Our Privacy Commitment to you
The Social App will only collect the data that we need to operate our Services and provide our users with a private, secure, safe, smooth and efficient messaging experience. We use our patent-pending “Ninja Mode” end-to-end encrypted messaging technology to provide a secure private message thread. Once the conversation is deactivated, the thread will delete itself and black line redactions will appear in the primary thread. Upon disabling Ninja Mode, all copies of conversations sent in Ninja Mode encryption will be deleted from the users devices and The Social App servers. In keeping with our commitment to use your data only for the successful operation of our services, The Social App does not use your data for ad targeting or other commercial purposes, and we do not host advertising in our App. To improve our services, we may use data we collect in an aggregated and de-identified form which cannot reasonably be used to identify you.
Information Provided Directly By You
We collect information you provide directly to us, such as when you request information, create or modify your personal account, request Services, complete a form, survey, questionnaire or application, contact customer support, make a subscription purchase through our Services, join or enroll for an event or otherwise communicate with us in any manner. This information may include, without limitation: name, date of birth, e-mail address, physical address, business address, phone number, photograph, user profile, or any other personal information you choose to provide.
Information Collected Through Your Use of Our Services
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you) and how you interact with other users of our Services and us. The following are situations in which you may provide Your Information to us:
1.) When you fill out forms or fields through our Services;
2.) When you register for an account with our Service. In order to enable you to connect with your contacts, when you register for an account with us you will provide us with your phone number and the phone numbers in your mobile device phonebook on a continual basis, including phone numbers of both the users of our Services and your other contacts;
3.) When you upload, share or post user-generated content (“User Content” as further defined in The Social App Terms of Service Here: https://thesocialapp.com/terms-and-conditions/ or other submissions to our Service;
4.) When you participate in forums, communities, groups, and reviews;
5.) When you order services from us and purchase a subscription for Services;
6.) When you provide responses to a survey or a questionnaire;
7.) When you join or enroll in an event through our Services;
8.) When you sign up for any newsletters or other materials through our Services;
9.) When you provide information to us through a third-party application, service or Website;
10.) When you communicate with us or request information about us or our products or Services, whether via email or other means;
11.) When you participate in any of our marketing initiatives, including, contests, events, or promotions.
12.) We also automatically collect information via the Website or App through the use of various technologies, including, but not limited to Cookies. Pixel Tags and Web Beacons (explained below). We may collect your IP address, browsing behavior and device IDs. This information is used by us in order to enable us to better understand how our Services are being used and allows us to administer and customize the Services to improve your overall experience.
Information Collected From Other Sources
We may also receive information from other sources and combine that with information we collect through our Services. For example if you choose to link, create, or log in to your account with a social media service, e.g. Facebook, LinkedIn or Twitter, or if you engage with a separate App or Website that uses our API, or whose API we use, we may receive information about you or your connections from that Site or App. This includes, without limitation, profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, your contact names, e-mail addresses, phone numbers, and other identifiers and any other information you permit the social network to share with third parties. The data we receive is solely dependent upon your privacy settings with the social network.
Cookies, Log Files and Anonymous Identifiers
1. When you visit our Services, we may send one or more Cookies – small data files – to your computer to uniquely identify your browser and let us help you log in faster and enhance your navigation through the Sites. “Cookies” are text-only pieces of information that a website transfers to an individual’s hard drive or other device or website browsing equipment for record keeping purposes. A Cookie may convey anonymous information about how you browse the Services to us so we can provide you with a more personalized experience, but does not collect personal information about you. Cookies allow the Sites to remember important information that will make your use of the site more convenient. A Cookie will typically contain the name of the domain from which the Cookie has come, the “lifetime” of the Cookie, and a randomly generated unique number or other value. Certain Cookies may be used on the Site regardless of whether you are logged in to your account or not.
2. Session Cookies are temporary Cookies that remain in the Cookie file of your browser until you leave the Site.
3. Persistent Cookies remain in the Cookie file of your browser for much longer (though how long will depend on the lifetime of the specific Cookie).
4. When we use session Cookies to track the total number of visitors to our Site, this is done on an anonymous aggregate basis (as Cookies do not in themselves carry any personal data).
5. We may also employ Cookies so that we remember your computer when it is used to return to the Site to help customize your web experience. We may associate personal information with a Cookie file in those instances.
