Social Circle Privacy Policy

Our Social Circle and Sosho.ly Services track, trend, and evaluate influencers/creators and influencer campaigns everywhere across multiple platforms. We also provide Services for users to collaborate and connect with other users to make and find great content together. Any registered user of Social Circle or Sosho.ly can identify other users and any other Creators who’s content and profile is in the public domain.


Influencer/creator users of Social Circle Creator can sign up to Sosho.ly automatically and vice versa subject to our Terms & Conditions.


This Privacy Policy describes how and when we collect, use and share your information across our applications, websites, SMS, email notifications, APIs, buttons, widgets, ads, commerce services, and our other covered services that link to this Policy (collectively, the “Services”), and from our partners and other third parties. For example, you send us information when you use our Services on the web, via SMS, or from an application such as Social Circle, Social Circle.media or Sosho.ly. When using any of our Services you consent to the collection, transfer, storage, disclosure, and use of your information as described in this Privacy Policy. This includes any information you choose to provide that is deemed sensitive under applicable law.


When this policy mentions “we” or “us,” it refers to the controller of your information under this policy. Your information is controlled by Social Climbers Ltd, Unit B, Jack's Place, 16-22 Corbet Place, London, E1 6NH You alone control and are responsible for any posting of any content to Social Circle, Sosho.ly or any social media or digita media that may be reported or submitted on the Social Circle or Sosho.ly applications. as provided in the Terms of Service and Social Circle Rules


Irrespective of which country you live in, you authorise us to transfer, store, and use your information in the United States, Ireland, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live.


If you have any questions or comments about this Privacy Policy, please submit a request to privacy. [email protected].


Information Collection and Use


We collect and use your information below to provide, understand, and improve our Services.


Basic Account Information: If you choose to create a Social Circle or Sosho.ly account, you must provide us with some personal information, such as your name, username, password, email address, or phone number. On Social Circle, your username is listed publicly, including on your profile page and in search results, and you can use either your real name or a pseudonym. Some of our product features, such as searching and viewing public Sosho.ly user profiles do not require you or a viewer to create an account.


Contact Information: You may use your contact information to allow contact between brands and influencers to provide each other with the ability to directly communicate. We may also use the contact information such as your email address or phone number, to customize your account or enable certain account features, for example, for login verifation or Social Circle via SMS. If you provide us with your phone number, you agree to receive text messages to that number from us. We may use your contact information to send you information about our Services, to market to you, to help prevent spam, fraud, or abuse, and to help others find your account, including through third-party services and client applications. You may use your settings for email and mobile notifications to control notifications you receive from Social Circle. You may also unsubscribe from a notification by following the instructions contained within the notification or the instructions on our website. Your Discoverability privacy settings control whether others can find you on Social Circle by your email address or phone number. If you choose a third party such as manager, agent, parent or guardian as your preferred contact for other Social Circle or Sosho.ly users we do require your personal contact details for security purposes.


Additional Information: You may choose to provide us with additional information to help improve and personalize your experience across our Services. For example, you may choose to upload and sync your address book so that we can help you find and connect with users you know or help other users find and connect with you. We may later tailor content, such as making suggestions or showing user accounts for you and other users, based on imported address book contacts. You can delete your imported address book contacts at any time by visiting Contacts Control in your privacy settings. If you email us, we may keep your message, email address and contact information to respond to your request. When you connect your account on our Services to your account on another service in order to provide the Services with your user data or to cross-post between our Services and that service, the other service may send us your profile information or registration on that service and other information that you authorise. The registration information helps us improve the Services, and is deleted from our Services within a few weeks of your disconnecting from our Services your account on the other service.


Social Circle Profiles, Performance, Evaluation, Results Lists, Profile, and other Public Information: Social Circle is primarily designed to enable users to track, trend, evaluate and report on engagement across social media platforms in order for brands and influencers/creators to reach a fair and reasonable commercial arrangements or partnerships. Both Social Circle and Sosho.ly share the same core database. As an Influencer/ Creator, most of the profile information you provide us through Social Circle is information you are asking us to make public to brands.


