Privacy Notice

Last updated: May 16, 2022

1. OUR COMMITMENT TO PRIVACY

SOCi, Inc. and its affiliates and subsidiaries (“SOCi,” “Company,” “we,” “us,” “our” ) respect your (“you,” “your”) right to privacy. Our privacy policy (“Privacy Policy”) outlines who we are, how we collect, share and use information, how you can exercise your privacy rights, and how to contact us with any questions.

Our Privacy Policy applies to all visitors of www.soci.ai/ (the “Site”), users of the SOCi platform or services (“Service” or “Services”), your interaction with our social media sites, customer success team, communications with SOCi, and any participation in our sponsored events. For more information about the terms governing your use of our Services, please refer to our Terms of Service or refer to your signed agreement with us.

2. DEFINITIONS

For purposes of our Privacy Policy, the following definitions apply:

“Personal Data” means any information or set of information that directly or indirectly identifies or could be used by SOCi or its representatives to identify an individual, such as a name, address, location data, online identifier, one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual, and also includes information referred to as “personally identifiable information” or “Personal Information” under applicable data privacy laws, rules, or regulations.

“Aggregate Data” is de-identified information, learnings, logs, and data SOCi collects about a group or category of services or users.

Personal Data does not include Aggregate Data or publicly available information that has not been combined with non-public Personal Data.

Personal Information, as defined by the California Consumer Privacy Act (“CCPA”) does not include:

• Publicly available from government records;
• Deidentified or aggregate consumer information; or
• Otherwise excluded from the scope of the CCPA, such as:
  • Personal data covered by sector-specific privacy laws
  • Clinical trial or health or medical information covered by other acts

3. OUR SERVICES

SOCi is a U.S. based marketing technology company that provides a suite of localized marketing tools and services that are accessible via the Services. Our Services allow multi-location businesses and agencies to easily manage social media, publish localized business information and content, engage with your customers and visitors of your social media pages, and manage marketing events and ads through our centralized all-in-one platform.

As to the use of our Services, our customers are the controllers of the data they curate and/or upload to our Services, including content customers publicly publish via the Services and SOCi is the processor. More information about the SOCi Services is available at www.soci.ai/products/. As to the registration, login and use of SOCi’s Services, we are the controller of the Personal Data. The Personal Data we collect is further explained below.

4. INFORMATION WE COLLECT

Information Provided Directly from You

Account Information. If you create an account to use our Services, we collect Personal Data related to its creation and the usage of our Services via this account. When you sign up, you may provide us with your name, email address, 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 and contact details, and the content, date, and time of our communications.

Careers. If you apply for a job with us, you may provide us with your resume, name, contact details, and any other relevant information. If you become an employee, we collect additional information, such as your family information, beneficiary selections, banking information, and other relevant information for employment, payroll, and benefit purposes, and we may collect certain sensitive Personal Data such as trade union membership data or biometric data for identity verification.

Support Information. When you request technical support services, we will process your Personal Data 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.

Information Automatically Collected

Visiting our Site or Services. When you visit our Site or use our Service, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location, third party web pages accessed via the Service and other technical information. We may also collect information about how your device has interacted with our Site or Service.

Collecting this information enables us to better understand the visitors and/or customers who come to our Site or use our Services, where they come from, and what content and functionality is of interest to them. We use this information for our internal analytics purposes and to improve the quality of our Site and/or Services to our visitors and customers.

Social Media. We may collect Personal Data via social media tools, widgets, or plug-ins to connect you to your social media accounts. These features may allow you to sign in through your social media account, share a link, or post directly to your social media account. When you visit a website that contains such tools or plugins, the social media or other service provider may learn of your visit. Your interactions with these tools are governed by the privacy policies of the corresponding social media platform.

Cookies. We may collect Personal Data via cookies and similar technologies (see our Cookie Notice).

5. HOW WE USE YOUR INFORMATION

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

Providing Services: including to operate, maintain, support, and provide our 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 comments and questions) or to send you marketing communications, including updates on promotions and events, relating to products and services offered by us.

Personalization: including to customize our Services to you and provide you with the most relevant marketing and advertising materials.

Analytics and Product Development: including to analyze usage trends and preferences in order to improve our Services, and to develop new products, services, and features.

Customer and Vendor Relationship Management: including to track emails, phone calls, and other actions you have taken as our customer or vendor.

