Effective Date: November 5, 2020
Information We Collect
Information collected directly
Model N collects personal data regarding individuals associated with its current, prospective, and former clients and customers, and, with respect to the Model N site and Services, users, visitors, and guests (collectively “Individuals”).
We may collect personal data directly from Individuals, such as your name, address and email address, and other information that can be used to contact you. We will only collect such information where it is helpful for us to communicate with you, for example, to fulfill an order you place, register for one or more Services from us, or provide you with additional information you have requested.
Information collected through the Services
We may collect personal data indirectly from individuals associated with our customers using our Services such as your name, address and email address, and other information that can be used to contact you and provide you access to our website and/or Services. The types of information and the use of such information collected through our Services shall be limited to the purpose of providing the Services for which the customer has engaged Model N.
Please note, if Model N collected personal data about you through someone other than you, we would encourage you to first direct your query to Model N’s customer (the data controller). Model N will support the data controller as requested.
Information from Third-Party Sources
We may collect data, such as corporate addresses or product pricing, from third-party sources to supplement information provided by our customers. This supplemental information allows us to verify information and to enhance our ability to provide information about our business, products, and Services. Model N’s agreements with these third-party sources typically limit how we may use this supplemental information.
From time to time, we may contact you to participate in online surveys. If you decide to participate, you may be asked to provide certain information which may include personal data. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our products, sites and/or Services and in any manner consistent with the policies provided herein.
From time to time, we may provide Services that are specifically designed to be compatible and used on mobile devices. We will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings and the operating system of your device. Mobile versions of Model N’s Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with user accounts. In addition, Model N may enable individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit personal data to us to enable Individuals to access user accounts and to enable us to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Model N may use personal or non-identifiable information transmitted to us to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Policy or in other notices we provide.
Pixel Tags/Web Beacons
We may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our website. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the browser type and language; the device type; geographic location; and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable email, we or our third-party service providers may use “format sensing” technology, which allows pixel tags to let us know whether you received and opened our email.
We may also use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on our website, and to develop website content. This analytics data is not tied to any personal data. For more information about Google Analytics, click here. You can opt out of Google’s collection and processing of data generated by your use of the Service by clicking here.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our websites or on third party websites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt-out of the Technologies we employ on our websites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
“Do Not Track”
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Model N does not recognize or respond to browser initiated DNT signals. For information about “do-not-track”, click here.
Use of your Information
We use your information for a variety of business and commercial purposes as described below. We will not sell (other than as defined under CCPA), rent, loan or lease your personal data to others unless we have your permission or are required by law to do so. We will not use or share the personal data that you provide us online in ways unrelated to those described herein without first letting you know and, where required, seeking your consent.
To Provide Products, Services, or Information Requested
We may use personal data about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to (i) generally manage Individual information and accounts; (ii) respond to questions, comments, and other requests; and (iii) provide access to certain areas, functionalities, and features of Model N’s Services and websites.
You may sign-up to receive newsletters or promotional communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you.
Marketing Products and Services
We may use your personal data to provide you with the Services. We may also use your contact information to tell you about other products we think might interest you. However, if you don’t want us to contact you for promotional purposes, you can tell us by following the instructions in the Contacting Us section. Your contact preferences only apply to marketing content. We may need to communicate with you regarding the usability of the Services or critical messages relating to the Services (such as service messages, subscription renewal notices, critical notices, or legally mandated notices).
Research and Development
We may use personal data and other data about you to create de-identified information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services.
Information Submitted Via Services
We may use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Model N will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
De-Identified and Aggregated Information
We may use information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Model N’s Services or websites, or other analyses we create. De-identified and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. De-identified or aggregated information is not personal data, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Model N and with third parties for our or their purposes in a de-identified or aggregated form that is designed to prevent anyone from identifying you.
We may use personal data for other purposes for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purposes disclosed to you at the time you provide personal data, or with your consent.
How We Share Information
Except as provided below, we do not share, disclose, or sell your personal information.
Vendors and Service Providers
We may share your information with our affiliates, consultants, vendors and service providers who assist us in maintaining our website and provide related services on our behalf including (i) provision of IT and related services; (ii) provision of information and the Service that you have requested; (iii) payment processing; and (iv) customer service activities. When we supply your information to our partners and these third parties, we require them to use it only for the function they are helping us with. We may transfer personal information to companies that help us provide our Services or websites. Transfers to subsequent third parties are covered by the service agreements with our clients. Model N complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
Advertising Partners. Through our Services, we may allow third party advertising partners to set Technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day). We may also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your personal information with third party advertising partners, you may follow the instructions in the section Choice/Opt-Out below.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures)
We may have to disclose your information when required by law or under the good-faith belief that such disclosure is necessary to conform to applicable law, comply with legal process or protect the property, safety or interests of Model N, its agents, its employees or the public. Under such circumstances, Model N may be prohibited by law, court order or other legal process from providing notice of the disclosure, and we reserve the right not to provide such notice in our sole discretion.
