Privacy Notice

Last updated: December 1, 2023

This Privacy Notice (“Notice”) describes how SOCi, Inc. and its subsidiaries and affiliates (“SOCi”, “we,” “our,” or “us”) use, disclose, and protect the Personal Data collected:

• through our website, www.soci.ai/, and any other website where this Notice is posted or linked and any services available through such websites (the “Website”);
• in connection with the delivery of our products and services to our customers;
• in connection with our business development and marketing activities; and
• through our other offline and business interactions (collectively, the “Services”).

In this Notice, “Personal Data” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual.

Please note that this Notice does not apply to Personal Data that our customers provide or otherwise make available to us for processing on their behalf in connection with the delivery of our products and services to them (“Customer Personal Data”). Our processing of Customer Personal Data is governed by our customers’ privacy notices.

If you are a SOCi customer, you may access our Privacy Addendum here.

California Notice at Collection

We collect the categories of personal information (as defined in the California Consumer Privacy Act (CCPA)) listed in the table below.

As further described in the “How We Use Personal Data” section below, we generally collect and use the above-listed categories of personal information to provide and manage the Services and achieve legitimate business or commercial purposes.

As noted in the table above, we “sell” or “share” (as these terms are defined in the CCPA) certain categories of personal information, and you may exercise your right to opt out of such disclosures by completing and submitting the form available here.

We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described in this Notice, including to satisfy legal or reporting requirements.

More information, including a description of your legal rights, can be found below in the “California Privacy Rights” section.

1. Personal Data We Collect

We may collect Personal Data about you from various sources, as described below.

Data Provided by You

• Account Information. If you create an account to use the Services, we collect Personal Data related to its creation and the usage of the Services via this account. When you sign up, you may provide us with your name, email address, account password, mobile phone number, interests, and other account information.
• Communications. When you contact us via a contact form, email, or other means, you provide us with Personal Data, such as your name; contact details; and the content, date, and time of our communications.
• Support Information. When you request technical support services, we will collect Personal Data that you make available, such as your name and the contact details you use to contact us, as well as information on the reasons for your support request, and any additional information you may provide in that context.

Where applicable, we may indicate whether and why you must provide us with your Personal Data as well as the consequences of failing to do so. For example, it may be necessary for you to disclose certain Personal Data in order for us to provide the Services to you.

Please note that if you post in a public space on the Website, we may collect the Personal Data that you post. If you choose to share your Personal Data publicly, please understand that we cannot control the actions of third parties who also may have access to or collect this data. Please exercise caution when disclosing Personal Data in these public areas.

Data We Collect by Automated Means

When you visit and interact with the Website, we (and our service providers and partners) may use cookies and other similar technologies to collect certain data automatically. The specific types of data we (and our service providers and partners) may collect include:

• Computer or device information, which includes the Internet Protocol (IP) address and/or other unique identifier(s) assigned to your device, the location of your device, and other information about your browser, device, and operating system.
• Usage information, which includes information about your interaction with the Website (e.g., the date and time of your visit(s); the areas or pages that you visit; the amount of time you spend viewing or using the Website; the domain name from which you accessed the Website, and other click-stream or site usage data).

We (and our service providers and partners) may also use cookies or other similar technologies to collect data about the actions that you take upon receipt of an email from us.

We also use third-party analytics and tracking tools to better understand who is using the Website, how people are using the Website, and how to improve the effectiveness of the Website and related content. We may also use these tools to help us or our third-party partners serve interest-based advertisements to you across the Internet. These tools may include cookies, pixel tags, or similar technologies that automatically collect and store certain Personal Data about your interaction with the Website. Our third-party partners and providers may combine data collected from your interaction(s) with the Website with data they collect from other sources. To learn more about your interest-based advertising choices, please see the “Your Choices and Legal Rights” section below.

Please note that we use Google Analytics to better understand how users interact with the Website. For information on Google Analytics’ data handling practices and how you can control the use of data sent to Google, please visit https://policies.google.com/technologies/partner-sites. If you wish to prevent your data from being used by Google Analytics, Google has developed the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout.

