Global Privacy Policy

We generally collect personal data from the following three categories of sources: (1) you provide personal data directly to us, (2) we automatically collect personal data from you when you use our Site (e.g. cookies) or when we provide Services, or (3) we receive personal data about you from third-party sources (e.g. from public sources).

WE COLLECT PERSONAL DATA YOU PROVIDE

We collect personal data that you provide directly to us. Personal data is required to use certain features of the Sites, for example, to create an online account, download resources, purchase training or other materials, take courses, submit job applications, send us questions through our Sites, receive or request data from us, and respond to communications from us. We also collect information you provide which may not be considered personal data, such as information about your organization, the team you work on and what brought you to Sandler or its Sites.

Online Forms. We collect personal data when you fill-out online forms or send other communications through our Sites, such as our “contact us” form, when you sign-up for an account (such as when you want to access the e-Learning Library or create a Sandler Online account), when you request more information about being a franchisee or strategic partner, when you download resources, articles, white papers and other guides, and when you sign-up for a webinar, immersion program, summit or other event.

Online Accounts / Sandler Online. We offer several resources that require you to set up an account with Sandler, such as when you sign up for Sandler Online or want to use our e-Learning Library.  When you create an account with Sandler through our Sites, we collect your contact information and any other information requested from you at such time. You are also required to choose a password which you should keep confidential.  When you are signed into your account, we may link your account with the activities you perform on our Site.

Purchases. When you make a purchase through our Sites, you will be re-directed to a PCI-compliant payment processor (“Payment Processor(s)”).  Our Payment Processors may be located in other countries, and they may transfer certain personal data to other countries in order to provide us payment processing services, such as transaction processing and fraud prevention.  For example, we may use Authorize.net to power our online store–you can read more about how Authorize.net uses your personal data here: https://usa.visa.com/legal/privacy-policy.html [authorize.net].

Any information that you provide directly to the Payment Processor is governed by that Payment Processor’s privacy policy, not this Privacy Policy. Sandler does not receive your credit card, debit card or other financial information when you make a payment – such information is provided directly by you to the Payment Processor. However, Sandler does receive information about your purchase and your contact information (e.g. name, email address, mailing address, phone number). Sandler will keep a record of your purchases. We may collect tax identification numbers you submit for tax-exemption purposes.

Blog / Forum / Comments. If you leave a comment on our Sites, such as a response to a blog post, those comments may be posted publicly on our Sites or removed from our Sites, in Sandler’s sole discretion.  Comments you send us will not be kept confidential, and we may identify you as the source of the comment.  If you are signed into your account when you comment on our Sites, we may be able to link you and your account to your comments, and others in your organization may be able to read your comments.

Franchise or Strategic Partner Information. If you apply for or request information about becoming a Sandler franchisee or strategic partner, we will collect the information requested from you in our online forms, and any follow-up information during any screening or application process.  We may collect information pertaining to your financial security, such as bank account balances and information pertaining to your spouse. Additional terms and conditions will apply, as agreed to between you and us, if we decide to proceed with your franchisee or strategic partner application.

Chats with Sandler. If you use the chat feature of a Site, we will collect all text and other data that you submit via that chat feature. If you use a chat feature while signed into your Sandler account, we may link the chat information to your account.

Meet With Us. If you enter your email, you will gain access to an integrated calendar that will allow you to schedule a meeting with a representative from Sandler.

ROI Calculator. We collect the information that you provide when using our ROI calculator.  We use a third party to help us run the ROI calculator, and they may collect certain personal data about your use of that ROI calculator.

Marketing Communications. We may use your email and mailing address to send you promotional and other electronic and hardcopy communications. We may use third parties or service providers to deliver these communications to you. You may opt out of such emails by using the unsubscribe link in the email or contacting us at [email protected] with “Unsubscribe” in the subject line. To opt out of other communications (e.g., postal marketing), please contact us as set forth in the “Contact Us” section below. Opting out of marketing communications does not opt you out of other, non-marketing communications from us.

