This Privacy Policy explains how SEABISCUIT SOFTWARE LLC, a legal entity incorporated under the laws of Ukraine, registration number 38277419, with its registered address at 27B Nauky Avenue, Kharkiv, Ukraine, 61072, operating the Lead Navigator platform under the SSA Group brand ("SSA Group", "we", "us" or "our"), collects, uses, discloses and protects personal information in connection with the Lead Navigator platform (the "Service").
This Privacy Policy applies to Customer representatives, Authorized Users, website visitors, persons who contact us, and individuals whose business-related personal information may be processed or made available through the Service.
By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy. Where consent is required by applicable law, we will request it separately. If you do not agree with this Privacy Policy, you should discontinue use of the Service.
Depending on the processing context, SSA Group may act as an independent controller or, where expressly agreed, as a processor acting on documented instructions of a Customer. Customers are independently responsible for their downstream use of Outputs and for compliance with laws applicable to that use.
1. Information We Collect
We collect and process personal information reasonably necessary to operate, secure, support and improve the Service, process subscriptions and payments, comply with legal obligations, and provide the business intelligence functionality described below. The categories of information depend on how an individual interacts with the Service.
1.1 Information Provided by Customers and Users
We may collect information voluntarily provided when an account is created, a Subscription is purchased, support is requested, or the Service is otherwise used, including:
- name and business contact details, including business email address and telephone number where provided;
- company name, job title, role and account affiliation;
- billing and invoicing information, including billing address, tax information and other details required to process an order;
- account credentials, authentication information and account preferences;
- User Data uploaded, imported or otherwise submitted through the Service; and
- information contained in support requests, inquiries, feedback or other communications.
The Customer is responsible for ensuring that information provided to us is accurate, complete and lawfully supplied. We do not intentionally request special categories of personal data or other sensitive personal information through the ordinary operation of the Service.
1.2 Transactional Information
When a Subscription is purchased or paid for, we may process payment amount and currency, transaction date, payment status, payment reference or identifier, purchased plan, billing details, and information made available by the relevant payment service provider, bank or financial institution. We do not receive or store full payment card details. Card payments are processed by LiqPay or another payment provider identified at checkout.
1.3 Technical and Usage Information
When the Service or related website is accessed, we may automatically collect:
- IP address and approximate location derived from the IP address;
- browser type and version, device type, operating system and language settings;
- access times, session duration, pages, searches and features used;
- navigation paths, interactions and account activity; and
- diagnostic logs, system events, security records, error reports and performance metrics.
1.4 Business Contact Data
Lead Navigator is a B2B business intelligence, lead discovery and campaign preparation platform. The Service may process and make available business-related personal information concerning representatives, employees, owners, officers, directors and other professional contacts associated with companies or other organizations.
Business Contact Data may include:
- name;
- job title, seniority, professional function and department;
- company or organizational affiliation and related company information;
- professional or business email address and associated technical verification status;
- publicly available professional profile information;
- business location and other business-related identifiers or attributes; and
- information inferred, matched, classified or enriched from available business-related data.
The Service is intended exclusively for business and professional use. Business Contact Data is not intended for personal, family or household use.
1.5 Sources of Business Contact Data
Business Contact Data may be obtained from or generated using:
- publicly available websites and company websites;
- public business directories, corporate records and commercial registries;
- publicly accessible professional profiles, publications and announcements;
- licensed commercial data providers and other third-party sources;
- information supplied by Customers or other users; and
- proprietary aggregation, extraction, matching, classification, enrichment, inference and technical verification processes.
We do not represent that Business Contact Data was obtained directly from the individual concerned. Where applicable law requires information about indirect collection, this Privacy Policy is intended to provide general information about the relevant categories, sources, purposes and rights.
1.6 Cookies and Similar Technologies
We use cookies and similar technologies for authentication, security, preference management, analytics and performance. Essential cookies are required for core operation. Where required by applicable law, analytics or other non-essential cookies are used only after consent. Available consent tools or browser settings may be used to withdraw or change consent. Disabling essential cookies may affect Service availability or functionality.
