(Data Controller) Last updated: September 09, 2021
Social27 Inc. (“Social27”, “we”, “us” or “our”) is committed to protecting your privacy, as well as our clients and prospective clients (the “Client/ s”), and other users of the www.Social27.com website (the “Site”) and services, and we want to ensure that you have a positive experience when you use our video conferencing and communication services (the “Services”), visit our Site webpages, interact with us on social media, or attend a Social27 sponsored event online or offline.
When we collect information that relates to an identified or identifiable individual (the “Personal Data” or “Personal Information”), we may be doing so one of two ways, (i) on our own behalf (in which case we will be considered a “controller” of your data), and (ii) your personal information, also referred to as the “Platform Content” may be collected on behalf of a Client who is using the Services through SOCIAL27’s Virtual Communication Platform, which includes services related to our Webinars, Virtual Environments, Channels, and Portals (collectively, the “Platform”) to organize an event and manage other event-related activities (in which case, the Client will be the “controller” and Social27 will be considered a “processor” of your Personal Information/Platform Content). The Personal Information we collect and how we use it varies depending upon the nature of our relationship, and whether Social27 is the data controller or data processor.
For the purposes of the EU General Data Protection Regulation (the “GDPR”) and other relevant applicable laws SOCIAL27 is the controller of your personal information collected pursuant to this Policy. With respect to any Platform Data, our Clients are the data controllers or businesses for their respective Platform Data, and we are a data processor or service provider, as defined under applicable privacy laws.
If you are invited to, register for, check into, or receive information regarding a Client event through a Client Site or Service, you will be considered an “Event Attendee” and we will provide any Personal Information you submit through the Site or Service to the Client organizing that event via the Event Attendees, participants and other end users of the Platform and/or Client events the “Platform Data”. Social27 does not control the Client’s event registration or management process or determine the Platform Content that a Client requests from Event Attendees. When SOCIAL27 collects, submits, manages, creates, or records Platform Data via the Platform, or the Personal Information Social27 collects, accesses, stores, uses or otherwise processes (collectively, “process”) in order to provide our Services to Clients; we will only Process such Platform Data on behalf of the particular Client in order to provide our Services to that Client. As a processor, our collection, use, disclosure and other processing of Platform Data on behalf of Clients is subject to the privacy policy of our respective Clients. Please see the SOCIAL27 Platform Privacy for information about our processing of Platform Data. As set out in the SOCIAL27 Platform Privacy Policy, SOCIAL27 is a processor of the Platform Data; we only use the personal information that we Process as part of the Platform Data subject to our agreements with Clients and their written instructions, or where otherwise required by law. This Policy also does not apply to job applicants and candidates who apply for employment through our job application portal, or to employees and non-employee workers, whose personal information is subject to different privacy notices. Please see the SOCIAL27 Platform Privacy for information about our processing of Platform Data.
Social27 collects, or may collect, if requested by a Client, the following types of Personal Information:
If you are a California resident, please be sure to review the section “Additional Information for Individuals in Certain Jurisdictions” below for important information about our privacy practices and your rights under California privacy laws, including your right to submit a request.
In general, Social27 may use and disclose the Personal Information we collect for the following business and commercial purposes:
If you are a California resident, please be sure to review the section “Additional Information for Individuals in Certain Jurisdictions” below for important information about our privacy practices and your rights under California privacy laws, including your right to submit a request.
The Personal Information that Social27 collects and processes will vary depending upon the circumstances. You do not have to provide us with your Personal Information to access certain sections of the Site. If you choose not to disclose certain Personal Information, you can still visit our Site, but you will not be able to create an account with us, and you may not be able to access certain options and services, and we may be unable to fully respond to your inquiries.
We may collect personal information about you directly from you or from the Client. For example, when you fill out a ‘Contact Us’ form, signup for our mailing lists, or register for events we host or sponsor, or otherwise provide us information through the Site, we may collect Personal Information such as:
We use cookies, log files, pixel tags, local storage objects, and other tracking technologies to automatically collect information when users access or use the services or visit the Site, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring/exit URLs, operating system, language, clickstream data, and other information about the links clicked, features used, size of files uploaded, streamed or deleted, and similar device and usage information. For more information, see the Cookies and Similar Devices section below.
We may collect personal information about you from third party sources, such as business partners, social media platforms, public sources, joint marketing partners (so that we can deliver our Platform and related services) and third parties to whom you have expressed interest in our products and services, as well as information that you shared on social media platforms (subject to the respective Platform terms and applicable laws.
