Salesforce DMP is not in the business of setting industry standards, but we do all that we can to advance industry dialogue and improve standards of practice. We provide a Platform that enables our clients to manage their digital data subject to their own privacy policies. In that way, we enable our clients to manage their data in a responsible way and we empower consumers to better understand what data is collected via the Platform and how it is used.
We are members of the Network Advertising Initiative (“NAI”) and adhere to the 2015 NAI self-regulatory codes of conduct. We also adhere to the Self-Regulatory Principles of the Digital Advertising Alliance (“DAA”) in the U.S., Canada, and standards regulated by the European Digital Advertising Alliance (“eDAA”). In our work, we will seek to maintain alignment with standards established by industry groups such as the Interactive Advertising Bureau (“IAB”), NAI, and DAA, and we are members in good standing of the IAB, NAI, and eDAA.
Salesforce DMP Website
The Salesforce DMP Site is primarily directed to our clients (our “Clients”) and prospective clients; which are generally businesses. We don’t collect personally identifiable information (“PII”) such as email addresses or telephone numbers from the Salesforce DMP Site unless it is provided to us. For example, a user may choose to send us an email that contains their PII, or download a white paper in which case we’ll ask for PII such as their name, company name, email and telephone number. Our clients typically provide PII in order to setup an account with us, including their name, home or business address, email address, and/or telephone number. We use the PII we’re provided to answer questions, send requested information and/or to service our Clients’ accounts. We also collect the same non-personally identifiable information (“Non-PII”) from the Salesforce DMP Site as we obtain from our Clients via our technology Platform, as described below. Non-PII is information that cannot by itself be used to directly identify a particular person or entity, and may include an IP host address, pages viewed, browser type, Internet browsing and usage habits, Internet Service Provider, domain name, the time/date of a visit to a website, the referring URL and a computer or device’s operating system. We do not enable our technology Platform on the sections of the Salesforce DMP Site that enables our Clients to login and manage their accounts.
Salesforce DMP Technology Platform
Salesforce DMP uses HTML5 cookies in Connection with the Platform, including on the Salesforce DMP Site and most Client Sites. An HTML5 cookie is also known as HTML5 Web storage and is an alternative to the commonly used HTTP browser cookie. Salesforce DMP uses HTML5 cookies as a backup storage mechanism to HTTP cookies; storing both ad targeting data as well as user opt-outs in both HTTP and HTML5 cookies (collectively, our “Cookies”).
Salesforce DMP is experimenting with the use of statistical identifiers in connection with the Platform, including on the Salesforce DMP Site and some Client Sites where requested by Clients. Statistical identifiers are created using non-PII about computers and mobiles devices such as the operating system, user-agent string, IP address (in jurisdictions where this is not considered to be personal data), Internet browser, installed fonts, and similar information. This information makes your computer or device distinct enough for our systems to determine within a reasonable probability that they are encountering the same computer or device. Statistical identifiers enable users to be uniquely identified via the Platform, enabling the Platform to store ad targeting, analytics and other data. If you want to see whether Salesforce DMP is using a Statistical Identifier on the browser you are currently using, please visit http://optout.networkadvertising.org/#/.
Mobile Device Identifiers
Salesforce DMP uses mobile device identifiers such as the Android Advertising ID and Apple iOS’ IDFA in connection with the Platform where Clients ask Salesforce DMP to store information collected via Client Mobile Apps. Mobile device identifiers enable users to be uniquely identified via the Platform, enabling the Platform to store ad targeting data.
How we Collect and use Non-PII via our Technology Platform
Salesforce DMP offers a technology Platform for website and mobile application operators, and we utilize the Platform when users visit the Salesforce DMP Site. When a user visits the website or mobile application of one of our Clients (the "Client Site" or “Client App”, collectively, the “Client Site and App”), the Client collects and transfers to Salesforce DMP and/or enables Salesforce DMP to collect Non-PII related to that user’s visits to their website or mobile app (our Client’s "Session Data"). This Session Data may include information about how the user came to the Client Site and App, which search engines they use, the search terms used to find the Client Site, their experience on the Client Site and App, information about how they interact with the Client Site and App, demographic information that the Client has collected from that user and other visitors, data from third-party data providers, and information regarding how users interact with advertisements on the Client Site and App. Additionally, browsers automatically send certain standard information to every website a user visits, such as an IP address, browser type and language settings, access times, and referring website addresses. This information is collected during visits to each Client Site and App, including the Salesforce DMP Site. We make Session Data accessible only to each individual Client. The Client typically uses this data on our Platform to deliver targeted advertising campaigns both on the Client Site and App as well as off their sites and apps. For example, Clients may use the Platform to help them find interested users and to deliver ads that attempt to bring those users back to the Client’s Site and App. Where our systems can reasonably infer that a particular computer and/or mobile device belong to the same user or household, we may store such information for use on the Platform. The data stored on our Platform may be combined with other third party Non-PII data in order to better target advertisements, to enable Clients to better understand users across multiple computers and devices, and for ad delivery and reporting purposes.
