Website Privacy Policy

(Data Controller) Last updated: September 09, 2021

Privacy Policy- Data Controller

Social27 Inc. (“Social27”, “we”, “us” or “our”) is committed to protecting your privacy, as well as our clients and prospective clients (the “Client/ s”), and other users of the www.Social27.com website (the “Site”) and services, and we want to ensure that you have a positive experience when you use our video conferencing and communication services (the “Services”), visit our Site webpages, interact with us on social media, or attend a Social27 sponsored event online or offline.

When we collect information that relates to an identified or identifiable individual (the “Personal Data” or “Personal Information”), we may be doing so one of two ways, (i) on our own behalf (in which case we will be considered a “controller” of your data), and (ii) your personal information, also referred to as the “Platform Content” may be collected on behalf of a Client who is using the Services through SOCIAL27’s Virtual Communication Platform, which includes services related to our Webinars, Virtual Environments, Channels, and Portals (collectively, the “Platform”) to organize an event and manage other event-related activities (in which case, the Client will be the “controller” and Social27 will be considered a “processor” of your Personal Information/Platform Content). The Personal Information we collect and how we use it varies depending upon the nature of our relationship, and whether Social27 is the data controller or data processor.

Controller and Responsible Party under GDPR

For the purposes of the EU General Data Protection Regulation (the “GDPR”) and other relevant applicable laws SOCIAL27 is the controller of your personal information collected pursuant to this Policy. With respect to any Platform Data, our Clients are the data controllers or businesses for their respective Platform Data, and we are a data processor or service provider, as defined under applicable privacy laws.

If you are invited to, register for, check into, or receive information regarding a Client event through a Client Site or Service, you will be considered an “Event Attendee” and we will provide any Personal Information you submit through the Site or Service to the Client organizing that event via the Event Attendees, participants and other end users of the Platform and/or Client events the “Platform Data”. Social27 does not control the Client’s event registration or management process or determine the Platform Content that a Client requests from Event Attendees. When SOCIAL27 collects, submits, manages, creates, or records Platform Data via the Platform, or the Personal Information Social27 collects, accesses, stores, uses or otherwise processes (collectively, “process”) in order to provide our Services to Clients; we will only Process such Platform Data on behalf of the particular Client in order to provide our Services to that Client. As a processor, our collection, use, disclosure and other processing of Platform Data on behalf of Clients is subject to the privacy policy of our respective Clients. Please see the SOCIAL27 Platform Privacy for information about our processing of Platform Data. As set out in the SOCIAL27 Platform Privacy Policy, SOCIAL27 is a processor of the Platform Data; we only use the personal information that we Process as part of the Platform Data subject to our agreements with Clients and their written instructions, or where otherwise required by law. This Policy also does not apply to job applicants and candidates who apply for employment through our job application portal, or to employees and non-employee workers, whose personal information is subject to different privacy notices.Please see the SOCIAL27 Platform Privacy for information about our processing of Platform Data.

Categories of Personal Information Collected

Social27 collects, or may collect, if requested by a Client, the following types of Personal Information:

  • Identifiers: includes direct identifiers, such as name, account name, username, phone number, mailing address, email address, online identifier, Internet Protocol (“IP”) address, or other similar identifiers.
  • Customer Records: includes Personal Information, such as name, signature, contact information, and payment information (e.g. credit cards), that individuals provide us to purchase or obtain our Services.
  • Commercial Information: includes records, or Services purchased, obtained or considered, or other purchasing or use histories.
  • Usage Data: includes browsing history, clickstream data, search history, access logs and other usage data and information regarding an individual’s interaction with our Site and Services, and our marketing emails and online ads.
  • Geolocation Data: includes precise location information about a particular individual or device.
  • Audio, Video and Electronic Data: includes audio, electronic, visual, or similar information, and call recordings.
  • Professional Information: includes professional and employment- related information, such as current and former employer(s) and position(s) and business contact information.
  • Protected Classifications: includes characteristics of protected classifications under applicable laws, such as disability information and medical conditions provided by you when you register for events and other activities.
  • Inferences: includes inferences drawn from other Personal Information that we collect to create a profile reflecting an individual user’ preferences, behavior or other characteristics. For example, we may analyze Personal Information in order to identify the offers and information that may be most relevant to our Clients, so that we can better reach them with relevant ads and offers.

If you are a California resident, please be sure to review the section “Additional Information for Individuals in Certain Jurisdictions” below for important information about our privacy practices and your rights under California privacy laws, including your right to submit a request.

