This Privacy Policy (“Privacy Policy”) outlines how we collect and process your Personal Data in connection with our using our Website and Service as set out in our Terms of Service (“General Terms”), available at https://www.licence.one/terms-of-service, collectively referred to in this Privacy Policy as the “Agreement”.
Any terms used in our Privacy Policy, unless otherwise defined, will be considered to have the same definitions as the General Terms. Don’t worry - we’ll make them stand out by capitalizing the first letter of the word from herein.
By accessing and using our Website and Service, you agree to review this Privacy Policy, which may be changed or updated at any time without notice. Any changes will be published on our Website available at https://www.licence.one/privacy, and we advise you to consult it regularly.
Before moving on, allow us to define the categories of Personal Data we may Process:
Our Services are intended for use by businesses and not for consumer purposes. Therefore, we treat all Personal Data covered by this Privacy Policy, including information about any visitors to our Website, as relating to individuals acting as business representatives, rather than in their personal capacity. To the maximum extent permitted by applicable law, you hereby acknowledge and agree that consumer laws do not apply.
We may collect Personal Data directly from an individual or automatically when an individual interacts with our Website or Services. We may also collect Personal Data from other sources and third parties before our first interaction with you. Specifically, we may collect or generate the following types of Personal Data about individuals:
We automatically collect or generate connection, technical and aggregated usage data, such as;
We may collect information such as:
We may collect or receive Personal Data about Prospects (such as name, contact details, position and company) when they interact with our ads, when voluntarily providing us Personal Data by submitting details to our forms on our Website, subscribing to our newsletter, or through the interactive Service demonstrations present on our Website. We may also receive such data from our business partners or Commercial Sub-Processors and through the use of tools and channels commonly used to connect between companies and individuals to explore potential business and employment opportunities, such as LinkedIn.
As a rule of thumb, we process Personal Data to the extent needed to run our Website, our content, and our Services. The processing of Personal Data takes place regularly only with consent, with exception to cases in which prior consent cannot be obtained and the processing of the data is permitted by law.
The processing of your data is either based on:
If you reside or are using the Services in a territory governed by privacy laws under which consent is the only or most appropriate legal basis for the processing of Personal Data as described herein (“Consent”), your acceptance of our General Terms or use of the Website will be deemed as your consent to the processing of your Personal Data for all purposes detailed in this Privacy Policy, unless applicable law requires a different form of consent. If you wish to revoke your Consent, please contact us as outlined in ‘11. Call me maybe’.
We use Personal Data for the following purposes, and in reliance on the legal bases for processing which we have outlined in the ‘Legal basis for processing’ columns below, as appropriate:
| Purpose | Legal basis for processing |
|---|---|
| To facilitate, operate, enhance, and provide our Services | Performance of Contract Legitimate Interest |
| To provide our Customers and Account Users with assistance and support, to test and monitor our Service, or diagnose or fix bugs, and to train our Customers and personnel | Performance of Contract Legitimate Interest |
| To personalize our Services, including by recognizing an individual and remembering their information when they return to our Service, and to provide further localization and personalization capabilities | Performance of Contract Legitimate Interest |
| To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our Service more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Service, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioural and interests-based advertising based on your activity, preferences or other data available to us or to our business partners | Legitimate Interest Consent |
| To facilitate, sponsor and offer events, contests and promotions | Legitimate Interest |
| To gain a better understanding of how individuals use and interact with our Services, which content and data they have processed through our Services, and how we could improve their and others’ experience and the value generated from our Services, so we may improve our products, offerings and the overall performance of our Services | Legitimate Interest |
| To contact our Customers, Account Users and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them | Performance of Contract Legitimate Interest Legal Obligation |
| To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity | Performance of Contract Legitimate Interest Legal Obligation |
| To create aggregated statistical data, inferred non-Personal Data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose | Legitimate Interest |
| To enforce the Agreement, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties | Legitimate Interest |
| To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards | Performance of Contract Legitimate Interest Legal Obligation |
| For any other lawful purpose, or other purpose that you consent to | Legal Obligation Consent |
We maintain, store, and process Personal Data for the Service in France, unless we transfer it to Sub-Processors outlined in our DPA (‘Annex 3 - Our Sub-Processors’), under which the conditions both parties will have engaged to on, or before we consider the Data Subject as an Account User.
