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Unified-CXM Platform
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Reduce call volume with a radically different contact center solution

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Build & manage an online community integrated into your Care strategy

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Automate workflows and processes — and drive more first-contact resolutions

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Analyze your content’s performance vs. competitors and best-in-class brands

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Sprinklr AI turns unstructured data into actionable, real-time insights for your
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Visualize real-time data on command centers, retail signage, stadium screens,
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SPRINKLR PRIVACY POLICY



Last Updated: April 1, 2021

EFFECTIVE AS OF APRIL 1, 2021

Your privacy is extremely important to us and we are committed to fair practices
that protect your personal data. We have developed this Privacy Policy to
clearly and transparently communicate what information we collect, how we
collect it and what we do with it when you access and use our websites and
products.


1. Coverage


This Privacy Policy covers the usage of the Sprinklr Customer Experience
Platform and other Sprinklr products, accessed remotely via the Internet. 

This Privacy Policy also covers Sprinklr’s privacy practices for our corporate
websites that directly link to this policy when you click on “Privacy” in the
website footer.

This Privacy Policy also doesn’t cover third-party websites accessed via our
websites. Such third-party websites are governed by the terms applicable to your
relationship with that third party, and Sprinklr accepts no responsibility or
liability in respect of third-party websites.



2. Controller, EU Representative and Data Protection Officer


This website is provided by Sprinklr, Inc. 29 West 35th Street, New York, NY
10001, USA (“Sprinklr”). Sprinklr is the controller for the purposes of all
applicable data protection legislation. Sprinklr is subject to the investigatory
and enforcement powers of the Federal Trade Commission (the “FTC”).

Sprinklr’s EU representative is Sprinklr Germany, GmbH, Alter Wall 67 – 69,
20457 Hamburg, Germany. Sprinklr Germany GmbH can be contacted by email
at privacy@sprinklr.com.

Sprinklr’s representative for the United Kingdom (“the “UK”) is Sprinklr UK
Ltd., 123 Victoria St, Westminster, London SW1E 6RA, UK.    Sprinklr UK Ltd. Can
be contacted by email privacy@sprinklr.com. 

Sprinklr’s data protection officer can be contacted at Sprinklr Inc, 29 West.
35th St. 7th Floor, New York, NY 10001, USA or at privacy@sprinklr.com.



3. Sprinklr Platform


The Sprinklr Platform is the leading front office platform, providing social
engagement, social care, social listening, social advertising, social advocacy
and several other services to our customers. Our customers are the controllers
of the data processed via the Sprinklr Platform (e.g. publicly accessible data
collected from the social media networks via social media listening). Detailed
information on the Sprinklr Platform functionalities and its data protection
principles is provided in Sprinklr Social Media Management System (SMMS) Privacy
Policy. In addition, our commitment as a data processor to our customers is
governed by a separate Data Processing Amendment (DPA). An overview of our data
protection compliance measures is given by our GDPR Compliance Overview. All
documents are also accessible via www.sprinklr.com/legal.

Sprinklr however remains Controller of the personal data related to the
registration, login and usage of our platform and products (“system”) by system
users. During the registration process basic user profile data is collected
including the user’s name, business email address (used as user identifier),
password (stored in hashed format), and permissions. During login you’ll be
required to provide your business email address and your password. While you’re
using the Sprinklr Platform, we create logs of your actions including what you
accessed, from which IP address and at which time. To better understand how you
use our products and to continuously improve our product offerings, we may use
additional analytic tools. When you are a registered user of the Sprinklr
Platform, we may automatically register you in our support system, which
simplifies the process for you to contact our technical support team.
Furthermore, we use relevant information for billing purposes. Without a
registered user account, you cannot use the Sprinklr Platform.

