Social Factor Privacy Policy

Social Factor takes your privacy seriously. Please read this privacy policy carefully as it contains important information on who we are, as well as how and why we collect, store, use, and share your Personal Information. It also explains rights you may have in relation to your Personal Information and how to contact us or supervisory authorities in the event you have a complaint.

What we do, and how that’s related to your Personal Information.  Social Factor reviews and analyzes comments left by individuals on social media platforms and websites.  We do this to provide our own clients, who own or operate channels on those social media platforms and websites, with insights and advice on their own products and services.  The services we provide to support the business purposes of our clients may cause us to collect and process Personal Information about those who voluntarily choose to engage in such communications.  

Social Factor’s responsibilities with respect to Personal Information.  The extent to which Personal Information is contained within the identifier of a specific commenter, or within their comment, will of course vary, but because we collect and/or use such Personal Information in doing our job, we may become responsible for certain Personal Information about you while engaged in the above processing.  As a “Processor” and “Service Provider” for our clients (who are the “Controllers” of such Personal Information), we are subject to various laws that now and in the future may apply in the United States, and the General Data Protection Regulation which applies across the European Union (including in the United Kingdom).  At the same time, Social Factor is an employer, and may also interact with Personal Information while running its own business, which is not collected solely because of its role as a Processor and Service Provider to clients.  In those cases, we are the “Controller” of certain Personal Information for the purposes of those same laws.    

  1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:

 

We, us, our Social Factor, Inc.
Our data protection officer (DPO) Contact information provided below
Personal information  Any information relating to an identified or identifiable individual, device, or household.
Special category Personal Information Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; Genetic and biometric data; Data concerning health, sex life or sexual orientation.

 

  1. Personal Information We Collect About You. We may collect and use the following Personal Information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

 

Categories of Personal Information Specific Types of Personal Information Collected
Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) Since Social Factor processes comments left by individuals on various social media platforms and websites, it is possible that any of these Identifiers could be included by the commenter both in identifying himself/herself or within his or her comment.  This information may also be collected from job applicants and employees.  In addition, our clients may provide Identifiers for individual employees who are points of contact for us, and individuals may submit their own identifiers via our website’s contact page. 
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Since Social Factor processes comments left by individuals on various social media platforms and websites, it is possible that any of this information could be included by the commenter both in identifying himself/herself or within his or her comment.  This information may also be collected from job applicants and employees.  In addition, our clients may provide names and other identifiable information for individual employees who are points of contact for us, and individuals may submit this type of information via our website’s contact page. 
Characteristics of protected classifications under California or federal law. Since Social Factor processes comments left by individuals on various social media platforms and websites, it is possible that information regarding a commenter’s characteristics protected under law could be included by the commenter both in identifying himself/herself or within his or her comment.  This information may also be collected from job applicants and employees.
Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) Since Social Factor processes comments left by individuals on various social media platforms and websites, it is possible that this type of commercial information could be included by the commenter both in identifying himself/herself or within his or her comment.   In addition, individuals may submit this type of information via our website’s contact page. 
Biometric information None currently.
Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement) Since Social Factor processes comments left by individuals on various social media platforms and websites, information regarding a consumer’s interaction with those platforms and websites will be processed.      
Geolocation data Since Social Factor processes comments left by individuals on various social media platforms and websites, it is possible that those platforms and websites could include the geographic location of the commenter (both in terms of the user account, if any, as well as the location of an IP address used to post the comment).   
Audio, electronic, visual, thermal, olfactory, or similar information None currently.
Professional or employment-related information Since Social Factor processes comments left by individuals on various social media platforms and websites, it is possible that this type of professional or employment related information could be included by the commenter both in identifying himself/herself, or within his or her comment.   In addition, Social Factor may collect this information from job applicants and employees.  In addition, our clients may provide names and other identifiable information for their individual employees who are points of contact for us, which will inherently reveal their employment status with our client.
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA) Since Social Factor processes comments left by individuals on various social media platforms and websites, it is possible that this type of education information could be included by the commenter both in identifying himself/herself, or within his or her comment.   
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes Social Factor processes the information in comments left by individuals on various social media platforms and websites to provide this type of inferential data to its clients, both in an aggregated format as well as in a manner that may include reference to an identifiable individual in providing examples of online behavior.

As noted above in Section 1, the above Personal Information, when processed for clients, is used solely to provide services to our clients, who are the Controllers of the Personal Information individuals have voluntarily posted or otherwise submitted to channels on social media platforms or websites.  When collected from job applicants, employees, or others with whom we directly engage for running our business (such as those who may submit information on our website’s contact page), we use such information solely for the limited purposes described in this privacy policy.  