You may provide us with profile information to make public on Social Circle, such as a short biography, your location, your website, your blog, interest tags, date of birth, or a picture. Additionally, your public information includes the content you create, on your social media posts and engagements, and any data accessed through the logins you have provided to us via platform APIs , such as audience demographics, engagements, when you posted and the client application or platform you used to post; information about your account, such as creation time, language, country, and time zone; and any content shared, liked, commented or any other interaction or engagement with content of any digital media or social media platform. Social Circle or Sosho.ly may disseminate your public information to a wide range of users, customers, and services, including search engines, developers, and publishers that integrate Social Circle or Sosho.ly data or content into their services, and organizations such as universities, public health agencies, and market research firms that analyse the information for trends and insights. If you share information or content like your user stats, photos, videos, and links via the Services, you should think carefully about what you are making public. Our default is almost always to make the information you provide through the Services public t brands and agencies for as long as you do not delete it, but we may provide you optional settings or features to make the information more private if you want. For certain profile information fields we provide you with SeeMe options to select who can see this information in your profile. If you provide us with profile information and you don’t see a visibility setting, that information is public. We may also provide you with time zone and language and settings associated with your account at any time using your account settings.


Social Circle Profiles, Performance, Evaluation, Results and Lists for Brands and Agencies: We do not make publicly identifiable any lists, profiles, campaigns or any results of any campaigns or commercially sensitive information that you have reported on the platform without your prior written consent. The data may however be anonymised to provide tools and features including but not limited to our Cost Per Enegagement Calculator to allow us to benchmark sector specific costs and performance and to develop any sentiment or sales and performance analysis by us or select third parties. The information provided to you or your company on the platform is not to be released to the public without our specific written consent. Logins are not transferable and if a registerd Brand or Agency side user leaves a company the company using the Services must take all necessary steps to ensure we are informed and any logins used by that individual have been erased.


Sosho.ly Profiles, Lists, Content, Forums, Performance and other Public Information: Sosho.ly is primarily designed to provide a platform for Creators and their fans to find and share new and aggregated content from all digital media and social platforms. Both Social Circle and Sosho.ly share the same core database. As an Influencer/Creator, most of the profile information you provide us through Sosho.ly is information you are asking us to make available to the public.


You may provide us with profile information to make public on Sosho.ly, such as a short biography, your location, your website, your blog, interest tags, date of birth, a video or a picture. Additionally, your public information includes the content you create; the metadata provided with your posts, such as when you posted and the client application or platform you used to post; information about your account, such as creation time, language, country, and time zone; and the lists you create, people you follow, and any content you share, like, comment or any other interaction or engagement with content any any digital media or social platform.


If you decide to allow us to sell goods or services through your shop in your profile we may use that information to sell other merchandise, goods or services across the platform and we may also disseminate your sales information to a wide range of customers, and services, including search engines, developers, and publishers that integrate Social Circle or Sosho.ly data or content into their services, and organisations that analyse the information for trends and insights. However, it is not our policy to make public any information with regards to income generated by Creators on Sosho.ly.


When you share information or content like photos, videos, blogs, and links via the Services, you should think carefully about what you are making public. We may use this information to make inferences, like what topics you may be interested in. We almost always try to make public the information you provide through the Services for as long as you do not delete it, but we will endeavour to give you settings or features that can allow private chat, collabs or content swaps. For certain profile information fields we provide you with visibility settings to select who can see this information in your profile. If you provide us with profile information and you don’t see a visibility setting, that information is public. You can change the language and time zone associated with your account at any time using your account settings, available at sohso.ly/usersettings.


121 and Non-Public Communications: We may provide certain features that allow you to communicate more privately at times. For example, you can use 121 to have private conversations with other SocialCircle users such as between influencers/creators and brands, or between Creators. When you privately communicate with others through our Services, such as by sending and receiving 121s, we will store and process your communications, and information related to them. Please note that if you share Social Circle content or stats created by Social Circle either via 121 or shared via any social media or digital channels, those interactions may be made public. While features like 121s are intended to be private, please remember that recipients may copy, store, and re-share the contents of your communications.