The purposes for which we may process personal information will vary depending upon the circumstances. In general, we use Personal Information for the business and commercial purposes set forth below, and where the GDPR or other relevant laws apply, we have set forth the legal bases for such processing in parenthesis (see above for further explanation of our legal bases):
We also create and use aggregate, anonymous and de-identified data to assess, improve and develop our business, products and Services, and for similar research and analytics purposes. This information is not generally subject to the restrictions in this Policy, provided it does not identify and could not be used to identify a particular individual.We may share aggregate, anonymous or de-identified data with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.
In general, we disclose the Personal Information we collect for the business and commercial purposes explained below:
We and our third-party service providers use “cookies,” pixels, java script, log files, and other mechanisms on the Site. For more detailed information about the use of cookies on the Site and how you can manage your cookie preferences, you can review our Cookie Policy found here
A “cookie” is a small text file that may be used, for example, to collect information about website activity. Some cookies allow us to make it easier for you to navigate the Site, while others are used to enable a faster log-in process or to allow us to track your activities while using the Site. Most browsers allow you to control cookies, including whether or not to accept them, and how to remove them. See our Cookie Policy or more information.
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (also referred to as web beacons, web bugs or pixel tags), in connection with our services to, among other things, track the user activities of our Services, help us manage content, and compile statistics about usage of our Services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
Most browsers collect certain information, such as your IP address, device type, screen resolution, operating system version, and internet browser type and version. This information is gathered automatically and stored in log files.
We also use automated devices and applications to evaluate use of our Services. We use these tools to gather non-personal information about users to help us improve our Site and services, as well as user experiences. These analytics providers may use cookies and other technologies to perform their services and may combine the information they collect about you on the Site with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties.
The Site does not respond to do-not-track signals. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies) and set out in our Cookie Policy.
SOCIAL27 is headquartered in the United States and has operations and service providers in the United States and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions (including but not limited to the United States, and the European Union (“EU”)), that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.
If you are in the European Economic Area (“EEA”), and we process your Personal Information in a jurisdiction that the European Commission has deemed to not provide an adequate level of data protection (a “third country”), we will implement measures to adequately protect your Personal Information, such as putting in place standard contractual clauses approved by the European Commission or another measure that has been approved by the EU Commission as adducing adequate safeguards for the protection of Personal Information when transferred to a third country. You have a right to obtain details of the mechanism under which your Personal Information is transferred outside of the EEA; you may request such details by contacting us as set forth in the Contact Us section below.
SOCIAL27 does not publish content that is targeted at children. The Site is not intended for minors under the age 13. We do not knowingly or specifically collect information about minors under the age of 13. If you believe we have unintentionally collected such information, please notify us as set out in the Contact Us section below.Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers.If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information.
Wherever your Personal Information may be held within SOCIAL27 or on its behalf, we take reasonable steps to protect the Personal Information that you share with us from unauthorized access or disclosure, including, without limitation, restricting access to certain portions of our Site through access controls, and using firewalls. Regardless of the precautions taken by us, SOCIAL27 cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk. You are responsible for all actions taken with your User ID and password, if any. Therefore, we recommend that you do not disclose your password to anyone. If you lose control of your password, you may lose substantial control over your Personal Information and may be subject to legally binding actions taken on your behalf.
If you wish to access Personal Information that you have submitted to us, to request the correction of any inaccurate information you have submitted to us, or to request deletion of your information, please send your request to privacy@Social27.com. We will review your request and make reasonable efforts to respond to it as soon as practicable. We may ask you for additional information so that we can confirm your identity.
You may always opt-out of direct marketing emails. If you would like to unsubscribe from SOCIAL27 email subscriptions or otherwise change your email preferences with SOCIAL27, please click [Put your link Here] or follow the instructions in any SOCIAL27 promotional email that we send to you. We may continue to send you transactional or service-related communications, such as service announcements and administrative messages.
We will take steps to try to resolve any complaint you raise regarding our treatment of your Personal Information. You also have the right to raise a complaint with the privacy regulator in your jurisdiction. Expected response time for privacy inquiries and requests is upto 30 days
In the section “Additional Information for Individuals in California and Europe” below, we provide additional information as required under California privacy laws, as well as the GDPR. Users in California and the EEA should review this section for more information regarding their rights under these respective laws.
As a general rule, we retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected or as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements. In general, for example, we will retain relevant contact information of Clients, prospective Clients and Site visitors for three years from the date of our last interaction with you and in compliance with our obligations under applicable laws. Our Clients instruct us on how long to retain Platform Data, which we handle as a data processor. We may retain Personal Information for longer where required by our regulatory obligations, professional indemnity obligations, or where we believe necessary to establish, defend, or protect our legal rights and interests or those of others.