Use of Personal Information

In general, Social27 may use and disclose the Personal Information we collect for the following business and commercial purposes:

  • Operating Site and Services and providing related support
  • Responding to user and Client inquiries and fulfilling requests
  • Analyzing and improving the Site, our Services, and our business
  • To provide you with technical and administrative information relating to our Sites and Services, such as security notices, Service-related status reports, and changes to our policies or Terms of Use.
  • Please note that these communications are considered part of our Services and you may not opt out of them.
  • Personalizing user experiences
  • To send you updates, newsletters and other content that you have requested or subscribed to, as well as informational materials regarding our Services.
  • If you have consented, and it is in compliance with applicable laws, we may send you marketing communications regarding products and services that we believe may be of interest to you. If you later decide that you no longer want to receive this type of promotional information, you may opt-out at any time by clicking the “Unsubscribe” button at the bottom of the marketing communication or contacting us at the email or mailing address provided in the “Contact Us” section of this Privacy Policy.
  • Protecting our legal rights and preventing misuse
  • Complying with legal obligations

Related to Our General Business Operations

If you are a California resident, please be sure to review the section “Additional Information for Individuals in Certain Jurisdictions” below for important information about our privacy practices and your rights under California privacy laws, including your right to submit a request.

Personal Information Not Required-Limited Use

The Personal Information that Social27 collects and processes will vary depending upon the circumstances. You do not have to provide us with your Personal Information to access certain sections of the Site. If you choose not to disclose certain Personal Information, you can still visit our Site, but you will not be able to create an account with us, and you may not be able to access certain options and services, and we may be unable to fully respond to your inquiries.

Personal Information Collected Directly

We may collect personal information about you directly from you or from the Client. For example, when you fill out a ‘Contact Us’ form, signup for our mailing lists, or register for events we host or sponsor, or otherwise provide us information through the Site, we may collect Personal Information such as:

  • Name, company name, and title/position
  • Payment and billing information:
  • Email address, phone number, mailing address and contact details Job title, other company information (such as country and industry sector)
  • Contact preferences and interests
  • Business affiliations:
  • Customer (and authorized user) account information (to access various parts of the Platform, and to create events and webinars) – name, email address, telephone number, company name, and other information necessary to confirm that you are an authorized user of a Client (where relevant)
  • Other information related to your request or inquiry

Personal Information Collected Indirectly

Automatically-Collected Personal Information

We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information when users access or use the services or visit the Site, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information. For more information, see the Cookies and Similar Devices section below.

Personal Information Collected from Third Parties

We may collect personal information about you from third party sources, such as business partners, social media platforms, public sources, joint marketing partners (so that we can deliver our Platform and related services) and third parties to whom you have expressed interest in our products and services, as well as information that you shared on social media platforms (subject to the respective Platform terms and applicable laws.

Purposes and Legal Bases of Personal Information Use

Personal Information Purpose

The purposes for which we may process personal information will vary depending upon the circumstances. In general, we use Personal Information for the business and commercial purposes set forth below, and where the GDPR or other relevant laws apply, we have set forth the legal bases for such processing in parenthesis (see above for further explanation of our legal bases):

  • Operating Site and services and providing related support: to provide and operate the Site and services, communicate with you about your use of the Site and our services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, communicate with you, and for similar service and support purposes. (Legal bases: performance of our contract with you; and/or our legitimate interests)
  • Responding to requests: to respond to your inquiries and requests and consider your request or application. (Legal basis: performance of our contract with you)
  • Analyzing and improving the Site, our services, and our business: to better understand how users access and use the Site and our services, as well as other products and offerings, both on an aggregated and individualized basis, to administer, monitor, and improve our Services, for our internal purposes, and for other research and analytical purposes. (Legal basis: our legitimate interests)
  • Personalizing experiences: to tailor content we may send or display on the Site, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences. (Legal basis: our legitimate interests)
  • Advertising and marketing: to promote SOCIAL27’s products and Services on third-party websites, as well as for direct marketing purposes, including to send you communications, Client alerts and information we think may interest you. If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them. (Legal bases: our legitimate interests; and/or with your consent)
  • Protecting our legal rights and preventing misuse: to protect the Site and our business operations; to prevent, detect and investigate fraud, misuse, harassment or other types of unlawful activities; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of this Policy and our applicable Terms of Use and agreements. (Legal bases: our legitimate interests; and/or compliance with laws)
  • Complying with legal obligations: to comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements. (Legal bases: our legitimate interests; and/or compliance with laws)
  • Related to our general business operations: to consider and implement mergers, acquisitions, reorganizations, and other business transactions, and where necessary to the administration of our general business, accounting, recordkeeping and legal functions. (Legal bases: our legitimate interests; and/or compliance with laws)

