Privacy Policy

Archived - May 22, 2020

Last updated: May 22, 2020

This Privacy Policy explains how Scratchpad, Inc. (“Scratchpad”, “we”, “us”, “our”) handles personal data collected by us as a data controller during the normal course of business (sales, marketing, and support), as well as how Scratchpad as a data processor handles all client relationship management information input into the Scratchpad software by the Account Owner or Authorized Users or generated on behalf of Account Owners in connection with the services. This Privacy Policy operates in connection with the Scratchpad Terms of Service and all capitalized terms not otherwise defined herein have the meaning set out in the Terms of Service.

Personal Information Definitions

Account Data: Information pertaining to the owner of the Account, including name, email, address, billing information.Information pertaining to the owner of the Account, including name, email, address, billing information.

Business Data: Information generated either by the Account Owner (and its Authorized Users) or Scratchpad, where such Business Data does not include any personal Customer Data.

Customer Data: Information relating to the identity and identification of a client or customer of the Account Owner, including name, address, etc. that is used for client relationship management purposes.

1. Scratchpad software and services

Scratchpad provides a user interface experience for use in connection with a Salesforce account. The software is accessed through the browser as a web application or chrome extension. Scratchpad products are self-service; Authorized Users determine and are solely responsible for what and how Customer Data is collected.  Scratchpad acts as a conduit through which Business and Customer Data flows into the Salesforce platform from you as the data collector. We do not store any data for longer than necessary to provide the Services.Scratchpad acts as a data processor with respect to Business Data and Customer Data and processes this data as instructed by Authorized Users, who are the data controllers.

2. Data collected during normal business transactions (unrelated to the software)

In the normal course of business, Scratchpad collects Account Data such as contact information (e.g. name, address, phone number, e-mail address, and employer) and payment details for Account Owners. We may also collect browsing data from individuals who visit the Scratchpad Site or use the Scratchpad Services. In these circumstances, Scratchpad acts as a data controller. Scratchpad also acts as a data controller with respect to our own internal client relationship management data. This is data that Scratchpad needs in order to provide services to our Customers, including performing contractual obligations, engaging in marketing activities, and providing support services (e.g. processing and responding to Customer inquiries and requests). The Account Owner owns and retains all rights to the Account Data, including the right to request deletion of the Account Data in accordance with this policy.

We process Business and Customer Data on behalf of the Account Owner by facilitating its transmission and providing additional analytical tools at the Account Owner’s request. This processing is only done in order to fulfill contractual obligations, based on the individual’s consent, or in accordance with our legitimate business interests in improving our services, software and website experiences for users.  Where processing is based on consent, an individual may withdraw consent at any time by contacting us. Instructions for contacting us are provided below in Sections 4 and 5. We retain Customer and Business Data only for as long as necessary to fulfill the purposes of its collection and processing, including for the purposes of satisfying any legal, accounting, or reporting requirements, or for the length of time requested by the Account Owner, whichever is longer.

For the site, Scratchpad may collect and analyze aggregate visitor information, including the domain name, visited surveys, referring URLs, and other publicly available information. We use this information to improve our website and services and to customize the content of our pages for each website visitor.

Cookies may be used to deliver customized content to website visitors. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. A cookie is a small file that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

  • Required Cookies. These cookies are required to enable core site functionality.
  • Functional Cookies. These cookies allow us to analyze site usage so we can measure and improve performance.
  • Targeting cookies. These cookies are used by advertising companies to serve ads that are relevant to your interests.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

Scratchpad collects Account Data from you directly or from your employer. Scratchpad will treat this Account Data according to this Privacy Policy, plus any additional restrictions imposed by the third party that provided Scratchpad with it or the applicable national law.  These third-party sources include Scratchpad business dealings with your employer and/or third parties you directed to share your Account Data with Scratchpad.

Scratchpad does not sell personal information of any type, including Account Data, Business Data, and Customer Data.

3. Data collected by our users

Account Owners own, and are data controllers of, Business and Customer Data. Depending on how the Account Owner and their Authorized Users choose to use the software, Customer Data may include certain personal information relating to the customers and clients of the Account Owner. Account Owners manage all Customer Data, as well as the users who create, manage, distribute, or report any Business Data generated by the Services. To the extent that Scratchpad processes or creates Business Data, Scratchpad does so as a data processor on behalf of Customers.

Scratchpad processes Customer and Business Data on behalf of Customers in a manner consistent with this Privacy Statement. This may include performing certain analytical functions as part of the Services. Scratchpad only provides such services at the request of the Account Owner, and does not process Customer or Business Data except as explicitly directed by the Account Owner.

Scratchpad treats all Customer and Business Data as confidential. All Customer and Business Data is safeguarded using industry-standard security practices to prevent unlawful disclosure.  Scratchpad does not sell or make available Customer or Business Data except as requested by a valid court order, search warrant, subpoena, or otherwise as agreed by the parties or required by law.

Authorized Users of Organizational Accounts may generate information that is not subsequently linked to Salesforce or their organization. Until such information is linked to Salesforce or their organization, such information belongs to the Authorized User. If the Authorized User links an Object (as the term is defined in the Terms of Service), they acknowledge that they no longer have any rights of privacy or ownership over that information, and Scratchpad is under no obligation to ensure that private information belonging to Authorized User is not transferred to an Organizational Account’s control. Please carefully review your Objects, including “Notes,” to ensure that any information you link to Salesforce is information you are willing to share with your employer and/or complies with your employment agreement between you and the organization.

If you wish to exercise rights in relation to Account Data for which Scratchpad acts as a data controller, you should contact [email protected].  If you are located in the State of California, you may also call toll-free at (844) 987-2535.  Please note, however, that Scratchpad can or will delete your Account or Business Data only if there is no statutory obligation or prevailing right of Scratchpad to retain it.  Note further that if you request that Scratchpad deletes your Account Data, you will not be able to continue to use any Scratchpad service that requires Scratchpad’s use of your Account Data.

4. Data subject rights

In certain circumstances, individuals may have the following rights under data protection law in relation to their personal information:

  • A right to access Customer or Account Data that Scratchpad collects, uses, discloses, or processes (if applicable) about you
  • Rectification of inaccurate data
  • Erasure of personal data
  • Restriction of processing of personal data
  • Right to data portability
  • Right to object to processing of personal data and the right to be assured that such objections are promptly remitted to the data controller for correction
  • Right to withdraw consent to processing of any personal data
  • Right to opt-out of the sale of personal data, if applicable
  • Right to non-discriminatory treatment for exercise of data protection rights

Scratchpad will take steps to ensure that it verifies your identity to a reasonable degree of certainty before it will process the data protection rights you want to exercise. When feasible, Scratchpad will match Customer or Account Data provided by you in submitting a request to exercise your rights with information already maintained by Scratchpad. This could include matching two or more data points you provide when you submit your request with two or more data points that are already maintained by us.

In accordance with the verification process set forth in the California Consumer Privacy Act (“CCPA”), Scratchpad will require a more stringent verification process for deletion requests, or for Account Data that is considered sensitive or valuable, to minimize the harm that might be posed to you by unauthorized access or deletion of your Account Data. If Scratchpad must request additional information from you outside of information that is already maintained by Scratchpad, Scratchpad will only use it for the purposes of verifying your identity so you can exercise your data protection rights, or for security and fraud-prevention purposes.

Scratchpad will decline to process requests that are manifestly unfounded, excessive, fraudulent, or are not otherwise required by local law.