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 incidentally collect and process Personal Information about those who voluntarily choose to engage in such communications, often without either us or our client having requested or sought such Personal Information from the individual responsible for its provision to our client. Regardless, our collection and processing of such Personal Information is on behalf of the client, to provide a service in support of the client’s business, and only with respect to information already in the client’s possession.
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 might collect, reference, and/or use such Personal Information in doing our job for a client, 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, such as in the contact information for representatives of potential Social Factor clients, which in either case 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.
- 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.|
2. 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, marketing vendors providing contact information for potential clients, 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, marketing vendors may provide contact information for potential clients, and individuals may submit this type of information via our website’s contact page.|
|Characteristics of protected classifications under state 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, and marketing vendors may provide contact information for potential clients. 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. Social Factor also may create inferential data from leads provided by marketing vendors who provide contact information for potential clients.|
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. 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”.
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”
4. 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, marketing vendors who may provide contact information for potential clients, 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, including determining the potential for a new client engagement; 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. Any marketing vendors who may provide contact information for potential clients have agreed to terms with Social Factor which obligate such vendors to only provide such information when it has been lawfully collected, including with appropriate third party consents to the use of such information in this manner (if required).
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, potential new clients, 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.
5. 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, potential new clients identified by marketing vendors, 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 firstname.lastname@example.org;
- 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.
6. 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.
7. Personal Information We Have Sold or Disclosed for a Business Purpose.
8. 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”.
9. 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.
10. 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).
11. 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/).
12. Your Rights Under Certain U.S. State Privacy Laws. You may also have rights under the certain data privacy legislation enacted by various U.S. states, depending on whether such state laws are applicable to Social Factor and the Personal Information practices described in this policy. As a Processor only (not a “Controller,” since we do not sell Personal Information, and only process it as a service provider to support the business purposes of our clients), we will refer inquiries regarding the exercise of such rights to our clients for response, to the extent required by law and/or the terms of our contracts with such clients. As a Controller, we will assess each request to exercise such rights to determine whether it is regarding laws that apply in the specific circumstances of such request.
13. 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.
- Email us at email@example.com; or
- Call us at +01 512-200-3535 .
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.
15. 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.
|Our contact details||Our Data Protection Officer’s contact details|
1227 W. Magnolia Ave.
Fort Worth, TX 76104
18. 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
19. 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).