Aggregate, De-identified, or Anonymous Data

We also create and use aggregate, anonymous and de-identified data to assess, improve and develop our business, products and Services, and for similar research and analytics purposes. This information is not generally subject to the restrictions in this Policy, provided it does not identify and could not be used to identify a particular individual.We may share aggregate, anonymous or de-identified data with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

Disclosures of Personal Information

In general, we disclose the Personal Information we collect for the business and commercial purposes explained below:

  • Enterprise users: if you use, access or communicate with us about our Platform or related services on behalf of your company (our Client), we may share Personal Information about your access, and your communications or requests, with the relevant enterprise Client.
  • Service providers: third party service providers who perform functions on our behalf. Third party service providers will only process your Personal Information in accordance with our instructions and will implement adequate security measures to protect your personal information.
  • Advertising and analytics partners: to third parties we engage to provide advertising, campaign measurement, online and mobile analytics, and related services to us (with your consent, where required by applicable laws). In response to legal process: in order to comply with the law, judicial proceedings, a court order, or other legal process, such as in response to a subpoena.
  • To protect our rights: where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of the SOCIAL27 Terms of use Policy or this Privacy Policy, to respond to claims asserted against us or, or as evidence in litigation in which we are involved.
  • Business transfers: as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event, including related to due diligence conducted prior to such event where permitted by law.

Cookies and Similar Devices

We and our third-party service providers use “cookies,” pixels, java script, log files, and other mechanisms on the Site. For more detailed information about the use of cookies on the Site and how you can manage your cookie preferences, you can review our Cookie Policy found here

Cookies

A “cookie” is a small text file that may be used, for example, to collect information about website activity. Some cookies allow us to make it easier for you to navigate the Site, while others are used to enable a faster log-in process or to allow us to track your activities while using the Site. Most browsers allow you to control cookies, including whether or not to accept them, and how to remove them. See our Cookie Policy or more information.

Clear GIFs, Pixel Tags and Other Technologies

Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our services to, among other things, track the user activities of our Services, help us manage content, and compile statistics about usage of our Services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Log Files

Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.

Third-Party Analytics

We also use automated devices and applications to evaluate use of our Services. We use these tools to gather non-personal information about users to help us improve our Site and services, as well as user experiences. These analytics providers may use cookies and other technologies to perform their services and may combine the information they collect about you on the Site with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties.

Do-Not-Track Signals

The Site does not respond to do-not-track signals. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies) and set out in our Cookie Policy.

International Transfers

SOCIAL27 is headquartered in the United States and has operations and service providers in the United States and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions (including but not limited to the United States, and the European Union (“EU”)), that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.

If you are in the European Economic Area (“EEA”), and we process your Personal Information in a jurisdiction that the European Commission has deemed to not provide an adequate level of data protection (a “third country”), we will implement measures to adequately protect your Personal Information, such as putting in place standard contractual clauses approved by the European Commission or another measure that has been approved by the EU Commission as adducing adequate safeguards for the protection of Personal Information when transferred to a third country. You have a right to obtain details of the mechanism under which your Personal Information is transferred outside of the EEA; you may request such details by contacting us as set forth in the Contact Us section below.

Protection of Children’s Personal Information

SOCIAL27 does not publish content that is targeted at children. The Site is not intended for minors under the age 13. We do not knowingly or specifically collect information about minors under the age of 13. If you believe we have unintentionally collected such information, please notify us as set out in the Contact Us section below.Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.

Security

Wherever your Personal Information may be held within SOCIAL27 or on its behalf, we take reasonable steps to protect the Personal Information that you share with us from unauthorized access or disclosure, including, without limitation, restricting access to certain portions of our Site through access controls, and using firewalls. Regardless of the precautions taken by us, SOCIAL27 cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk. You are responsible for all actions taken with your User ID and password, if any. Therefore, we recommend that you do not disclose your password to anyone. If you lose control of your password, you may lose substantial control over your Personal Information and may be subject to legally binding actions taken on your behalf.

Your Choices and Rights Access, Amend, and Correct

If you wish to access Personal Information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, or to request deletion of your information, please send your request to privacy@Social27.com. We will review your request and make reasonable efforts to respond to it as soon as practicable. We may ask you for additional information so that we can confirm your identity.

