At Databook, we respect the privacy rights of our users and recognize the importance of protecting the personal information we collect about you. Our Privacy Policy is designed to help you understand what information we collect and how we use and share that information. This Privacy Policy applies to our Websites and Services. By using or accessing the Site or Services, you are accepting the practices described in this Privacy Policy.

As part of our Services, we provide our Customers access to certain information (including Personal Information) regarding executives at many different companies. This information is generally publicly available, including on company websites and in public filings. We call this type of Personal Information, “Executive Information” and the persons about whom such information relates, “Executives.” If we believe that we may have Executive Information about you and wish to understand how we use and share that information, please see “Executive Information” below. If you are in the EU, please see “Additional Information for European Union Users” below to understand your rights regarding any Executive information we have about you.

Definitions

When we say “we”, “us”, “our”, or “Databook”, we’re referring to Databook Labs, Inc.

“Websites” means Databook’s marketing websites (including without limitation databook.com and trydatabook.com) and its community websites (community.strategicsales.com, community.databook.com, strategicsales.com, and any successor URLs, mobile or localized versions and related domains and subdomains), and the “Services” means Databook’s products, web and mobile applications and services, in each case in whatever format they may be offered now or in the future. Services include the Databook web application, the DatabookGPT conversational AI application and product integrations including PowerPlatform connectors, Copilot connectors and Databook C4S (our integration with Microsoft Copilot for Sales). The Websites and Services are collectively referred to herein as the “Offerings.”

“Customer” refers to any customer that has entered into an agreement with Databook to use Databook’s services.

“Visitor” refers to anyone accessing the Databook marketing properties at databook.com and trydatabook.com, or its community properties at community.strategicsales.com, community.databook.com, and strategicsales.com.

“Personal Information” refers to any information which may identify an individual personally, such as first and last name, billing address, email address, job role and employer, telephone number, etc.

Information we collect

Personal Information

Website Visitors

Databook marketing websites. When accessing the Websites as a Visitor, you may choose to interact with the Websites in a way that results in you providing Personal Information to Databook, such as giving us your name, email address, phone number and company name when contacting us with an enquiry or request to demo Databook.

We only collect Personal Information from Visitors that is reasonable or necessary to accomplish the purpose of your interaction with Databook as a Visitor. Any Personal Information provided by you as a Visitor to the Site will be used only as described in this Privacy Policy.

Databook community websites. We collect the minimal information that can be used to identify you by default. You do not need an account if you want to browse our Databook community websites, which are focused on allowing people to come together and form communities, some of which are public.

When you submit content (including a post, comment, or chat message) to a public part of the Databook community websites, any visitors to and users of our Databook community websites will be able to see that content, the username associated with the content, and the date and time you originally submitted the content. Content posted is not to include private or personal information from any third parties (either businesses or individuals) that have not granted prior consent.

Your Databook community website profile page is public. Your profile contains information about your activities on the Service, including your user name, prior posts, and comments.

Customers of the Services

When registering as a Customer to use the Services, we may require or ask you to provide certain personally identifiable information (these are referred to below as your “Personal Contact Information”). The Personal Contact Information that we require you to provide may include, but is not limited to, the following:

• E-mail
• Full name
• Company name
• Job title

If you are a Customer personally purchasing access to the Services, we will require you to provide financial and billing information, such as billing name and address, and credit card number (“Billing Information”). Your Personal Contact Information and your Billing Information, together with any other information we gather through the Services that may be used to identify, contact, or locate you individually, are collectively referred to herein as your “Personal Information.”

The information we collect from a Customer is used only in accordance with the Agreement and this Privacy Policy.

We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Data, Diagnostic & Login Information

You may be able to create, upload, publish, transmit, distribute, display, store or share information, data, text, graphics, video, messages or other materials using our Services (this is collectively referred to below as “Data”). Some of this Data may be stored and maintained on our servers.

We may also collect certain information regarding your Operating System version, hardware, and browser version (“Diagnostic Information”), which helps us identify and resolve technical errors that may occur in the course of using the Services.

Additionally, certain login information may be maintained in a cookie stored locally on your personal computing device (i.e. not on a server) in order to streamline the login process (“Login Information”).

Google Calendar data

As a Customer using our Services, you may choose to use the optional Google Calendar integration. Our Google Calendar integration accesses event data from your calendar on a daily basis to create a personalized daily agenda email. We use calendar data relating to upcoming events, such as event title, and event time and date to provide details of your upcoming meetings in the agenda email. We do not store or share any data accessed via the Google Calendar integration.