We Process Personal Data for our Website and Services across the Commercial Sub-Processors outlined in the ‘12. Our Commercial Sub-Processors’ section of this Privacy Policy (“Commercial Sub-Processors”). Where we engage Commercial Sub-Processors, we will impose data protection terms that provide at least the same level of protection for Personal Data as outlined in our DPA, to the extent applicable to the nature of the services provided by our Commercial Sub-Processors.
We retain Personal Data collected through our Website or Services for reasonably necessary durations to maintain and enhance our relationship with you, to deliver our Website or Services, and to fulfil our legal and contractual duties.
When determining how long to retain your Personal Data, we weigh factors like the volume, type, and sensitivity of the data, along with the possibility of harm from unauthorized access or disclosure. Our Processing objectives and Legal Obligations are also considered when establishing appropriate retention periods.
Upon the expiration of these periods or when the Personal Data is no longer necessary for the purposes it was collected, we will securely delete or anonymize it within a reasonable delay after receiving your Instruction, unless you are party to our DPA which may supersede these data retention obligations. Even when retained due to Legal Obligations, we will restrict Processing to what is strictly necessary for compliance and safeguard the data from further use.
We may disclose Personal Data in the following ways:
We engage selected third-party companies and individuals to perform services on our behalf. Our Commercial Sub-Processors, outlined in ‘12. Our Commercial Sub-Processors’ may have access to Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Website and Services, and may only use Personal Data as determined in our agreements with them.
We also engage selected third-party companies to help provide our Service, the terms and details of which are outlined in our DPA.
Our Customers have access to any Personal Data of the Account Users that we process on their behalf in our capacity as a Processor. In such cases, sharing such Personal Data means that other individuals from your organization may receive such Personal Data on the organization’s behalf, and will be able to monitor, process, and analyse your Personal Data and associated content.
If you attend an event or webinar organized by us, or download or access an asset on our Website related to such an event, webinar or other activity involving third-party sponsors or presenters, we may share your Personal Data with them.
We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations.
Such disclosure or access may occur if we believe in good faith that:
We may share Personal Data with others if we believe in good faith that this will help protect our rights, property or personal safety, or that of our Account Users or Customers, or any members of the general public.
We may share Personal Data internally for the purposes described in this Privacy Notice. In addition, should we or any of our Affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, Personal Data may be shared with or transferred to the parties involved in such an event. We may disclose Personal Data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Data may also be disclosed in the event of insolvency, bankruptcy or receivership.
For the avoidance of doubt, we may share Personal Data in additional manners, pursuant to your Instruction, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
Our Website and Services utilize cookies, anonymous identifiers, pixels, container tags and other technologies in order for us and our Commercial Sub-Processors to provide and monitor our Services and Websites, to ensure that they perform properly, to analyse our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall Personal Data, such as an IP address, as indicated by a Prospect or Account User.
Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application; however, most browsers allow you to control cookies, including whether to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.
You have a choice regarding the use of cookies as described in this notice. Please note that rejecting or removing certain cookies may result in inadequate Service or Website experiences.
You can opt out of each cookie category, except strictly necessary cookies, by changing your settings here on the ‘Manage cookies’ footer of the Website.
Most modern browsers also allow you to adjust your cookie storage settings. To help you set this up for your browser, we’ve listed and linked to cookie settings’ helpdesk articles for the most popular browsers below:
| Google Chrome | Mozilla Firefox | Safari for Desktop |
| Safari for iPhone, iPad or iPod | Android | Opera |
If you are concerned about third-party cookies generated by advertisers, you may also opt out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, location permitting. You can opt out by visiting:
Please note that if you change device or browser, erase, or otherwise alter your browser’s cookies, including upgrading certain browsers, you might reset the opt-out preferences established on the above opt-out services. In doing so, you will therefore need to repeat this process to prevent additional tracking.