  1. How Your Personal Information is Collected. Other than our job applicants and employees, who submit Personal Information directly to us (or approve of our collection of such information from third-party sources), as well as visitors to our website using our contact page to submit Personal Information, we collect most other Personal Information from our clients — either directly pursuant to the provisions of Data Processing Agreements we have with them, or by accessing the third-party platforms used by clients to which we are granted access for the sole purpose of the processing described in this privacy policy.  We may also collect information from publicly accessible sources (e.g., property records), a third party (e.g., Sprinklr, YouTube, Facebook), Cookies and Beacons on our website (more on this below); and via our own internal IT systems, including door entry systems and reception logs, and automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems.  

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You will be asked to consent to the use of cookies.  You may refuse to accept cookies, but then you may be unable to access certain parts of our website if the cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site. Visit socialfactor.com/cookies for a full description of the cookies in use on our website.

Flash Cookies. Certain features of our website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

Web Beacons. Pages of our website and some of our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Disabling Cookies.  If you want to disable cookies, please visit socialfactor.com/cookies.  You also can change your own browser settings to reject cookies; instructions for the most popular browsers are below:

For Microsoft Internet Explorer:

Choose the menu “tools” then “Internet Options”

Click on the “privacy” tab

Select appropriate setting

For Google Chrome:

Choose Settings> Advanced

Under “Privacy and security,” click “Content settings”.

Click “Cookies”

For Safari:

Choose Preferences > Privacy

Click on “Remove all Website Data”

For Mozilla Firefox:

Choose the menu “tools” then “Options”

Click on the icon “privacy”

Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:

Choose the menu “Files”> “Preferences”

A note about links to third-party sites.  Our own website and some emails from us from time to time may post content or contain links to third-party websites that are not owned or controlled by Social Factor. Social Factor does not monitor and assumes no responsibility for the content, tracking and data gathering (which includes but is not limited to the use of cookies, flash cookies, web beacons, other data tracking devices, data gathering practices, or collection of personally identifiable information), terms and conditions, or privacy policies or practices of any third-party websites. In addition, Social Factor does not censor or edit the content of any third-party websites. Social Factor is not responsible nor liable for your use of any third-party websites accessed through the Social Factor website. Accordingly, Social Factor encourages you to be aware when you leave this website or the Services found at this website and to review the terms and conditions, privacy policies, and any other governing documents of any other website you may visit.

We also use Google Analytics, a web analysis service provided by Google, to better understand consumers’  use of our website.  Google Analytics collects information such as how often users visit the websites, what pages they visit and what other sites they used prior to visiting. Google uses the data collected to track and examine the use of the website, to prepare reports on its activities and share them with other Google services. Google may use the data collected on our website to contextualize and personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics about your visits to the websites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google offers an opt-out mechanism for the web available here.

  1.  How and Why We Use Your Personal Information. The processing of your Personal Information, when collected from our clients to provide them with a service that supports their own business purposes, is governed primarily by Data Processing Agreements with our clients, in which we commit that we will not use Personal Information given to us by our clients for any other reason.  

As to the Personal Information we may collect from job applicants, employees, web visitors, and otherwise in supporting our own business operations, we will use such Personal Information only if we have a proper reason for doing so, such as:

  • To comply with our legal and regulatory obligations;
  • For the performance of our contract with you or to take steps at your request before entering a contract;
  • For our legitimate interests or those of a third party; or
  • Where you have given consent (such as by using our website’s contact page).

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains how we use (process) your Personal Information, and our reasons for doing so:

 

How we use your Personal Information  Our reasons
Assessing and analyzing comments posted into channels of social media platforms and websites To provide a service in support of the business purposes of our clients, as more fully explained above, and in compliance with Data Processing Agreements with those clients
To prevent and detect fraud    For our legitimate interests or those of a third party (i.e., to minimize fraud)  
Processing of applicant and employee information necessary to comply with professional, legal, and regulatory obligations that apply to our business  To comply with our legal and regulatory obligations, such as I-9 verification or W-4 processing
Ensuring business policies are adhered to (e.g., policies covering security and internet use) For our legitimate interests or those of a third party (i.e., to make sure we are following our own internal procedures)
Operational reasons, such as improving efficiency, training, and quality control, or responding to website contact page submissions For our legitimate interests or those of a third party (i.e., to be as efficient as we can so we can deliver the best service)
Ensuring the confidentiality of commercially-sensitive information For our legitimate interests or those of a third party, (i.e., to protect trade secrets and other commercially valuable information)
To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business (e.g., in relation to our financial performance, customer base, product range or other efficiency measures) For our legitimate interests or those of a third party (i.e., to be as efficient as we can so we can deliver the best service for you at the best price)
Preventing unauthorized access and modifications to systems For our legitimate interests or those of a third party (i.e., to prevent and detect criminal activity that could be damaging for us and for you)
To comply with our legal and regulatory obligations
Statutory returns To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party (e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service)
Marketing our services and those of selected third parties to:
—existing and former clients;
—third parties who have previously expressed an interest in our services;
—third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party (i.e., to promote our business to existing and former customers)
External audits and quality checks (e.g., SOC-2, etc.) For our legitimate interests or a those of a third party (i.e., to maintain our accreditations so we can demonstrate we operate at the highest standards)
To comply with our legal and regulatory obligations