The legal basis for the processing of such personal data is “performance of a
contract” (Art. 6 (1) lit b) GDPR). The purpose of the processing of such
personal data is the provisioning, maintenance, improvement and security of the
Sprinklr Platform. The above-mentioned personal data will be deleted after they
are no longer necessary to achieve the purpose for which they were collected,
generally upon the expiration of the underlying service contract, considering
retention periods under tax and commercial law.



4. Information We Automatically Collect


When you visit our website, we collect certain information related to your
device, such as your device’s IP address, browser types and versions used,
operating system used by the accessing system, referring website, what pages
your device visited, and the time that your device visited our website.

5. Information You Provide to Us


We may collect any Personal Information that you choose to send to us or provide
to us:

5.1 Newsletter

On our website, you can subscribe to our email newsletter. When an email address
is registered for our newsletter, a confirmation email will be sent to the
e-mail address registered and the email newsletter will only be sent if the
email address is confirmed by clicking a link provided in that confirmation
email (so-called double opt-in procedure). We store the IP address and a
timestamp, both for the registration and the subsequent confirmation. This data
is collected for legal protection purposes, it enables Sprinklr to document and
provide evidence for the addressees’ consent to be sent the email newsletter.

You may unsubscribe from our email newsletter and withdraw your consent to be
sent the email newsletter at any time. Every email newsletter contains an
unsubscribe link. In addition, you can send your request to unsubscribe
to privacy@sprinklr.com and you can use our Preference Center.

We also may use tracking pixels in our email newsletter enabling Sprinklr to see
if and when an email was opened and if certain links in that email were clicked
by the addressee. This allows analysis, reporting and optimization of email
marketing campaigns. Legal basis of the usage of such tracking pixels is our
legitimate interest in performing, analyzing, reporting and optimizing our email
marketing campaigns. You may opt-out from email newsletter tracking by
unsubscribing from our newsletter or by contacting privacy@sprinklr.com.

5.2 Forms

If you contact us via the website, request a demo, register for a webinar, input
information to estimate your potential return on investment from our solutions,
or otherwise enter information into forms on our website, we will use the data
provided for the purpose of processing your request. We will keep a record of
the correspondence and the information that you enter, and we may use that
information to contact you about the Sprinklr Platform and services.

5.3 Job Applications

Sprinklr processes the personal data provided in the context of a job
application for the purpose of processing the application.

6. Cookies and other tracking technologies


Our websites use cookies (small text files containing a string of alphanumeric
characters that we put on your computer) and other similar tracking technologies
(like web beacons, tags and scripts) to uniquely identify your browser and to
gather information about how you interact with the websites.

Some cookies collect information about browsing behavior when you access this
website via the same computer or device. This includes information about pages
viewed, products purchased and your journey around a website. We do not use
cookies to collect or record information on your name, address or other contact
details.

We use this information for the following purposes:

 * assisting you in navigation;

 * assisting in registration, login, and your ability to provide feedback;

 * analyzing your use of our website; and

 * assisting with our promotional and marketing efforts (including behavioral
   advertising).

How do I disable cookies?

If you want to disable cookies, please visit Cookie Preferences. You also can
change your website browser settings to reject cookies. How you can do this will
depend on the browser you use. Further details on how to disable cookies for the
most popular browsers are set out below:

For Microsoft Internet Explorer:

Choose the menu “tools” then “Internet Options”

Click on the “privacy” tab

Select the setting the appropriate setting

For Google Chrome:

Choose Settings> Advanced

Under “Privacy and security,” click “Content settings”.

Click “Cookies”

For Safari:

Choose Preferences > Privacy

Click on “Remove all Website Data”

For Mozilla firefox:

Choose the menu “tools” then “Options”

Click on the icon “privacy”

Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:

Choose the menu Files”> “Preferences”

7. Website Analytics


On some websites we also utilize Google Analytics, a web analysis service
provided by Google, to better understand your use of our Websites and Services.
Google Analytics collects information such as how often users visit the
Websites, what pages they visit and what other sites they used prior to
visiting. Google uses the data collected to track and examine the use of the
Websites, to prepare reports on its activities and share them with other Google
services. Google may use the data collected on the Websites to contextualize and
personalize the ads of its own advertising network. Google’s ability to use and
share information collected by Google Analytics about your visits to the
Websites is restricted by the Google Analytics Terms of Use and the Google
Privacy Policy. Google offers an opt-out mechanism for the web available here.