Usage and Analytics Information

As a Visitor to the Websites and as a Customer using our Services, we may also collect information through the use of commonly-used information-gathering tools, such as cookies, log files, and Web beacons. Collectively, this information is referred to as “Usage and Analytics Information.”

Cookies

We use standard browser cookies to allow Databook to remember details of a user session. For example, we may use cookies to make it easier for the user to resume a recent session without re-entering their log-in details. Our Cookie Policy can be viewed here.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Log Files

As is true of most websites, we gather certain information automatically to analyze trends in the aggregate and administer the Services. This information may include your Internet Protocol (IP) address (or the proxy server you use to access the World Wide Web), your browser type, the pages and files you viewed, your operating system, and date/time stamps associated with your usage. Due to Internet communications standards, when you visit or use our websites and Services, We automatically receive the URL of the website from which you came and the website to which you go when you leave our website. This information is used to analyze overall trends, to help us improve the Services, to track and aggregate non-personal information, and to provide the Services. For example, we use IP addresses to monitor the regions from which customers and visitors navigate the Sites. We also collect IP addresses from customers when they log into the Services as part of the “IP Restriction” security feature as well as to maintain audit logs.

Web Beacons

We use web beacons alone or in conjunction with cookies to compile information about your usage of the Services and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website or Service tied to the web beacon, and a description of a website or Service tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to one of our websites. We also use web beacons to operate and improve the Services and our email communications.

Geo-Location Information

We do not use GPS technology to collect any information regarding your precise real-time geo-location while using the Services. However, we may use elements of your Usage and Analytics Information (such as your IP address) to determine your generalized location. This information is referred to as “Generalized Geo-Location Information.”

Use of Information. We use the information we collect in the following ways:

Information Collected	Use
Personal Contact Information	We use this information to manage your account, to provide the Services, to maintain our customer/visitor lists, to respond to your inquiries or request feedback, for identification and authentication purposes, for service improvement, and to address issues like malicious use of the Services. We may also use Personal Contact Information for limited marketing purposes, namely, to contact you to further discuss your interest in the Services, and to send you information about us. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
Billing Information	We use Billing Information to manage your account, to provide the Services, and to check the financial qualifications of prospective customers and to collect payment for the Services. We may use a third-party service provider to manage credit card processing. If we do so, such a service provider will not be permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on our behalf.
Data, Diagnostic Information and Login Information	We use this information for the purpose of administering and improving our Services to you. We may also use this information in conjunction with an analytics service to monitor and analyze use of the Services, for the Services’ technical administration, and to increase the Services’ functionality and user-friendliness.
Usage and Analytics Information	We may use your Usage and Analytics Information in conjunction with an analytics service such as Google Analytics to monitor and analyze use of the Services, for the Services’ technical administration, to increase the Services’ functionality and user-friendliness, and to verify users have the authorization needed for the Services to process their requests. We may also use this information to compile reports for enterprise customers analysing Databook usage, but limited only to usage by their employees and other users on the enterprise customer’s enterprise account.

Please note that if you are registering for or using the Services as an administrator on behalf of an organization, you may be able to view the activity and/or content associated with your Associated users use of the Services, including, but not limited to, their Personally Identifiable Information.

If we plan to use your Personal Information in the future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy. See further the section of this Privacy Policy entitled “Amendment of this Privacy Policy”.

Payment Information

When you make a purchase on the Offerings, any credit card information you provide as part of your Payment Information is collected and processed directly by our payment processor Stripe through their Stripe Checkout service. We never receive or store your full credit card information. Stripe commits to complying with the Payment Card Industry Data Security Standard (PCI-DSS) and using industry standard security. Stripe may use your Payment Information in accordance with their own Privacy Policy here: https://stripe.com/us/checkout/legal.

Disclosure of your Information

We will never sell your data to third parties. However, in the course of business, we may hire third-party individuals and organizations to help us improve the Offerings. For example:

• We may share your personal information with third parties including our web host provider, other SaaS providers, such as an email hosting service, payment processors or outside contractors we hire to perform maintenance or assist us in securing our website.
• We may share your personal information when we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce a Customer Agreement, including investigation of potential violations thereof, or (c) protect against imminent harm to our rights, property or safety, or that of our users or the public as required or permitted by law;
• We may share your personal information with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues;
• We may share your personal information with a third party if we have your consent to do so.

