Last updated: September 13, 2020
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
Please see the SOCIAL27 Platform Privacy for information about our
processing of Platform Data. As set out in the SOCIAL27 Platform
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
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
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
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
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 Information”
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
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
Contact preferences and interests
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
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
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
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
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
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
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.
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: to 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
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
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.
Aggregate, De-identified or Anonymous data.
Aggregate, De-identified or Anonymous data. 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
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
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
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.
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)
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 16. We do not knowingly or specifically collect
information about minors under the age of 16. If you believe we have unintentionally
collected such information, please notify us as set out in the Contact Us section
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 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.
Additional Information for Certain Jurisdictions. In the section “Additional
Information for Individuals in Certain Jurisdictions” 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.
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
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
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
information on our privacy practices.
contact us at:
Attn: Ike Kehal
2733, 152 ND AVE NE
Redmond, WA, 98052
EU Representative. Individuals in the EU may also contact us through our office
Prague 1 110 02
Additional Information for Individuals in California
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
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
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
Our enterprise customers
Directly from the individual
Data analytics providers
Internet service providers
Operating systems and platforms
Publicly available sources
B. 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
a copy of the specific pieces of Personal Information we have collected about
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
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
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
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
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
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
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
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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Create and share interactive reports, presentations, personal stories, and more.
Social27, Inc. (“SOCIAL27,” “we”, “us”, or “our”) understands the importance of
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
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
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”). 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
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
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
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
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
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.
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
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,
communications are considered part of our Services and you may not opt out
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
To personalize your experience on the Sites by offering content tailored to
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.
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:
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.
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
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.
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
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
to a business transfer and becomes subject to the acquiring company’s
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 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
SOCIAL27 to pursue legitimate and lawful business interests.
ACCESSING, AMENDING AND LIMITING USE OF YOUR PERSONAL
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.
SOCIAL27 makes it a priority to safeguard the security and privacy of your Personal
These measures include security controls to prevent unauthorized access to our
facilities and systems, strong authentication procedures and strict password
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 email@example.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
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.
Please contact us with any questions about this Policy:
Attn: Ike Kehal
2733, 152 ND AVE NE
Redmond, WA, 98052
EU Representative. Individuals in the EU may also contact us through our office at:
Prague 1 110 02
VeraSafe has been appointed as Social27's representative in the European Union for data protection matters,
pursuant to Article 27 of the General Data Protection Regulation of the European Union.
If you are in the European Economic Area, VeraSafe can be contacted in addition to firstname.lastname@example.org,
only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this
or via telephone at: +420 228 881 031.
Alternatively, VeraSafe can be contacted at: VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road