Location Information: We may receive information about your current location through Sosho.ly. For example, you may choose to publish your location in your social posts and in your Sosho.ly profile. We may also determine location by using other data from your device, such as precise location information from GPS, information about wireless networks or cell towers near your mobile device, or your IP address. We may use and store information about your location to provide features of our Services or to improve and customize the Services. If activated, you can turn off Location Services through our FindMe feature. If you do not have the option to turn off location information or the FindMe feature is absent, don’t worry, it means we are not collecting or using that data.


Links: We may keep track of how you interact with links across our Services, including our email notifications, third-party services, and client applications, by redirecting clicks or through other means. We do this to help improve our Services, or to be able to share aggregate click statistics such as how many times a particular link was clicked on. Links, campaigns, lists and non-public communications like 121s shared on the Services will be processed and links shortened.


Cookies: Like many websites, we use cookies and similar technologies to collect additional website usage data and to improve our Services, but we do not require cookies for many parts of our Services. A cookie is a small data file that is transferred to your computer or mobile device. We may use both session cookies and persistent cookies to better understand how you interact with our Services, to monitor web traffic routing on our Services, aggregate usage by our users and to customize and improve our Services. Although most web browsers automatically accept cookies, some browsers’ settings can be modified to decline cookies or alert you when a website is attempting to place a cookie on your computer. However, some Services may not function properly if you disable cookies. We honor the Do Not Track browser option to give you control over how your website visits are used to personalize your Social Circle and Sosho.ly experience.


Using Our Services: We receive information (“Log Data”) when you interact with our Services, even if you have not created an account. For example, when you sign into our Services, visit our websites, , interact with our email notifications, use your account to authenticate to a third-party website, application, or service.we may receive information about you. This Log Data may include your browser type, IP address, operating system, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms, or cookie information. We use Log Data to make inferences, like what topics you may be interested in, and to customize the content we show you. We keep Log Data as needed for the purposes described in this Privacy Policy. We will either delete Log Data or remove any common account identifiers, such as your username, full IP address, email address, or phone number, after a maximum of 18 months, if not sooner as provided below for Widget Data.


Widget Data: We may tailor the Services for you based on your visits to third-party websites that integrate with Social Circle or Sosho.ly . When these websites first load our buttons or widgets for display, we receive Log Data that includes the web page you visited and a cookie that identifies your browser (“Widget Data”). After a maximum of 10 days, we start the process of deleting, de-identifying, or aggregating Widget Data, which is usually instantaneous but in some cases may take up to 2 weeks. We may use Widget Data to tailor content for you, such as suggestions for people to follow and other content you may be interested in. Tailored content is stored separately from other Widget Data such as page-visit information. If we are storing this data you can control this feature from the Data Setting within your Security and Privacy Settings, available at socialcircle.media/settings. If there is no option to control the feature we are not storing this data.


Commerce Services: You may provide your payment information, including your credit or debit card number, card expiration date, CVV code, and billing address (collectively, “Payment Information”), along with your shipping address, to complete a commerce transaction through our Services. To facilitate future purchases, we store your Payment Information (excluding CVV code) and shipping address, which you can remove from your account at any time using your account settings. We consider your Payment Information and shipping address private and do not make such information public. To facilitate order fulfillment, we collect and store information created by your purchases made through our Services (“Transaction Data”). Transaction Data may include the seller’s name and the date, time, and amount of the transaction.


Third-Parties and Affiliates: We may receive information about you from third parties, such as other Social Circle users, partners or our corporate affiliates. For example, other users may share or disclose information about you, such as when they mention you, share a photo of you, or tag you in a photo. Our ad partners and affiliates may share information with us such as a browser cookie ID, mobile device ID, or cryptographic hash of a common account identifier (such as an email address), as well as demographic or interest data and content viewed or actions taken on a website or app. Our ad partnersmay enable us to collect similar information directly from their website or app by integrating our advertising technology.


Information Sharing and Disclosure We do not disclose your private personal information except in the limited circumstances described here.


User Consent or Direction: We may share or disclose your information at your direction, such as when you authorise a third-party web client or application to access your account or when you direct us to share your feedback. If you’ve shared information, like 121s, with another user who accesses Social Circle through a third-party service, keep in mind that the information may be shared with the third-party service.


