Sprinklr CXM Privacy Policy

Last Updated: April 2, 2020

Sprinklr CXM Privacy Policy


This Privacy Policy explains how Sprinklr collects, uses, discloses and otherwise processes personal information to facilitate governments’ and citizens’ use of Sprinklr Citizen Experience Management Platform (“Sprinklr CXM”).


About Sprinklr CXM

Sprinklr CXM is a tool that enables government agencies at all levels (hereafter, “governments”) to process and manage publicly available and self-reported data to enable tracing, tracking, communication, and quarantining to combat the spread and impact of the COVID-19 and future pandemics.


Roles in Handling Personal Information


Governments that use Sprinklr CXM:

  • Decide what types of personal information to collect using the platform and how to share the information.
  • Are responsible for complying with their respective jurisdictions’ legal requirements that apply to the collection, use and disclosure of personal information.
  • Decide what consents, privacy notices, choices and privacy rights they need to provide to individuals whose information they process through Sprinklr CXM.
  • Decide how long to retain personal information in Sprinklr CXM.


Sprinklr, in its role as a service provider/processor on behalf of governments:

  • Facilitates the collection and processing of the information under a contract with each government that uses Sprinklr CXM.
  • Handles personal information only on behalf and for the benefit of the governments.
  • Helps governments comply with their legal obligations – for example, by facilitating individuals’ ability to exercise their privacy rights.


How Sprinklr CXM Works

The Sprinklr CXM enables governments to manage pandemic-related information of their citizens obtained through social media and self-reported data. The Sprinklr CXM provides governments with the following pandemic-response capabilities:


Information Intelligence

The Sprinklr CXM enables governments to use all digitally available data in decision making, in understanding where the next hotspot is, and in gaining insights into public opinion and knowledge.

Public Communications
The Sprinklr CXM enables governments to provide citizens with the latest public health data, content, and announcements, as well as combat misinformation.

Modern Citizen Hotline
The Sprinklr CXM enables governments to engage with citizens en masse or 1-to-1 via modern channels (automated or live) to alleviate the burden on call centers.

Citizen Portal
The Sprinklr CXM enables citizens to register themselves and others as vulnerable citizens, potential carriers, or currently infected, and to access current information.

Private Communications
The Sprinklr CXM enables governments to monitor, check-in, and support citizens through private communication channels.


The Content that Sprinklr CXM Collects


Publicly Available Social Media Content

The Sprinklr CXM enables governments to monitor, manage, and measure publicly available social media content on the Internet. Such information can be found by anyone online using a search engine. This includes, but is not limited to, information obtained from:

  • Twitter
  • Facebook
  • YouTube
  • LinkedIn
  • Google+
  • SlideShare
  • Instagram
  • Vkontakte
  • Sina Weibo
  • RenRen
  • QQ
  • Blogs & blog comments
  • Mainstream news sources and
  • Forums

Sprinklr CXM does not circumvent any of individuals’ privacy settings on any of these platforms.


Self-Reported Data

Sprinklr CXM enables governments to monitor, manage, and measure information that individuals provide through the Citizen Portal. This includes, but is not limited to, the following information that you may provide about yourself or others:

  • Name
  • Date of birth
  • Telephone number
  • Passport number
  • Address
  • Location
  • Emergency contact details
  • Family members
  • Symptoms and other health information
  • Geo-locations


How Sprinklr Uses Personal Information

We use the information we collect at the instruction of governments that use Sprinklr CXM and in accordance with our agreements with these users, to provide the platform and for related internal purposes, including to maintain and improve the platform and the services it offers, and to respond to inquiries, complaints, and requests for support.

We may also use personal information as we believe necessary appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern Sprinklr CXM; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.


How Sprinklr Shares Personal Information

We share the personal information:

  • With governments that use Sprinkr CXM, to the extent the information pertains to the country’s citizens,
  • With third-party service providers that perform services for or on behalf of Sprinklr, for the purposes described in this Privacy Policy, including: to provide the platform; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the platform; to provide technical support; and/or to provide other services to Sprinklr,
  • With public interest organizations, health care organizations and researchers that we determine to have a legitimate public interest purpose for processing the information; these recipients agree to privacy and security terms to protect the personal information we may share with them.

We also enable citizens to share information when using Sprinklr CXM.

