Last Revised September 1, 2015
This Policy applies to Saba Software, Inc., and its affiliated entities throughout the world (collectively referred to as “Saba,” “we,” or “us”). A list of our affiliated entities is available at http://www.saba.com/us/about/locations/
Saba provides certain software products and services to its customers (“Customers”) and their end users (“Users”). Customers may elect to obtain Saba’s services as an online, web-based application, which is provisioned by Saba in a subscription-based, software as a service environment (“Subscription Services”). The User information supplied by Customers and/or their Users in the course of utilizing the Subscription Services is in the custody of, and may be accessible to, Saba and its agents. This User information may include personal information. Saba is committed to protecting the personal information of its Customers and their Users. This Policy describes the personal information Saba may receive from its Customers and their Users, the circumstances under which Saba may receive that information, the purposes for which it uses and shares that information, and how Saba safeguards that information. The use of information collected through Saba’s Subscription Services shall be limited to the purpose of providing the Subscription Services for which the Customer has engaged Saba. This Policy applies to information collected through our Subscription Services located on www.sabacloud.com and/or such other URLs as Saba and/or the Customer may designate.
Saba has received TRUSTe's Privacy Seal signifying that this Policy and our practices have been reviewed for compliance with the TRUSTe program viewable on the validation page available by clicking the TRUSTe seal. The TRUSTe certification only covers information collected through our Subscription Services located at www.sabacloud.com and does not cover information that may be collected through our mobile applications.
If you have any questions or complaints regarding this Policy or our privacy practices, please contact us at firstname.lastname@example.org. If you have any unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at https://feedback-form.truste.com/watchdog/request.
Saba complies with the U.S. – EU Safe Harbor framework and the U.S. – Swiss Safe Harbor framework as set forth by the Department of Commerce regarding the collection, use, and retention of personal information from the European Union and from Switzerland, and Saba has certified its adherence to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor Framework, and to view Saba’s certification, please visit http://www.export.gov/safeharbor/.
Collection of Personal Information
The Subscription Services are delivered to Customers and Users in an on-line, web-based environment that is provided and maintained by Saba and its agents. Depending on the particular service and configuration, the Subscription Services may request, display and/or store information about each User. This may include personal information about Users over 13 as well as under 13, such as the User’s name, email address, parent’s email address, gender, date of birth, social security number or identity number, address, phone numbers, employment status, rate of compensation, ethnicity, and religion (collectively, “Personal Information”). Each User also defines or is assigned a unique user name, for use of the Subscription Services. The Customer is responsible for defining the fields of User information that are required or requested for use of the Subscription Services. In most instances, the Customer populates some or all of the User information from Customer’s own records. The Customer may also request that each User supply and/or correct his or her User information, as necessary for use of the Subscription Services.
When Customers and Users supply User information for the Subscription Services, that User information is received and maintained by Saba and its agents. User Personal Information collected by Saba in this manner may be stored, transferred and accessed in the United States, or any other country in which Saba or its agents maintain facilities, for purposes of performing tasks on behalf of and under the instructions of Saba.
If we provide Subscription Services to a Customer who wishes to collect information from Users under the age of 13, we will ensure that the Customer is obtaining the proper consent for us to collect such information on their behalf.
Information Related to Data Collected for our Clients
Saba collects information under the direction of its Clients, and has no direct relationship with the individuals whose personal data it processes. If you are a customer of one of our Clients and would no longer like to be contacted by one of our Clients that use our service, please contact the Client that you interact with directly. We may transfer personal information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our Clients.
Use of Personal Information
Saba may use Personal Information to:
Additionally, Users may display and use their own Personal Information, to identify themselves to other Users during collaborative sessions facilitated by the Subscription Services. Saba will only share Personal Information with third parties in ways that are described in this Policy.
Saba will not use Personal Information for any other purpose incompatible with the purposes listed above, unless the specific usage is required or authorized by the Customer or User, is in the vital interest of the Customer or User, or is necessary to comply with a legal obligation. Personal Information may be shared with Saba business affiliates in a manner consistent with the Policy.
Collection and Use Of Aggregated Information
Saba may collect aggregated, non-personally identifiable information that reflects how Customers and Users access, use and otherwise interact with the Subscription Services (“Aggregated Information”). Saba may retain and use Aggregated Information for the same purposes described for Personal Information, above. Additionally, Saba may share Aggregated Information publicly, and/or with Saba’s partners, Customers, vendors and agents. For instance, Saba may use Aggregated Information to illustrate usage patterns, adoption rates, or other facets of how Customers and Users use the Subscription Services.
