Espressive Privacy Policy
Revised 07/2025, Reviewed 07/2025
Espressive, Inc. its affiliates and subsidiaries (collectively “Espressive”, “we”, “our”, or “us”) knows you care about how your Personal Information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing Espressive’s Website or by using any of Espressive’s materials or services (the “Espressive Solution”)in any manner, you acknowledge that you accept the practices and policies outlined in this PrivacyPolicy, and you hereby consent that we may collect, use, and share your information in the ways detailed throughout this policy.
Changes to this Privacy Policy
Espressive may make changes to this Privacy Policy. The most current version of the Privacy Policy will govern Espressive’s use of information about you and will be located at https://www.espressive.com/privacy-policy/. If Espressive makes material changes to this Privacy Policy, Espressive will notify you by posting a notice on our website and may send an email to the address Espressive has on file for your account, if applicable.
This Privacy Policy explains:
- The type of information we collect
- How Espressive collects your information, including tracking and cookies
- How Espressive uses your personal information
- How you can correct or update the information Espressive has
- Consent to Commercial Electronic Messages
- Who we may share information with
- Inform individuals of the opportunity to choose where to have personal data used or be disclosed
- How we handle Do Not Track requests
- Linked sites and services
- Data security
- Retention of your information
- Notice of privacy rights to California residents
- Right to be informed of appropriate safeguards where Personal Information is Transferred to a Third Country or to an International Organization; Notice of privacy rights to residents of the European Union Area
- Our policy with respect to children
- How to contact us
1. The Type of Information We Collect
Espressive may collect information that you provide to Espressive in connection with your use of the Espressive Solution when you:
- Register your account with Espressive as a user of the Espressive Solution (including through registration as an employee, contractor or other user of the Espressive Solution on behalf of a Espressive customer (“Customer”),
- Make changes to your user profile information,
- Send email messages, forms, or other information to Espressive or other users using the Espressive Solution, or
- Install, use, or otherwise interact with the Espressive Solution.
This information may include your first and last name, your address, email address, telephone number, your location, and any additional information you provide to Espressive during the account registration process or via the Espressive Solution.
Espressive may also collect certain technical information about your use of the Espressive Solution.This technical information may include technical information about your device(s), browser type and version, geo-location information, computer and connection information, statistics on page views, traffic to and from the Espressive Solution, ad data, Wi-Fi connection information, internet protocol(“IP”) address, and standard web log information.
Additionally, when expressing an interest in obtaining additional information about the Espressive Solution or registering to use the Espressive Solution, we or a Customer may require you to provide us with personal contact information, such as your name, company name, address, phone number, and email address (“Required Information”). Although Espressive uses third party service providers to process payments, when purchasing access to the Espressive Solution, we may require a Customer to provide our payment processing service providers with financial and billing information, such as billing name and address, credit card number, and the number of employees within the Customer that will be using the Espressive Solution (“Financial Information”). We may also ask an actual or prospective Customer to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Required Contact Information, Billing Information, and Optional Information about Customers are referred to collectively as “Customer Data.”
2. How Espressive Collects your Information; Tracking and Cookies
When you register for an account with Espressive either directly or through a Customer, we may ask you to provide us with certain information in order to create your account, and to provide you with our Espressive Solution. This information is collected by us when you fill out forms that may be provided to you through the Espressive Solution.
Espressive, and third parties we interact with, including our third-party service providers, may use cookies, web beacons, hashed identifiers derived from email addresses for the purposes of cross-device tracking for targeted advertising, local shared objects (sometimes called“flash cookies”), and similar technologies in connection with your use of theEspressive Solution to provide and support the Espressive Solution(collectively referred to in this policy as “Cookies”). Cookies are small data files that may have unique identifiers, and reside, among other places, on your mobile device, in emails we send to you, and on our applications. Locally shared objects or “flash cookies” are data files that can be created on your computer by the websites you visit and are a way for websites to store information for later use. Locally stored objects are different than cookies because they are stored in different parts of your computer than cookies. Web beacons are small strings of code that provide a method for delivering a graphic image on a web page or in an email message for the purpose of transferring data.
If Cookies are used, they may be used to collect information about you and your use of the Espressive Solution, such as your browser type, preferences, data relating to content that has been displayed to you or that you have clicked on, and the date and time of your use. Cookies may also be used in order to further features and processes on the EspressiveSolution, provide authentication and security for your transactions using the Espressive Solution, store your preferences, facilitate relevant advertising, and help us learn more about how users engage with the Espressive Solution.
We sometimes use service providers to help us provide certain products and services or to integrate other features. These third-party providers may collec t information when you view or use them, including information about you and yourdevice or browser. They may do this using Cookies or similar technologies. These third-party providers also may use these technologies to help share information with us, like how you use their website or application. To learn more about the information they collect or receive, review their privacy policies.