You may be able to adjust your device or browser settings to limit certain tracking or to decline cookies. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete cookies and/or disable your device or browser from receiving cookies or adjust your tracking preferences.

To learn more about cookies, including how to manage them, please visit https://allaboutcookies.org/.

Data Collected from Other Sources

We may obtain Personal Data about you from third parties, such as our affiliates, data brokers, our business partners, our customers, social media platforms, and other entities.

We use the Personal Data we receive from other sources to provide the Services and fulfill the purposes described in this Notice.

Combination of Data

We may combine the Personal Data that we collect from and about you, including data you provide to us, data we automatically collect through the Website, and data we receive from third-party sources, and use the combined data for the purposes described in this Notice.
2. How We Use Personal Data

We use the Personal Data we collect for the following purposes:

• Providing the Services, including to operate, maintain, support, and provide the Services.
• Communicating with You, including to contact you for administrative purposes (e.g., to provide services and information that you request or to respond to your comments and questions) or to send you important updates and communications about this Notice and/or other applicable terms and conditions.
• Sending You Marketing and Promotional Communications, including messages about promotions, events, products, or services that we think may interest you. Details on how to exercise your choices with respect to marketing and promotional communications from us can be found in the “Your Choices and Legal Rights” section below.
• Personalizing the Services, including to tailor the content we may send or display to you and otherwise personalize your experience with us.
• Engaging in Interest-Based Advertising, including to serve you interest-based advertising on the Website or on other online services across the devices you may use. Details on how to exercise your choices with respect to interest-based advertising can be found in the “Your Choices and Legal Rights” section below.
• Conducting Analytics and Developing Products, including to analyze usage trends and preferences in order to improve the Services and to develop new products, services, and features.
• Maintaining Security and Preventing Fraud, including to monitor and maintain the security of our systems and networks and to detect, prevent, investigate, and protect you, our business, and others from fraud, unauthorized transactions, and other unlawful or unsafe activity.
• Satisfying Our Legal Obligations, including complying with applicable law and responding to lawful requests and communications from law enforcement authorities and other government officials.
• Supporting Our Business Operations and Business Transactions, including to administer our general business and other related functions and to carry out sales or other business transactions.

We will also use your Personal Data as described to you at the point of data collection or with your consent. Additionally, we will use your Personal Data as we believe necessary or appropriate to protect our rights, privacy, safety, property, and/or those of others.

3. Grounds for Processing Personal Data

Applicable law in certain jurisdictions requires us to set out the “legal basis” that we rely on to collect and use your Personal Data. Where applicable, the legal bases upon which we rely to collect and use your Personal Data are as follows:

• Consent. We may collect, use, and disclose your Personal Data on the basis of the consent that you provide at the point of data collection or disclosure. Where required by law, we will rely on your consent for direct marketing and to collect data from your device via cookies and other similar technologies.
• Contractual Necessity. We may collect and use certain Personal Data where it is either necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. This may include Personal Data used to provide you with the Services.
• Compliance with a Legal Obligation. We are subject to various legal requirements in the jurisdictions in which we operate, including tax and accounting obligations. Accordingly, we may use, disclose, and retain your Personal Data if necessary for us to comply with a legal obligation arising under applicable law.
• Legitimate Interests. We may collect and use your Personal Data to the extent necessary to carry out our legitimate interests (or those of a third party), provided that such interests do not outweigh your interests or fundamental rights and freedoms. For example, we may collect and use your Personal Data in reliance on a legitimate interest in managing our relationship with you; conducting and managing our business; providing you with customer support; developing and enhancing the Services; detecting and preventing fraud and other harmful activities; and monitoring and maintaining the security of our data, systems, and networks.