Aggregation: we may aggregate or anonymize Personal Data and use the resulting information for statistical analysis or other purposes.

Administrative and Legal: such as to address administrative issues or to defend our legal rights and to comply with our legal obligations and internal policies as permitted by law.

6. YOUR RIGHTS AND CHOICES REGARDING INFORMATION ABOUT YOU

As provided under applicable law and subject to any limitations in such law, you have the following rights:

Access and Portability. You may ask us to provide you with a copy of the Personal Data we maintain about you, including a machine-readable copy of the Personal Data that you have directly provided to us, and request certain information about its processing by submitting your request via our Privacy Request Form.

Rectification. You may ask us to update and correct inaccuracies in your Personal Data.

Deletion. You may ask to have your Personal Data anonymized or deleted, as appropriate, by submitting your request via our Privacy Request Form.

Restriction and Objection. You may ask us to restrict the processing of your Personal Data or object to such processing.

Consent Withdrawal. You may withdraw any consent you previously provided to us regarding the processing of your Personal Data at any time and free of charge. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdrew your consent.

Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.

You may exercise these rights by contacting us using the contact details at the end of this Policy. Note that applicable laws contain certain exceptions and limitations to each of these rights.

7. HOW WE DISCLOSE INFORMATION ABOUT YOU

We may disclose Personal Data about you in the following circumstances:

Group Entities. We may disclose Personal Data about you to our affiliates and subsidiaries.

Public Posts. Any information that you voluntarily choose to post to a publicly accessible area of our Services will be available to anyone who has access to that content.

Service Providers. We work with third parties to provide services such as hosting, maintenance, and support. These third parties may have access to or process your Personal Data as part of providing those services to us.

Legal. We may disclose your Personal Data if it is necessary (i) for compliance with our legal obligations or (ii) to establish, exercise, or defend legal claims.

Merger. Information about our users, including Personal Data, may be disclosed and otherwise transferred 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 an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets.

Aggregated Information. We may use and disclose aggregated or otherwise anonymized information for any purpose, unless we are prohibited from doing so under applicable law.

8. SECURITY AND DATA RETENTION

Our Security Standards

Our Site and Services implement and maintain various reasonable and appropriate administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. These security safeguards include, but are not limited to, network and host security controls, data encryption, and operating procedures that are designed to protect your information.

Password and Single Sign On

You should protect your user ID and password and NOT share it with anyone. We recommend enabling two-step verification or SSO integration when available. If you believe your user ID and password have been compromised or you have trouble changing your user ID/password on the Site or Service, please contact our technical support department ([email protected]). Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

Security and Privacy Training

SOCi maintains industry standard security safeguards to protect your information including appropriate security and privacy training and guidance for all SOCi employees.

How Long We Retain Your Information

We take measures to delete 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. Some examples of legitimate business purposes include: to provide the Services to you, comply with our legal and regulatory obligations, for tax or accounting purposes, to resolve disputes or to enforce the applicable Terms of Service or other agreement in place between you (or your organization) and SOCi, Inc.

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. When we have no ongoing legitimate business need to process your information, we will either delete or anonymise it in accordance with our data retention policy, or, in the limited circumstances where this is not possible (for example, because your information has been stored in backup archives), then we will securely store your information and isolate it from any further processing until deletion is possible.

9. THIRD-PARTY SERVICES

Our Services may contain features or links to websites and services provided by third parties. Any information you provide via these websites or services is provided directly to these third-party operators and is subject to their privacy policies, even if accessed through our Services. We encourage you to learn about these third parties’ policies before providing them with your Personal Data.

This Privacy Policy does not apply to information that you may provide to one of our customers, partners, and applications or services that SOCi does not own or maintain or to any entities that are integrated with the SOCi Application Programming Interface (‘API’). We are not responsible for the privacy practices of any third-party operator that you may link to from our website. Please contact any third-party directly to exercise your CCPA rights in relation to their services.

10. EEA AND UK VISITORS AND USERS OF OUR SERVICES

We may transfer your Personal Data outside of the country in which it was collected and where the level of protection of Personal Data may be different than in your country. Personal Data may be transferred to the United States, Switzerland, the United Kingdom, and countries in the European Economic Area (“EEA”). If we do so, we will comply with applicable data protection laws, in particular by relying on an EU Commission adequacy decision, on contractual protections for the transfer of your Personal Data, or on another approved derogation for a specific situation, such as your explicit consent. For more information about how we transfer Personal Data internationally, or to obtain a copy of the safeguards we use for such transfers, please contact us as specified in the “Contact Us” section below.

