Last Revised 23 May 2018
This Policy applies to www.saba.com, associated website pages where Saba offers support to and interaction with and between Saba customers and any other website that expressly references this Policy (collectively the "Website"). References to "Saba", "we" or "us" means Saba Software, Inc., and its affiliated entities worldwide.
Saba is committed to protecting information which can be used to directly or indirectly identify an individual ("personal data") when using our Website. For that reason, Saba created this Policy which explains what personal data Saba collects about you, the purposes for which it uses and shares this data, how you may correct such data and how we safeguard that data.
The entity responsible within the meaning of the EU General Data Protection Regulation (GDPR) is: Saba Software Inc., 4120 Dublin Blvd, Suite 200, Dublin, 94568, California, USA,
The EU-located representative of the above entity is: Saba Software (UK) Limited, 3 Arlington Square, Bracknell, Berkshire, RG12 1WA, United Kingdom,
Subject to applicable law, you may have the right to contact the responsible supervisory authority with complaints regarding data protection. In the EU, the UK Information Commissioner's Office can be reached via the website https://ico.org.uk/.
2. APEC Cross Border Privacy Rules & U.S. Privacy Shield Framework
Saba's privacy practices described herein comply with the APEC Cross Border Privacy Rules System. For more information, please visit: http://www.apec.org/Groups/Committee-on-Trade-and-Investment/~/media/Files/Groups/ECSG/CBPR/CBPR-PoliciesRulesGuidelines.ashx.
Saba Software, Inc. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework's applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce's Privacy Shield List https://www.privacyshield.gov/.
Saba 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. Saba complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Saba is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
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. Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
3. Basis for Processing
We may update this Policy from time to time. When we do so, changes in our Policy will be effective immediately upon posting the revised Policy to the Website. As a result, we recommend that you check this Policy on a regular basis. If you do not agree with the terms of this Policy, please do not continue using this Website.
Saba processes personal data as required in order to comply with applicable laws, rules and regulations and further to Saba's legitimate interests. As may be required by applicable law, we may also seek your consent to process certain personal data provided by you or collected on this Website. Any consent will be entirely voluntarily. However, should you choose not to grant the requested consent to the processing of your personal data, certain offerings or services may limited in scope or not available.
4. Collection of personal data
However, when you use the contact and other communication, sharing, download or other interactive functions of the Website, this requires the provision of the data described in more detail in this Policy when you use such function. If you do not provide us with the information required, you cannot use the respective function on our Website.
The personal data you may provide us falls into two broad categories: user-provided information and website usage information, each of which is described below. Personal data collected by Saba may be stored in the US or other countries in which Saba maintain facilities.
We may collect personal data that you choose to provide to us. For example, this may occur when you:
- register for events, training or other Saba offerings;
- subscribe for Saba newsletters, information or other communications from Saba or its partners;
- participate in on-line surveys, bulletin boards or discussion groups;
- apply for a job with Saba;
- request access to limited-entry areas of our Website;
- download materials from the Website;
- provide us with a written or video testimonial;
- ask us to contact you, or pose questions for us to answer; or
- otherwise submit your contact information to Saba.
In such cases, we may collect personal data such as: your first and last name, location, your postal and email address, your telephone number, social media information, and certain information about the company you are working for, such as: your company's name, address, your job title/seniority level. In the event you choose to provide Saba with your social media information, Saba may retrieve publicly available information about you on such social media platforms.
Should you apply for a job at Saba, we may also require you to submit additional personal data such as your address, phone number, education, past work experience as well as a resume.
Website Usage Information
When you visit our Website, we may collect information regarding your visit for marketing purposes and to better improve our Website and your experience with it. Technologies such as cookies, beacons, tags and scripts are used by Saba and our online marketing partners. These technologies are used in analyzing trends, administering the Website, tracking users' movements around the Website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies on an individual as well as aggregated basis. More specific details about information we may collect is as follows:
Web Functionality Cookies: These cookies are used to remember information you have entered or the choices you have made to provide a more personalized experience on our website. These cookies are owned by Saba and will remain on your computer for up to a year.
Web Analytics cookies: These cookies are used to determine how our website is functioning and what areas of our websites interest our visitors. This enables us to make the structure, navigation, and content of our Websites as user friendly as possible. It also helps us respond to our users in a more relevant way when they ask to be contacted by us. These cookies are owned by 3rd party tools that Saba leverages. For more information about these cookies, please consult the vendor's respective data privacy policies.
When you visit our Website, we may also use clear GIFs, web beacons, pixel tags or similar techniques in our Website and/or in our communications with you. A clear GIF is typically a one-pixel, transparent image located on a web page or in an e-mail or other type of message that helps us to verify an individual's viewing or receipt of a web page or message. Clear GIFs allow us to know whether you have viewed a web page prior to visiting our Website and may enable us to relate such information to other information, including your personal data. We use information provided from these to allow more accurate reporting and improve the effectiveness of our marketing.
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 may combine this automatically-collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or site functionality.
We also use local storage (also referred to as HTML5) to store content information and preferences. Third parties with whom we partner to provide certain features on our Website or to display advertising based upon your web browsing activity use local storage to collect and store information.
You can log in to our job portal using sign-in services such as Facebook, LinkedIn and Google. These type of services will authenticate your identity and provide you the option to share certain personal data with us such as your name and email address to pre-populate our sign up form.