Merger, Sale, or Other Asset Transfers
Model N may sell, transfer or otherwise share some or all of its assets, including personal data, in connection with a merger, reorganization, or sale of assets, or in the event of bankruptcy. In such an event, your personal data may be transferred to and used by another company.
You have the right to opt out of certain uses and disclosures of your personal data.
Email and Telephone Communications
- If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. We will process your request within a reasonable time after receipt. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain communications regarding Model N and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Service or this Policy).
- We maintain “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
Your Privacy Rights
In accordance with applicable law, you may have the right to:
- Request Access to/Port Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal data transferred to another party.
- Request Correction of your personal data where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal data or we may refer you to the controller of your personal data who is able to make the correction.
- Request Deletion of your personal data, subject to certain exceptions prescribed by law.
- Request Restriction of or Object to Processing of your personal data including the right to opt in or opt out of the sale of your personal data to third parties, if applicable, where such requests are permitted by law.
- Not be Discriminated Against by us for exercising your privacy rights.
If you would like to exercise any of these rights, please send an e-mail to firstname.lastname@example.org. We will process such requests in accordance with applicable laws. To protect your privacy, we may take steps to verify your identity before fulfilling your request.
Please note, if Model N collected personal data about you from individuals associated with our customers using our Services (as noted in section titled “Information collected through the Services” above) we would encourage you to first direct your query to Model N’s customer. Model N will support our customers as requested within a reasonable timeframe.
Supplemental Notice for California Residents
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Model N has collected about them and whether we have disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
|Category of Personal Information Collected by Model N||Category of Third Parties Information is Disclosed to for a Business Purpose|
|Identifiers. A real name, business postal address, Internet Protocol address, business email address, account name, or other similar identifiers.||
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, business address, and business telephone number.||
|Internet or other electronic network activity. Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.||
|Geolocation data. Physical location or movements.||
|Professional or employment-related information. Current or past job history.||
CCPA “Do Not Sell My Personal Information” We only sell personal information as defined under CCPA because we allow our advertising partners to set Technologies and other tracking tools that collect information such as IP address or device ID. If you wish to opt out of interest-based advertising, click here, or if located in the European Union, click here. This will keep your information from being used on those websites going forward. Please note you will continue to receive generic ads.
|Category of Personal Information Sold by Model N||Category of Third Parties Information is Disclosed to for a Business Purpose|
|Internet or other electronic network activity. Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.||
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us at email@example.com or as set forth below.
Verification. To protect your privacy, we will take steps the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name and email address.
California’s Shine the Light law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal data (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal data disclosed to those parties. Model N does not share personal data with third parties for their own marketing purposes.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us at firstname.lastname@example.org or as set forth below. We will process such requests in accordance with applicable laws.
If you are located in the European Economic Area or the UK, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
Third Party Websites and Social Media Platforms
Model N retains the personal data we receive as described in this Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
We use physical, electronic and administrative safeguards, including firewall, encryption and password protection for our databases, designed to protect the security of the data collected and to prevent unauthorized access to or disclosure of your personal data. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Model N strives to protect your personal data, we cannot ensure or warrant the security of any information you transmit to Model N, and you do so at your own risk. You are responsible for maintaining the secrecy of your own passwords. If you have any questions about the security of your personal data, you can contact us at email@example.com.
Because of the financial nature of our business, this website is not designed to appeal to children under the age of 13 and we do not knowingly request or receive any information from children.
Transfer to and Use in the United States
Model N will transfer any personal data you provide to the United States of America to use and store the information for the purposes described herein. By using our website and providing us with your personal data, you consent to such transfer, use, and storage of your personal data.
EU-U.S. Privacy Shield
Model N participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, and the United Kingdom in reliance on the Privacy Shield Framework to the Framework’s applicable principles. To learn more about the Privacy Shield Framework, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List by clicking here.
Model N is responsible for the processing of the personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. Model N complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Model N is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) by clicking here.
Model N has further committed to cooperate with EU data protection authorities (DPAs) for EU employees with regard to unresolved privacy shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.
Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
Changes to the Policy
Model N may update this Policy from time to time as it deems necessary in its sole discretion. If there are any material changes to this Policy, Model N will notify you as required by applicable law. Model N encourages you to review this Policy periodically to be informed regarding how Model N is using and protecting personal data and to be aware of any policy changes. Your continued relationship with Model N after the posting or notice of any amended Policy shall constitute your agreement to be bound by any such changes. Any changes to this Policy take effect immediately after being posted or otherwise provided by Model N.