Feedback. When you provide comments or feedback about our Sites, the content on the Sites, or our products or Services (“Feedback”), we will not treat that Feedback as confidential.  We may use that Feedback for any purpose in our sole discretion so long as it does not personally identify you.  Feedback will be used without attribution or compensation to you.

If you choose to submit information pursuant to our #HowToSucceed campaign, you understand that we may use your picture, a video of you and your statements about Sandler publicly, including posted on our Site, without compensation owed to you.  We may shorten or modify any statements you make or videos you provide in order to fit within a certain word count or time length for posting on our Site. 

Business Contracts. If you enter into a business relationship with us, such as if you become a franchisee or strategic partner, we may use information collected about you in accordance with any contract agreed to between you and us.  If your employer purchased access to our LMS platform, the personal data we received directly from that employer is used pursuant to our contract with that employer; however, any information we collect from users of the LMS (including employees of such employers) is used in accordance with this Privacy Policy.

Conferences and Tradeshows. If you attend one of our tradeshows, conferences or events, such as the Sandler Summit, we may collect information to confirm your registration, provide logistics-related information, for marketing purposes, or to send related promotional or future event offers.

EXTERNAL LINKS

If any part of the Site links you to other websites, those websites DO NOT operate under this Privacy Policy, but are linked for your convenience only. We recommend you read the privacy notices posted on those websites to understand their procedures for collecting, using, and sharing personal data.

Applying to Work With Sandler. To submit job application materials online to work or intern with Sandler, you will be redirected from our Sites to a website operated by BambooHR (or another service provider we may use to help us collect job application materials). You may be required to create an account with that vendor.

Events. When you sign up for an event or purchase hotel accommodations for an event, you are re-directed from our Site to a third-party website. 

HubSpot. If you choose to visit the HubSpot Academy linked on our Sites, you will be re-directed to HubSpot’s website and you may be required to sign up for a HubSpot account to access academy courses.

Evernote. If you choose to download an Evernote template linked on our Sites, you will be re-directed to Evernote’s website and you may be required to sign up for an Evernote account to download such template.

Podcasts. We use a third-party service provider to host our Sandler podcasts.  When you visit the “how to succeed” website to listen to our podcasts, you are visiting a third-party website.  Further, our third-party service provider syndicates our podcasts with Apple and Spotify- those third parties may receive data about your interactions with those podcasts.

When you visit the Site, we automatically collect certain information from you through use of cookies and other online tracking mechanisms.  Please review our Cookie Policy found here for more information about our use of cookies and online tracking.

INFORMATION COLLECTED FROM THIRD-PARTY SOURCES

We obtain data about individuals from our franchisees, strategic partners, referral sources, various third-party companies and public sources.  We may combine that data with personal data or other data we collect from you. This enhances our existing data about our customers and Site users, improves our ability to contact you, and enhances our marketing capabilities. If you sign up for a Sandler event through a third-party website, that third party may share certain personal data about you with us. We also receive contact information of prospective new customers from current Sandler customers if someone refers a contact to us.

HOW IS PERSONAL DATA USED?

In addition to the uses described throughout this Privacy Policy, we use personal data for the following purposes:

As Stated or Agreed to at the Point of Collection. We may use personal data for the purposes stated or agreed-to (or as is obvious) at the point of collection. For example, we use personal data to respond to your questions, comments, or complaints. We may also use personal data as requested or consented to by you.

Administration. We use personal data for administrative purposes, such as managing your accounts, facilitating transactions and processing payments, refunds and credits, to inform our business strategies, to understand the demographics of our Sites and user preferences, for evaluating applications, to live chat with you, and to provide you materials or resources that you requested or that we think may interest you.   

Management of Sites and Services Improvement. We use personal data to manage the Sites, such as troubleshooting problems, improving the content and functionality of the Sites, statistical and other analyses of the Sites, and to customize the Sites to you and our users.  We may also use your personal data to improve our Services and customer service efforts, and to develop new products or Services.

