Social SafeGuard, Inc.

PRIVACY POLICY

Last updated September 2016

Social SafeGuard, Inc. including its business unit OpenQ (“Company,” “we” our us) is committed to protecting the privacy of individuals who visit the Company’s Websites (“Visitors”), individuals who register to use our Services (as defined below) (“Customers”), third parties that interact with the Customers and/or their End Users (as defined below) (“End User Contacts”), and individuals who register to attend the Company’s corporate events (“Attendees”) (collectively, “Users” or “you”). This Privacy Statement describes Social SafeGuard’s privacy practices in relation to the use of the Company’s Websites and the related applications software-as-a-service solutions, including the Social SafeGuard, and OpenQ Engage Solutions, Social SafeGuard Mail, Social SafeGuard Sites and Social SafeGuard Messages (collectively, the “Social SafeGuard Services” or “Services”).

Social SafeGuard, Inc. is based in the United States and by using our Service or otherwise providing your personal data to us, your personal data will be transferred to and processed in the United States.

Social SafeGuard complies with the E.U.-U.S. Privacy Shield (“Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Social SafeGuard has certified that it adheres to the Privacy Shield Principles of notice, choice, and accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability. To learn more about the Privacy Shield program, and to view Social SafeGuard’s certification, please visit the Privacy Shield website.

Social SafeGuard is subject to the investigatory and enforcement powers of the Federal Trade Commission, Department of Transportation and any other US authorized statutory body.  Social SafeGuard is a Delaware Company and subject to Virginia law.

 

Web sites and Services covered

This Privacy Statement covers the information practices of Web sites that link to this Privacy Statement, including:  www.socialsafeguard.com (referred to as “Social SafeGuard’s Website” or “the Company’s Website”) and www.openq.com (referred to as “OpenQ’s Website”).

Social SafeGuard may allow access to third party social media websites via its Services.  When those sites are made available by Social SafeGuard and the application links to this Privacy Statement, this Privacy Statement applies. When applications are posted by third parties, the privacy statement of the third party applies, and this Privacy Statement does not apply.

The Services also enable Social SafeGuard Customers to create websites that are hosted by Social SafeGuard. When Customer Sites are hosted by Social SafeGuard, Social SafeGuard will perform its duties required under its license agreement with Social SafeGuard’s Customers pursuant to this Privacy Statement; however, this Privacy Statement does not necessarily apply to any website activity that occurs on the Customer Sites.

Social SafeGuard’s Websites and Services may contain links to other Websites. The information practices or the content of such other Websites is governed by the privacy statements of such other Websites. The Company encourages you to review the privacy statements of other Websites to understand their information practices.

 

Information Use and Collection

Data you give to us directly
On some places on the Social SafeGuard Website, you can fill in a web form to share your data (i.e., name, e-mail address, address, phone number, etc.) with us directly, such as on our “Contact Us” page, on our “Request a Demo” page, or on our blog home page. We collect the information you provide in response to those web forms. Occasionally, we may also offer opportunities for you to share your data with us such as through a survey, to sign up for a newsletter, or to register for or receive details about an event we are sponsoring. If you participate in those surveys, sign up for a newsletter, or register for an event, we will collect the information you provide to us in doing so.

Social SafeGuard collects the email addresses of those who communicate with us via email, contact information of Users that communicate through other channels (such as phone number and physical address), information on what pages Users visit on the Social SafeGuard Website, IP addresses of those accessing the Social SafeGuard Website, information volunteered by the User (such as survey information), and information collected from the End User of the Service (e.g. name) (“Social SafeGuard Data”).  This also includes information on the senders and recipients of communications sent using Social SafeGuard Services (including Mail and Messages), by the End User of the Service and the people they are communicating with (“End User Contacts”).  We may also monitor the online activity of End User Contacts that provide information to the Services, such as their interaction with End User websites, social media, and other online content related to the End User.  We collect this information on behalf of our End Users to enable them to provide better services.

 

Website Navigational Information

Cookies, Web Beacons and IP Addresses
When you visit the Social SafeGuard Website, we and our service providers acting on our behalf automatically collect certain data using tracking technologies like cookies, web beacons, and similar technologies.

A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a website’s computers and stored on your computer’s hard drive.

These technologies are used to help us better understand user behavior and facilitate and measure the effectiveness of our Social SafeGuard Website. We treat information collected by cookies and other technologies as non-personal information.

We use cookies to record current session information.  We also use third party cookies (e.g. Google Analytics) to provide anonymized and aggregated information on website usage statistics and patterns.

All modern Internet browsers allow you to control your cookie settings. These settings are usually accessed in the ‘Options’ or ‘Preferences’ section of your browser. On your mobile device, go to Settings, then go to the specific web-browser, and then to the Cookies section. Please note that certain features of the website will not be available once cookies are disabled.