Service Providers: We engage service providers to perform functions and provide services to us in the UK, United States, Asia, Ireland, and other countries. For example, we use a variety of third-party services and platforms to help provide our Services, such as content, hosting our various content streams, in-app shops, payment gateways, and to help us understand and improve the use of our Services, such as Google Analytics. We may share your private personal information with such service providers subject to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and on the condition that the third parties use your private personal data only on our behalf and pursuant to our instructions. We share your Payment Information with payment services providers to process payments; prevent, detect and investigate fraud or other prohibited activities; facilitate dispute resolution such as chargebacks or refunds; and for other purposes associated with the acceptance of credit or debit cards.


Commerce Transactions: If, at any stage you make a payment as part of a commercial transaction through our Services, we may provide the seller, commerce provider, marketplace, or charity with your name, email address, shipping address, Payment Information and Transaction Data to facilitate payment processing, order fulfillment, and dispute resolution (including payment and shipping disputes) and to help prevent, detect, and investigate fraud or other prohibited activities. Please refer to these third parties’ privacy policies for information about their privacy practices.


Law and Harm: Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process of government request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our users’ rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.


Business Transfers and Affiliates: In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. This Privacy Policy will apply to your information as transferred to the new entity. We may also disclose information about you to our corporate affiliates in order to help provide, understand, and improve our Services and our affiliates’ services..


Public or Non-Personal Information: As an Influncer/Creator we may share or disclose your public, aggregated or otherwise non-personal information, such as your public user profile information, the people you follow or that follow you, the number of times people engaged with your content (for example, the number of users who clicked on a particular link, or reports to advertisers about unique users who saw or clicked on their ads after we have removed any private personal information.. Information, like your username are always public on Social Circle, unless you delete your profile and account as described below.


Accessing and Modifying Your Personal Information


If you are a registered user of our Services, we provide you with tools and account settings to access, correct, delete, or modify the personal information you provided to us and associated with your account. You can download certain account information on request by contacting our User suppor team here.


You can also permanently delete your SocialCircle public profile account. If you follow the instructions here, your account will be deactivated and then deleted. When deactivated, your account, including your name, username, and public profile, is not publicly viewable on socialcircle.media. For up to 30 days after deactivation it is still possible to restore your account if it was accidentally or wrongfully deactivated. Absent a separate arrangement between you and us to extend your deactivation period, after 30 days, we begin the process of deleting your account from our systems, which can take up to a week.


Keep in mind that search engines and other third parties may still retain copies of your public information, like your user profile information and public content, even after you have deleted the information from the Social Circle Services or deactivated your account.


Our Global Operations


To bring you the Services, we operate globally. Social Climbers Ltd complies with the EU-US Privacy Shield principles (the “Principles”) regarding the collection, use, sharing, and retention of personal information from the European Union.


If you have a Privacy Shield-related complaint, please contact us here. As part of our participation in Privacy Shield, if you have a dispute with us about our adherence to the Principles, we will seek to resolve it through our internal complaint resolution process, alternatively through the independent dispute resolution body JAMS, and under certain conditions, through the Privacy Shield arbitration process.


Privacy Shield participants are subject to the investigatory and enforcement powers of the US Federal Trade Commission and other .authorised statutory bodies. Under certain circumstances, participants may be liable for the transfer of personal information from the EU to third parties outside the EU. Learn more about Privacy Shield here.


As described in this Privacy Policy, we may share information with our corporate affiliates and third parties and may be required to disclose information in response to valid governmental requests, including under applicable law enforcement or national security requirements.


Social Climbers Ltd. also complies with the US-Swiss Safe Harbor Framework and principles, , and applies the Privacy Shield Principles to information from Switzerland.


Changes to this Policy


We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at socialcircle.media If we make a change to this policy that, in our sole discretion, is material, we will notify you via an @socialcircle.media update or email to the email address associated with your account. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.


Effective: August 2017


Thoughts or questions about this Privacy Policy? Please, let us know by contacting us or writing to us at the appropriate address below.