Privacy policy

Two roles, two sets of rules

SEAD handles personal information in two distinct ways, and this notice covers only the first.

As a controller. When you visit our website, book a demo, email us, or apply for a job, we decide what happens to the information you give us. We are the controller of that information, and this notice describes it in full.

As a processor. Separately, we process personal information on behalf of our clients inside the Co-Wright platform. Our clients decide what information enters the platform and how it is used. We act on their instructions under contract. That processing is governed by our agreement with each client, not by this notice.

Where a client's data includes sensitive or regulated information, we handle it under the controls described in section 7, including permissioning at the row and column level, SOC 2 Type II audited processes, and HIPAA-aligned handling where the engagement requires it.

If you are an individual whose information is held in a client's Co-Wright instance and you want to access, correct, or delete it, contact that organization directly. They control that data. We will support them in responding to you.

Summary of key points

This summary provides key points from our Privacy Notice. You can find more detail on any of these topics by reading the full notice below.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us, the choices you make, and the products and features you use. See section 1.

Do we process any sensitive personal information? Not in our role as a controller. We do not ask for sensitive personal information when you book a demo, contact us, or apply for a role. Information we process on behalf of clients is covered under "Two roles" above.

Do we collect information from third parties? No. We collect personal information only from you, directly.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. See section 2.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. See section 3.

How do we keep your information safe? We maintain organizational and technical processes and procedures designed to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be completely secure, so we cannot promise or guarantee that unauthorized third parties will not defeat our security and improperly collect, access, steal, or modify your information. See section 8.

What are your rights? Depending on where you are located, applicable privacy law may give you certain rights regarding your personal information. See section 9 and section 11.

How do you exercise your rights? Email us at contact@seadsoftware.com. We will consider and act on any request in accordance with applicable data protection laws.

1. What information do we collect?

Personal information you disclose to us

In short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide. We do not collect personal information from you simply for visiting our website. You give us information in three situations:

When you book a demo. First name, last name, email address, job title, company, and optionally a mailing address.

When you contact us directly. Whatever you choose to include when you email us, including your name, email address, and any other details you provide.

When you apply for a role. If you apply for an open position, you send us your resume by email. A resume typically contains your name, contact details, employment history, and education. We keep applications for 30 days from receipt, after which they are deleted unless you have been hired or have asked us to keep your details on file.

All personal information you provide to us must be true, complete, and accurate, and you must notify us of any changes.

Sensitive information. We do not ask for, and do not want, sensitive personal information in any of the three situations above. Information we process on behalf of our clients is covered separately under "Two roles" above and is not governed by this section.

Information automatically collected

In short: Some information, such as your IP address and browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting.

Like many businesses, we also collect information through cookies and similar technologies.

Log and usage data. Service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and record in log files. Depending on how you interact with us, this may include your IP address, device information, browser type and settings, information about your activity in the Services such as date and time stamps, pages and files viewed, searches, and other actions you take, and device event information such as system activity, error reports, and hardware settings.

Google API. Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

2. How do we process your information?

In short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries and offer support. We may process your information to respond to your inquiries and resolve any issues you have with the requested service.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

3. When and with whom do we share your personal information?

In short: We do not sell or share your personal information. We may transfer it in the event of a business transaction.

We do not sell, rent, or share the personal information we collect as a controller with third parties for their own purposes.

Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Legal requirements. We may disclose your information where required to do so by law, or in response to valid requests by public authorities.

Service providers. We use a small number of service providers to operate our business, such as email and hosting. They act on our instructions under contract and may not use your information for their own purposes.

4. Do we use cookies and other tracking technologies?

In short: We use only the cookies required to operate the site.

We use only strictly necessary cookies, which are required for the website to function. We do not use analytics cookies, advertising cookies, or third-party tracking technologies, and we do not permit third parties to place tracking technologies on our website.

Because we do not use non-essential cookies, there is nothing to opt out of and no consent banner to dismiss. If this changes, we will update this notice and introduce the appropriate controls before deploying any such technology.

Most web browsers accept cookies by default. You can set your browser to remove or reject cookies, which may affect certain features of the site.

5. Do we offer artificial intelligence-based products?

In short: We offer products, features, and tools powered by artificial intelligence, machine learning, and similar technologies.

As part of our Services, we offer products, features, and tools powered by artificial intelligence, machine learning, and similar technologies (collectively, "AI Products"). These are designed to enhance your experience and provide innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI technologies. We provide certain AI Products through a third-party AI service provider, OpenAI, for API-based tasks. We do not pass client data through this provider.

We also use AI-assisted development tools internally, alongside our engineers, for writing application code, queries, and data pipelines. These are development tools operating on our own code. They are not part of the Services and they do not process client data or the personal information described in this notice.

You must not use the AI Products in any way that violates the terms or policies of any AI service provider.