Social SafeGuard uses web beacons with cookies or separately to compile information about Users’ usage of the Company’s Websites and interaction with the Company, its Customers, or End Users through Social SafeGuard emails and Services.  Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular website tied to the web beacon, and a description of a website tied to the web beacon.

When you visit the Social SafeGuard Website, we collect your Internet Protocol address (“IP Address”) to monitor the regions from which you navigate the Social SafeGuard Website.

 

Social Media Features

We allow you to “Connect With Us” through various social media networks through our website. Clicking on these links takes you away from the Social SafeGuard Website to the Social SafeGuard Website on those specific social media networks (Social SafeGuard on FacebookSocial SafeGuard on TwitterSocial SafeGuard on LinkedInSocial SafeGuard on Google+).

Each third party website and social media network has its own terms and privacy policy regarding information stored, collected, processed and shared on those respective website and networks.  So, your participation with Social SafeGuard on those websites and social media networks is subject to the websites’ and social media networks’ terms and privacy policy, not ours.

You should not provide Social SafeGuard with any personally identifiable information (or post any personally identifiable information to the Social SafeGuard Website) unless you would like that information to be used in accordance with this Privacy Policy.

 

Do Not Track Statement

Certain internet web browsers allow a “do not track” (DNT) setting that relies on a technology known as a DNT header, which sends a signal to websites visited by the individual about the individual’s browser DNT setting. At this time, we do not currently commit to respond to DNT signals, whether that signal is received on a computer or on a mobile device.

 

Public forums, refer a friend, and Customer testimonials

Social SafeGuard may provide community forums such as blogs on the Company’s Websites (collectively, “Forums”). Any personal information you choose to submit in such a Forum may be read, collected, or used by others who visit these Forums, and may be used to send you unsolicited messages. Social SafeGuard is not responsible for the personal information you choose to submit in these Forums.

Social SafeGuard posts recorded Customer testimonials on the Company’s Website that contain information such as Customer names and titles. Social SafeGuard obtains the consent of each Customer prior to posting any information on such a list or posting testimonials.

 

Sharing of information collected

We use third party vendors and hosting partners to provide hardware, software, networking, storage, support or related technology required to run our Services. Your information may be accessible by such third party vendors for the purpose of enabling them to store such data in connection with the permitted uses of your information under this Privacy Policy. Our third party service providers have an obligation to maintain the confidentiality of the information, except where disclosure is required by law.

To the extent permitted by applicable law, we may disclose information where it is necessary in order to investigate, prevent, or take action regarding illegal activities (including cooperating with governmental authorities regarding the investigation of illegal activities), suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.

Suspected or actual violations of this Privacy Policy should be sent to us by forwarding a copy suspected or actual violation to privacy@SocialSafeGuard.com. It is our policy to catalog, investigate, and take appropriate action on all reports of abuse.

 

International transfer of information collected

Social SafeGuard, Inc. is based in the United States and by interacting with the Social SafeGuard Website or otherwise providing your personal data to us, your personal data will be transferred to and processed in the United States.

Dispute Resolution

We have chosen the EU Data Protection Authorities (EU DPAs) to serve as an independent recourse mechanism for dispute resolution arising from collection, use, and retention of personal information transferred from EU member countries to the United States.

If you have any questions or concerns regarding this Policy, please contact us first at privacy@SocialSafeGuard.com. If contacting us does not resolve your complaint, you may file a complaint, free of charge, with the EU Data Protection Authorities (EU DPAs).

 

Further, as explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address residual complaints not resolved by any other means.

 

Correcting and Updating Your Information

You have the right to access your personal information that we control and request rectifications of any personal information that may be obsolete, incomplete or incorrect. We will need to validate your identity in order to implement such a request to ensure that we do not provide your information to anyone who does not have the right to that information. In some cases, we will not be able to provide the information we hold about you. That may occur if: (1) it contains reference to other persons; except where those persons have given their consent to the disclosure or the disclosure is reasonable without their consent; or (2) it is subject to solicitor-client (attorney-client) privilege or litigation privilege.

To request access to your personal information or to file a privacy complaint, please email our Privacy Officer at: privacy@SocialSafeGuard.com.

If your personal information changes (such as zip code, phone, email or postal address), or if you no longer desire to be contacted about our products and services, you can correct, update, delete or deactivate your use of the website and Services at any time. This can be done by emailing Social SafeGuard at: privacy@SocialSafeGuard.com

 

Service-Specific Privacy and Customer Data

All Services are accessible via an internet browser and certain services also have a mobile app. Generally, our Customers are companies who give their employees, contractors and agents access to the Social SafeGuard Services (those individuals are collectively, “End Users”).

