, stores the credit card or other payment information in an encrypted form and will not sell, share, or use it again without prior consent. (The only exceptions are described in the sections below on “Disclosures to Service Providers,” “Disclosures for Legal Reasons,” and “Disclosures to a Buyer of the Company”).

Using Diffbot Integrations. As part of the Services, Diffbot may make available to its Subscribers certain “Integrations.” In using Diffbot’s Integrations, such as Diffbot’s Excel Add-In and web browser extensions, Business Information from Subscriber’s CRM, MAT, or sales enablement software may be transmitted to Diffbot for purposes of matching or cleansing the Subscriber’s data against Diffbot’s knowledge graph as a feature of the Services.

Connecting the Services to an email account or calendar. In order to provide certain Services, Diffbot may require access to the user’s email account and/or calendar (e.g., through G-Suite or Office 365). Depending on the specific Services being used, we may collect email header information, email subjects, email bodies and attachments, and calendar meeting information such as meeting participants, meeting description, subject, and date and time of the meeting. Subscribers have control over what data is collected, including which mailboxes are connected, whether message attachments or content is collected, and which emails or email domains should not be collected. Diffbot’s access to and use of information received from Google Accounts will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

From our affiliates. Diffbot may obtain personal information from our affiliates, such as our current and future parents, subsidiaries or other companies under common control and ownership with Diffbot. We may use this information to enhance the information that we already maintain and to improve the accuracy of our records, in addition to other purposes described in this Policy.

From third parties. Diffbot may obtain personal information from third-party sources such as our service providers and strategic partners. We may use this information to enhance the information that we already maintain and to improve the accuracy of our records, in addition to other purposes described in this Policy.

Creation of aggregated information. Diffbot may aggregate collected information about our users in a form that does not allow users to be personally identified for the purpose of understanding our Subscriber base and enhancing the Site and the Services that we and our strategic partners and Subscribers can provide you.

Creation of information from inferences. We may use personal information we already have in order to draw inferences or to produce scores or ratings. We use scoring models and algorithms that evaluate selected data points to produce a score predicting the likeliness of a Organization to respond to sales outreach efforts. We do not make any decisions about individuals, and we do not tell our Subscribers whether to reach out to a particular candidate or not.

Automated information collection. We also collect information using cookies and similar technologies, as described below under the “Cookies and Similar Technologies” section.

III. How we Use Information

In addition to the uses described in the above section, we may also use Business Information and/or personal information for one or more of the following purposes:

• Provide, maintain, and improve the Site
• Verify, cleanse, update, and maintain Business Information and other information provided through the Site or through the other methods described in this Policy
• Provide and deliver the Services, process transactions, and send related information, including communications and invoices
• Send technical notices, updates, security alerts, and support and administrative messages
• Respond to comments, questions, and requests, and provide Subscriber support
• Create Diffbot account(s) and identify users signing in to their account
• Communicate about products, services, offers, promotions, rewards, and events offered by Diffbot and others, and provide news and information
• Monitor and analyze trends, usage, and activities in connection with the Site
• Detect, investigate, and prevent fraud and other illegal activities
• Protect the rights and property of Diffbot, our Subscribers, and others
• Personalize and improve the Site
• Provide notice of important changes to the Site, including changes or updates to this Privacy Policy
• Consider persons for possible employment with Diffbot, and communicate about employment opportunities or submitted employment applications
• Respond to requests from individuals to access, correct, or delete their information, or requests to exercise other rights related to their information under applicable law
• 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 or Subscribers may use to provide and improve our respective services
• Comply with our contractual and legal obligations, resolve disputes with users, and enforce our agreements
• Carry out any other purpose described at the time the information was collected

IV. How we Share Information

Disclosures of Organization Profiles. We may make any Business Information that we collect from public web sources, that we license from third parties, or that we otherwise collect as described in this Policy available to users of the Site, to our strategic partners, and to our Subscribers. Information provided, including Business Information, in creating or updating a Professional Profile, will be included in the Graph and thus can be viewed by third parties.