2. How We Use Personal Information
We may process personal information for the following purposes:
- creating, authenticating, administering and securing accounts;
- providing access to the Service and its features;
- processing orders, subscriptions, payments, renewals and refunds;
- delivering technical, billing and customer support;
- sending service-related, security, billing and transactional communications;
- monitoring performance, troubleshooting, preventing misuse and protecting the Service;
- maintaining records and complying with legal, tax, accounting and regulatory obligations;
- conducting analytics and improving Service functionality, usability, data quality and coverage;
- communicating about the Service and sending marketing communications where permitted by law and subject to applicable preferences; and
- establishing, exercising or defending legal claims.
2.1 Business Intelligence Functionality
We may process Business Contact Data to operate and provide target company search, business contact discovery, data aggregation, matching, enrichment, classification, technical verification, account research, analytics and AI-assisted campaign preparation functionality. Unless expressly agreed otherwise in writing, SSA Group does not send emails, messages, calls or other outreach on behalf of Customers.
2.2 Automated Processing and AI-Assisted Features
The Service may use automated matching, inference, validation, deliverability checks, classification and AI-assisted generation to produce Outputs. Such processing may generate or suggest professional classifications, target-account relevance, draft campaign content or other business-related results. These processes do not independently confirm information directly with the individual concerned and may produce incomplete, outdated or incorrect results. The Service is not intended to make decisions producing legal or similarly significant effects concerning individuals.
3. Legal Bases for Processing
Where applicable law requires a legal basis, we rely on one or more of the following, as appropriate to the relevant processing activity:
3.1 Performance of a Contract
Processing necessary to create and manage accounts, provide the Service, administer Subscriptions, process payments, communicate about the Service and provide support.
3.2 Legitimate Interests
Processing necessary for our legitimate interests or those of third parties, provided such interests are not overridden by applicable rights and interests. These interests may include operating and improving a B2B business intelligence service, maintaining data quality, securing the Service, preventing fraud and misuse, supporting business continuity, communicating with business customers, and establishing or defending legal claims.
3.3 Legal Obligations
Processing required to comply with applicable legal, tax, accounting, regulatory or law-enforcement obligations.
3.4 Consent
Processing based on consent where consent is legally required, including certain non-essential cookies or marketing communications. Consent may be withdrawn at any time without affecting processing lawfully carried out before withdrawal.
3.5 Vital Interests and Other Lawful Grounds
Processing necessary to protect vital interests or based on another lawful ground available under applicable data protection legislation, where relevant.
4. How We Share Personal Information
We do not sell personal information. We may disclose personal information only as described below or where otherwise permitted or required by law.
4.1 Customers and Authorized Users
Business Contact Data and related Outputs may be made available to Customers and their Authorized Users as part of the ordinary operation of the Service and within applicable Subscription limits. Customers independently determine the purposes and means of their downstream use of Outputs and are responsible for establishing a lawful basis, providing required notices, honoring data subject rights, maintaining suppression lists, and complying with applicable privacy, direct marketing and communications laws.
4.2 Service Providers
We may disclose information to providers supporting hosting, cloud infrastructure, security, payment processing, analytics, monitoring, customer support, communications, professional advice and other operational functions. Such providers are authorized to process information only for the relevant service purposes and subject to appropriate contractual and legal safeguards.
4.3 Legal and Regulatory Disclosures
We may disclose information where reasonably necessary to comply with law or a lawful request, respond to courts, regulators or authorities, enforce agreements, protect legal rights, investigate fraud or misuse, or address security incidents or unlawful activity.
4.4 Business Transfers
Information may be transferred in connection with a merger, acquisition, financing, reorganization, sale of assets or similar transaction, subject to appropriate confidentiality and data protection safeguards.
5. International Data Transfers
Personal information may be transferred to and processed in countries other than the country where the individual is located. Where applicable law requires safeguards for an international transfer, we use legally recognized measures appropriate to the transfer, which may include adequacy decisions, standard contractual clauses or equivalent contractual and organizational safeguards.