11. YOUR CALIFORNIA PRIVACY RIGHTS

Information for California Residents

This Privacy Notice for California residents is meant to supplement SOCi’s full Privacy Policy and only applies to visitors, users, and others who reside in the state of California (“Consumers”) from whom we collect personal information.

Personal Information that is collected within the context of a person acting as a job applicant to, employee of, owner of, director of, officer of, medical staff member of, and/or contractor of SOCi is excluded from this Policy as those individuals are not Consumers. Persons acting in those roles should review the applicable CCPA Limited Privacy Notice made available by SOCi.

This notice is in compliance with the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”). For the purposes of this CCPA Privacy Notice, any terms used in this notice have the same meaning as defined in the CCPA.

California Consumers’ Rights and Choices

The CCPA provides California consumers with specific rights regarding their personal information. This section describes your rights, as a consumer, and explains how you can exercise those rights in regards to the data collected about you during the previous 12-month period.

Exercising the Right to Know

Once we receive and confirm your verifiable consumer request, we can disclose to you:

• The categories of Personal Information (as defined by the CCPA) we have collected, sold or disclosed about you;
• The business and/or commercial purposes for collecting and/or selling the Personal Information collected by us;
• The categories of sources from which we collect Personal Information;
• The categories of third parties with whom we share Personal Information; and
• The specific pieces of Personal Information we have collected about you and in some cases your Household (Also called a data portability request).

Exercising the Right to Delete

You have the right to request that we delete the personal information we have collected about you up to two times per 12 month period. We will acknowledge your request within 10 days, and once verified, delete the relevant personal information within 45 days unless delayed by reasonable necessity.

Your request may be refused, and your Personal Information may be retained if it is necessary for us to retain it for one of the following reasons:

• Exercising or defending free speech and/or other legal rights
• Compliance with contractual obligations
• Compliance with the California Electronic Communications Privacy Act
• Compliance with legal obligations
• Security
• Debugging
• Conducting public interest research
• Usage restricted to internal, reasonable purposes

Exercising the Right to Opt-Out and Opt-In

You have the right to direct us not to sell your personal information at any time (the right to ‘opt-out’). Consumers who opt-in to allowing the sale of their personal information may still opt-out of future sales at any time.

You may also opt-out of receiving marketing communications from us; however, you may still receive administrative communications regarding our services;

You may opt-in to certain financial incentive programs we may offer related to the collection, retention, or sale of your Personal Information.

You may exercise your right to opt-out and remove your consent at any time by completing our Right to Opt-Out Form.

Minors

Our services are not intended for Children. We request that they not provide us with Personal Information. Our intent is not to market to anyone under the age of 18, and we do not knowingly collect or sell Personal Information of anyone under the age of 16.

If you learn that a child has provided us with Personal Information, then you may contact us through the Contact Us section below”>Contact Us section.

Further, the CCPA provides Consumers with the right not to receive discriminatory treatment by a business for the exercise of these CCPA privacy rights, subject to certain limitations.

Use of Personal Information

The Personal Information may be used for the purposes disclosed to Consumers at the time of collection, in our general Privacy Policy and for the purposes of:

• providing our services
• communicating with Consumers
• personalizing the experience of Consumers on our services (including providing tailored content)
• de-identifying and aggregating the Personal Information
• responding to trust and safety issues
• complying with judicial process or government requests
• detecting security incidents (including protecting against malicious, deceptive, fraudulent, or illegal activity) and prosecuting those responsible
• debugging to identify and repair errors that impair existing intended functionality
• performing services on our behalf or on behalf of our service providers (including maintaining or servicing accounts, providing customer service
• processing or fulfilling orders and transactions
• verifying customer information
• processing payments
• providing financing
• providing advertising or marketing services
• providing analytic services
• providing similar services for our or our service providers’ short-term transient use) and undertaking activities to verify or maintain the quality or safety of a service or device that is owned/manufactured for or controlled by us and to improve/upgrade/enhance the service or device that is owned/manufactured for or controlled by us.

The Personal Information may also be used or disclosed as otherwise permitted or required by applicable law.