We may share personal information with government, law enforcement officials or private parties as required by law, when we believe such disclosure is necessary or appropriate to (a) comply with applicable law; (b) enforce the terms and conditions that govern the platform; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

We may sell, transfer or otherwise share some or all of Sprinklr’s business or assets, including personal information, in connection with a business transaction such as a merger, consolidation, acquisition, reorganization or sale of assets or in the event of bankruptcy. We will require the recipient to abide by this Privacy Policy.


Privacy Rights & Choices

In some countries, individuals have the right to submit privacy-related requests, such as to access to information Sprinklr CXM maintains about them, to correct the information or delete it. To make a request, please send a letter or an email to Sprinklr Privacy Compliance. Please include the following information in your request:

1) Your name;
2) Your contact information, including phone number, address and email; and
3) The precise nature of your request.

Such requests can be sent to privacy@sprinklr.com or be mailed to:

Sprinklr Privacy Compliance
29 W. 35th St. 7th Floor
New York, NY 10001
(917) 933-7800
privacy@sprinklr.com

Please note that these rights may be limited in your country.

Individuals who initially consented to the collection of their geo-location information through the platform, can subsequently stop the collection of this information at any time by changing the preferences on their mobile device.


Automated Decision-Making

The Sprinklr CMX features automated processing, including profiling, of the personal information that individuals provide to us and that we have otherwise collected. This information may include health-related information, including symptoms and Coronavirus test status. The automated processing may produce legal effects or other similar consequences that similarly significantly affects individuals.

Automated processing involves making a decision using technology, without any person being involved. Profiling involves automated processing of your information to help us evaluate certain things about you.

The activities in which we engage that may involve automated processing, including profiling, of personal information are as follows:

  • Synthesizing information ahead of traditional news sources to alert authorities, key stakeholders, and citizens to the changing landscape of the pandemic using AI-based smart alerts and automated notifications.
  • Prioritizing and surfacing citizen concerns to authorities and key stakeholders.
  • Visualizing the impact of the virus as it spreads and where responses may be breaking down.
  • Improving response quality and day-to-day productivity of hotline agents and triaging citizen inquiries based on agent specializations and resource availability.
  • Providing check-ins with citizens to ensure and enforce self-quarantine and social-distancing compliance.
  • Monitoring less fortunate or less able population segments to route and respond to basic human needs as necessary.
  • Providing exposed and infected citizens with proactive assistance, best practices, information, and support.

In some countries, individuals may have the right to withdraw their consent to such automated processing of their personal information.


Cross-Border Data Transfer

Sprinklr may transfer personal information outside of the country in the individuals to whom the information pertains are located.
For transfers of personal information from European Economic Are, United Kingdom or Switzerland to the United States, Sprinklr has self-certified its compliance with the E.U.-US and Swiss–U.S. Privacy Shield Framework, as set out in our SMMS Privacy Policy.


Data Retention

Sprinklr retains personal information for as long as necessary to (a) provide Sprinklr CXM; (b) comply with legal obligations; (c) resolve disputes; and (d) comply with our obligations under the platform terms, including the data retention periods set out by governments that use the platform.


Creation of Anonymous Data for Analytics

We may create anonymous and aggregated data from personal information. We make personal information into anonymous and aggregated data by excluding information that makes the data personally identifiable to individuals, and use that anonymous and aggregated data as permitted by platform terms and applicable law.


Information about Children

Sprinklr CXM will collect information about children in accordance with the instructions of the government that uses the platform. These government users are responsible for processing children’s data in accordance with legal requirements in their respective countries.


Information Security

We use technical, organizational and administrative security measures designed to protect the personal information we hold in our records from loss, misuse, and unauthorized access, disclosure, alteration and destruction. We cannot guarantee that these security measures will always be effective.


Contact Us

If you have any questions about this Privacy Policy, or if you wish to exercise your rights under applicable data protection laws, please feel free to contact us through our websites, at privacy@sprinklr.com or write to us at Sprinklr, Inc., Data Protection Officer, 29 West 35th Street, New York, NY 10001, USA or at Sprinklr Germany GmbH, Alter Wall 67/79, 20457 Hamburg, Germany F.O.A The Data Protection Officer.

Effective as of April 2, 2020