6. Data Security
We implement reasonable technical and organizational measures designed to protect personal information against unauthorized or unlawful access, use, alteration, disclosure, loss or destruction. Measures may include access controls, encryption where appropriate, monitoring and logging, security updates, internal confidentiality requirements, backup and recovery controls, and assessment of relevant service providers. No system or method of transmission can guarantee absolute security.
7. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including account and Subscription administration, provision and improvement of the Service, support, security, fraud prevention, legal compliance, dispute resolution and protection of legitimate business interests.
Retention periods may vary according to the type, source, sensitivity and purpose of the information, the duration of the Customer relationship, applicable limitation periods and legal retention requirements. Business Contact Data may be updated, suppressed, deleted or anonymized when it is no longer reasonably required or where a valid request requires such action. Aggregated or anonymized information that no longer identifies an individual may be retained for analytics and Service improvement.
8. Rights of Individuals
Depending on the individual’s location and applicable law, an individual whose personal information we process, including a user of the Service or a person whose Business Contact Data appears in the Service, may have the right to:
- request access to personal information;
- request correction of inaccurate or incomplete information;
- request deletion of personal information;
- request restriction of processing;
- object to processing, including processing based on legitimate interests or for direct marketing;
- request data portability where applicable;
- withdraw consent where processing is based on consent; and
- lodge a complaint with a competent data protection authority.
Requests may be submitted to contact@ssa.group. The request should provide sufficient information to identify the individual and the relevant data. We may request reasonable verification of identity and may retain limited information necessary to record and honor an objection, deletion or suppression request. Rights may be subject to limitations and exemptions under applicable law.
Where a Customer independently controls downstream processing of an Output, the relevant request may need to be directed to that Customer. We will respond to requests relating to processing for which SSA Group is responsible and, where appropriate, explain if another controller is responsible.
9. Customer Responsibilities
Customers are responsible for the lawfulness of User Data submitted to the Service and for their independent use of Outputs. The Customer must determine and document an appropriate legal basis where required, provide legally required notices, respect objections and opt-outs, apply appropriate retention and deletion practices, and ensure that any outreach or other downstream activity complies with applicable privacy, electronic communications, direct marketing and consumer protection laws. The Service does not provide consent, permission or legal authorization for Customer communications.
10. Third-Party Services and Links
The Service may integrate with or contain links to third-party services, such as payment providers, CRM systems or professional platforms. Third parties process information under their own terms and privacy policies where they act independently. We are not responsible for independent third-party privacy practices, and users should review the relevant third-party policies.
11. Children
The Service is intended exclusively for business and professional use and is not directed to children. We do not knowingly collect personal information from children through the Service. If we become aware that such information has been collected contrary to applicable law, we will take appropriate steps to delete it.
12. Accuracy and Informational Nature of Business Contact Data
Business Contact Data may originate from third-party or public sources and may be inferred, matched, enriched or technically verified through automated processes. We do not guarantee that such information is complete, accurate, current, deliverable or suitable for a particular purpose. A “Verified” status reflects only the automated technical, matching, validation or deliverability checks available within the Service at the relevant time and does not mean that the information was independently confirmed directly with the individual or organization concerned.
13. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in the Service, our processing activities, legal requirements or operational practices. The “Last Updated” date identifies the current version. Where appropriate or required by law, material changes may be communicated through the Service, by email or by another reasonable method.
14. Contact Information
The entity responsible for the processing described in this Privacy Policy is:
Legal name: SEABISCUIT SOFTWARE LLC
Registration number (Enterprise code): 38277419
Registered address: 27B Nauky Avenue, Kharkiv, Ukraine, 61072
Privacy and support email: contact@ssa.group
Service website: https://www.ssa.group/lead-navigator-policy-lead-generation-platform/
Questions about this Privacy Policy and requests concerning personal information may be sent to contact@ssa.group.