8. We may use third-party services such as Google Analytics to help understand use of the Services. These services typically collect the information sent by your browser as part of a web page request, including Cookies and your IP address. They receive this information and their use of it is governed by their respective privacy policies. You may opt-out of Google Analytics for Display Advertisers including AdWords and opt-out of customized Google Display Network ads by visiting the Google Ads Preferences Manager here https://adssettings.google.com/authenticated?hl=en. To provide website visitors more choice on how their data is collected by Google Analytics, Google has developed an Opt-out Browser add-on, which is available by visiting Google Analytics Opt-out Browser Add-on here https://tools.google.com/dlpage/gaoptout. For additional information on how Google uses data when you use Google partners’ sites or apps, go here: https://policies.google.com/technologies/partner-sites.
12. When you use our Services, we may employ Web Beacons (also known as clear GIFs or tracking pixels) to anonymously track online usage patterns. No Personally Identifiable Information from your account is collected using these Web Beacons.
When you use our Services through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request and basic usage information about your use of our Services, such as date and time. In addition, we may collect information regarding application-level events and associate that with your account to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
When you use the Services we may collect your precise location data. We may also derive your approximate location from your IP address.
We do not knowingly collect personally identifiable information (PII) from persons under the age of 13 in the United States (“U.S.”), or under the age of 16 in the European Union (“EU”), the “Protected Age”. If you are under the Protected Age, please do not provide us with information of any kind whatsoever. If you have reason to believe that we may have accidentally received information from a child under the Protected Age, please contact us immediately. If we become aware that we have inadvertently received Personal Information from a person under the Protected Age, we will delete such information from our records.
Protective Measures We Use
We protect your information using commercially reasonable technical and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. Although we take measures to secure your information, we do not promise, and you should not expect, that your personal information, or searches, or other information will always remain secure. We cannot guarantee the security of our information storage, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet including, without limitation, email and text transmissions. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
The Legal Basis and Reasons For Collection and Processing Your Personal Information
The legal basis upon which we rely for the collection and processing of your Personal Information under the GDPR are the following:
3. It is necessary registering you as a user, managing your account and profile, and authenticating you when you log in;
4. It is necessary for our legitimate interests in the proper administration of our App, our Website and our business; analyzing the use of our Services; assuring the security of our App, our Website and our Services; maintaining back-ups of our databases; and communicating with you;
5. To resolve technical issues you encounter, to respond to your requests for assistance, comments and questions, to analyze crash information, to repair and improve the Services and provide other customer support;
6. To send communications via email and within the Services, including, for example, responding to your comments, questions and requests, providing customer support, and sending you technical notices, product updates, security alerts, and administrative and account management related messages;
7. It is necessary for our legitimate interests in the protection and assertion of our legal rights, and the legal rights of others, including you.
How We Use Information We Collect
We will not rent, sell, lease or barter your information to anyone unless you grant us explicit permission for this information to be shared in that manner. Our primary purpose in collecting, holding, using and disclosing your Information is for our legitimate business purposes and to provide you with a safe, smooth, efficient, and customized experience. We will use this information in order to:
1. Operate and provide our Services;Improve our internal operations, systems, products, and Services;
2. Provide users with customer support including, sending you related information, including confirmations, invoices, technical notices, updates, security alerts, and administrative messages;
3. Understand you and your preferences to enhance your experience and enjoyment using our Services;
4. Contact you and provide you with important notices;
5. Analyze, improve and manage our Services and operations;Contact you for administrative, account maintenance purposes;
6. Resolve problems and disputes, and engage in other legal and security matters;
7. Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
8. Enforce our Terms of Service and any terms and conditions of any agreements for our Services;
9. Send you communications we think will be of interest to you, including information about our products, services, promotions, news, and events of The Social App;
10. Verify your identity and prevent impersonation, spam or other unauthorized or illegal activity including, without limitation, infringement of intellectual property rights of third parties.
How We Share Information We Collect
1. With third party Service Providers to enable them to provide the Services you request;
2. With third parties with whom you choose to let us share information, for example other websites or apps that integrate with our API or Services, or those with an API or Service with which we integrate.With The Social App subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data verification, data centralization and/or logistics purposes;
3. With entities that provide payment processing services on our behalf;
4. With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
5. In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, court or legal process;
vii. With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our user agreements, Terms of Service, or policies, or to protect the rights, property, or safety of The Social App or others;
viii. In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
If we otherwise notify you and you consent to the sharing; and
In an aggregated and/or de-identified form which cannot reasonably be used to identify you. We only use such data in the aggregate form and our analytical services do not record any personal information.
2. We may disclose Your Information as follows:
1. To any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
2. As required by law or ordered by a court, regulatory, or administrative agency;
3. As we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with another’s rights or property, including, without limitation, our rights or property;
Sharing Information With Law Enforcement
1. The Social App is committed to cooperating with law enforcement while respecting each individual’s right to privacy. If The Social App receives a valid and enforceable subpoena for user account information from a government or law enforcement agency investigating criminal activity, we will review the request to be certain that it satisfies all legal requirements before releasing information to the requesting agency. No information will be released unless a valid and legally enforceable subpoena is received by The Social App.