For the Social27 Events Platform:
SOCIAL27 may update this Policy to reflect new or different privacy practices or to reflect changes in industry standards or legal requirements. Revisions will be posted on our Site. This statement of privacy is for the information of our users and does not constitute a contract or modification of any contract. When changes are made to this Privacy Policy, SOCIAL27 will post a new version of this Privacy Policy . If the changes will materially affect the way we use or disclose your Personal Information, we will endeavor to notify you in advance of the change, such as by sending a notice to the primary email address associated with your account or by posting a notice on the Site. We encourage you to periodically review this Privacy Policy for the latest information on our privacy practices.
The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly affects him or her.Right not to be subject to automated decision-making: You have the right not to be subject to a decision when it is based on automatic processing if it produces a legal effect or similarly significantly affects you, unless it is necessary for entering into or performing a contract between us. Data subjects can request more information on an automated decision by writing an email to privacy@social27.com
International data transfers to and from the EU that have not been deemed to provide an adequate level of data protection by the European Commission are protected through standard contractual clauses or other approved transfer mechanisms. Internally, Social 27 has implemented standard contractual clauses between each of its legal entities to ensure that all data transfers within the company are conducted pursuant to a legally sufficient transfer mechanism including encrypted email through GDPR compliant partner entities like Microsoft Outlook.
It is understood that in order to comply with this right to access Social 27 must provide the individual requesting access to their data, both confirmation that their data is being processed and access to their personal data.Data subjects can request more information on an automated decision by writing an email to privacy@social27.com
SOCIAL27 welcomes your comments regarding this Privacy Policy.
Please feel free to contact us at:
Social27 Inc.
Data Protection Officer: Bally S. Kehal
Data Controller: Dalvir Singh
Data Processors: Ranbeer Gill, Govind Singh
2733, 152 ND AVE NE Redmond, WA, 98052
Phone:1.800.720.4851
Email: privacy@social27.com
Individuals in the EU may also contact us through our office at:
Klimentská 46
Prague 1 110 02
Czech Republic
In this section, we provide additional information for California residents about how we handle their Personal Information, as required under California privacy laws, including the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the CCPA.
While our collection, use and disclosure of Personal Information varies based upon our relationship and interactions with you, in this section we describe, generally, how we have collected and disclosed Personal Information about consumers in the prior 12 months.
The table below identifies the categories of personal information (as defined by the CCPA) we have collected about consumers, as well as how we have disclosed such information for a business purpose. For more information about the business and commercial purposes for which we collect, use and disclose personal information, please see the Purposes and Legal Bases and the Disclosures of Personal Information sections above.
Under the CCPA, a “sale” includes disclosing or making available Personal Information to a third-party in exchange for monetary compensation or other benefits or value. We do not disclose Personal Information to third parties in exchange for monetary compensation.
As further described in the “Information We Collect” section above, we may collect Personal Information from the following sources:
In general, California residents have the following rights with respect to their personal information:
Requests to Know and Requests to Delete may be submitted: By email at privacy@Social27.com When you submit a request to know or a request to delete, we will take steps to verify your request by matching the information provided by you with the information we have in our records. You must complete all required fields on our webform (or otherwise provide us with this information via the above toll-free number) and verify your email address. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us as set forth in the Contact Us section above; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.For more information about our privacy practices, you may contact us as set forth in the Contact Us section above.
Below, we inform about other rights, including the GDPR and similar applicable laws, that may apply to you. Subject to the conditions set out in the applicable law, individuals in in the EU/EEA have the following rights with regards to our processing of their personal information:
Please contact us as set out in the Contact Us section above to exercise one of these rights. If we receive any requests from individuals related to the Platform Data, we will forward the request to the relevant Clients to address.
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Last updated: September 13, 2020
Social27, Inc. (“SOCIAL27,” “we”, “us”, or “our”) understands the importance of privacy. This Platform Privacy Policy (this “Policy”) explains how SOCIAL27 collects, stores, uses and shares personal information collected, stored or processed by us through SOCIAL27’s video conferencing and communication services (the “Services”), which includes services related to our webinars, virtual environments, and portals (collectively, the “Platform”). In this Policy, “personal information” is information that identifies or could be used to identify an individual (“Personal Information”) and is also referred to as “personal data” in our Data Controller Privacy Policy.