 

Collection of personally identifiable information we control

Social SafeGuard collects the email addresses of those who communicate with us via email, contact information of Users that communicate through other channels (such as phone number and physical address), information on what pages Users visit on the Social SafeGuard Website, IP addresses of those accessing the Social SafeGuard Website, information volunteered by the user (such as survey information), and information collected from the User of the Service (e.g. name) (“Social SafeGuard Data”).  This also includes information on the senders and recipients of communications sent using Social SafeGuard Services (including Mail and Messages), by the User of the Service and the people they are communicating with.

 

Use of personally identifiable information

The Social SafeGuard Data we collect and process is used to improve the content of our website and the quality of our Services and to contact Users.

 

Data we process as a data processor to provide the Social SafeGuard Service

We act as a data processor for our Customers that use the Service. We process information that our Users and/or Customer’s End User Contacts provide, or grant us access to, after either (i) giving their explicit consent to connect their social media accounts to the Service; or (ii) submitting their contact information (name, job title, company name, business address, and/or phone number to the Service (“Services Data”).  We may use Services Data across multiple products to enable End User Contact communications, such as sending and receiving email, sending and receiving text messages, populating website information at the request of End User’s organization, and other digital communications. Services Data processed includes the content of any posts End User Contacts make to social media sites in order to enable our Customers to monitor the social media activity of its Users. We use the Services Data solely in order to provide the Service in accordance with our license agreement.  Such use includes:

  • Monitoring: Our Service monitors content posted to connected social media accounts in accordance with the terms our license agreement.
  • Multi-Service Use: If an End User purchases or is otherwise granted a license to another Social SafeGuard Service, we may use Services Data derived from the End User’s social media account to populate information within the additional Social SafeGuard Service.  For example, we may populate Social SafeGuard Sites contact information with a Customer’s business address or an individual End User’s business address from his or her social media account.   When an End User deactivates his or her Social SafeGuard account from the Social SafeGuard Engage Solution platform, the token will be deleted from our Service and our Service will have no access to such accounts.  We may, however, continue to include Services Data derived from social media within another Social SafeGuard Service for as long as the End User maintains a license for the particular Social SafeGuard Service, unless the End User (or the Customer on behalf of the End User) submits a request for deletion of Services Data to privacy@SocialSafeGuard.com.
  • Authentication: Once a registered End User links his or her social media account to our Social SafeGuard Engage Solution platform, we request and subsequently store an End User access token for such account. This will only occur if the End User explicitly grants permission. Our platform is then able to access content of posts and other interactions within that social media account and also write information to that social network account when explicitly instructed to do so by the registered End User.
  • Analysis: Our Services monitor information posted or sent, and the corresponding responses or engagements (any actions taking on the piece of content that is trackable) to report on, analyze and better understand the expected responses to posting or sending additional content broadly, or to a specific individual.
  • Disclosure to Customers: Our Service provides supervision capability for each Customer to report on content, and review of content, posted by their employees, contractors and personnel that have connected their accounts to our service.

 

Confidentiality

We have comprehensive security controls to protect against unauthorized review and use of the personal information that is submitted to or processed by us, including electronic safeguards such as encryption software and firewalls. Access to personal information is restricted to authorized employees only.

 

Disclosure to third parties

Social SafeGuard Data and Services Data are not shared with or sold to other organizations except under the following circumstances:

To the extent permitted by applicable law, we may disclose information where it is necessary in order to investigate, prevent, or take action regarding illegal activities (including cooperating with governmental authorities and law enforcement agencies regarding the investigation of illegal activities), suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
To the extent permitted by applicable law, we may transfer information about you to a successor or acquirer of Social SafeGuard, in which case such successor’s or acquirer’s use of such information shall be subject to this Privacy Policy and our contractual obligations.
We do not share your information with third parties for the third parties’ own and independent direct marketing purposes unless we receive your permission.

 

Social SafeGuard, Inc. End User License Agreement

This Terms of Use and License Agreement governs the use of Social SafeGuard, Inc.’s web-based social management service (“Service”) and is a legal agreement between you and Social SafeGuard. By accessing or using the Service, you agree to be bound by and accept the terms of the agreement.  Please contact Social SafeGuard for a copy of this agreement.

 

Changes to this Privacy Statement

We may periodically update this policy. We will notify you about material changes (e.g. material changes to the use of your personal information) in this Privacy Policy by placing a prominent notice on our website.  We will comply with applicable law with respect to any changes we make to this notice.

 

Contacting us

Any questions about this Privacy Policy or requests for access to or deletion or rectification of data should be addressed to privacy@SocialSafeGuard.com or by mail at: Social SafeGuard, Attn: Legal, 410 A East Main Street, Charlottesville, VA 22903 USA.