We partner with a third party to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
5. Use and Purpose of Collected Personal Data
Saba uses personal data to:
- Assist you with learning and people management requirements, and collaboration sessions;
- Maintain databases and subscription lists;
- Process job applications;
- Alert you to product upgrades, special offers, updated information and other new or complementary products and services;
- Deliver services, such as newsletters, information, materials, other communications, events, training and software requested;
- Better improve our Website and your experience with it;
- Provide you with access to limited-entry areas of our Website, as appropriate;
- Otherwise conduct its business operations; and
- Contact you as necessary for the above purposes.
We will not use personal data for any other purpose incompatible with the purposes listed in this Policy, unless it is authorized by you, or is necessary for us to comply with a legal obligation. In addition, the personal data you provide or we collected on the Website will not be used for automated individual decision making
Saba may also receive information about you from other sources, including third parties from whom we have purchased data, and combine this information with personal data we already have about you. This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide products and services that may be of interest to you.
6. Sharing Your Personal Data
Personal data may be shared within the companies making up the Saba group, solely in connection with the purposes set out in this Policy. All such companies are bound by appropriate data processing agreements and/or confidentiality undertakings, and will only use personal data in accordance with this Policy. Such companies are located within the European Economic Area, in countries that are regarded by the EU Commission as featuring an adequate level of data protection, or are subject to a valid transfer mechanism.
Personal data may also be shared, as required, with those who provide products and/or services to Saba and it customers - such as web site hosting, information technology consulting, web site management, foreign language support, complementary products and services requested by Users, data analysis, audit, legal, administrative, back-up, security, marketing and promotion. We only provide these third parties with the minimum amount of personal data necessary to provide the services on our behalf, and the third parties are (where legally required) bound by appropriate order data processing agreements (including a GDPR compliant level of data protection) and/or comprehensive confidentiality undertakings and therefore not permitted to use your personal data except for the limited purpose of completing the requested service or transaction.
Circumstances may arise where Saba may decide to sell, buy or otherwise reorganize some or all of its business. Such a transaction may involve, in accordance with applicable law, the disclosure of personal data to prospective or actual purchasers. Saba will seek appropriate protection for personal data in these types of transactions. Saba may also retain and disclose personal data 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, Website visitors, clients or the public; and (5) enforce our Website terms of service.
7. Preferences; Opt-Out (Withdrawal)
We may also ask Website Users to choose whether to allow Saba to share their personal data with third parties for marketing purposes. We will honor the choices made. If you subsequently decide that you no longer wish to receive promotional emails from Saba, or if you no longer wish to allow Saba to share your personal data on a going-forward basis for marketing purposes with third parties, you may opt-out of receiving such emails or from such sharing by simply following the opt-out procedure specified in such e-mail. In addition, if you have registered on our site, you may opt out of receiving any future marketing or similar messages by emailing your request to unsubscribe here:
We will endeavor to comply with your request as soon as reasonably practicable, and in conformance with applicable law. If you wish to cease receiving marketing-related emails from such third parties, please contact such third parties directly or utilize any opt-out mechanisms set forth in their respective privacy policies or marketing-related emails.
Your personal data will be stored after the opt-out request for as long and as far as we are obliged to do so within the scope of the legal archiving obligations or we still need your personal data to carry out or process an existing contractual relationship or for purposes of proof.
We point out to you that the processing of your personal data, which we have carried out on the basis of your given consent until your withdrawal, is not affected by the withdrawal and remains legal.
Subject to applicable law, you may be entitled to withdraw your consent (opt-out) to the processing of your personal data for the future at any time. To do so, please contact the office mentioned in Section 12 below.
8. External Links
9. Security and Confidentiality
Saba takes appropriate and commercially reasonable technical and organizational measures to protect personal data against unauthorized access, accidental loss or damage and unauthorized destruction. Unfortunately, however, no security system or system of transmitting data over the Internet can be guaranteed to be entirely secure. Saba staff and third parties who handle personal data are required to treat it confidentially and are not permitted to use or share it except as provided in this Policy.
For the aforesaid purpose, your personal data is encrypted during transmission using Transport Layer Security (TLS). This means that the communication between your computer and the servers of the Website takes place using a recognized encryption method, which is considered secure in the current version (currently TLS 1.2). If your browser supports TLS, this function protects the transmission of personal data. In this case, most browsers display a short dialog box or a graphic icon to indicate whether the security protocol is supported. You can find further information in the help function of your browser.
10. Data Retention
We will not keep personal data longer than as necessary for the fulfillment of the purposes outlined herein, or as required by law or regulation. We seek to avoid the retention of unnecessary or duplicative information. Thus, we delete personal data of Website users routinely, unless we are legally obliged to keep such data for a longer period or we still need your personal data to carry out or process an existing contractual relationship or for purposes of proof. In such a case we delete the relevant data after the legal retention period has expired or as soon as we no longer need the data for the execution or processing of an existing contractual relationship or for purposes of proof.
11. Access, Deletion, Correction, Restriction of Processing, Objection and Data Portability
Our goal is to ensure your personal data is accurate and complete. You can help us accomplish this by letting us know when it changes. Subject to applicable law, you may have the right to obtain information from us about your personal data processed by us, as well as the right to correct, delete, restrict processing, object to processing and to data portability. If you wish to exercise one or more of the above rights, please contact the office indicated in Section 12 below. Should there be a requirement for Saba to retain your personal data, Saba will delete it when the requirement to retain it has ceased.
12. Contact Information
Questions regarding this Policy should be directed to Saba at or by contacting us at: .