This Privacy Policy describes how Gong.io Ltd. and its affiliated companies (collectively, “Gong”, “we”, “our” or “us”) collects, stores, uses and discloses the following categories of personal data:

Specifically, this Privacy Policy describes our practices regarding:

If you are a Customer, User or Prospect, please read this Privacy Policy carefully and make sure that you fully understand it.

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 Policy, 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 (as defined below), please do not provide it to us and avoid any interaction with us or with our Sites, or use our Services.

1. Data Collection & Processing

When we use the terms “personal data” or “personal information” in this Privacy Policy, 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 deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

Sometimes we collect personal data automatically when an individual interacts with our Services or Sites (such as through our website chat feature) and sometimes we collect personal data directly from an individual. At times, we may collect personal data about an individual from other sources and third parties (such as our Customers and Service Providers), even before our first direct interaction. Gong does not collect, use, or disclose sensitive personal data.

We may collect or generate the following types of personal data about individuals through the Services:

For the purposes of the California Consumer Privacy Act (“CCPA”), in the last 12 months, we may have collected the following categories of Personal Information, as defined in the CCPA: identifiers; customer record information; internet or other electronic network activity information; professional or employment-related information; geolocation data; commercial information; inferences; and audio, electronic, and visual information.

2. Data Uses

We use personal data as necessary for the performance of our Services (“Performance of Contract”); to comply with our legal and contractual obligations (“Legal Obligation”); and to support our legitimate interests in maintaining and improving our Services, e.g., in understanding how our Services are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our Customers, Users, Prospects, ourselves and our Services (“Legitimate Interests”).

If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal 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) (“Consent”), your acceptance of our Terms and Conditions and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy, unless applicable law requires a different form of consent. If you wish to revoke such consent, please contact us at privacy@gong.io.

Specifically, we use personal data for the following business and commercial purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

Customer and User personal data

Customer, User and Prospect personal data

3. Data Location

We and our authorized Service Providers (defined below) maintain, store and process personal data in the United States of America, Europe, Israel and other locations, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.

While privacy laws may vary between jurisdictions, Gong is committed to protect personal data in accordance with this Privacy Policy 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.

Gong.io Ltd. is headquartered in Israel, a jurisdiction which is considered by the European Commission, the Swiss Federal Data Protection and Information Commissioner (FDPIC), and the UK Secretary of State to be offering an adequate level of protection for the personal data of residents of the European Economic Area (“EEA”), Switzerland and the UK, respectively. We transfer personal data from the EEA, Switzerland and the UK to Israel on this basis.

Gong.io Inc., our US subsidiary, complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce and will be further liable in cases of onward transfers of your personal data to third parties (including our Service Providers).

Gong.io Inc. 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) regarding 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 the EU-U.S. DPF.

Gong.io Inc. has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) regarding 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 policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern for personal data transferred under the DPF. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

For data transfers from the EEA, Switzerland or the UK to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission, FDPIC and UK Information Commissioner’s Office (ICO). You can obtain a copy of these clauses by contacting us as indicated in Section ‎11 below.

4. Data Retention

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.

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.

If you have any questions about our data retention policy, please contact us by e-mail at privacy@gong.io.

5. Data Disclosure

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 may 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, our website chat feature, 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 and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal information, 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.

Partnerships: We engage selected business and channel partners, resellers, distributors and providers of professional services related to our Services, which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our Customers, Users and Prospects. In such instances, we may share relevant contact, business and usage details with the respective partner, to allow them to engage with those entities and individuals for such purposes. If you directly engage with any of our partners, please note that any aspect of that engagement which is not directly related to the Services and directed by Gong is beyond the scope of Gong’s Terms and Conditions and Privacy Policy, and may therefore be covered by the partner’s terms and privacy policy.

Service Integrations: You may choose to use a third-party service to integrate with our Services, for example in order to upload or retrieve personal data to or from the Services, or to enrich the data you have processed on either service or enhance your usage thereof (provided that such integration is supported by our Services). The provider of this 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 your 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).

Event Sponsors: If you attend an event or webinar organized by us, or download or access an asset on our Sites related to such an event, webinar or other activity involving third-party sponsors or presenters, we may share your personal data with them. If required by applicable law, you may consent to such sharing via the registration form or by allowing your attendee badge to be scanned at a sponsor booth. In these circumstances, your personal data will be subject to the sponsors’ privacy statements. If you do not wish for your personal data to be shared, you may choose to not opt-in via event/webinar registration or elect to not have your badge scanned, or you can opt-out in accordance with Section ‎9 below;

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.”

Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.

Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Gong, any of our Users or Customers, or any members of the general public.

Gong Subsidiaries and Affiliated Companies: We may share personal data internally within our group, for the purposes described in this Privacy Policy. In addition, should Gong or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, personal data may be shared with or transferred to the parties involved in such an event. We may disclose personal data to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal data may also be disclosed in the event of insolvency, bankruptcy or receivership.

For the avoidance of doubt, Gong 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.

For the purposes of the CCPA, in the past 12 months, we may have disclosed the following categories of Personal Information, as defined in the CCPA: identifiers; customer record information; internet or other electronic network activity information; professional or employment-related information; geolocation data; commercial information; inferences; and audio, electronic and visual information to Service Providers, partnerships, service integrations, Gong subsidiaries and affiliated companies, for legal compliance, or to protect rights and safety. We may have disclosed identifiers and customer record information to event sponsors. We do so in pursuit of the business and commercial purposes described in Section 2 above.

6. Cookies and Data Collection Technologies

We and our Service Providers use cookies, pixels and other technologies to enable and improve the Services we provide, to track the performance of our Sites, perform analytics and gain insights on the use of our Services and the performance of our activities, and for personalization purposes.

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 session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.

We use “Persistent Cookies” to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.

Some cookies are necessary for the Services to function properly, and cannot be declined or disabled unless you delete and block them through your web browser settings. Other cookies, which are used for functional, performance, analytics and marketing purposes, are optional. These include web analytics tools, including Google Analytics, Mixpanel and Mouseflow. These tools help us understand Users’ behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service providers is available at: www.google.com/policies/privacy/partners/; https://mixpanel.com/terms/ and https://mouseflow.com/terms/. Further information about your option to opt-out of these analytics services is available at: https://tools.google.com/dlpage/gaoptout; https://mixpanel.com/optout; and https://mouseflow.com/opt-out/.

You may opt-in or opt-out to the use of such optional cookies through the “Your Privacy Choices” feature available on our website. If you choose to opt-out of certain cookies, this will typically generate a new cookie which will preserve your choice, and indicate it to our Services in your next visits so that the cookies you opted-out of will not be utilized. You can also manage your cookies preferences, and accept, remove or entirely block cookies, through your browser settings. Certain web browsers may transmit “Do Not Track” signals to websites with which the browser communicates. However, due to differences in how web browsers interpret this feature and send those signals, and lack of standardization, we currently do not respond to such “Do Not Track” signals.

Please note that if you get a new device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.

7. Communications

We engage in service and promotional communications, through e-mail, phone, SMS and notifications.

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. If you are registered as a User to our Services, you can typically control your communications and notifications settings from your profile settings, or otherwise in accordance with the instructions included in the communications sent to you. Please note that you will not be able to opt out of receiving certain service communications which are integral to your use (like password resets or billing notices).

Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our Customer, User or Prospect. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.

If you do not wish to receive such promotional communications, you may notify Gong at any time by sending an e-mail to: privacy@gong.io, changing your communications preferences in your profile settings whilst being logged as a User to our Services, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.

8. Data Security

We implement systems, applications and procedures 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 Sites or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

To learn more, please visit https://www.gong.io/trust-center/security/.

9. Data Subject Rights

Individuals have rights concerning their personal data. Please contact us by e-mail at: privacy@gong.io if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (GDPR), the Brazilian Data Protection Act (LGPD), the CCPA, or the Swiss Federal Act on Data Protection (FADP) . Such rights may include – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request rectification or erasure of your personal data held with Gong, or to restrict or object to such personal data processing (including the right to direct us not to sell or share your personal data to third parties now or in the future, as described below), or to port such personal data, or the right to equal services and prices (e.g., freedom from discrimination) (each to the extent available to you under the laws which apply to you). If you are a GDPR-protected individual, you also have the right to lodge a complaint with the relevant supervisory authority in the EU or the UK, as applicable. If you are an LGPD-protected individual, you also have the rights to confirmation of existence of processing; to request review of decisions made solely based on automatic decisions that affect your interests; to lodge a complaint with the supervisory authority and with consumer protection authorities in Brazil.