Note that the above table does not apply to special category Personal Information, which we will only knowingly process with your explicit consent.  We take advanced steps to prevent the processing of special category Personal Information whenever practicable.

  1.  Promotional Communications. We will not use Personal Information collected during processing of client data for promotional communications.  However, we may send promotional communications to our clients, and informational announcements or job postings to applicants and employees, as well as those who provide consent to do so when submitting information via our website contact page.  Where consent is needed, we will ask for this consent separately and clearly.

Regardless, we will always treat your Personal Information with the utmost respect and never sell or share it with other organizations for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by:

  • Contacting us at info@socialfactor.com;
  • Using the “unsubscribe” link in emails or “STOP” number in texts; or

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

  1.  Where we share your Personal Information. We routinely share Personal Information with:
  • Service providers we use to help deliver our services to our clients.  When we do, we will do so under Sub-processor Agreements in which they promise not to use the Personal Information for any other reason;
  • Other third parties we use to help us run our business, such as marketing agencies or website hosts, data storage providers, cloud IT services and SaaS providers, and online training platforms, including, but not limited to Asana, Google, HubSpot, Pantheon, or Zenefits, and you hereby agree to the terms and conditions of each of their linked privacy policies by permitting us to process the Personal Information provided;

We only allow our service providers to handle Personal Information once we are satisfied they take appropriate measures to protect that Personal Information. We also impose contractual obligations on service providers to ensure they can only use your Personal Information to provide services to us and to you. 

We may also share Personal Information with external auditors (e.g., in relation to SOC-2 or other accreditation and the audit of our accounts).

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some Personal Information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible.  Regardless, the recipient of the information will be bound by confidentiality obligations.

 

  1. Personal Information We Have Sold or Disclosed for a Business Purpose.

At the time of this privacy policy’s publication, we have never sold or disclosed to a third party (other than for the internal support purposes described above) any Personal Information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

  1. Where Your Personal Information is Held. 

Personal Information held by Social Factor is stored in enterprise cloud-based data storage solutions.  This data storage may be licensed by us, or by our service providers, representatives, and agents as described above (see above: “Where we share your Personal Information ”).  Some of these storage solutions may be based outside the European Economic Area.  For more information, including on how we safeguard your Personal Information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

  1. How Long Your Personal Information Will Be Kept. 

We will keep Personal Information provided by clients while processing it for them, for a period of seven (7) years thereafter, or for the specific period provided for in the Data Processing Agreement for each client.  

For job applicants and employees, and those who submit information via our website contact page, we will keep your Personal Information for as long as is necessary:

  • To respond to inquiries for services and other options as indicated on the website contact page;
  • To respond to any questions, complaints, or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.

We will not retain your Personal Information for longer than necessary for the purposes set out in this policy, and when it is no longer necessary to retain Personal Information as provided above, we will delete or anonymize it.

  1.  Transferring Personal Information Out of the EEA. 

To deliver services as we have outlined in this policy, it is sometimes necessary for us to share Personal Information outside the European Economic Area (EEA), e.g.:

  • While processing Personal Information for a client who is in the EEA, and who sends us information from the EEA, or allows us to access Personal Information hosted in the EEA;
  • To utilize service providers for data storage and other processing who are located outside the EEA (e.g., processing data on servers located outside of the EEA);
  • If you are based outside the EEA, and we directly engage with you.

These transfers are subject to special rules under European and UK data protection law.

The following countries to which we may transfer Personal Information have been assessed by the European Commission as providing an adequate level of protection for Personal Information: mainly US, Canada but can also vary based on the user’s own location as indicated by Google and Asana.