Direct Marketing

You may always opt-out of direct marketing emails. If you would like to unsubscribe from SOCIAL27 email subscriptions or otherwise change your email preferences with SOCIAL27, please click [Put your link Here] or follow the instructions in any SOCIAL27 promotional email that we send to you. We may continue to send you transactional or service-related communications, such as service announcements and administrative messages.

Complaints

We will take steps to try to resolve any complaint you raise regarding our treatment of your Personal Information. You also have the right to raise a complaint with the privacy regulator in your jurisdiction. Expected response time for privacy inquiries and requests is upto 30 days

Additional Information for Certain Jurisdictions

In the section “Additional Information for Individuals in California and Europe” below, we provide additional information as required under California privacy laws, as well as the GDPR. Users in California and the EEA should review this section for more information regarding their rights under these respective laws.

Retention

As a general rule, we retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. In general, for example, we will retain relevant contact information of Clients, prospective Clients and Site visitors for three years from the date of our last interaction with you and in compliance with our obligations under applicable laws. Our Clients instruct us on how long to retain Platform Data, which we handle as a data processor. We may retain Personal Information for longer where required by our regulatory obligations, professional indemnity obligations, or where we believe necessary to establish, defend, or protect our legal rights and interests or those of others.

Classification of Data Categories, Types and Sensitivities:

For the Social27 Events Platform:

  1. S1 (Most Sensitive) Data Elements includes Passwords, Credit Card Info (Always stored in Encrypted / Masked form).
  2. S2 (Medium Sensitive) Data Elements includes Name, Contact Information, Address, Postal Code, City, Region, Country Photo, Email, Event Ticket Price, Job Title & Company.
  3. S3 (Less Sensitive) Data Elements includes User activity like Introduction Video, Browser Information, Latitude/Longitude Information, Any Comments or Reaction on Post, Any Reviews or Rating Provided on Sessions or Post, Gamification Badges/ points Earned, Page/Session/Booth Visits Data.

Changes to the Policy

SOCIAL27 may update this Policy to reflect new or different privacy practices or to reflect changes in industry standards or legal requirements. Revisions will be posted on our Site. This statement of privacy is for the information of our users and does not constitute a contract or modification of any contract. When changes are made to this Privacy Policy, SOCIAL27 will post a new version of this Privacy Policy . If the changes will materially affect the way we use or disclose your Personal Information, we will endeavor to notify you in advance of the change, such as by sending a notice to the primary email address associated with your account or by posting a notice on the Site. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.

Others

The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly affects him or her.Right not to be subject to automated decision-making: You have the right not to be subject to a decision when it is based on automatic processing if it produces a legal effect or similarly significantly affects you, unless it is necessary for entering into or performing a contract between us. Data subjects can request more information on an automated decision by writing an email to privacy@social27.com

International transfers

International data transfers to and from the EU that have not been deemed to provide an adequate level of data protection by the European Commission are protected through standard contractual clauses or other approved transfer mechanisms. Internally, Social 27 has implemented standard contractual clauses between each of its legal entities to ensure that all data transfers within the company are conducted pursuant to a legally sufficient transfer mechanism including encrypted email through GDPR compliant partner entities like Microsoft Outlook.

Right to Access

It is understood that in order to comply with this right to access Social 27 must provide the individual requesting access to their data, both confirmation that their data is being processed and access to their personal data.Data subjects can request more information on an automated decision by writing an email to privacy@social27.com

Contact Us

SOCIAL27 welcomes your comments regarding this Privacy Policy.

Please feel free to contact us at:

Social27 Inc.

Data Protection Officer: Bally S. Kehal

Data Controller: Dalvir Singh

Data Processors: Ranbeer Gill, Govind Singh

2733, 152 ND AVE NE Redmond, WA, 98052

Phone:1.800.720.4851

Email: privacy@social27.com

EU Representative

Individuals in the EU may also contact us through our office at:

Klimentská 46

Prague 1 110 02

Czech Republic

Additional Information for Individuals in California and Europe

California Residents

In this section, we provide additional information for California residents about how we handle their Personal Information, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.

Categories of Personal Information Under the CCPA

While our collection, use and disclosure of Personal Information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed Personal Information about consumers in the prior 12 months.

Categories of Personal Information Collected and Disclosed

The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the Purposes and Legal Bases and the Disclosures of Personal Information sections above.

Do We “Sell” Personal Information?

Under the CCPA, a “sale” includes disclosing or making available Personal Information to a third-party in exchange for monetary compensation or other benefits or value. We do not disclose Personal Information to third parties in exchange for monetary compensation.