Disclosures via Knowledge Graph. Diffbot makes certain limited Business Information from its Professional Profiles publicly available on our Sites. The categories of Business Information that may be made available in the Knowledge Graph include past or current name, company, company headquarters telephone number, office address, job title, and/or education information. Information in the Knowledge Graph is publicly available to visitors who visit our Knowledge Graph webpages on our Site.

Disclosures to Affiliates. We may share Business Information with our affiliates who may act for us for any of the purposes set out in this Privacy Policy, including our current and future parents, subsidiaries, and other companies under common control and ownership with Diffbot.

Disclosures to Service Providers. Diffbot may from time to time disclose Business Information or other collected information to service providers, solely for providing functions related to our operation of the Site and provision of the Services and for no other purpose. For example:

• Diffbot uses service providers to process credit card payments on our Sites. Information such as name, billing address, phone number, email address, and credit card information will be submitted to service providers for verification and to manage any recurring payments.
• Diffbot uses software hosted by a service provider to provide us with information regarding our Subscribers’ activities on our Sites. When individuals use our Site, that service provider may set cookies on our behalf and may receive information about such individuals’ activity on our Sites.

Disclosures to Integration Partners. In using Diffbot’s Integrations, such as Diffbot’s SFNA and web browser extensions, Business Information from Diffbot may be disclosed to a Subscriber’s CRM, MAT, or sales enablement software as requested or directed by our Subscribers.

Disclosures for Legal Reasons. We may disclose collected information, including Business Information, to a third party if we believe in good faith that such disclosure is necessary or desirable: (i) to comply with lawful requests, subpoenas, search warrants, or orders by public authorities, including to meet national security or law enforcement requirements; (ii) to address a violation of the law; (iii) to protect the rights, property, or safety of Diffbot, its users, or the public; (iv) to allow Diffbot to exercise its legal rights or respond to a legal claim; or (v) to respond to data subject requests for access to data to the extent necessary to comply with applicable laws.

Disclosures to a Buyer of the Company. If our company or substantially all of our assets are acquired, or in the event of a merger or bankruptcy, information about you and/or information you provide to Diffbot may be among the transferred assets.

Other Disclosures Information about individuals who register for a Diffbot event with a third-party speaker will generally be shared with the speaker and any third-party sponsors or partners of the event.

We post Subscriber testimonials on our Site which may contain the Subscriber’s name. We obtain consent from the Subscriber prior to posting any testimonial. If a Subscriber wishes to update or delete their testimonial, they can contact us at privacy@diffbot.com. Our Site offers publicly accessible blogs or community forums. Any content provided in these areas may be read, collected, and used by others who access them. Individuals can request the removal of their personal information from our blog or community forum by contacting us at privacy@diffbot.com. In some cases, we may not be able to remove the personal information, in which case we will let the requestor know that we are unable to do so and why.

V. Cookies and Similar Technologies

Most websites, including our Subscriber Sites, use a feature of browsers to set a small text file called a “cookie” on a computer. The site placing the cookie on a computer can then recognize the computer when the user of the computer revisits the site to allow auto login and track how the user is using the site.

When individuals use our Sites, our servers and/or those of our service providers automatically record certain information that the web browser sends, such as web request, Internet Protocol address, browser type, referring/exit pages and URLs, page loads and clicks, domain names, landing pages, pages viewed, time and date of use, and other information. We may link this information to information that individuals submit while on our Sites, which does allow such individuals to be personally identified.

Individuals are free to decline cookies and can configure their browser to accept all cookies, reject all cookies, erase cookies, or notify the user when a cookie is set. Electing to reject or disable cookies may substantially limit an individual’s ability to use our Sites.

Diffbot may also adopt other technologies that serve similar functions as cookies.

A. Third Party Cookies The use of cookies and similar technologies by our partners, affiliates, tracking utility company, and service providers is not covered by this Policy. We do not have access to or control over these cookies. Our partners, affiliates, tracking utility company, and service providers may use session ID cookies in order to:

• personalize subscribers’ experience
• analyze which pages our subscribers visit
• provide website app features such as saved searches To disable or reject third-party cookies generally, please refer to the third-party’s relevant website or configure your browser settings appropriately. Individuals can also reject third-party analytics cookies by clicking the “Close” button on the cookie banner when visiting our Sites.