We engage in Service-based and promotional communications, through email, phone and in-App notifications.
If you are a Customer or Account User, we may contact you with important information regarding our Service. For example, we may send you notifications of changes or updates to our Service, billing issues or notifications you have otherwise set up in the App. You can typically update your communication preferences and notifications settings from your profile settings in the App, or where indicated otherwise in the notifications sent to you. You will not be able to opt out from receiving notifications that we reasonably consider to be of high importance, such as failed login attempts, password reset notifications, and magic sign-in links.
We may occasionally notify you about changes in the App, new services, events, special opportunities or any other information we think you will find valuable as our Customer, User or Prospect. We may provide such notices through any of the contact means available to us through the Services, or through our marketing campaigns on any other platforms.
If you do not wish to receive promotional communications, you can let us know at any time by following the “unsubscribe” instructions contained in the promotional communications we send.
We implement and maintain appropriate technical and organizational measures to protect Personal Data from Personal Data Breaches; however, we cannot guarantee that our Service will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
For more information about our security practices, please visit the security page on our website, available at https://www.licence.one/security, or head to the ‘Annex 2 - Technical and Organizational Provisions’ section of our DPA.
You have the right to manage your Personal Data at any time, and we will do our utmost to respond in a timely manner.
If you want to exercise your rights under any applicable law, just email us at legal@licenceone.com. We'll help you with requests such as accessing, correcting, or deleting your Personal Data, or if you want us to stop sharing your data with third parties. This applies whether you’re covered by GDPR in Europe, CCPA in California, VCDPA in Virginia, or other relevant laws.
These rights include, but aren't limited to:
When you reach out, we might ask for proof of identity to ensure we’re talking to the right person and that protecting others’ information too. We'll keep this identification info for legal reasons, like proving we responded to your request.
Sometimes, when we share your Personal Data with you, we might remove information that's about other people.
Please note that in instances where you wish to exercise your Data Subjects rights as an employee of a LicenceOne Customer, you may be directed to speak with your employer, who has the sole responsibility, as the Data Controller, to respond to any such Data Subject Requests.
Data Protection Laws recognize two important roles when Processing Personal Data:
Let's break down how this works in relation to Website and Services when these laws apply.
LicenceOne acts as the Data Controller for Prospect Data. We're responsible for this Personal Data, as explained in this Privacy Privacy, and our Commercial Sub-Processors who process it act as Data Processors, as outlined in ‘12. Our Commercial Sub-Processors’ section.
For Account User Data, LicenceOne can be both a Data Controller and Data Processor (or “Business” and “Service Provider” respectively, under CCPA). We use some of this data for our own Legitimate Interest, as described in ‘3. Data uses’, making us a Data Controller. And, when we Process Personal Data on behalf of Customers, we're a Processor.
When it comes to Customer Data, we are the Data Processor, operating under the reasonable Instruction of our Customers; who act as the Data Controller. If our Sub-Processors Process Customer Data for us, they become Sub-Processors, as outlined in ‘Annex 3 - Our Sub-Processors’ section of the DPA.
We process Customer Data following our Customer's reasonable Instructions, and as detailed in our Agreement with them.
Our Customers are solely responsible for deciding how to use our Service and ensuring that they comply with the applicable laws, including informing Data Subjects about how their Personal Data is Processed and handling requests related to Data Subject rights in relation to our Customer’s use of our Service. It's also our Customers who are responsible for any legal obligations related to Personal Data they Process using our Service. recognize two important roles when Processing Personal Data:
This Privacy Policy outlines what personal information we might collect and where it comes from (‘2. Data collection and Processing’), how long we store it (‘4. Data retention’), and how we delete it (‘9. Your rights as a Data Subject’). It also explains how we use your information (sections 2 through 7), including for "business purposes" as defined by the California Consumer Privacy Act (CCPA) and similar state laws. We don't sell or share your personal information for CCPA purposes or give it to third parties for their direct marketing.