Advertising and Notice. We may use personal data to send you promotions or to perform targeted advertising, to notify you of new Services, products or programs, to notify you of new features of our Sites, to notify you of changes to our Terms or this Privacy Policy, and for other similar communications.

To Protect Our Rights. We may use personal data to protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Sites, or to other users of the Sites.  We may also use personal data to address any U.S. DMCA claims or counterclaims, to seek business, financial or legal advice, and to respond to other legal requests.

CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE PERSONAL DATA

We may share your personal data with the following categories of third parties and/or service providers:

Employees, Affiliates and Subsidiaries. We may share your personal data with our employees, affiliates and subsidiaries who have a need to know the information for our business purposes.  If you are a Sandler employee or independent contractor, other employees can see certain information about you, such as contact information and employment information, through Sandler’s HR platform.

Franchisees. We may share personal data with our franchisees for our business purposes, such as to refer prospects and provide local training offerings.

Service Providers and Third Parties. We may share personal data with service providers that provide services for us. For example, we may share personal data with service providers that help us host and manage the Sites; maintain physical storage for paper files and documents; provide targeted advertising and other marketing; improve the content and functionality of the Sites; perform data analysis and statistical analysis; troubleshoot problems with the Sites; provide public relations; provide email services; provide payment processing services, support delivery of our Services and products, provide data processing; and support or provide the security of the Sites. We may also share personal data with third parties such as event sponsors, referral partners and other strategic partners of Sandler.

Government Officials / Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose personal data: (i) if we believe in good faith we are legally required to disclose that personal data, (ii) if we are advised to disclose personal data by our legal counsel, or (iii) when necessary to identify, contact, respond to or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, Sandler or any other party.

Professional Advisors. We may share personal data with certain professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to Sandler.

Other Users. In the event of a copyright infringement claim relating to the Site, we may share your personal data with any person or entity to whom the notice or counter-notice relates, in order to facilitate a prompt resolution of the copyright infringement claim. For U.S. residents only, copyright infringement notices and/or counter-notices will be treated in accordance with our Digital Millennium Copyright Act Policy found at: https://www.sandler.com/dmca/ (“DMCA Policy”). In addition, if you are using Sandler Online, you may be able to chat with other users of Sandler Online, and they can see certain information about you through their accounts with Sandler Online.

Business Transactions. We may use your personal data in connection with certain business transactions, including the purchase, sale, merger, rental, combination or any other type of business acquisition, transfer, disposition and securitization of financing as well as in connection with any bankruptcy or similar insolvency proceeding, including as part of any related due diligence process.

Your Employer and Our Trainers. When you sign-up for Sandler Online to take courses provided through your employer, we may share certain information with your employer, such as whether you complete certain courses. When taking courses using Sandler Online, Sandler or you may share your personal data with Sandler employees, contractors, trainers or franchisees that are providing training to you through Sandler Online.

Other. We may share personal data with third parties or service providers when explicitly requested by or consented to by you, or for the purposes for which you disclosed the personal data to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

INFORMATION WE DO NOT INTEND TO COLLECT

Special Categories of Personal Data. “Special Categories of personal data” is any data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of identifying a person, data concerning health or a person’s sex life and/or sexual orientation, and any other data that is considered “sensitive data” under applicable law. Except as described above when you apply to work with Sandler, we do not knowingly collect Special Categories of personal data from you. Your provision of Special Categories of personal data, or other sensitive data, is not mandatory; however, we may not be able to consider you for employment with Sandler if you do not provide certain, requested information. Please refrain from sending Special Categories of personal data to us unless requested during your job application process.

Information from Minors. We do not knowingly collect personal data from persons under the age of majority in their place of residence (typically 18 years old). Do not send us personal data if you are under the age of majority. If you are a parent or guardian and you believe your child provided us with their personal data, you may contact us as described in the “Contact Us” section below and we will make good faith efforts to delete that data.  