While Salesforce DMP does not allow PII directly onto the Platform, we do receive PII from Clients outside of the Platform. Typically, we receive the PII as part of an onboarding process whereby Salesforce DMP receives data that contains PII and render that data into Non-PII targeting segments utilizing a privacy-by-design process. Salesforce DMP may work with a third-party technology partner to help facilitate the onboarding process.
Salesforce DMP does not directly share Non-PII with either partners or third parties. Clients may choose to share their Non-PII data with others at their discretion, and Salesforce DMP may assist them to share user data collected on those Client Sites and Apps. Reporting is done at the aggregate level, with no user level information accessible.
How we use and share PII
We aim to keep PII data off of our Platform and do not intentionally collect PII via the Platform. As described above, we may obtain PII when visitors to the Salesforce DMP Site choose to provide it. For Clients who have setup an account with Salesforce DMP, we use the PII we have to administer their account. When Clients terminate their accounts, Salesforce DMP removes their PII from our systems within a reasonable time following such termination, subject to our right to retain (i) copies of transactions between the client and Salesforce DMP and related payment information, (ii) information relating to any dispute or potential fraud, (iii) any additional information that in Salesforce DMP’s discretion, we need to keep to protect our legal rights or the rights of others.
From time to time, Salesforce DMP engages with partners to perform services on behalf of Salesforce DMP or other Clients who use our services. For example, we may provide information to corporate affiliates, or to third parties under contract with Salesforce DMP ("Contracted Parties") to provide services such as credit card verification and processing, fraud detection and prevention, or data hosting. In all cases, Contracted Partners are contractually required to maintain the confidentiality of PII and may not use it for purposes other than performing the specific services on Salesforce DMP's behalf.
Other than such disclosure to Contracted Parties, Salesforce DMP may also disclose PII if such disclosure is required for Salesforce DMP to comply with valid and binding legal requirements, to protect Salesforce DMP's rights or property (or that of Salesforce DMP Clients), and/or where needed to protect personal safety. For example, Salesforce DMP may be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request. In the event we are required to disclose information in response to legal process or a government request, we will attempt to notify affected users for which we have contact information to the extent we are legally permitted to do so.
Finally, Salesforce DMP may transfer information, including any PII, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change. If Salesforce DMP is involved in a merger, acquisition, or sale of all or a portion of its assets, users will be notified via email and/or a prominent notice on the Salesforce DMP Site of any change in ownership or uses of PII, as well as any choices users may have regarding their PII. We may disclose your personal information to any third party with your prior consent.
Children, Sensitive Data
In accordance with industry standards and law (e.g., the Children’s Online Privacy Protection Act (“COPPA”) regulations in the U.S.), we do not knowingly collect, administer, or enable the commercial use of PII relating to children less than 13 years of age. If we become aware that a child under 13 has provided us with any information that would require compliance with the COPPA, then we will delete this information from our databases.
Ability to Opt-Out
Browser Opt-out - Salesforce DMP offers a one click web browser opt-out solution for users who wish to opt-out here. If you choose to opt-out, Salesforce DMP deletes any targeting data it may have for your browser, and we will no longer enable our Clients to target that browser using our technology Platform. You will likely still receive advertisements, but Salesforce DMP technology will have no input or impact on tailoring those ads to be more relevant to your interests. Please note that if you delete, block, or otherwise restrict cookies, or if you use a different computer, device or Internet browser, you will need to renew your opt-out choice. Also, because we utilize HTML5 cookies to record your opt-out choice, it may take an additional visit to one of our Clients’ websites for your opt-out choice to go into effect. To the extent that a particular browser and a mobile device are linked via our Platform, opting out will sever the link. If you choose to disable cookies, it may limit your use of certain features or functions on our website or service.
Mobile App Opt-out - Salesforce DMP honors the mobile device settings for Android and Apple iOS devices. To exercise this opt-out, please visit the privacy settings of your Android or iOS device and select “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android). On devices where we see that such a selection has been made, we will not target that mobile device via the Salesforce DMP Platform. To the extent that a particular browser and a mobile device are linked via our Platform, opting out will sever the link.
You may also find additional information about delivering targeted advertising to mobile devices and your choices with respect to Salesforce DMP and other companies who are members of the self-regulatory organizations below.
Do Not Track - Some web browsers offer a mechanism, known as a "Do Not Track" ("DNT"), that allows a user to elect to stop the collection of certain browsing data by websites and technology companies. Currently, the standards regarding the DNT signals and appropriate responses are not defined. As a result, Salesforce DMP is experimenting with DNT and may place an opt-out cookie on computers or other devices when we see a valid DNT signal.