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

In addition, if we are involved in a merger, acquisition or asset sale, your Personal Information may be transferred. We will provide notice before your Personal Information is transferred and becomes subject to a different Privacy Policy.

From time to time we may employ third parties to help us provide and/or improve the Services. These third parties may have limited access to databases of user information or registered member information solely for the purpose of helping us to provide and/or improve the Services and they will be subject to contractual restrictions prohibiting them from using the information about our users for any other purpose. Such agents or third parties do not have any rights to use Personal Information beyond what is absolutely necessary to assist us. We endeavour to keep an updated list of such third parties, with links to their privacy policies, which you can find here.

The Offerings may also contain links to third party websites. This Privacy Policy applies solely to information collected by us. Even if the third party is affiliated with us through a business partnership or otherwise, we are not responsible for the privacy practices of such third party. We encourage you to familiarize yourself with the privacy policies of such third parties to determine how they handle any information they separately collect from you. Please be aware that we do not warn you when you choose to click through to another website when using the Offerings. The Websites contain features that enable you to post reviews, comments or other content that is publicly viewable. You should be aware that any personal information you submit as part of those posts can be read, collected, or used by other visitors to the Websites, and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to publicly post on the Websites.

Your Controls and Choices

Communication Preferences

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications or on the Offerings. Please note, however, that you may be unable to opt-out of certain service-related communications.

Blocking Cookies

You can remove or block certain cookies using the settings in your browser but the Offerings may cease to function properly if you do so.

Choosing not to share your personal information

Where we need to collect your personal information by law, or to be able to provide the Services to you and you do not provide that information when requested (or you later ask to delete it), we may not be able to provide you with the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Service or through other appropriate means.

Do Not Track Signal

We treat the data of everyone who comes to our site in accordance with this Privacy Policy, whatever their Do Not Track setting.

Right to Access, Edit, and Remove Your Information

You have a right to access personal information we hold about you. Whenever you use our Websites or Services, we strive to make sure that the Personal Information is correct. If that information is wrong, we give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your Personal Information, we may ask you to verify your identity before making any changes. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems). Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. Because we protect information from accidental or malicious destruction, even after information is deleted from Databook Services, it may not be immediately deleted from Databook’s servers.

If you prefer Databook to not sell or share your information: Submit a request on the web form or email us at privacy@trydatabook.com.

Executive Information

Through the Services, we provide our Customers and users access to Personal Information about various Executives. We refer to this as Executive Information.

We obtain the Executive Information exclusively from publicly available sources, such as websites for the companies at which an Executive works or public company filings made with governmental regulators. We provide this Executive Information to our Customers and users to give them business insights regarding our Customers clients and competitors.

In particular, we store and provide our Customers access to the following categories of Executive Information:

• First and last name
• Job title
• Biographical information
• Compensation

We take the following steps to ensure the integrity of the Executive Information:

• Business Information Only – Databook only collects business-related information about Executives.
• Opt Out – Anyone added to our databases may request to be removed at any time, via the contact information provided below. While Databook will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws.

In many cases, we have no direct relationship with the Executives who are the subject of the Executive Information. If you are contacted by one of our Customers who uses our Services and would no longer like to be contacted by them, please contact the Customer that you interact with directly. We may transfer Executive Information to companies that help us provide our Services. Transfers to subsequent third parties are covered by the service agreements with our Customers.

If you would like to know if we hold any Executive Information about you, or if you wish for us to correct, amend, or delete such information, please follow the instructions under “Right to Access, Edit, and Remove Your Information” above.

Security Measures

The security of your personal information is important to us. We maintain a variety of appropriate technical and organizational safeguards to protect your personal information. No method of transmission over the Internet, method of electronic storage or other security methods are one hundred percent secure. Therefore, while we strive to use reasonable efforts to protect your personal information, we cannot guarantee its absolute security.

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your password, and safeguard your user name, password and personal credentials when you are using the Services, so that other people will not have access to your Personal Information. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.

Changes to the Privacy Policy

We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post or provide appropriate notice. Except as explained below, any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted, and any material changes will become effective 30 days from their posting on /privacy-policy or via email to your listed email address. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you and your account. The date on which the latest update was made is indicated at the top of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Services signifies your acceptance of any changes.

If applicable law requires your opt in consent to any particular amendment to this Privacy Policy, the amendment will not apply to your Personal Information until we receive such consent from you. To the extent we cannot provide some or all of the Services without your consent to such amendment to the Privacy Policy, your decision not to consent may result in our having to limit your ability to use certain aspects of the Services.