However, as detailed in ‘5. Data disclosure’, we might share Personal Data with third parties like our Customers (who we Process data for), our service providers, or business partners who abide by our strict data and privacy obligations. Also, if you add third-party services to our Service or explicitly ask us to share your personal information with them, we may do so.
Our Services might include links to other websites or services, but we can't take responsibility for how those third parties handle your privacy. When you click away from our Services, remember to check out the Privacy Policies on each new website or service you visit. Just so you know, this Privacy Policy only applies to our Website and Services.
Our Website and Services aren't made for children under 18, or the age of majority in the jurisdiction where you reside. We don't intentionally collect their Personal Data, and we don't want to. If we find out a child is using our Website or Services, we'll move quickly to stop this use and delete any Personal Data we may have. If you think we might have Personal Data from a child under 18, please email us immediately at legal@licenceone.com
Okay, alright - we don’t have a phone number to call about this Privacy Policy, but if you have any questions about your Personal Data in relation to our Website or Services, you can get in touch by post or email, and we’ll respond in a timely manner. That’s why we have named a Data Protection Officer (“DPO”).
If you're concerned about how we Process your Personal Data, have questions about our Privacy Policy, or wish to make a complaint, you can reach our DPO by post or by email:
Please find below the details of who is behind the Website and Service, in other words - LicenceOne. We consent in advance that you can send us cookies of the delicious kind.
As outlined in ‘5. Data disclosure’, we may Sub-Process your Personal Data to the Commercial Sub-Processors listed below, if applicable to how you use our Website and Services.
Please note that this list is not to be mistaken with the list of Sub-Processors that we use to provide our Service to Customers, which instead can be found in ‘Annex 3 - Our Sub-Processors’ of our DPA.
| Entity | Address | Use | Location | Transfer mechanism |
|---|---|---|---|---|
| Webflow, Inc. | 398 11th Street, 2nd Floor, San Francisco, CA 94103, USA | Hosting for our Website and the forms found within it | USA | DPA + SCC + DPF |
| Hotjar Limited | Dragonara Business Centre 5th Floor, Dragonara Road, Paceville St Julian's STJ 3141, Malta | Analysing and reporting on interactions for our Website | Ireland | DPA + SCC |
| Cal.com, Inc | 2261 Market Street #4382, San Francisco, California 94114, USA | Reserving an App demonstration call with our personnel | USA | DPA + SCC |
| Dealfront Group GmbH dba Leadfeeder | Durlacher Allee 73, D-76131 Karlsruhe, Germany | Detect corporate companies visiting our Website via reverse IP lookup | EU | DPA |
| Lusha Systems, Inc. | 800 Boylston St. Suite 1410 Boston, MA 02199, USA | Identifying the professional contact details of Prospects | USA | DPA + SCC |
| Google Ireland Limited dba Google Ads | Gordon House, Barrow Street, Dublin 4, Ireland | Paid advertising campaigns and retargeting for Prospects on the Google search platform | EEA, USA, Turkey, South Africa, UK, Peru, New Zealand, Kenya, Israel, UAE, Columbia, Chile, Canada, Brazil, Australia, Argentina,India, Philippines, Taiwan | DPA + SCC |
| Meta Platforms Ireland Limited | Attn : Privacy Operations, Merrion Road, Dublin 4, D04 X2K5, Ireland | Paid advertising campaigns and retargeting for Prospects on the Meta platforms, including but not limited to Facebook, Messenger and Instagram | USA, Ireland, Denmark, Sweden | SCC |
| LinkedIn Ireland Unlimited Company | Wilton Plaza, Wilton Place, Dublin 2 Ireland | Paid advertising campaigns and retargeting for Prospects on the LinkedIn platform | USA | DPA + SCC + DPF |