Sources of Personal Information

As further described in the “Information We Collect” section above, we may collect Personal Information from the following sources:

  • enterprise customers
  • Directly from the individual
  • Advertising networks
  • Data analytics providers
  • Social networks
  • Internet service providers
  • Operating systems and platforms
  • Publicly available sources

California Residents’ Rights: CCPA Rights

In general, California residents have the following rights with respect to their personal information:

  • Do-not-sell (opt-out): to opt-out of our sale of their personal information. While we may “sell” personal information as defined by the CCPA, we do not sell personal information about California consumers who we know are younger than 16 years old. California residents may opt out of sales of their personal information by us, by contacting Social27 using the contact information in the Contact Us section. Right of deletion: to request deletion of their Personal Information that we have collected about them and to have such Personal Information deleted (without charge), subject to certain exceptions.
  • Right to know: with respect to the Personal Information we have collected about them in the prior 12 months, to require that we disclose the following to them (up to twice per year and subject to certain exemptions):
  • categories of Personal Information collected;
  • categories of sources of Personal Information;
  • categories of Personal Information about them we have disclosed for a business purpose or sold;
  • categories of third parties to whom we have sold or disclosed for a business purpose their Personal Information;
  • the business or commercial purposes for collecting or selling their Personal Information;
  • and a copy of the specific pieces of Personal Information we have collected about them.
  • Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising their rights under the CCPA.

Submitting Verifiable Requests

Requests to Know and Requests to Delete may be submitted: By email at privacy@Social27.com When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must complete all required fields on our webform (or otherwise provide us with this information via the above toll-free number) and verify your email address. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us as set forth in the Contact Us section above; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.For more information about our privacy practices, you may contact us as set forth in the Contact Us section above.

Individuals in the European Union / European Economic Area

Below, we inform about other rights, including the GDPR and similar applicable laws, that may apply to you. Subject to the conditions set out in the applicable law, individuals in in the EU/EEA have the following rights with regards to our processing of their personal information:

  • Right of access: You can ask us to: confirm whether we are processing your Personal Information; give you a copy of that information; provide you with other information about your Personal Information such as what data we have, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your information from and whether we have carried out any profiling, to the extent that such information has not already been provided to you in this Policy.
  • Right to rectify and complete Personal Information: You can ask us to rectify inaccurate information. We may seek to verify the accuracy of the Personal Information before rectifying it.
  • Right of erasure: You can ask us to erase your Personal Information, but only where it is no longer needed for the purposes for which it was collected; you have withdrawn your consent (where the data processing was based on consent); following a successful right to object (see ‘Objection’ below); it has been processed unlawfully; or to comply with a legal obligation to which we are subject. We are not required to comply with your request to erase your Personal Information if the processing of your Personal Information is necessary: for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims. There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request.
  • Right of restriction: You can ask us to restrict your Personal Information, but only where: its accuracy is contested, to allow us to verify its accuracy; the processing is unlawful, but you do not want it erased; it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; you have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your personal information following a request for restriction, where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
  • Right to object to our use of your Personal Information for direct marketing purposes: You can request that we change the manner in which we contact you for marketing purposes. You can request that we not transfer your Personal Information to unaffiliated third parties for the purposes of direct marketing or any other purposes.
  • Right to object for other purposes: You have the right to object at any time to any processing of your Personal Information which has our legitimate interests as its legal basis. You may exercise this right without incurring any costs. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms. The right to object does not exist, in particular, if the processing of your personal information is necessary to take steps prior to entering into a contract or to perform a contract already concluded.
  • Right not to be subject to automated decision-making: You have the right not to be subject to a decision when it is based on automatic processing if it produces a legal effect or similarly significantly affects you, unless it is necessary for entering into or performing a contract between us.
  • Right to (data) portability: You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another data controller, but only where our processing is based on your consent and the processing is carried out by automated means.
  • Right to withdraw consent: You can withdraw your consent in respect of any processing of Personal Information which is based upon a consent which you have previously provided.
  • Right to obtain a copy of safeguards: You can ask to obtain a copy of, or reference to, the safeguards under which your Personal Information is transferred outside the EU/EEA. We may redact data transfer agreements to protect commercial terms.
  • Right to lodge a complaint with your local supervisory authority: You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issue with us first, although you have a right to contact your supervisory authority at any time.

Submitting a GDPR

Please contact us as set out in the Contact Us section above to exercise one of these rights. If we receive any requests from individuals related to the Platform Data, we will forward the request to the relevant Clients to address.