2. In the event that we receive a valid and enforceable subpoena from a government or law enforcement agency, The Social App, in complying with the request, will incur certain expenses resulting from the retrieval process due to the fact that the data exists only in an encrypted, and difficult to retrieve, format. The Social App, depending upon the type of information being subpoenaed, reserves the right to demand and receive payment from the agency issuing the subpoena and/or from the user whose information is being subpoenaed by the agency.
Social Media Sharing
1 .Our Services may now, or in the future, integrate with social sharing features of social media sites, plug-ins, applications and other related tools which let you share actions you take on our Services with those other Apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.
2. Any information or content that you voluntarily disclose or share to a social sharing service becomes available to the public, as controlled by any applicable privacy settings that you set with that social sharing service. Once you have shared User Content or made it public, that User Content may be re-shared by others. If you remove information that you shared to the social sharing service, copies may still remain viewable in cached and archived pages, or if other users or third parties, using the social sharing service, have re-shared, copied or saved that User Content.
User Content and Public Sharing
Analytic Services Provided By Others
Links to Third-Party Websites
Do Not Track Settings
Some web browsers may give you the ability to enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked. This is different than blocking or deleting Cookies, as browsers with a “do not track” feature enabled may still accept Cookies. There currently is no accepted standard for how to respond to this signal, and we do not take any action in response to this signal.
International Privacy Practices
You may correct your account information at any time by logging into your online account. If you wish to cancel your account, please log in to your online account and follow the directions we provide or email us at email@example.com. Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have violated our Terms of Service, we may seek to resolve the issue before deleting your information.
Promotional Information Opt Out
Your Access and Rights to Your Personal Information
You have certain rights in relation to Personal Information we hold about you. You can exercise any of the following rights by contacting us using any of the methods in the Contact section below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
2. Right of Correction or Completion of Your Personal Data- If personal information we hold about you is not accurate, out of date or incomplete, you have a right to have the data corrected or completed. To make corrections to your account please contact us at the email address in our Contact section below.
3. Right of Erasure or Deletion of Your Personal Data. In certain circumstances, you have the right to request that personal information we hold about you is deleted. If we cannot delete the information you want, we will let you know and explain why. To request information deletion please contact us at the email address in our Contact section below.
4. Right to Object to or Restrict Processing of Your Personal Data- In certain circumstances, you have the right to object to our processing of your personal information. For example, you have the right to object to use of your personal information for direct marketing purposes. Similarly, you have the right to object to use of your personal information if we are processing your information on the basis of our legitimate interests and there are no compelling legitimate grounds for our processing which supersede your rights and interests. You may also have the right to restrict our use of your personal information, such as in circumstances where you have challenged the accuracy of the information and during the period where we are verifying its accuracy. To object to or restrict processing please contact us at the email address in our Contact section below.
5. Right to Data Portability or Transfer of Your Personal Data- You have the right to be provided with a copy of the information we maintain about you in a structured, machine-readable and commonly used format. To receive a copy of the information we maintain about you please contact us at the email address in our Contact section below.
6. Right to Withdrawal of Consent- If you have given your consent to us to process and share your Personal Information after we have requested it, you have the right to withdraw your consent at any time. To withdraw your consent please contact us at the email address in our Contact section below.
7. Right to Complain- If you’re based in the EU, you can file a complaint with the supervisory authority in your Member State.
Your California Privacy Rights
1. California Civil Code Section 1798.83 entitles California residents to request information concerning whether a business has disclosed Personal Information to any third parties for their direct marketing purposes. California residents may request and obtain from us once a year, free of charge, information about the personal information, if any, we disclosed to third parties for direct marketing purposes within the immediately preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information within the immediately preceding calendar year.If you are a California resident and would like to make such a request, please submit your request in writing to: firstname.lastname@example.org.
Our Information Retention Policy
Unless you request that we delete certain information, we retain the information we collect for as long as your account is active or as needed to provide you services. Following termination or deactivation of your account, we will retain information for at least 1 year and may retain the information for as long as needed for our business and legal purposes. We will only retain your Personal Data for so long as we reasonably need to unless a longer retention period is required by law (for example for regulatory purposes).
If you have any questions or if you would like to contact us about our processing of your personal information, including exercising your rights as outlined above, please contact us by any of the methods below. When you contact us, we will ask you to verify your identity.
Contact name: Data Protection Officer
Our office address:Social, Inc
1440 GST NW℅ GTOWN/SOCIAL
Washington DC, 20005
Last updated: August 1, 2019