As part of using our Espressive Solution, Espressive’sCustomers may submit to Espressive electronic data or information (“Submitted Data”) that constitutes personal information of other individuals. Such data may include an individual’s name, email address, phone number or any other data that the Customer chooses to submit to us. Espressive generally has no direct relationship with the individuals to whom Submitted Data may pertain. Espressive processes Submitted Data on behalf of our Customers and any uses of Customer Data by Espressive are done so pursuant to our Terms of Espressive Solution or a separate agreement in place between Espressive and the applicable Customer, which governs our treatment of Submitted Data.
Espressive requires express consent for the collection of Personal Information and, to the extent you provide your data directly to Espressive, you consent to Espressive’s collection, retention and use of that data pursuant to the terms of this Privacy Policy. For personal information and data collected as part of Submitted Data, Espressive requires its Customers to similarly obtain express consent for the collection, retention and use of that data by Espressive pursuant to the terms of the relevant agreement betweenEspressive and the relevant Customer.
3. How Espressive Uses Your Information
Espressive may use your information to:
- Provide access to the Espressive Solution to communicate with you
- Personalize, customize, measure, and improve Espressive’s products, services, content, and advertising
- Prevent, detect, and investigate potentially prohibited or illegal activities or a breach of the applicable agreement(s) between you and Espressive
- Analyze the accuracy, effectiveness, usability, or popularity of the Espressive Solution
- Generate and review reports and data about Espressive’s user base and Espressive Solution usage patterns
- Compile aggregate data for internal and external business purposes
- Resolve disputes and troubleshoot problems; and
- Contact you with information, including promotional, marketing, and advertising information and recommendations that Espressive believes may be of interest to you.
Consistent with applicable laws, including United States CAN-SPAM laws, if you do not wish to receive commercial emails, you may unsubscribe following the instructions on any email. We may still send you administrative notices, however.
We endeavor to protect the privacy of your account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. In particular, you acknowledge that Espressive is not responsible for any loss of any passwords or login information which you receive for access to the Espressive Solution which results from your failure to keep that information secure.
The lawful basis for Espressive’s use and retention of information collected by Espressive through its website and similar marketing outreach efforts is individual consent. The lawful basis for Espressive’s use and retention of Submitted Data information collected by Espressive is Espressive’s legitimate business interest. Espressive also requires each of its Customers to ensure that their Customer has a legitimate basis to provide the Submitted Data to Espressive for use in the Espressive Solution.
4. Correcting and Updating Your Information
Please access and complete the Data Subject Access Request form, or email SecurityCompliance@espressive.com, to exercise any of the rights stated in this section.
You have the right to revoke your consent to the collection, processing and use of your PersonalInformation.
You have the right to request access to any Personal Information which Espressive may have about you. The information will be provided in a machine-readable format. You may also ask that we transfer the Personal Information to a third party, which we will do if technically feasible.
You have the right to review, add and update your Personal Information.
You also have the right to object or restrict processing of your personal information.
You may also request the deletion of your Personal Information, where:
- The personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed,
- You withdraw consent to Espressive’s possession of the information on which the processing is based and where there is no other legal ground for Espressive’s retention of the information,
- You object to Espressive’s possession of the information and there is no overriding legitimate basis for the retention,
- The personal information has been unlawfully obtained or processed, or
- The personal information has to be erased for compliance with a legal obligation in the European Union or other law to which Espressive is subject.
When you update information, however, we may maintain a copy of the unrevised information in our records. Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
If Espressive has yourPersonal Information as Submitted Data as a result of your relationship with one of Espressive’s Customers, you should first contact that Customer before contacting Espressive.
You may, however, at anytime contact Espressive with regard to the collection, processing and use of your Personal Information as set forth in this Section but keep in mind some information may be needed to take advantage of product features or may be required by your relationship with one of Espressive’s customers.
If you are dissatisfied with how your data subject access request was handled, you have the right to lodge a complaint with your respective Supervisory Authority. A list of Supervisory Authorities can be found by referencing the following link: https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-at
5. Consent to Commercial Electronic Messages
If you provide us with an email address, you expressly consent to receiving Commercial Electronic Messages from Espressive about your use of the Website, the Espressive Solution and our Products. If you have any questions about Espressive’s Commercial Electronic Messages, you can contact Espressive at:
Espressive, Inc.
5201 Great America Parkway
Suite #429
Santa Clara, CA 95054
Attention: Privacy Officer or by emailing SecurityCompliance@espressive.com
In addition, you may opt out of receiving Commercial Electronic Messages at any time by emailing: SecurityCompliance@espressive.com.