The SOCIAL27 Platform is a video conferencing and communication tool used by businesses, including direct clients of SOCIAL27 and their employees and agents authorized to access the Platform as administrators and that host or organize the Platform events (collectively the “Client/s”) to deliver webinars and other content to registrants, attendees, participants, and other end users that access the Site (the “End Users”, or “Event Attendees”). Collectively, End Users and Clients are “Platform Users”. The End User may have entered a Subscription Services Agreement or other agreement with Client containing separate terms and conditions that govern delivery, access and use of the Platform by the End User (a “Client Agreement”).Social27 Inc. (“we”, “us”, “our” or “Social27”) collects your personal data (the “Data”) directly from you (“you”, “your” or the “End User”), through our mobile and web applications (the “Platform”). This Privacy Policy explains how we collect, use, and disclose your information. All capitalized terms not otherwise defined in this Privacy Policy shall have the same definitions ascribed to them in the Terms and Conditions.
This Policy applies to the Personal Information that SOCIAL27’s Clients submit to us via the Platform, as well as the Personal Information we collect, access, store, use or otherwise process (collectively, “process”) via the Platform on behalf of Clients, including but not limited to registration information and Platform User communications, as well as other Personal Information we process from End Users of the Platform (together the “Platform Data”).
With respect to the Platform Data, SOCIAL27 is a “data processor” or “service provider” under applicable data protections laws. As a data processor or service provider, we will only process the Platform Data pursuant to our Client’s instructions, as set forth in our applicable client agreements, and as otherwise required by applicable privacy and data protection laws. This Policy does not apply to processing of Platform Data or any other Personal Information collected via the Platform by Clients, which is subject to the Clients’ own policies and practices.For more information about how SOCIAL27 processes Personal Information as a controller, please see the SOCIAL27 online Data Controller Privacy Policy.If you are invited to, register for, check into, or receive information regarding a Client event through our Site or Service, you will be considered an “Event Attendee” and we will provide any Personal Information you submit through our Site or Service to the Client organizing that event. Social27 does not control the Client’s event registration or management process, or the Personal Information that a Client requests from Event Attendees.When we collect information from you, we may be doing so on our own behalf (in which case we will be considered a “controller” of your data, subject to the Social27 Data Controller Privacy Policy), or on behalf of a Client who is using the Services to organize an event and manage other event-related activities (in which case, the Client will be the “controller” and SOCIAL27 will be considered a “processor” of your data).
If you choose to store any Sensitive Personal Information on our servers, you are responsible for complying with any regulatory controls regarding that data.We do not encourage end users to share any personal information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (for the purpose of uniquely identifying a natural person), data concerning health, or data concerning a natural person's sex life or sexual orientation. Sharing of personal data may be a threat and end users are responsible for sharing this type of information.
If you are a child under the age of 13, you may not have an Account on Social27. Social27 does not knowingly collect information from or direct any of our content specifically to children under 13. If we learn or have reason to suspect that you are a User who is under the age of 13, we will have to close your Account.
Account Information
To access various parts of the Platform, and to create webinars and events, you must have an online account. To register for an account on the Platform, you must provide your name, email address, telephone number, company name, and other information necessary to confirm that you are an authorized user of Client (where relevant). We may also collect additional information such as job title, information about your company (such as country and industry sector) and other End User profile information such as age, gender, zip code, and areas of special interest to you. Our processing of account information is subject to the SOCIAL27 Data Controller Privacy Policy.
End User Information
To access webinars, virtual environments and other events administered by Clients via the Platform as an End User, you may be required to register. While our Clients determine what information to collect from End Users, the requested Personal Information typically includes name, email address, telephone number, company name and job title as well as information about your company such as country and industry sector.
User Communications
When you send email or other communication to SOCIAL27 or another user, we may retain those communications in order to process your inquiries, respond to your requests and to improve our Services.
Affiliated Sites
We may offer services in connection with other websites or suppliers. Personal information that you provide to those sites may be sent to us in order to deliver these services. We process such information in accordance with this Policy.
Other Information
SOCIAL27’s Clients may request additional information, like surveys or polls, be filled out in some webinars or virtual environments. Clients are responsible for configuring the Platform to collect this information, which may include Personal Information.
Log Information
When you use SOCIAL27, our servers record, in a server log, information that your browser sends whenever you visit a website. Server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
Cookies, clear GIFs, etc
The Platform may use cookies (small pieces of information that are stored by your browser on your computer’s hard drive), clear GIFs, java script and other technology to collect and store information about your use of the Platform, such as your search activity, the pages you view, and the date and time of your visit, your browser type, type of computer or mobile device, browser language, IP address, mobile carrier, unique device identifier, location information, and requested and referring URLs. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information. Please see our Cookie Policy for more information.