YOUR RIGHTS AND CHOICES REGARDING PERSONAL DATA*

THE CONSEQUENCES OF NOT PROVIDING PERSONAL DATA

Sandler will not be able to provide some Services or provide you with access to certain parts of the Sites without processing certain personal data. For example, we need to collect login and contact information from you when you access certain parts of our Sites, and we need to collect certain contact information from you when you make a purchase.

DATA RETENTION

Sandler will only keep your personal data for so long as it has a reasonable business purpose for doing so or where we are required to keep it by applicable law.

DE-IDENTIFIED OR AGGREGATED INFORMATION

Sandler may collect, use, share, transfer, create and otherwise Process de-identified and aggregated information for any purpose in compliance with applicable laws. Sandler is the sole and exclusive owner of such de-identified and aggregated information, including if Sandler de-identifies personal data so that it is no longer considered personal data under applicable laws.

SOCIAL MEDIA

We are active on social media. The Sites may allow you to connect and share data with social media platforms. These features may require us to use cookies, plug-ins, and APIs provided by such social media platforms to facilitate those communications and features. The Sites may also use advertising networks and services offered by social media platforms to deliver advertising content. Use of these services requires the applicable social media platforms to implement cookies or pixel tags to deliver ads to you while you access a Site.

Anything you post on social media is public information and will not be treated confidentially. We may post (or re-post) on the Sites and our social media pages any comments or content that you post on our social media pages. Your use of social media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Privacy Policy. We encourage you to review those policies and terms before using any social media features provided through our Sites or third-party websites.

INFORMATION SECURITY

We make commercially reasonable efforts to protect personal data.  We protect personal data using technical and organizational measures designed to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration of personal data appropriate to the type of personal data processed.  If a breach of your personal data occurs, we will notify you of the breach if and as required under applicable law.

HOWEVER, NO DATA TRANSMISSION OVER THE INTERNET OR A DEVICE CAN BE GUARANTEED TO BE 100% SECURE.  WHILE WE STRIVE TO PROTECT PERSONAL DATA, WE DO NOT GUARANTEE THE SECURITY OF ANY PERSONAL DATA AND YOU PROVIDE PERSONAL DATA AT YOUR OWN RISK.

ACCESS TO PERSONAL DATA IN OTHER COUNTRIES

If you access the Sites from outside the United States, please be aware that personal data may be transferred to, stored in, and Processed in the United States. Certain governmental authorities may not consider the level of protection of personal data in the United States to be equivalent to that required in other jurisdictions.

The European Union (EU) and the United Kingdom (UK) specifically have determined that the United States does not have an adequate level of protection for personal data.  Further, certain countries require that personal data transferred to other countries can only occur if the recipient resides in a country with materially similar data protection laws.  Given that the U.S. does not have data protection laws in every state that provide a materially similar level of protection of personal data as certain other countries, Sandler uses (1) the Standard Contractual Clauses in transferring personal data of EU or UK citizens across international borders or other approved methods by the EU, and (2) other data transfer agreements that may be required by other countries in order to transfer personal data across country borders.  You may request a summary of the appropriate safeguards or seek inquiries regarding such safeguards by contacting us at [email protected]. We will respond to your request or inquiry within a reasonable time period.

ADDITIONAL TERMS APPLICABLE TO CALIFORNIA RESIDENTS

The CCPA and Personal Information. If you are a California resident, you may have additional rights (or different rights than described above) under the California Consumer Privacy Act, as amended, and its implementing regulations (the “CCPA”). Although the terms “personal information” and “personal data” can often be used interchangeably, in this section when referring to “personal information”, we are referring to how that term is defined under the CCPA.

Collection, Source, Purpose and Sharing of Personal Information. To view the categories of personal information we collect, the sources from which personal information is collected, the purposes for which we collect personal information, and the categories of third parties and/or service providers with whom we share personal information, please click on the applicable hyperlink in this paragraph, or see the applicable section in this Privacy Policy above.

Selling or Disclosing Personal Information for a Business Purpose.

In the last 12 months we sold, or disclosed your personal information for a business purpose, if indicated below. See the section above titled “Personal Data We Collect” for more detail on the type of personal information in each category.