6. Who Espressive May Share Information With
Espressive may disclose the information we collect from you to the following third parties:
Users of the Espressive Solution; Public Information. When you share information with us via the Espressive Solution, Espressive may share your information to other users, in accordance with the privacy settings you or the respective Customer has chosen for your account or that are applicable to that information. To the extent you share any information to a public audience or via a publicly accessible portion of the Espressive Solution such as an online customer community or forum, that information may be available to anyone who has access to that customer community or forum.
Espressive Solution Providers. Espressive may share your information with third-party contractors, agents, collaborators, or service providers who provide certain services to Espressive or on Espressive’s behalf, such as operating and supporting the Espressive Solution. Espressive may also request your information from a previous service provider, which we need to provide our services to you. Alternatively, Espressive may pass on your information to a service provider that Espressive Customers have chosen to replace Espressive.
Companies that Acquire Espressive's Business or Assets. If Espressive becomes involved in a merger, acquisition, sale of assets, securities offering, bankruptcy, reorganization, or dissolution or if the ownership of all or substantially all of Espressive’s business relating to the Espressive Solution otherwise changes, Espressive may provide your information to a third party or parties in connection with the applicable transaction.
Espressive Affiliates. Espressive may share some or all of your information with Espressive’s parent company, subsidiaries and corporate affiliates, joint ventures or other companies under common control with Espressive.
Espressive Customers. If Espressive has received your information as part of Submitted Data, Espressive may share that information, or any modifications or revisions to that information with that Customer.
Switching Espressive Solution Providers. Espressive may request your information from your previous service provider, which we need to provide our services to you. Alternatively, Espressive may pass on your information to a service provider that you have chosen to replace Espressive.
Aggregate Information. Espressive may share information relating to our visitors and users with affiliated or unaffiliated third parties on an aggregate basis, however this information will not identify you personally.
Legal Requirements. Espressive may share your information with law enforcement, governmental agencies, or authorized third parties, in response to a request relating to a criminal investigation or alleged illegal activity or any other activity that may expose Espressive, you, or any other Espressive user to legal liability, or to protect Espressive’s rights or property, or during emergencies when safety is at risk. Espressive may also share your information in response to court orders, subpoenas, or other legal or regulatory requests, and Espressive may provide access to your information to Espressive’s legal counsel and other consultants in connection with actual or potential litigation. Espressive shall remain liable under thePrinciples if its agent processes such personal information in a manner inconsistent with the Principles, unless Espressive proves that it is not responsible for the event giving rise to the damage.
7. Inform Individuals of the Opportunity to Choose Whether to Have Personal Data Used or Disclosed
If personal data covered by this Privacy Policy is to be used for a new purpose that is materially difference from that for which the personal data was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party in a manner not specified in this Policy,Espressive will provide you with an opportunity to choose whether to have your personal data so used or disclosed. Requests to opt out of such uses or disclosures of Personal Data should be sent to us as specified in the “How toContact Us” section below.
Certain personal Data, such as information about medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, is considered “Sensitive Information.” Espressive will not use Sensitive Personal data for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless Espressive received your affirmative and explicit consent (opt-in).
8. How Espressive Handles "Do Not Track" Requests
You may be able to adjust your browser settings or other settings so that “do not track” requests are sent to our websites and mobile applications. Espressive does not use any tracking technology that would respond to any “do not track” requests that are sent to our services. Espressive does not collect personally identifiable information about your online activities over time and across different websites when you use the Espressive Solution; however, certain service providers that use Cookies may collect your personally identifiable information over time and across different websites.
9. Linked Sites and Espressive Solution
Espressive’s website or application may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
10. Data Security
Espressive takes reasonable measures to protect the information you provide to Espressive or submit through the Espressive Solution against misuse, loss, theft, unauthorized use, disclosure, or modification. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk and your information may be disclosed to third parties in unforeseeable situations or situations that are not preventable even when commercially reasonably protections are employed, such as in the case that Espressive or if the Espressive Solution are subject to a hacking or other attack. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
11. Retention of Your Information
In relation to Submitted Data, customers are provided the option to define and configure a personal information retention period. This can be systematically accomplished directly in the service. Once the retention period is met, personal information is redacted. If a retention period is not configured, personal information is retained for only as long as necessary and relevant forEspressive’s operations, and for Espressive’s customers to work with their consumers. Unless otherwise prohibited by contractual, legal, or regulatory obligations, personal information will be securely disposed of once personal information is no longer necessary and relevant for Espressive’s operations or within 35 days of the termination of services.
In relation to Espressive organizational data, personal information, will be retained as longas necessary and relevant for Espressive’s operations. Employment-related personal information will be retained throughout the active employment period and seven (7) years after termination of employment.
Espressive may also retain information collected from you to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, and take other actions permitted by law or disclosed in this Privacy Policy.