Disclosure of Personal Information to Other Users
Depending on how the Subscription Services are configured and utilized by each Customer and User, the Subscription Services may display Personal Information in a format that is visible to other Users (e.g. during collaborative online sessions). Saba does not and cannot control or restrict access to a given User’s Personal Information by other Users, if that access is enabled by the specific Subscription Services configuration selected by a Customer. Saba advises its Customers and Users to implement and adhere to appropriate policies and procedures governing Personal Information that may be visible to other Users via the Subscription Services. Users may also be able to restrict or modify the means by which their Personal Information may be visible to other Users, as well as the amount of Personal Information displayed, depending on the configuration parameters chosen by the Customer.
Use of Personal Information by Third Parties
Saba may share Personal Information including children’s Personal Information with third party agents who provide products and/or services to Saba, such as web site hosting, information technology consulting, web site management, marketing, promotion, data analysis, audit, legal, administrative, back-up and security services. Saba works to ensure that such third parties use the Personal Information only for the purposes for which we engage them, and under privacy protections that are similar to what we maintain.
In the event that Saba merges with or is acquired by an unrelated third party, or there is any other change in Saba's corporate structure (including, without limitation, consolidation, liquidation, or transfer of substantial assets), Saba may transfer, sell or assign information in Saba’s possession, custody or control, including, without limitation, aggregated information and Personal Information, to one or more successor entities, who will be bound by the terms of the legal agreements entered into between Saba and its customers.
Saba may also disclose Personal Information in order to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal processes; (4) protect the rights, privacy, safety or property of Saba, Customers, Users, clients or the public; (5) enforce our license terms; and (6) permit us to pursue available remedies or limit the damages that we may sustain.
Use of “Cookies” and Other Tracking Technologies
Technologies such as: cookies, beacons, tags and scripts are used by Saba and our analytics providers. These technologies are used in analyzing trends, administering the Site, tracking users’ movements around the Site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you. We use Local Storage also referred to as HTML5 to track click-through performance and preferences. Various browsers may offer their own management tools for removing HTML5 LS’s.
Security and Confidentiality
Saba takes appropriate and commercially reasonable technical and organizational measures to protect Personal Information against unauthorized access, accidental loss or damage, and unauthorized destruction. Saba employees who have access to confidential, proprietary or personal information are required to treat it confidentially, and are not permitted to use it for purposes unrelated to Saba's business, nor to disclose it to unauthorized third parties.
Saba uses technology (such as encryption) to protect the Personal Information that Customers and Users supply in the Subscription Services environment. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure. Customers and Users who have reason to believe that their interactions with Saba (including their use of the Subscription Services) are no longer secure are strongly encouraged to notify us of the problem by contacting us at email@example.com.
Saba will not keep your Personal Information or Personal Information that it processes on behalf of Customers for longer than is necessary for the fulfillment of the purposes outlined herein. Saba may retain Aggregate Information for so long as there is a legitimate or foreseeable business purpose for retaining such Aggregate Information. Saba seeks to avoid the retention of unnecessary or duplicative information.
Wherever possible, Saba takes reasonable steps to ensure that the Personal Information it maintains is reliable for, and relevant to, its intended use. We also endeavor to ensure that such Personal Information is accurate, complete and current.
Access and Correction For the Subscription Services, User information is supplied by Customers, and/or by Users themselves. Depending on the configuration of the Subscription Services, as defined by the Customer and its administrator(s), Users may have the ability to supply, correct, delete inaccuracies, or remove their own Personal Information. Where required by applicable law, Saba will make reasonable efforts to work with its Customers to allow Users to access and correct their Personal Information. For information about how to exercise these rights, or to unsubscribe from our newsletters or from our sharing information with third parties for their marketing purposes, please contact Saba Privacy at firstname.lastname@example.org. We will respond to your access request within 30 days.
If you would like access, update or request deletion of your child’s personal information, please contact the Saba Customer that you or your child have been interacting with to do so. Parents may refuse further contact with their child by contacting the Saba Customer directly. If we have collected your child’s information directly, you may contact us at email@example.com.
Access and Retention of Data Controlled by our Customers:
Saba has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to the appropriate Saba Customer (the data controller). If the Customer requests Saba to remove the data, we will respond to their request within 30 days.
This Policy was last revised in September 1, 2015. We may update this Policy from time to time. Changes to this Policy will be posted on the Saba Policies and Entitlements page, at https://policy.saba.com, and those changes will be effective immediately upon posting the revised Policy to the Policies and Entitlements page. We recommend that our Customers and Users review this Policy on a regular basis. By continuing to use the Services after a revised version of this Policy has been posted, each Customer and User will be deemed to have agreed to the changes to this Policy. If we make material changes to this Policy, we will notify you here, by email, or by means of a notice on our home page prior to the change becoming effective.
If we make material changes to how we use Personal Information collected from children under age 13, we will ensure that our Customer notifies parents in order to obtain verifiable parental consent for the new uses of the child's Personal Information.
Questions regarding this Policy should be directed to Saba at firstname.lastname@example.org or by contacting us at:
Saba Software, Inc.
Attn: Legal Dept.
2400 Bridge Parkway
Redwood Shores, CA 94065
+1 650 581 2500