B. Google Analytics We use Google Analytics, a web analytics service provided by Google, Inc., on our Leadgraph and Diffbot Dashboard web applications and on the Leadgraph public Site. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Site, compile reports on the Site’s activity, and provide other services related to Site activity and usage. The technologies used by Google may collect information such as IP address, time of visit, whether a visitor is a return visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google click here.

To opt-out of interest-based advertising by participating companies in the following consumer choice mechanisms, please visit: Digital Advertising Alliance’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices) European Interactive Digital Advertising Alliance’s consumer opt-out page (http://youronlinechoices.eu) Network Advertising Initiative’s self-regulatory opt-out page (http://optout.networkadvertising.org/).

VI. Your Choices

A. How To Change or Delete Professional Information

Update Professional Diffbot Profile. Individuals can keep their Diffbot Professional Profile up to date for recruiters and others who may want to reach them by verifying their Professional Profile and updating information such as work history, education history, and contact information. Please email privacy@diffbot.com to view, verify, and update your Professional Profile.

Request Access to Information Diffbot has Collected. Individuals who want to access the information that Diffbot has collected about them can email privacy@diffbot.com to submit an access request. Once we have verified an individual’s identity, we will send a report with the information we have collected about such individual.

Remove Diffbot Profile Completely. If you wish to completely remove your existing Professional Profile from the Graph, please email privacy@diffbot.com. If you make this choice, your Professional Profile and the information within it will be removed from our search results as soon as possible.

B. How To Change or Delete Company Information

Update a Organization Profile on Diffbot. An authorized individual can verify their Diffbot Organization Profile to update its company description, industry, company location, and more. Please email privacy@diffbot.com to view, verify, and update a Diffbot Organization Profile.

Removal of Organization Profiles. Diffbot is a knowledge graph of companies and professionals. We gather information about companies from corporate web sites, press releases, and/or SEC documents filed with the US government and similar documents filed with governments around the globe. The company summaries are created automatically by Diffbot’s software based on the information we find on those documents and from other sources such as our partners or service providers.

As a company policy, Diffbot does not remove company information from our graph. If you are aware that any of the company information is incorrect, please update the Organization Profile by contacting us using the information listed in the “Contact Us” section below.

C. How To Opt-Out of Certain Uses of Information Diffbot gives individuals the opportunity to “opt out” of having their information used for certain purposes.

Individuals who no longer wish to receive our newsletter may opt-out of receiving it by following the instructions included in each newsletter or communication or by visiting /unsubscribe or by logging into the Diffbot Dashboard and indicating in your account that you do not want to receive marketing emails. After we receive a request, we will send the requestor an email message to confirm that the individual has been unsubscribed.

VII. How Do We Keep Information Secure?

Information security is important to us. We follow generally accepted industry standards to protect the information submitted to us, both during transmission and once we receive it. However, no method of Internet transmission or electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect information, we cannot guarantee its absolute security.

VIII. Data Retention

We will retain personal information for a period of time consistent with the original purpose(s) for which we collected it, as described in this Privacy Policy, including, as applicable, (i) for as long as we have an ongoing relationship with the individual to whom the information pertains; (ii) as long as needed to provide users, our Subscribers, or our partners the Services; (iii) as necessary to comply with our legal obligation(s); (iv) as necessary to resolve disputes or to protect ourselves from potential future disputes; or (v) as necessary to enforce our agreements. Retention periods will be determined taking into account the amount, nature, and sensitivity of the personal information and the purpose(s) for which it was collected. After the retention period ends, we will delete the personal information. Where we are unable to do so, we will ensure that appropriate measures are put in place to prevent any further use of such information.