No Children Under Age 13

The Offerings are not intended for use by anyone under the age of 13, nor does Databook knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, you may not attempt to register for the Offerings or send any information about yourself to us, including your name, address, telephone number, or email address. In the event that we confirm that we have collected personal information from someone under the age of 13 without verification of parental consent, we will delete that information promptly. If you are a parent or legal guardian of a child under 13 and believe that we might have any information from or about such a child, please contact us at the email or mailing address provided at the end of this Privacy Policy.

Your California Privacy Rights and Disclosures

This section provides additional details about the personal information Databook collects about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information Databook has collected over the last 12 months, including the categories of sources, please see the Information We Collect section above. Databook collects this information for the business and commercial purposes described in the Information We Collect and Your Controls and Choices sections above. Databook shares this information with the categories of third parties described in these sections. Databook does not sell (as such term is defined in the CCPA) the personal information Databook collects. Please note that Databook may use third-party cookies for our advertising purposes as further described in our Cookie Policy.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information Databook collects (including how Databook uses and discloses this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at privacy@databook.com. Databook will verify your request using the information associated with your account, including your email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

If you prefer Databook to not sell or share your information: Submit a request on the web form or email us at privacy@trydatabook.com.

California Shine the Light Law

If you are a California resident and we disclose your personally identifiable information to third parties for such third parties’ direct marketing purposes, California’s Shine the Light Law (CA Civil Code Section 1798.83) allows you to request certain information from us about such disclosures. To make a request under the Shine the Light Law, please contact us at security@trydatabook.com. Please note that under California law, businesses are not required to respond to such requests more than once during any calendar year.

California Minors

At any time, you can delete or remove your posts using the same deletion or removal procedures described in Section 8 (Accessing and Updating Your Personal Information) above, or otherwise through the Offerings. If you have questions about how to remove your posts or if you would like additional assistance with deletion you can contact our support team at security@trydatabook.com. Although we offer deletion capability for our Offerings, you should be aware that the removal of posts may not ensure the complete or comprehensive removal of that content or information posted through the Offerings.

International Transfer

Databook is headquartered in the United States and has affiliates and service providers in other countries, and your personal information may be transferred for storage and processing to the United States or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction. By providing your Personal Information through the Services, you consent to such transfer, storage, and processing.

European Union users should read the ‘Additional Information for European Union Users’ below.

What If I Have Questions or Concerns?

If you have questions or need to contact us about this Privacy Policy, please email us at security@trydatabook.com.

Additional Information for European Union Users

Personal Information

References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation. For the purposes of this “Additional Information for European Union Users” section of the Privacy Policy, “personal information” includes “Executive Information.”

Controller and Data Protection Officer

Databook is the controller of your personal information for purposes of European data protection legislation. You can contact our Data Protection Officer at security@trydatabook.com.

Lawful bases for processing

We only use your personal information as permitted by law. A summary of lawful bases of our processing of your personal information are outlined in the table below.

Processing Purpose	Core Types of Processing	Lawful Basis
To provide the Service	Provide, maintain and improve the Offerings and to operate certain features and functionality. Process payments you make through the Services. Communicate with you to deliver certain services or provide support.	Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Services.
To improve the Services To communicate with you	To analyse trends, administer or optimize the Offerings, monitor usage or traffic patterns (including to track users’ movements around the Offerings) and gather demographic information about our user base as a whole. If you request information from us, register for the Services or participate in our surveys, promotions or events, we may send you Databook-related marketing communications if permitted by law but will provide you with the ability to opt out.	These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with law	We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities.	Processing is necessary to comply with our legal obligations
With your consent	Post your personal testimonials or case studies along with those of other satisfied customers on our Site in addition to other endorsements.	Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at security@trydatabook.com.

Use for new purposes

We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it.

Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Information) for six years after they cease being customers for tax purposes.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

Your rights

European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:

• Opt-out Stop sending you direct marketing communications. You may continue to receive Service-related and other non-marketing emails.
• 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.
• Transfer Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Object Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You can submit these requests by email to security@trydatabook.com. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at security@trydatabook.com or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Cross-Border Data Transfer

Whenever we transfer your personal information out of the EEA to countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on one of the safeguards recognized by the European Commission as providing adequate protection for personal information, where required by EU data protection legislation.

Complaints

Please submit any inquiries or complaints to security@trydatabook.com. A member of the team will reach back out to you. We value and respect all feedback and your rights to privacy.