8. Purposes of and Legal Basis for Processing


Sprinklr only processes your personal data for the purposes described in this
Privacy Policy or as otherwise permitted under applicable law. The processing of
your personal data by Sprinklr for the purposes described hereunder is based on
your explicit consent or on the necessity to process your personal data for the
purposes of our legitimate interests.

We process your personal data for the following purposes, subject to your
consent where required by law:

 * administer our relationship with you, including to respond to your inquiries
   or complaints;

 * to provide any services or information you have requested and information
   about our products and services;

 * to administer, operate, maintain, and improve the websites and our services;

 * for efficient customer management relationship;

 * to simplify access to some interactive features on our websites;

 * to keep improving the way our websites work;

 * to count how many persons visit our websites, where they come from, when they
   visit, how long they stay and what pages they look at;

 * to associate your activity on our website in order to give us insights into
   products and services you might like and measure how our advertising
   performs;

 * to note browser, OS and device details used to make sure you get a good
   online experience when you access our websites;

 * to audit usage of the websites;

 * to market and improve the services that we offer;

 * Carry out research and statistical analysis including to monitor how all
   customers use our websites;

 * to comply with applicable laws and regulations.

Sprinklr does not use automatic decision-making or profiling.



9. Data Sharing


Our policy is to not give, sell or otherwise distribute personal data we collect
to third parties outside of Sprinklr (including Sprinklr affiliates), except
where required with your express consent or where this is necessary and in
accordance with applicable law. In such an event, Sprinklr will enter into
written agreements with each Sprinklr Group Company, Third-Party Service
Provider or Other data recipient containing data protection obligations not less
protective than those in this Policy to the extent applicable to the nature of
the services provided by such third party. Where the third party fails to
fulfill its data protection obligations under such written agreement, Sprinklr
will remain fully liable for the performance of the third party's obligations
under such agreement. In line with this, we share personal data with the
recipients listed below:

 * Sprinklr Group Companies

We may share your personal data with affiliates entities of Sprinklr for the
purposes specified above and as described under the section “International Data
Transfers” below.

 * Third-Party Service Providers

Your personal data may be disclosed to third party service providers, acting on
our behalf, in connection with managing services, data analytics, marketing,
finance, accounting or other administrative services and information technology
support. These third-party service providers will have access to and process
personal data only on our behalf and under our instructions and will be held to
appropriate security obligations.

 * Other data recipients

For the above purposes or where otherwise required by law, we may also need to
make personal data available to third parties such as advisors, banks and
financial institutions, professionals, independent consultants, potential or
existing investors and/or acquirers (in connection with a merger, acquisition,
or sale involving Sprinklr and/or affiliates entities of Sprinklr or as part of
a corporate reorganization, stock or asset sale, or other change in corporate
control),.

Additionally, Sprinklr may provide information, in response to properly made
requests, for the purposes of the prevention and detection of crime, and the
apprehension or prosecution of offenders, when required to do so by law, for
example under a court order, or in response to properly made court or
administrative demands or upon the order of regulatory and/or administrative
authorities, courts or police authorities. Sprinklr may also provide information
for the purpose of safeguarding national security. In either case, Sprinklr will
act in accordance with applicable data protection law.

10. Information Security


We use appropriate technical, organizational and administrative security
measures to protect any information we hold in our records from loss, misuse,
and unauthorized access, disclosure, alteration and destruction. We will also
take all reasonable precautions to ensure that our staff and employees who have
access to personal data about you have received adequate training.