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Platform Privacy Policy

Last updated: September 13, 2020

SOCIAL27 Privacy Policy- Platform Controller

Social27, Inc. (“SOCIAL27,” “we”, “us”, or “our”) understands the importance of privacy. This Platform Privacy Policy (this “Policy”) explains how SOCIAL27 collects, stores, uses and shares personal information collected, stored or processed by us through SOCIAL27’s video conferencing and communication services (the “Services”), which includes services related to our webinars, virtual environments, and portals (collectively, the “Platform”). In this Policy, “personal information” is information that identifies or could be used to identify an individual (“Personal Information”) and is also referred to as “personal data” in our Data Controller Privacy Policy.

The SOCIAL27 Platform is a video conferencing and communication tool used by businesses, including direct clients of SOCIAL27 and their employees and agents authorized to access the Platform as administrators and that host or organize the Platform events (collectively the “Client/s”) to deliver webinars and other content to registrants, attendees, participants, and other end users that access the Site (the “End Users”, or “Event Attendees”). Collectively, End Users and Clients are “Platform Users”. The End User may have entered a Subscription Services Agreement or other agreement with Client containing separate terms and conditions that govern delivery, access and use of the Platform by the End User (a “Client Agreement”).Social27 Inc. (“we”, “us”, “our” or “Social27”) collects your personal data (the “Data”) directly from you (“you”, “your” or the “End User”), through our mobile and web applications (the “Platform”). This Privacy Policy explains how we collect, use, and disclose your information. All capitalized terms not otherwise defined in this Privacy Policy shall have the same definitions ascribed to them in the Terms and Conditions.

Scope

This Policy applies to the Personal Information that SOCIAL27’s Clients submit to us via the Platform, as well as the Personal Information we collect, access, store, use or otherwise process (collectively, “process”) via the Platform on behalf of Clients, including but not limited to registration information and Platform User communications, as well as other Personal Information we process from End Users of the Platform (together the “Platform Data”).

Controller and Responsible Entity

With respect to the Platform Data, SOCIAL27 is a “data processor” or “service provider” under applicable data protections laws. As a data processor or service provider, we will only process the Platform Data pursuant to our Client’s instructions, as set forth in our applicable client agreements, and as otherwise required by applicable privacy and data protection laws. This Policy does not apply to processing of Platform Data or any other Personal Information collected via the Platform by Clients, which is subject to the Clients’ own policies and practices.For more information about how SOCIAL27 processes Personal Information as a controller, please see the SOCIAL27 online Data Controller Privacy Policy.If you are invited to, register for, check into, or receive information regarding a Client event through our Site or Service, you will be considered an “Event Attendee” and we will provide any Personal Information you submit through our Site or Service to the Client organizing that event. Social27 does not control the Client’s event registration or management process, or the Personal Information that a Client requests from Event Attendees.When we collect information from you, we may be doing so on our own behalf (in which case we will be considered a “controller” of your data, subject to the Social27 Data Controller Privacy Policy), or on behalf of a Client who is using the Services to organize an event and manage other event-related activities (in which case, the Client will be the “controller” and SOCIAL27 will be considered a “processor” of your data).

Data Collected

If you choose to store any Sensitive Personal Information on our servers, you are responsible for complying with any regulatory controls regarding that data.We do not encourage end users to share any personal information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (for the purpose of uniquely identifying a natural person), data concerning health, or data concerning a natural person's sex life or sexual orientation. Sharing of personal data may be a threat and end users are responsible for sharing this type of information.

If you are a child under the age of 13, you may not have an Account on Social27. Social27 does not knowingly collect information from or direct any of our content specifically to children under 13. If we learn or have reason to suspect that you are a User who is under the age of 13, we will have to close your Account.

Information Collected Directly

Account Information

To access various parts of the Platform, and to create webinars and events, you must have an online account. To register for an account on the Platform, you must provide your name, email address, telephone number, company name, and other information necessary to confirm that you are an authorized user of Client (where relevant). We may also collect additional information such as job title, information about your company (such as country and industry sector) and other End User profile information such as age, gender, zip code, and areas of special interest to you. Our processing of account information is subject to the SOCIAL27 Data Controller Privacy Policy.

End User Information

To access webinars, virtual environments and other events administered by Clients via the Platform as an End User, you may be required to register. While our Clients determine what information to collect from End Users, the requested Personal Information typically includes name, email address, telephone number, company name and job title as well as information about your company such as country and industry sector.