SOCIAL27 may process (i.e., collect, use and disclose) aggregate de-identified information, and other information that is not personally identifiable, for research, analytics and other purposes, provided such information does not identify, and could not reasonably be used to identify a particular Client or End User.
Social27 may use your Personal Information:
SOCIAL27 uses the personal information we collect via the Platform to provide our services to Clients, including to operate and improve the Platform and our services, to provision Platform Users’ accounts, to carry out the transactions Platform Users request via the Platform, and to respond to Platform User requests. We do not encourage data subject below 18 years of age to register on our platform.
Clients may use the Personal Information they collect via the Platform for additional purposes, such as to deliver targeted content within the Platform, to contact Platform Users about their use of the Platform, for marketing and promotional purposes, and for other purpose; you should review the Clients’ privacy policies for more information about how they collect, use and share the Personal Information collected via the Platform.
As noted, Platform User information, including Personal Information, is shared with the Client upon whose behalf the information was collected or Platform is being operated; this Policy does not apply to the processing (including collection, use and sharing) of Platform User personal information by Clients, and we are not responsible for such processing.
SOCIAL27 will not share Personal Information about Platform Users with third parties except to provide the products or services you have requested, with consent, or under the following circumstances:
Third parties who process Personal Information on our behalf must agree to use such personal information only for the purpose for which it is provided by us and they must contractually agree to provide adequate protections for personal information; SOCIAL27 will continue to be liable for any onward transfers of Personal Information to such third parties.
We will only retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and processed, or until you request deletion as described in this Policy. SOCIAL27 will retain Personal Information we collect from our Clients or Event Attendees, and process on behalf of a Client, for as long as necessary to provide our Services to the Client, and will maintain any such information controlled by a Client in accordance with the Client’s instructions, including any applicable Client Agreement terms, and as required by applicable law.We will also retain and use Personal Information for a period of time required to comply with our legal, tax, audit or regulatory obligations, to resolve disputes, and to enforce our agreements. SOCIAL27 may retain non-Personal Information for as long as necessary for the purposes and uses described in this Privacy Policy, including as necessary for SOCIAL27 to pursue legitimate and lawful business interests.
End Users have the right to access the Personal Information that is maintained about them, and in some cases to limit use and disclosure of such information. Registered End Users may log into their accounts to view and amend certain personal information in their profile. EU End Users who would like to request access to, to limit use of, or to limit disclosure of their Personal Information collected via the Platform by a Client should contact that Client directly; EU End Users may also make such requests by contacting us at privacy@Social27.com and providing the name of the Client. We will refer such requests to that Client and will support them as needed in responding to your request.
SOCIAL27 makes it a priority to safeguard the security and privacy of your Personal Information.These measures include security controls to prevent unauthorized access to our facilities and systems, strong authentication procedures and strict password protection protocols.While we take reasonable steps to protect your Personal Information, should you have any questions about security on our Sites, you can contact us using the information in the Contact Us section below.
To secure your personal information access to your data is password protected, and sensitive information is protected by encryption when it is exchanged between your Web browser and our Web site. It is your responsibility to keep your password confidential and not to share this information with anyone. While we will implement the security measures detailed above, transmission of information via the internet is not completely secure and therefore transmission via the internet is at your own risk.
Your privacy is important to us. End Users who have any questions, complaints, or disputes regarding this Policy or the manner in which SOCIAL27 handles or protects Personal Information may contact us at privacy@social27.com We will promptly investigate and attempt to resolve any complaints and disputes and will respond within 45 days of receiving any such complaint. We take complaints seriously, and it will be assessed by qualified staff with the goal of resolving it in a timely manner. Subject to applicable law, you also have the right to lodge a complaint with your local data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority.
SOCIAL27 may update this Policy from time-to-time, so please review it frequently. In the event we make material changes in the way we treat End User Personal Information, we will notify you by email.
Please contact us with any questions about this Policy:
Social27 Inc.
Data Protection Officer: Bally S. Kehal
Data Controller: Dalvir Singh
Data Processors: Govind Singh
2733, 152 ND AVE NE Redmond, WA, 98052
Phone:1.800.720.4851
Email: privacy@social27.com
Individuals in the EU may also contact us through our office at:
Klimentská 46
Prague 1 110 02
Czech Republic