Collection of Personal Information

In the preceding 12 months since this CCPA Privacy Notice was last reviewed, we may have collected Personal Information from the following categories of sources:

• directly from you (e.g. forms you complete or products and services you purchase)
• directly or indirectly from someone other than you
• our affiliates
• advertising networks
• internet service providers
• operating systems and platforms
• data brokers and our business partners

Sale of Your Information

We have not sold your Personal Information for the preceding 12 months from the date of the last review of this CCPA Privacy Notice.

Privacy Requests

If you are a Consumer, you can make requests to know what personal information we have collected from you in the past 12 months or requests to delete your personal information.

To exercise your access, data portability, and/or deletion rights, please submit a request by one of the following approved methods:

• Email: [email protected]
• Phone: 844-894-2429
• Our Privacy Request Form

Please be aware that we do not accept or process requests through other means (e.g., via fax or social media).

All requests must be made by the consumer or an authorized agent registered with the California Secretary of State acting on their behalf. If you believe that we have collected information from anyone under the age of 16, then a parent or legal guardian acting on behalf of a minor may also make the request.

Please note, we must be able to validate the authority of the request,verify your identity and confirm the personal data is related to the requestor in order to respond to the request and provide you with personal information.

Request Response Process

SOCi will acknowledge receipt of your request within 10 business days, at which time you will receive a follow-up email outlining the estimated amount of time it will take to complete your request and giving further instructions. That email may also include a link you must click on in order to verify your identity. If you do not click on that link, we will be unable to complete your request due to lack of verification. It is important that you provide a valid email address in order for us to be able to process your request.

We may be required to collect additional information to ensure we are interacting with the correct Consumer in order to protect the Personal Data entrusted to us. If you have a password-protected online account with us, you may be required to log-in to your account for identity verification. If you do not have an account with us, additional information to verify your identity may be required by law before we may take action upon such a request. This additional information may vary depending on the nature of your request and/or the nature of the information about which your request relates. In some cases, we may also be required by law to obtain a signed declaration under penalty of perjury from you that you are the subject of the request being made. If we suspect fraudulent or malicious activity on or from your account, we will delay taking action on your request until we can appropriately verify your identity and the request as authentic.

By law, we are not required to collect Personal Information that we otherwise would not collect in the ordinary course of our business, retain Personal Information for longer than we would otherwise retain such information in the ordinary course of our business, or reidentify or otherwise link information that is not maintained in a manner that would be considered Personal Information. If we have not requested specific additional information from you to verify your request, please do not send such information.

We reserve the right to charge a reasonable fee or take other appropriate action in response to requests from a Consumer or household that are manifestly unfounded or excessive, in particular because of their repetitive character.

Authorized Agent Requests

You may designate an authorized agent to make a request on your behalf pursuant to applicable law. We accept documentation of your designation in the form of a valid power of attorney and/or a written authorization signed by you and the authorized agent. You may submit evidence of your designation of an authorized agent in writing to us at the location or email address provided in the “How to Contact Us” section below.

We may require verification of your authorized agent in addition to the information for verification above for Consumers and households.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services
• Provide you a different level or quality of goods or services

Shine the Light

California’s “Shine the Light” Law (Civil Code Section 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make a request, please send an email [email protected] or write to SOCi at 225 Broadway, San Diego, California 92101, United States.

Notice of Financial Incentive

We do not offer financial incentives to Consumers based upon the collection, retention or sale of a Consumer’s Personal Information.

12. OTHER IMPORTANT INFORMATION

Children

Our Services are intended for a general audience, and are not directed at children under thirteen (13) years of age.

Consistent with the federal Children’s Online Privacy Protection Act of 1998 (COPPA), we do not knowingly request personal information from anyone under the age of 13 without requiring parental consent. Any person who provides their personal information to us through our Site or Service represents that they are at least 13 years of age. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at [email protected] or complete our Privacy Request Form. We will take steps to delete your child’s information.

Changes and Updates to this Privacy Policy

We may update this Policy from time to time to reflect changes in our privacy practices. We will follow applicable laws and regulations regarding notification of such changes. We recommend that you visit our Privacy Policy periodically to remain informed of changes.

How to Contact Us

SOCi, Inc. is the entity responsible for the processing of your Personal Data. If you have any questions or comments about this Privacy Policy, our privacy practices, or if you would like to exercise your rights with respect to your Personal Data, please contact us by email at [email protected] or by mail at:

SOCi, Inc.
225 Broadway, Suite 600
San Diego, California 92101
United States

In addition, you may contact our Data Protection Officer at [email protected] or 1-305-302-6909.