11. Notice of Privacy Rights to California Residents
Specific disclosures for California residents as required by the California Consumer Privacy Act and the California Privacy Rights and Enforcement Act are set out in the Schedule below titled “CALIFORNIA RESIDENTS– CCPA”.
12. Right to be Informed of Appropriate Safeguards where Personal Information is Transferred to a Third Country or to an International Organization; Notice of Privacy Rights to Residents of the European Economic Area
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by completing the Data Subject Access Request Form or by contacting us at SecurityCompliance@espressive.com.
Espressive complies with the EU-U.S. Data Privacy Framework (https://www.dataprivacyframework.gov/) (EU-U.S. DPF), the UK Extension tothe EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) asset forth by the U.S. Department of Commerce and has certified to the U.S.Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to theEU-U.S. DPF. Espressive has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPFPrinciples) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or theSwiss-U.S. DPF Principles, the Principles shall govern. To learn more about theData Privacy Framework (DPF) program, and to view our certification, please visit the Data privacy framework website. Espressive remains liable for damages caused by third parties or service providers in relation to Espressive services under the DPF. Espressive, Inc. is subject to FTC investigations and enforcement in relation to the EU- US DPF, the UK Extension to the EU-US DPF and to the Swiss-US DPF. Further details about the DPF and its requirements can be found on the official website here. In compliance with the EU-U.S. DPF, theUK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Espressive commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and theSwiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in [INSERT the United States, the European Union, the United Kingdom, and/orSwitzerland (as applicable)]. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a compliant. The services of JAMS are provided at no cost to you.
For additional information on personal data transfers, please visit Espressive Subprocessors and Personal Data Transfers.
13. Our Policy with Respect to Children
Our Services are not directed to children under 13 and we do not knowingly collect PII from children under 13. If we learn we have collected PII of a child under 13, we will delete such information from our files as soon as possible.
14. How to Contact Us
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Espressive, Inc. commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss, individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Espressive via SecurityCompliance@espressive.com, or via postal mail at:
Espressive, Inc.
5201 Great America Parkway
Suite #429
Santa Clara, CA 95054
Attention: Privacy Officer
Effective: July 9, 2024
CALIFORNIA RESIDENTS: CCPA
This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to“personal information” of California residents that is subject to the CCPA.
We collect, use, share and sell the categories of personal information about California consumers as set out in the table below. Our Services are not directed to children under 13 and we do not knowingly collect PII from children under 13. If we learn we have collected PII of a child under 13, we will delete such information from our files as soon as possible.
Business and Commercial Purposes
The business and commercial purposes set out above are described in more detail in the section entitled "HOWWE USE YOUR PERSONAL INFORMATION".
Exercising Your CCPA Rights
Requests for Deletion, Right to Know, and Do Not Sell. Subject to certain exceptions, California consumers have the right to make the following requests, at no charge.
Deletion: The right to request deletion of the personal information that we have collected about you, subject to certain exemptions (such as where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).
Right to Know: The right to request(not more often than twice a year) that we disclose certain information about how we have handled your personal information in the prior 12 months, including the:
- Categories of personal information collected
- Specific pieces of personal information collected
- Categories of sources of personal information
- The purposes for which we use the personal information
- Categories of third parties with whom we have shared your personal information
- Categories of personal information that we have disclosed or sold to a third party
Do Not Sell: The right to request, absent an exception, that we stop selling your personal information (“opt-out”) except where you later provide authorization for us to do so. We will wait at least 12 months before asking you to opt back into the sale of your personal information.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. However, many features of our Site and Services will not function without your personal information. Unless permitted by the CCPA, we will not deny you products or services, charge you a different price, or provide a different level or quality of products or services just because you exercised your rights under the CCPA.
Submitting Requests. You can exercise your CCPA rights by submitting a request to our data privacy team at SecurityCompliance@Espressive.com. You may also open a request using our automated response line: +1 408-919-0203
We will respond to all CCPA requests within the period of time set out by the regulation.
Verification. When you submit your request, we will take steps to verify your identity. We will seek to match the information in your request to the personal information we maintain about you. We will only complete your request where we are satisfied that we have verified your identity to a reasonably degree of certainty.
Authorized Agents. To the extent the CCPA allows California consumers to designate an authorized agent to exercise their rights under the CCPA, you must provide a signed authorization directing such agent to act on your behalf as part of your access request.
Your California Privacy Rights Under California's Shine-the-Light Law
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California residents who provide us certain personal information are entitled to request and obtain from us, free of charge, information about the personal information (if any) we have shared with third parties for their own direct marketing use. Such requests may be made once per calendar year pertaining to any relevant third-party sharing in the prior calendar year. If you are a current California resident, you may make a Request by attesting to the fact that you are a California resident and providing a current California address in the Request Details section of the form.