4. How We Disclose Personal Data

We may disclose Personal Data to the following categories of recipients:

• Our Affiliates and Subsidiaries. We may disclose your Personal Data to our affiliates and subsidiaries for any of the purposes listed above.
• Our Service Providers. We engage third parties to provide services to us, such as website hosting, maintenance, and support and other services that help us operate our business and the Services. These third parties may have access to or process your Personal Data as part of providing their services to us.
• Our Analytics Providers. We disclose your Personal Data to parties that assist us in performing analytics and help us measure the effectiveness of the Services and our marketing and advertising efforts.
• Our Marketing and Advertising Partners. We disclose Personal Data to our marketing and advertising partners, including social media networks, third-party advertising networks, and other parties that assist us in serving and optimizing our advertisements.
• Governmental and Public Authorities. We will disclose your Personal Data to government and public authorities as necessary or permitted by the laws of any jurisdiction in which we operate.
• Relevant Third Parties in Connection with a Business Transaction. We may disclose or otherwise transfer your Personal Data to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction as well as in the event of any insolvency, bankruptcy, or receivership in which data is transferred to one or more third parties as one of our business assets.
• Other Parties. We will disclose your Personal Data to other parties as we believe necessary or appropriate either to: (i) comply with applicable law; (ii) protect our operations and those of our affiliates and subsidiaries; (iii) investigate and prevent against fraud; (iv) protect our rights, privacy, safety, property, and/or those of others; or (v) allow us to pursue available remedies or limit damages that we may sustain.

We may disclose your Personal Data for other reasons that we will describe at the time of data collection or prior to disclosing your data. Additionally, we will disclose your Personal Data when you consent or direct us to do so.

Please note that we may de-identify, anonymize, or aggregate Personal Data and disclose such information to third parties for various purposes as permitted by law.

5. Your Choices and Legal Rights

We respect your privacy and provide you with the ability to exercise control over our use of your Personal Data.

Your Choices

We provide you with the ability to make certain choices about how we use your Personal Data, as described below.

• Marketing and Promotional Communications: You can opt out of receiving marketing and promotional communications from us at any time by following the instructions included in any marketing or promotional communications that you receive from us. Please note that even if you opt out of receiving marketing and promotional communications from us, you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries/requests.
• Cookies: As noted above, we (and our third-party providers and partners) use cookies on the Website for various purposes, including for analytics and advertising purposes. To learn more about the cookies in use on the Website and adjust your cookie settings, you can click the “Cookie Settings” link in the footer of the Website.
• Interest-Based Advertising: You may be able to opt out of receiving interest-based advertising using the browser opt-out tools and consumer choice mechanisms provided by interest-based advertising self-regulatory groups by following the links below:
  • Digital Advertising Alliance (DAA): http://www.aboutads.info/choices
  • European Interactive Digital Advertising Alliance (EDAA): https://youronlinechoices.eu/
  • Network Advertising Alliance (NAI): http://www.networkadvertising.org/choices/

  Please note that you will need to opt out separately on all of your browsers and devices, as each opt-out will apply only to the specific browser or device from which you opt out. If you delete or reset your cookies, change browsers, or use a different device, any opt-out cookie may no longer work and you will have to opt out again.

  Some of our advertising partners may provide you with additional choices with respect to interest-based advertising. For example, certain social media platforms may allow you to control your advertising preferences directly through their services. Please review the privacy notices of the third-party services you use for more information.

Your Legal Rights

Depending on applicable law, you may have certain rights in relation to your Personal Data, including the right to:

• request confirmation as to whether we are processing your Personal Data, and if so, to request access to the Personal Data and details regarding our processing;
• request correction of inaccurate or incomplete Personal Data that we hold about you;
• request deletion of your Personal Data (subject to applicable exceptions);
• object to our processing of your Personal Data under certain circumstances;
• request that we restrict our processing of your Personal Data in certain circumstances;
• request that we transmit your Personal Data to a third party (where technically feasible);
• withdraw the consent you have provided us to process your Personal Data (without affecting the lawfulness of any processing carried out before you withdrew your consent); and
• lodge a complaint about the way we handle or process your Personal Data with the appropriate data protection regulator.

If you are interested in exercising any of the above-listed rights, you can do so by emailing us at [email protected], completing and submitting the form available here, or writing to us at the address included in the “Our Contact Information” section below.

