Privacy Policy

Last Modified: February 11, 2025

This Privacy Notice describes how Sutro Data LLC (together with its affiliated companies - "Sutro Data", "we", or "us") collects, stores, uses and discloses personal data when you interact with us, including when you visit or interact with any of our linked websites, participate in any of our events, interact with any of our online ads and content, emails, sales and marketing channels, integrations or communications under our control.

Please review this Privacy Notice carefully, and please use the information herein to make informed choices. If you have any concerns or questions about our privacy practices, please feel free to contact us. By accessing the sites, registering for an account, or making a purchase from us, you are agreeing to all of the terms set forth in this Privacy Notice.

If you do not agree to this Privacy Notice, do not use the sites, purchase our products, interact with us, or give us any information.

Our Services are designed for businesses and are not intended for personal or household use. Accordingly, we treat all personal data covered by this Privacy Notice, including information about any visitors to our sites, as pertaining to individuals acting as business representatives, rather than in their personal capacity.

You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our service providers, please do not provide it to us and avoid any interaction with us or with any of our Services.

1. Data Collection & Processing

When we use the term “personal data” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or identified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual. Sutro Data does not collect, use, or disclose sensitive personal data.

We collect the following categories of personal data, with respect to the following types of data subjects:

• Merchant Data: personal data that we collect, process and manage on behalf of our business customers (“merchants” or “customers”), as part of our platform. We process such Merchant Data on behalf of and under the instruction of the respective customer. Accordingly, this Privacy Notice (which describes Sutro Data’s own privacy and data processing practices) does not apply to such processing done on its customers’ behalf. To learn about the Privacy Notice and practices of our customers, please contact them directly.‍
• User Data: personal data concerning our customers’ internal focal persons who directly engage with Sutro Data concerning their organizational account, and users of the platform on behalf of such customers, e.g., the account administrators and users, billing contacts and authorized signatories on behalf of the customer (collectively, “users”); as well as the customer’s business needs and preferences, as identified to us or recognized through our engagement with them.
• Prospect Data: personal data relating to visitors of our websites, participants at our events, and any other prospective customer, user or partner (collectively, “prospects”) who visits, purchases, or otherwise interacts with our sites and Services.

Specifically, we collect or generate the following types of personal data about such individuals through the Services:

• Usage, login credentials, and device information concerning customers, users and prospects (connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses (geolocation), device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, website chat feature data, log-in credentials to the Services, the cookies and pixels installed or utilized on their device, and inferred or presumed data generated from their use of the Services, other internet or electronic network activity information and other device or browser information);
• Information concerning our customers, users and prospects (contact and business details such as name, email, phone number, position, workplace and professional information, and related business insights, our communications with such individuals (correspondences, sensory information including call and video recordings, and transcriptions and analyses thereof), feedback and testimonials received, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement), purchasing details including interest and/or purchase history, commercial information, including records of our products or services purchased, obtained, or considered);
• Personal data contained in Customer Data which is provided by our customers or processed on their behalf and under their instruction, which may also include any of the types of personal data described above (with respect to users or other individuals whose data is contained in the Customer Data).

We have collected such personal information from the following sources:

• We have collected such personal information from the following sources:
• Merchants and Users
• Service Providers

2. Data Uses & Lawful Bases for Processing

We use your personal data as necessary for the following business and commercial purposes:

• To facilitate, operate and provide our Services.
• To monitor, study and analyze use of the Services.
• To provide customer service and technical support.
• To comply with applicable laws and regulations.

If you reside or are using the Services in a territory governed by privacy laws under which “Consent” is the only or most appropriate lawful basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by us or via the Services, or due to nature of such processing), your acceptance of our Terms of Service (or the execution of another service agreement with Sutro Data) and this Privacy Notice will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Notice, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at [email protected].

3. Data Storage and Transfer

We and our authorized service providers (further detailed below) maintain, store and process personal data in the United States of America and other locations, as reasonably necessary for the proper performance and delivery of our Services, for our internal business purposes in the locations where Sutro Data resides, or as may be required by law.

While privacy laws may vary between jurisdictions, Sutro Data is committed to protect personal data in accordance with this Privacy Notice and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred.

4. How Long We Retain Your Personal Data

We retain personal data for as long as we deem it as reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and applicable laws.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.

Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you.

If you have any questions about our data retention policy, please contact us by e-mail at [email protected].

5. How We Disclose Your Personal Data

We disclose personal data in the following ways:

Service Providers: We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, content transcription and analysis services, website chat services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial, privacy and compliance advisors (collectively, “service providers“). Our service providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.

Service Integrations: Using our Services to their fullest extent requires connecting or integrating with third-party services, for example, Facebook, Google Ads, inventory CRMs, financial CRMs, and more in order to share or receive data, which may include personal data, to the platform, or to enrich the data you have processed on the platform. The provider of this connected or integrated third-party service may receive certain relevant data about or from your account on the Services, or share certain relevant data from your account on the third-party provider’s service with our Services, depending on the nature and purpose of such integration. This could include Customer Data and/or User Data. Note that we do not receive or store your passwords for any of these third-party services (but do typically require your API key in order to integrate with them).

Business Customers: Our customers have access to any personal data we process on their behalf in our capacity as a “processor” or a “service provider”, as well as to personal data relating to their users, as it relates to their use of our Services.

For the avoidance of doubt, Sutro Data may share personal data in additional manners, pursuant to your explicit approval, 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.

6. Cookies and Data Collection Technologies and Do Not Track

We and our service providers use “cookies”, anonymous identifiers, pixels, container tags and other technologies in order to provide our Services and ensure that they perform properly, to analyze our performance and marketing activities, for personalization purposes, for product development and improvements, and to personalize your experience.

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser tab or window. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.

7. Communications

Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, log-in attempts or password reset notices, etc. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use of some of our Services (like password resets or billing notices).

8. Data Security

We have implemented industry-standard physical, procedural and technical security measures, designed to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, we cannot guarantee that our Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. If there is any unexpected activity or inaccurate information or if you have reason to believe that your information is no longer secure, or if you have any questions about our security, please contact us by e-mail at [email protected].