User Communications

When you send email or other communication to SOCIAL27 or another user, we may retain those communications in order to process your inquiries, respond to your requests and to improve our Services.

Affiliated Sites

We may offer services in connection with other websites or suppliers. Personal information that you provide to those sites may be sent to us in order to deliver these services. We process such information in accordance with this Policy.

Other Information

SOCIAL27’s Clients may request additional information, like surveys or polls, be filled out in some webinars or virtual environments. Clients are responsible for configuring the Platform to collect this information, which may include Personal Information.

Information Collected Automatically

Log Information

When you use SOCIAL27, our servers record, in a server log, information that your browser sends whenever you visit a website. Server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.

Cookies, clear GIFs, etc

The Platform may use cookies (small pieces of information that are stored by your browser on your computer’s hard drive), clear GIFs, java script and other technology to collect and store information about your use of the Platform, such as your search activity, the pages you view, and the date and time of your visit, your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, location information, and requested and referring URLs. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information. Please see our Cookie Policy for more information.

Aggregate and De-Identified Information

SOCIAL27 may process (i.e., collect, use and disclose) aggregate de-identified information, and other information that is not personally identifiable, for research, analytics and other purposes, provided such information does not identify, and could not reasonably be used to identify a particular Client or End User.

Use of Information

Social27 may use your Personal Information:

  • To respond to your inquiries and fulfill your requests, and to provide you with customer support when you ask for it.
  • To send you updates, and other content that you have requested or subscribed to, as well as informational materials regarding our Services.
  • To provide you with technical and administrative information relating to our Sites and Services, such as security notices, Service-related status reports, and changes to our policies or Terms of Use. Please note that these communications are considered part of our Services and you may not opt out of them.
  • If you have consented, and it is in compliance with applicable laws, we may send you marketing communications regarding products and Services that we believe may be of interest to you. If you later decide that you no longer want to receive this type of marketing or promotional information, you may opt-out at any time by clicking the “Unsubscribe” button at the bottom of the marketing communication or contacting us at the email or mailing address provided in the “Contact Information” section of this Privacy Policy.
  • To personalize your experience on the Sites by offering content tailored to your preferences.
  • For our internal business purposes that include administering your access and use of any Services, data analysis, securely identifying you when you log onto a Service, fraud monitoring and prevention, enhancing or modifying our Sites and Services, determining the effectiveness of our promotional campaigns, billing you for Services, and operating our business.
  • As necessary for us to comply with applicable law.

SOCIAL27 uses the personal information we collect via the Platform to provide our services to Clients, including to operate and improve the Platform and our services, to provision Platform Users’ accounts, to carry out the transactions Platform Users request via the Platform, and to respond to Platform User requests. We do not encourage data subject below 18 years of age to register on our platform.

Clients may use the Personal Information they collect via the Platform for additional purposes, such as to deliver targeted content within the Platform, to contact Platform Users about their use of the Platform, for marketing and promotional purposes, and for other purpose; you should review the Clients’ privacy policies for more information about how they collect, use and share the Personal Information collected via the Platform.

Sharing of Information: Onward Transfers

As noted, Platform User information, including Personal Information, is shared with the Client upon whose behalf the information was collected or Platform is being operated; this Policy does not apply to the processing (including collection, use and sharing) of Platform User personal information by Clients, and we are not responsible for such processing.

Sharing of End User Information with Third Parties

SOCIAL27 will not share Personal Information about Platform Users with third parties except to provide the products or services you have requested, with consent, or under the following circumstances:

  1. Aggregated Data: We may share aggregated, non-personally identifying information, log data and usage statistics with third parties for purposes including demographic, industry and marketing analysis.
  2. Service Providers: Social27 may use third-party contractors to provide certain services and perform functions on our behalf. Examples include providing cloud-hosting capabilities, offering chat-bot functionality, processing credit card payments, providing marketing assistance, and performing statistical analysis relating to usage of our Sites and Services. We may provide your Personal Information only to the extent necessary for such third party service provider to perform the duties for which it has been retained by Social27. Any such third parties will be bound to strict confidentiality and use obligations with respect to your Personal Information, which are no less protective than those set out in this Privacy Policy.
  3. Clients: If you are accessing any Site or Service as an administrator or authorized user of a Client, or as an Event Attendee for an event organized by a Client, Social27 is permitted to provide the Client with your information, including but not limited to your Personal Information, access information and usage data.
  4. Legal and Contractual Compliance Social27 may disclose your information to government or law enforcement officials, regulatory agencies or other third parties (such as attorneys or regulatory service providers), as necessary to (i) comply with applicable laws or regulations, (ii) cooperate with governmental or law enforcement investigations, (iii) respond to legal claims or processes, (iv) protect the safety and legal rights of the public or any individual, (v) detect, prevent or remedy any suspected fraud, market manipulation or illegal, tortious or wrongful activity; or (vi) enforce applicable Client Agreements or other Social27 contracts to which you have agreed. However, this does not include selling, renting or sharing or otherwise disclosing Personal Information for commercial purposes in a way that is contrary to the commitments made in this Privacy Policy.
  5. Business Transfers If Social27 is acquired by, acquires or is merged with another company, Social27 may transfer Personal and non-personal Information about you to such company. However, in the event of such a transfer, your information will remain subject to the protections of this Privacy Policy. Social27 will notify you if your Personal Information is subject to a business transfer and becomes subject to the acquiring company’s privacy policy.
  6. Third Party Websites and External Links Our Sites may contain links to websites (including social media sites) owned and operated by third parties. When you click on such links, you may leave our Website and be directed to the third parties’ websites. These websites may themselves collect Personal Information about you. If you submit information to any of those sites, your information is governed by their privacy policies, which may differ from those of Social27. Social27 is not, and will not be, responsible for the privacy practices or security of any such websites, and we urge you to read their privacy policies carefully.

Third parties who process Personal Information on our behalf must agree to use such personal information only for the purpose for which it is provided by us and they must contractually agree to provide adequate protections for personal information; SOCIAL27 will continue to be liable for any onward transfers of Personal Information to such third parties.

How Long Personal Information is Maintained

We will only retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and processed, or until you request deletion as described in this Policy. SOCIAL27 will retain Personal Information we collect from our Clients or Event Attendees, and process on behalf of a Client, for as long as necessary to provide our Services to the Client, and will maintain any such information controlled by a Client in accordance with the Client’s instructions, including any applicable Client Agreement terms, and as required by applicable law.We will also retain and use Personal Information for a period of time required to comply with our legal, tax, audit or regulatory obligations, to resolve disputes, and to enforce our agreements. SOCIAL27 may retain non-Personal Information for as long as necessary for the purposes and uses described in this Privacy Policy, including as necessary for SOCIAL27 to pursue legitimate and lawful business interests.

Accessing, Amending, and Limiting Use of Your Personal Information

End Users have the right to access the Personal Information that is maintained about them, and in some cases to limit use and disclosure of such information. Registered End Users may log into their accounts to view and amend certain personal information in their profile. EU End Users who would like to request access to, to limit use of, or to limit disclosure of their Personal Information collected via the Platform by a Client should contact that Client directly; EU End Users may also make such requests by contacting us at privacy@Social27.com and providing the name of the Client. We will refer such requests to that Client and will support them as needed in responding to your request.

Security

SOCIAL27 makes it a priority to safeguard the security and privacy of your Personal Information.These measures include security controls to prevent unauthorized access to our facilities and systems, strong authentication procedures and strict password protection protocols.While we take reasonable steps to protect your Personal Information, should you have any questions about security on our Sites, you can contact us using the information in the Contact Us section below.

To secure your personal information access to your data is password protected, and sensitive information is protected by encryption when it is exchanged between your Web browser and our Web site. It is your responsibility to keep your password confidential and not to share this information with anyone. While we will implement the security measures detailed above, transmission of information via the internet is not completely secure and therefore transmission via the internet is at your own risk.

Complaints and Disputes

Your privacy is important to us. End Users who have any questions, complaints, or disputes regarding this Policy or the manner in which SOCIAL27 handles or protects Personal Information may contact us at privacy@social27.com We will promptly investigate and attempt to resolve any complaints and disputes and will respond within 45 days of receiving any such complaint. We take complaints seriously, and it will be assessed by qualified staff with the goal of resolving it in a timely manner. Subject to applicable law, you also have the right to lodge a complaint with your local data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.

Changes

SOCIAL27 may update this Policy from time-to-time, so please review it frequently. In the event we make material changes in the way we treat End User Personal Information, we will notify you by email.

Contact us

Please contact us with any questions about this Policy:

Social27 Inc.

Data Protection Officer: Bally S. Kehal

Data Controller: Dalvir Singh

Data Processors: Govind Singh

2733, 152 ND AVE NE Redmond, WA, 98052

Phone:1.800.720.4851

Email: privacy@social27.com

EU Representative

Individuals in the EU may also contact us through our office at:

Klimentská 46

Prague 1 110 02

Czech Republic