IX. Links to Other Sites

This Site contains links to other sites that are not owned or controlled by Diffbot. We are not responsible for the privacy practices of such other sites. When individuals leave our Site, we encourage them to be aware and to read the privacy statements of each and every website that collects personally identifiable information. This Policy applies only to information collected by the Sites or in the method(s) otherwise discussed herein.

X. Social Media Widgets

Our Sites include social media features, such as the Facebook “Like” button and “Widgets,” such as the “Share” button or interactive mini-programs that run on our Sites. These features may collect IP address and which page was visited on our Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Site. Interactions with these features are governed by the privacy policy of the company providing it.

XI. Information for Users in Europe and Elsewhere Outside the U.S.

Individuals who use our Site outside of the United States should understand that we may collect, process, and store their personal information in the United States and other countries in which we or our affiliates or subcontractors maintain facilities. The laws in the U.S. regarding personal information may be different from the laws of such individuals’ state or country.

A. Users in the European Economic Area (EEA), the UK, and Switzerland

The following information applies to residents of the EEA, the UK, or Switzerland. Diffbot endeavors to comply with the provisions of the General Data Protection Regulation (“GDPR”) as to any information in its possession regarding EEA-, UK-, and Switzerland-based persons (“data subjects”). As such, Diffbot only processes personal information on data subjects where it has a lawful basis to do so, which may include the consent of the person (especially in the case of website visitors who provide their information), performance of a contract, compliance with a legal obligation, or the legitimate interest of Diffbot or a third party. Diffbot provides notice to all data subjects as required by GDPR Article 13 or 14, as appropriate, and honors the rights of data subjects provided in Articles 12-23, including the right to be forgotten. For any opt-out requests or other inquiries related to privacy, please email privacy@diffbot.com.

Purposes of processing and legal basis for processing: As explained above, we process personal information in various ways depending upon data subjects’ use of our Sites. We process personal information on the following legal bases: consent; as necessary to perform our agreement to provide Services or other applicable agreements; as necessary for compliance with a legal obligation to which we are subject; or as necessary for the legitimate interests of Diffbot and Diffbot’s Subscribers and partners to engage in direct marketing, sales, and recruiting activities, and Diffbot’s legitimate interests in organizing and making available Professional and Organization Profiles, given the limited impact that use of this Business Information and similar information presents to an individual’s private life Diffbot has put in place safeguards to protect personal privacy and individual choice, including disclosures of its data processing activities, and the use of consent or opt-outs wherever possible.

Right to lodge a complaint: Users that reside in the EEA, the UK, or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

Transfers: Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. Per the applicable requirements of the GDPR, we will ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR, such as the UK or EU Standard Contractual Clauses, as applicable.

Individual Rights: Individuals who are a resident of the EEA, the UK, or Switzerland are entitled to the following rights under the GDPR. Please note: In order to verify an individual’s identity, we may require them to provide us with personal information prior to accessing any records containing information about them. The right to access, correction, and restriction of processing. Individuals have the right to request access to, and a copy of, their personal information at no charge, as well as certain information about our processing activities with respect to their data. Individuals have the right to request correction or completion of their personal information if it is inaccurate or incomplete. Individuals have the right to restrict our processing if they contest the accuracy of the data we hold about them, for as long as it takes to verify its accuracy. The right to data portability. Individuals have the right to ask for a copy of their data in a machine-readable format. Individuals can also request that we transmit their data to another entity where technically feasible. The right to request data erasure. Individuals have the right to have their data erased from our Site if the data is no longer necessary for the purpose for which it was collected, they withdraw consent and no other legal basis for processing exists, or their fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing. The right to object to our processing. Individuals have the right to object to our processing if we are processing data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using data for direct marketing (including profiling); or processing data for purposes of scientific or historical research and statistics. When Diffbot is a Controller. Diffbot acts as a data controller when we collect and use information about data subjects who are visitors to our Sites, as well as when we collect and use information about data subjects for purposes of creating and maintaining our Professional Profiles and providing the Services. Diffbot’s Data Protection Officer can be contacted by email at privacy@diffbot.com.