11. International Data Transfers


In providing our services or websites to EU or UK citizens, we may need to
transfer your personal data outside the European Economic Area (“EEA”),
including in countries that do not provide the same level of protection for
personal data as in the EEA. In any case, we will only transfer personal data to
recipients that provide an adequate level of data protection or as permitted by
applicable data protection laws by implementing appropriate safeguards,
including, but not limited to, relevant data transfer agreements based on the
Standard Contractual Clauses, when needed. The Standard Contractual Clauses
shall apply to any transfers of Personal Data from the European Economic Area
and/or their member states, Switzerland and the United Kingdom to countries
which do not ensure an adequate level of data protection within the meaning of
applicable laws of the foregoing territories.

In addition, Sprinklr complies with the EU-U.S. Privacy Shield Framework and the
Swiss-U.S. Privacy Shield Framework as set forth by the US Department of
Commerce regarding the collection, use, and retention of personal information
from European Union and Switzerland to the United States, respectively. Sprinklr
has certified to the Department of Commerce that it adheres to the Privacy
Shield Principles. To learn more about the Privacy Shield program, and to view
our certification page, please visit https://www.privacyshield.gov/.

Sprinklr commits to resolve complaints about your privacy and our collection or
use of your personal information. For any inquiries or complaints regarding this
privacy policy and/or Sprinklr’s processing of your personal data, please
contact privacy@sprinklr.com.

If a complaint or dispute cannot be resolved through our internal process, we
agree to dispute resolution using the applicable data protection authorities
(“DPAs”) as an independent recourse mechanism. Sprinklr will cooperate with the
DPAs in the investigation and resolution of complaints brought by you under this
Privacy Policy. 


12. Retention and Deletion


We process and store your personal data only for the period necessary to achieve
the purpose of storage. If the storage purpose is not applicable, or if a
storage period prescribed by the European legislator or another competent
legislator expires, the personal data are routinely blocked or erased in
accordance with legal requirements.

13. Rights of the Data Subject


In accordance with applicable data protection law, you have a right to:

 * obtain confirmation of the existence of, and to request a written copy of the
   personal information Sprinklr holds about you;

 * have any inaccurate information about you corrected;

 * have personal data we hold about you deleted, blocked or removed;

 * withdraw your consent where relevant, without affecting the lawfulness of
   processing based on your consent before its withdrawal;

 * restrict the processing we make in relation with your personal data;

 * receive your personal data, which you have provided to us, in a structured,
   commonly used and machine-readable format in order to transmit them to
   another data controller;

 * object to the use of your details for marketing activities and other
   promotional activities;

 * lodge a complaint with a supervisory authority, in particular in the EU
   member state of your habitual residence, place of work or place of the
   alleged infringement if you consider that the processing of your personal
   data relating infringes applicable data protection law.

In case you wish to exercise any such rights, please submit a request
at https://www.sprinklr.com/privacy-request/ or contact us
at privacy@sprinklr.com. 

In addition to the above, you may revoke Sprinklr’s access to your personal data
via the Google security settings page, found at
https://security.google.com/settings/security/permissions.


14. Notice Concerning Children’s Information


Sprinklr does not direct any of its practices or system towards children. We are
committed to respecting the privacy of children online. If Sprinklr learns that
the information of a child under the age of 16 is stored, Sprinklr will promptly
delete any such personal information.

15. Updates to this Privacy Policy


We reserve the right to review this Privacy Policy at any time. Where
appropriate or required by law, we will notify you about the new privacy Policy
by posting appropriate notice on our websites. We encourage you to periodically
review this Privacy Policy to stay informed about our information practices. We
will indicate the date on which this Privacy Policy was last modified.

16. Contact


If you have any questions about this Privacy Policy, or if you wish to exercise
your rights under applicable data protection laws, please feel free to contact
us via https://www.sprinklr.com/privacy-request/ or write to us at Sprinklr,
Inc., Data Protection Officer, 29 West 35th Street, New York, NY 10001, USA.

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