In order to protect your privacy and confirm that you are entitled to exercise the above-listed rights, we may need to request specific information from you to help us confirm your identity. Where applicable, we will use the requested information for verification purposes only.

6. California Privacy Rights

The California Consumer Privacy Act (CCPA) provides California residents with certain rights in relation to their “personal information” (as defined in the CCPA). Pursuant to the CCPA, we are providing the following additional details regarding the categories of personal information that we collect, use, and disclose. This section also describes the rights available to you as a California resident in relation to your personal information and how you can exercise your rights.

Personal Information Collection and Disclosure

The following chart details which categories of personal information we have collected from and about California residents in the past twelve (12) months, the source(s) of each category of information, the categories of third parties to whom we have disclosed each category of information for a business purpose, and the categories of third parties to whom we have “sold” or with whom we have “shared” each category of information (as such terms are defined in the CCPA) (where applicable). Please note that the first column in the chart lists by category the types of information described in the “Personal Data We Collect” section above, as required by the CCPA.

Purposes for Collecting Personal Information

As described in more detail in the “How We Use Personal Data” section above, we collect personal information to provide and manage the Services and achieve a variety of legitimate business or commercial purposes.

Disclosures of Personal Information

As detailed in the “How We Disclose Personal Data” section above, we disclose personal information to fulfill the purposes described above. We will also disclose certain categories of personal information to competent governmental and public authorities and other third parties as necessary or appropriate, including when we have a legal or contractual obligation to disclose the information.

Sale and Sharing of Personal Information

We “sell” and “share” (as such terms are defined in the CCPA) certain categories of personal information to and with third parties. Additionally, as detailed in the chart above, we have “sold” and “shared” certain categories of personal information in the past twelve (12) months for analytics and advertising purposes. Please refer to the chart above for additional details.

We do not “sell” or “share” the personal information of minors we know to be under the age of 16.

Use and Disclosure of Sensitive Personal Information

As detailed in the chart above, we collect certain “sensitive personal information” (as defined in the CCPA). However, we do not use or disclose sensitive personal information for any purpose outside of the limited permissible purposes set forth in the regulations implementing the CCPA. These purposes include providing the Services and preventing, detecting, and investigating security incidents.

Your Legal Rights

You have the right to request that we:

• Disclose to you the following information covering the twelve (12) months preceding your request:
  • the categories of personal information we have collected about you and the categories of sources from which we collected such information;
  • the specific pieces of personal information we have collected about you;
  • the business or commercial purposes for collecting, selling, or sharing your personal information;
  • the categories of third parties to whom we disclosed such personal information; and
  • if we sold, shared, or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales and shares, identifying the personal information categories that each category of recipient received; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• Delete the personal information that we have collected from you, subject to certain exceptions.
• Correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing.

We will not discriminate against you if you decide to exercise your rights under the CCPA.

If you are interested in exercising any of the above-listed rights, you can do so by emailing us at [email protected], completing and submitting the form available here, or writing to us at the address included in the “Our Contact Information” section below.

To protect your privacy, we will require the matching of up to three pieces of personal information provided with your request with information we maintain to verify that it is you making the request. Where applicable, we will use the requested information for verification purposes only. Please note that we may decline a request where we are unable to verify your identity and confirm the personal information we maintain relates to you.

Authorized Agent

You may authorize someone to submit a privacy rights request on your behalf (an “authorized agent”). An authorized agent will need to demonstrate that you’ve authorized them to act on your behalf, unless you have provided the agent with power of attorney pursuant to applicable probate law. Depending on the evidence provided, we may also contact you to verify your identity with us or request confirmation from you that the agent is authorized to submit the request on your behalf.

Exercising Your Sale and Sharing Opt-Out Right

As detailed in the chart above, we “sell” and “share” certain categories of personal information to and with third parties. If you are 16 years of age or older, in addition to the rights described above, you have the right to direct us to not “sell” or “share” your personal information at any time. To exercise your opt-out right, you may submit a request to us by clicking the “Your Privacy Choices” link in the footer of the Website and completing and submitting the form. Additionally, if you would like to opt out of the “selling” or “sharing” of your personal information via the cookies present on the Website, you can click the “Cookie Settings” link in the footer of the Website and toggle the “Targeting Cookies” and/or “Functional Cookies” off.