To the extent applicable to you, you may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.

Please note that when you or an authorized agent ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. If your request relates to personal data that may be processed on our Customer’s behalf, as their “data processor” or “service provider” (as further explained in Section 10 below), note that such Customer exclusively determines how such data is processed, as well as if and how your request should be handled – so we advise that you submit your request directly to them. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we collected the personal data, or that such data is processed on behalf of one of our Customers, so that we may forward it to such Customer for their further handling. Such additional information may be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request, or proof of request fulfillment).

We may redact from the data which we will make available to you, any personal data or confidential information related to others.

In compliance with the EU-U.S. DPF, and the UK Extension of the EU-U.S. DPP and the Swiss-U.S. DPF Principles, we commit to resolve complaints about our collection or use of your Personal Information. EEA, UK and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework compliance should submit inquiries to dpo@gong.io. 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, Gong.io, Inc. has further committed to cooperate with EU Data Protection Authorities (DPAs), the UK Information Commissioner Office (UK ICO), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to independently address complaints that we have been unable to resolve.

Please note that under certain conditions (as described under the DPF Principles that Gong.io Inc. adheres to), you can invoke a binding arbitration by delivering a notice to us via dpo@gong.io. Please also note that Gong.io Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

10. Data Controller/Processor

Certain data protection laws and regulations, such as the EU GDPR, UK GDPR, Brazilian Data Protection Act, and the CCPA, typically distinguish between two main roles for parties processing personal data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Gong is the “data controller” of Prospect Data. With respect to such data, we assume the responsibilities of data controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.

Gong is the “data processor” of Customer Data, which we process on behalf of our Customer (who is the “data controller” of such data); and our Service Providers who process such Customer Data on our behalf are the “sub-processors” of such data.

Gong is both a “data controller” and “data processor” of User Data. Such data is processed by Gong for its own purposes (as described in Section 2 above), as an independent ‘controller’; whilst those certain portions of it which are included in Customer Data will be processed by us on our Customer’s behalf, as a ‘processor’.

Accordingly, Gong processes Customer Data strictly in accordance with our Customer’s reasonable instructions and as further stipulated in our Data Processing Addendum and other commercial agreements with such Customer.

Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the Customer, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.

11. Opt-Out of Sale/Sharing

Under some US data protection laws, like the CCPA, our disclosure of certain internet activity and device information with third parties through cookies on our website may be considered a “sale” or “sharing” of personal information. We do so in pursuit of the business and commercial purposes described in Section 2 above.

For the purposes of the CCPA, in the last 12 months we may have “sold” or “shared” Internet or other electronic network activity information, Geolocation data, Commercial information, and Inferences with our analytics and advertising Service Providers. Gong has not knowingly sold or shared the personal information of individuals under the age of 16.

You may opt out of all Cookies that may result in a “sale” and/or “sharing” of your personal information in the following ways:

Set the Global Privacy Control (GPC) for each participating browser system that you use to opt out of the use of third-party Advertising or other cookies (instructions on how to download and use GPC are available here).

12. Additional Notices & Contact Details

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the date it is published. We will provide prior notice if we believe that the changes involved materially alter your rights, via any of the communication means available to us or via the Services. After such notice period, all amendments shall be deemed accepted by you.

External Links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices. We encourage you to pay attention when you leave our Services for the website or application of such third parties, and to read the privacy policies of each and every website and service you visit. This Privacy Policy applies only to our Services.

Children: Our Services are not designed to attract children under the age of 16. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at privacy@gong.io.

Data Protection Officer: Gong has appointed Mr. Aner Rabinovitz of PrivacyTeam Ltd. as our Data Protection Officer (DPO), for monitoring and advising on Gong’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your Privacy, or if you wish to make a complaint about how your personal data is being processed by Gong, you can contact privacy@gong.io or our DPO at dpo@gong.io.

EU and UK Representative: Maetzler Rechtsanwalts GmbH & Co KG (Prighter) has been designated as Gong’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Prighter Ltd has been designated as Gong’s representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. Inquiries regarding our EU & UK privacy practices may be sent by e-mail to privacy@gong.io or via mail. To make an inquiry by mail, please visit the following page: https://prighter.com/q/18226468565.

Contacting Us: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact Gong’s support at help@gong.io or our Data Protection Officer at dpo@gong.io.

Last updated: March 2024.