When Diffbot is a Processor. When our Subscribers use our Services, they are acting as the data controller and are responsible for ensuring that personal information collected about data subjects is being processed lawfully. In those circumstances, we are acting as the data processor, and receive personal information as agents of our Subscribers merely for processing as instructed by our Subscribers. Our Subscribers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all third-party individuals that are a visitor to or user of a website, application, or service on which a Subscriber uses our Services have been provided with adequate notice regarding the processing of their personal information, have given informed consent where such consent is necessary or advised, and that all legal requirements applicable to the collection, use, or other processing of personal information through our Services have been met by such Subscribers. Our Subscribers 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. Diffbot’s obligations with respect to personal information for which we are solely a data processor are defined in our agreements with our Subscribers and are not covered by this Policy. In certain circumstances, Diffbot may act as an independent controller of personal information in connection with its provision of the Services to Subscribers, such as when Subscribers agree to contribute data to our knowledge graph.

B. Privacy Shield Frameworks

While Diffbot continues to adhere to the principles of the Privacy Shield Frameworks, in light of the Court of Justice of the European Union decision regarding the legal effect of the EU-US Privacy Shield Framework, Diffbot does not rely upon the Frameworks to ensure the lawful transfer of data from EEA to non-EEA countries.

Diffbot complies with the EU-US Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU and Switzerland to the United States. If there is any conflict between the policies in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, any rights to binding arbitration before a Privacy Shield Panel, and to view our certification page, please visit https://www.privacyshield.gov.

For information received under the Privacy Shield, Diffbot will require third parties to whom we disclose personal information to safeguard that personal information consistent with this Policy by contract, obligating those third parties to provide at least the same level of protection as is required by the Privacy Shield Principles. EU and Swiss citizens may choose to opt-out of such disclosures. Diffbot may have liability to individuals in case of failure to comply with the law or this Policy in handling onward transfer of such individuals’ information to third parties.

In compliance with the Privacy Shield Principles, Diffbot commits to resolve complaints about privacy and its collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Policy should first contact Diffbot at privacy@diffbot.com. European Union and Swiss individuals have the right to access their personal information.

Diffbot further has committed to refer unresolved privacy complaints under the Privacy Shield Principles to JAMS (Judicial Arbitration & Mediation Services), an independent alternative dispute resolution provider located in the United States and recognized for this purpose by the US Department of Commerce. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information, and to file a complaint. The Federal Trade Commission has enforcement authority regarding Diffbot’s compliance with the Privacy Shield Principles.

XII. California Privacy Rights

California law permits California residents to request certain information regarding the disclosure of their personal information by us to third parties for the third parties’ direct marketing purposes. To make such a request, please send the request, by mail or email, to the address at the end of this Policy under the “Contact Us” section.

XIII. Do Not Track Signals

Browsers or devices may include ‘Do Not Track’ functionality. Our information collection and disclosure practices, and the choices that we provide to visitors, will continue to operate as described in this Policy, whether or not a Do Not Track signal is received.

XIV. Children’s Privacy

Our Site is not directed to or intended for individuals under the age of 18. We do not knowingly collect or use any personal information from users of our Site who are under the age of 18. No personal information should be submitted to our Site by individuals who are under 18 years of age. If we learn that we have collected information from someone who is under 18, we will take steps to delete the personal information as soon as possible. Individuals who believe we may have collected personal information from someone under 18 should contact us at privacy@diffbot.com.

XV. Changes to this Policy

Diffbot reserves the right to modify this Policy from time to time, so please review it regularly. If we make material changes to this Policy, we will notify individuals here, by email, and/or by means of a notice on our homepage prior to the changes becoming effective. Continued use of the Site after any updates to this Privacy Policy constitutes acceptance of the updated Privacy Policy.

XVI. Non-Privacy Shield Related Questions or Complaints

For an unresolved data privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

XVII. Contact Us

For questions or concerns regarding this Privacy Policy, please contact us at:

Diffbot Technologies Corp. Attn: Privacy 333 Ravenswood Ave Menlo Park, CA 94025 Tel: 1 (855) 885-4800 Email: privacy@diffbot.com