Alternatively, where available, you can use certain preference signals to exercise your sale and sharing opt-out right automatically with all businesses that you interact with online, including SOCi. If you enable a browser-based opt-out preference signal that complies with the CCPA, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of personal information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each one that you use.

An authorized agent may also use the methods described above to submit a request to opt out on your behalf if you provide the agent with signed permission to do so. Please note that we may request from the agent documentation demonstrating that they have your authority to act on your behalf.

7. International Data Transfers

Depending on your country of residence, your Personal Data may be transferred to countries or regions with data protection and privacy laws that differ from those in your country of residence.

By using the Services, you acknowledge that your Personal Data may be transferred outside of your country of residence. You also understand that your Personal Data may be stored in the United States and may be subject to lawful requests by the courts or law enforcement authorities in the United States.

If you are situated in the European Economic Area, Switzerland, or the United Kingdom, please note that whenever we transfer your Personal Data to countries or regions that have not been recognized by the European Commission, the Swiss government, and/or the UK government as providing an adequate level of protection for Personal Data, we ensure that appropriate and suitable safeguards are in place to protect your data. In particular, we may use government-approved contracts that provide appropriate safeguards for Personal Data that is transferred to countries that have not been recognized as providing an adequate level of protection. For more information about how we lawfully transfer your Personal Data internationally, please contact us as specified below.

8. Data Privacy Framework (DPF)

SOCi complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. SOCi has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. SOCi has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, SOCi commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact SOCi at: [email protected].

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, SOCi commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Gibraltar Regulatory Authority (GRA) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. Individuals have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any of the other DPF mechanisms. See Annex I of the DPF Principles for additional information: https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

SOCi has responsibility for the processing of personal information it receives under the DPF Principles and subsequently transfers to a third party acting as an agent on its behalf. SOCi shall remain liable under the DPF Principles if its agent processes such personal information in a manner inconsistent with the DPF Principles, unless SOCi proves that it is not responsible for the event giving rise to the damage.

The Federal Trade Commission has jurisdiction over SOCi’s compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF). SOCi may disclose personal information in response to lawful requests by US public authorities, including to meet national security or law enforcement requirements.

9. Data Security and Data Retention

We use physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Data that we collect, maintain, and otherwise process.

We take measures to delete, de-identify, or anonymize your Personal Data when it is no longer necessary for the purposes for which we process it, unless we are required by law to keep it for a longer period. When determining the retention period, we take into account various criteria, such as the type of products or services provided to you, the nature and length of our relationship with you, mandatory retention periods, and applicable statutes of limitations.

If we de-identify data, we will maintain and use the data in de-identified form and not attempt to re-identify the data except as required or permitted by law.

10. Third-Party Services

The Website may contain features or links to websites and services provided by third parties, including social media widgets and plugins. Any data you provide to the owner or operator of another website or a third-party service is provided directly to the owner or operator and is subject to its privacy notice, even if accessed through the Website. We encourage you to learn about all third parties’ policies before providing them with your Personal Data.

11. Children’s Privacy

The Services are not intended for or directed to children under the age of 16, and we do not knowingly collect Personal Data from children under the age of 16.

12. Changes and Updates to this Notice

We may update this Notice from time to time to reflect changes in our privacy practices. The “Last updated” date at the top of this page indicates when this Notice was last revised. We will follow applicable laws and regulations regarding notification of changes to this Notice.

12. Our Contact Information

SOCi, Inc. is the entity responsible for the processing of your Personal Data. If you have any questions or comments about this Notice or our privacy practices, please contact us by email at [email protected] or by postal mail at:

SOCi, Inc.
350 10th Avenue, Suite 101
San Diego, CA 92101
United States

Our EU vDPO, Carl Gottlieb, Owner of Cognition, may be contacted at [email protected].