Some non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, regardless, ensure the transfer complies with data protection law and all Personal Information will be secure. In doing so, our standard practice is to use standard data protection contract clauses (SCC’s) that have been approved by the European Commission. To obtain a copy of those clauses as most recently updated on June 4, 2021, you may visit https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en. If you would like further information on the SCCs, and how we take steps to ensure adequate safeguards for data transferred outside of the EEA, please contact our Data Protection Officer (see “How to Contact Us” below).

  • Your Rights Under the GDPR.  If you are a resident of the EEA, you have rights with respect to your Personal Information:

 

Right to Access The right to be provided with a copy of your Personal Information (the right of access)
Right to Rectification The right to require us to correct any mistakes in your Personal Information
Right to be Forgotten The right to require us to delete your Personal Information—in certain situations
Right to Restriction of Processing The right to require us to restrict processing of your Personal Information—in certain circumstances (e.g., if you contest the accuracy of the data)
Right to Data Portability The right to receive the Personal Information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object The right to object:
—at any time to your Personal Information being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your Personal Information (e.g., processing carried out for the purpose of our legitimate interests)
Right Not to be Subject to Automated Individual Decision-Making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation (https://ico.org.uk/).  

  1. Your Rights Under the CCPA. If you are a California resident, you also have rights under the California Consumer Privacy Act of 2018 (CCPA) and its amendments.  As a Service Provider (not a “Business,” since we do not sell Personal Information, and only process it to support our clients), we will refer inquiries regarding the exercise of these rights to our clients for response.  Rights under the CCPA:

 

Disclosure of Personal Information Collected About You You have the right to know:
• The categories of Personal Information we have collected about you;
• The categories of sources from which the Personal Information is collected;
• Our business or commercial purpose for collecting or selling Personal Information;
• The categories of third parties with whom we share Personal Information, if any; and
• The specific pieces of Personal Information we have collected about you.
Please note that we are not required to:
• Retain any Personal Information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
• Re-identify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Information; or
• Provide the Personal Information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose In connection with any Personal Information we may sell or disclose to a third party for a business purpose, you have the right to know:
• The categories of Personal Information about you that we sold and the categories of third parties to whom the Personal Information was sold; and
• The categories of Personal Information that we disclosed about you for a business purpose.
You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your Personal Information. 
Right to Deletion Subject to certain exceptions set out below, on receipt of a verifiable request from you (as verified also by our client, the Business who collected the information), we will:
• Delete your Personal Information from our records; and
• Direct any service providers to delete your Personal Information from their records.
Please note that we may not delete your Personal Information if it is necessary to:
• Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
• Debug to identify and repair errors that impair existing intended functionality;
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
• Comply with the California Electronic Communications Privacy Act;
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
• Comply with an existing legal obligation; or
• Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:
• Deny goods or services to you;
• Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
• Provide a different level or quality of goods or services to you; or
• Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
Please note that we may charge a different price or rate or provide a different level or quality of [goods and/or services] to you, if that difference is reasonably related to the value provided to our business by your Personal Information.

 

  1. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent Personal Information from being accidentally lost or used or accessed in an unauthorized way. We also limit access to your Personal Information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems and are audited to ensure our internal controls are designed and implemented and/or operating effectively which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.  
  2. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period, and all such requests, if regarding client data, will be referred to our clients for validation and processing.  We will then assist our clients as appropriate.

If you choose to contact directly by email or phone, you will need to provide us with:

  • Enough information to identify you (e.g., your full name, address, and other reference info);
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.

We and our clients are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any Personal Information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

  1. How to File a GDPR Complaint. We hope that our DPO can resolve any query or concern you raise about our use of your information.  However, the General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.  Click here to locate contact information for your applicable Data Protection Authority.
  2. Changes to This Privacy Notice. This privacy notice was published on July 1, 2021 and last updated on July 10, 2021.  We may change this privacy notice from time to time, and when we do, we will inform you via this same URL where the privacy policy is now located.  You should periodically review this policy for updates. 
  3. How to Contact Us. Please contact us and our DPO by post, email or telephone if you have any questions about this privacy policy or the information we hold about you:

 

Our contact details Our Data Protection Officer’s contact details
1227 W. Magnolia Ave.

Suite 300

Fort Worth, TX 76104

Same.
Privacy@socialfactor.com
817.708.2500

 

  1. Notice Concerning Information of Children.  Social Factor does not direct any of its practices or system towards children. We are committed to respecting the privacy of children online. If Social Factor learns that the information of a child under the age of 13 is stored, Social Factor will promptly delete any such Personal Information
  2. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).