Our AI Products. Our AI Products are designed for the following functions: AI assistants and AI-generated insights.

How we process your data using AI. All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with third parties.

6. How long do we keep your information?

In short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law, such as for tax, accounting, or other legal requirements.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it. If this is not possible, for example because your personal information has been stored in backup archives, we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. How do we keep your information safe?

In short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards, no electronic transmission over the internet or information storage technology can be guaranteed to be completely secure, so we cannot promise or guarantee that unauthorized third parties will not defeat our security and improperly collect, access, steal, or modify your information. Transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

SEAD is SOC 2 Type II audited. Within the Co-Wright platform, access to data is controlled at the row and column level, and access is governed by role and by tenant. Where an engagement requires it, we follow HIPAA-aligned handling processes.

8. Do we collect information from minors?

In short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect data from, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of such a minor and consent to that minor's use of the Services. If we learn that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under 18, contact us at contact@seadsoftware.com.

9. What are your privacy rights?

In short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent. If we are relying on your consent to process your personal information, which may be express or implied depending on applicable law, you have the right to withdraw your consent at any time by contacting us using the details in section 14.

Withdrawal will not affect the lawfulness of processing before its withdrawal, nor, where applicable law allows, will it affect processing conducted in reliance on lawful grounds other than consent.

Cookies and similar technologies. Most web browsers accept cookies by default. If you prefer, you can usually set your browser to remove or reject cookies. Doing so could affect certain features or services.

If you have questions or comments about your privacy rights, email us at contact@seadsoftware.com.

10. Controls for do-not-track features

Most web browsers, and some mobile operating systems and applications, include a Do-Not-Track ("DNT") feature you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in future, we will inform you in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there is currently no industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. Do United States residents have specific privacy rights?

In short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, obtain a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing. These rights may be limited in some circumstances by applicable law.

Categories of personal information we collect

The table below shows the categories of personal information we have collected in the past twelve months. It includes illustrative examples of each category.

Categories of personal information and whether we collect them

Category B is YES because job applicants send us resumes containing employment and education history. Category I is YES for the same reason and for business contact details. Category C, Category J and Category L are NO: we do not ask for or process protected classification characteristics, student records, or sensitive personal information in our role as a controller.

We may also collect other personal information outside these categories where you interact with us in person, online, by phone, or by mail, in the context of:

• Receiving help through our customer support channels
• Participation in customer surveys or contests
• Facilitating delivery of our Services and responding to your inquiries

Sources of personal information. See section 1.

How we use and share personal information. See section 2.

Will your information be shared with anyone else? We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. See section 3.

We may use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration. This is not considered "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve months. We will not sell or share personal information belonging to website visitors, users, or other consumers in future.

Your rights

You have rights under certain US state data protection laws. These rights are not absolute, and in certain cases we may decline your request as permitted by law. They include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects

Depending on the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed, as permitted by applicable law including the privacy law in Minnesota
• Right to obtain a list of the categories of third parties to which we have disclosed personal data, as permitted by applicable law including the privacy laws in California, Delaware, and Maryland
• Right to obtain a list of specific third parties to which we have disclosed personal data, as permitted by applicable law including the privacy laws in Minnesota and Oregon
• Right to review, understand, question, and correct how personal data has been profiled, as permitted by applicable law including the privacy law in Minnesota
• Right to limit use and disclosure of sensitive personal data, as permitted by applicable law including the privacy law in California
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature, as permitted by applicable law including the privacy law in Florida

How to exercise your rights

To exercise these rights, you can email us at contact@seadsoftware.com, or use the contact details in section 14.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent who does not submit proof of valid authorization to act on your behalf in accordance with applicable laws.

Request verification

Upon receiving your request, we will need to verify your identity to determine that you are the same person about whom we hold information. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from information already held, we may request additional information for verification and for security or fraud-prevention purposes.

If you submit a request through an authorized agent, we may need to collect additional information to verify your identity, and the agent will need to provide written and signed permission from you.

Appeals

Under certain US state data protection laws, if we decline to act on your request you may appeal by emailing us at contact@seadsoftware.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine the Light" law

California Civil Code Section 1798.83, known as the "Shine the Light" law, permits users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information we disclosed to third parties for direct marketing purposes, and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit it in writing using the contact details in section 14.

12. Do UK and EU residents have specific privacy rights?

13. Do we make updates to this notice?

In short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated date at the top of this notice. If we make material changes, we may notify you either by prominently posting a notice of the changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently.

14. How can you contact us about this notice?

If you have questions or comments about this notice, email us at contact@seadsoftware.com or contact us by post at:

SEAD Software, LLC
270 Sylvan Avenue
Englewood Cliffs, NJ 07632
United States

15. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correction of inaccuracies, or deletion of your personal information. You may also have the right to withdraw your consent to our processing. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, email us at contact@seadsoftware.com.