Delete PII/Access – While we don’t knowingly obtain PII via our technology Platform, if you’ve provided Salesforce DMP with PII via the Website (e.g., by signing up for a product demonstration or white paper, sending us an email or by registering with Salesforce DMP as a Client), Salesforce DMP provides the ability for users to obtain and correct or request destruction of information maintained by Salesforce DMP by sending an email to firstname.lastname@example.org or by contacting us at the address noted below. We will answer these requests in a reasonable time. We will also allow users to control the delivery of promotional emails from Salesforce DMP.
For information that we are storing on behalf of our Clients, the Salesforce DMP has no direct relationship with the individuals whose personal data we’re processing. An individual who seeks access, or who seeks to correct, amend or delete such data, should direct his or her query to our Client and, if requested to remove data, we will respond within a reasonable timeframe.
Data Retention / Minimization
Salesforce DMP stores PII such as email address or billing details so long as you continue to have a business relationship with us. You may ask us to delete that information by following the instructions above.
Our cookies and similar tracking technologies expire six months from the last time our systems encounter a particular computer or device. We do not use any Session Data that is more than twenty-four (24) months old for user profiling or targeting. After 24 months, we remove any unique identifiers and store the data for up to 5 years.
We take commercially reasonable efforts to maintain security protections in accordance with industry practices to protect data we collect from loss, alteration, destruction, misuse and unauthorized access or disclosure. We have policies to help maintain control and physical security of the facilities used to store data and only allow access to authorized personnel, restrict access to data to those employees, contractors and agents that have a need to know the information in order to provide and support our services. All Salesforce DMP employees are bound by confidentiality obligations and may be subject to disciplinary or legal action if they fail to meet these responsibilities.
We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.
We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.
We endeavor to make our data reliable, accurate, complete, and current. One of the steps that we take is to permit users to provide demographic information, such as their age and gender, that will be associated with their browser. You can provide general demographic information by going to the following website: https://www.salesforce.com/products/marketing-cloud/sfmc/salesforce-dmp-consumer-choice/
We also allow users to control the delivery of promotional emails from Salesforce DMP, by updating their email preferences or by using the “unsubscribe” link found in the communications sent.
Data From the European Union (EU) or Switzerland
If Salesforce DMP received personal data about you from the EU or Switzerland, pursuant to Privacy Shield you have the following rights and options in addition to those explained elsewhere in this policy:
Access. You have the right to ask Salesforce DMP whether it has received personal information about you from the EU or Switzerland, and, if so, what data Salesforce DMP has received. Although Salesforce DMP will attempt in good faith to respond to your request, it may not be able to provide the requested information in all situations. For example, Salesforce DMP may not be able to provide the information that you request if it imposes an undue burden or expense, requires Salesforce DMP to release confidential commercial information, or requires the disclosure of information relating to another person. You can submit a request for information via email@example.com, or via mail to Attn: Salesforce DMP Privacy, 50 Fremont Street, Floor 40, San Francisco, CA 94105.
Correction. You have the right to ask Salesforce DMP to correct the personal information that it receives about you from the EU or Switzerland. For example, you can provide your gender and age so that it is associated to your browser at the following website: https://www.salesforce.com/products/marketing-cloud/sfmc/salesforce-dmp-consumer-choice/. Although Salesforce DMP will attempt in good faith to respond to other requests to correct information, it may not be able to make the correction in all situations. For example, Salesforce DMP may not be able to correct information about you if it would impose an undue burden or expense, or require Salesforce DMP to change information relating to another person. You can submit a request to correct information via firstname.lastname@example.org, or via mail to Attn: Salesforce DMP Privacy, 50 Fremont Street, Floor 40, San Francisco, CA 94105.
Onward transfer. As discussed above, Salesforce DMP may share information with third parties that provide Salesforce DMP with service. The Salesforce DMP is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Salesforce DMP complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. If such an entity takes an action that is contrary to the principles of the EU-US Privacy Shield or Swiss-US Privacy Shield, Salesforce DMP shall be liable for those actions unless it can prove that it was not responsible for causing such actions.
- Inquiries and Complaints: Salesforce DMP has committed to attempt to resolve privacy complaints under the EU-US Privacy Shield and Swiss-US Privacy Shield Principles. You may direct any inquiries or complaints concerning our Privacy Shield compliance to email@example.com. Salesforce will respond within 45 days. If you have an unresolved 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. If neither Salesforce nor our dispute resolution provider resolves your complaint, you may have the possibility to engage in binding arbitration through the Privacy Shield Panel, as described on the Privacy Shield Website: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.
Changes, questions, and communication
If we are required to contact you concerning your information, we may do so, if permitted by law, via email, telephone, and/or mail.
Last Updated: September 27, 2017