SOCIAL CIRCLE PRIVACY POLICY ("POLICY")

Social Climbers Limited ("we", "us", "our"), is committed to protecting and respecting your privacy.  

SCOPE OF POLICY

 

This Policy (together with the Social Circle Protocol –Terms and Conditions of Use and any additional terms of use incorporated by reference into these Terms and Conditions of Use) ("Terms") applies to your use of:

  1. The Social Circle Platform ("Social Circle" or the "Platform") – whether accessed via our website socialcircle.media or in mobile application software form in any format ("App") - once in use by you via any computer or handheld or other mobile form of device ("Device"); and
  2. Any of the services, the Social Circle Platform Services, accessible through the App ('Services') that are available through socialcircle.media or any other site of ours ('Services Sites'), unless the Terms states that a separate privacy policy applies to a particular Service in which case that privacy policy only applies.
 

This Policy sets out the basis on which any personally identifiable information (PII)/personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your PII/personal data and how we will treat it.

When using any of our Services you consent to the collection, transfer, storage, disclosure, and use of your information as described in this Policy. This includes any information you choose to provide that is deemed sensitive under applicable law.

For the purpose of the Data Protection Act 1998, the data controller is Social Climbers Limited (number 10225838) a company registered in England and Wales with its registered office at 12 King James Avenue, Cuffley, Potters Bar, Hertfordshire, EN6 4LR, United Kingdom.

 
  1. INFORMATION WE COLLECT FROM YOU AND HOW WE USE THAT INFORMATION
      We will collect and process the following data about you to provide, understand, and improve our Services:
    1. Basic Account Information: If you choose to create a Social Circle account, you must provide us with information such as your name, username, password, email address, or phone number. On Social Circle, your username is listed and made available to anyone who signs up to the Platform Services, and will be included on your Profile page and in search results.
    2. Contact Information: We may use your contact information to allow contact between Brands and Creators to provide each other with the ability to directly communicate. We may also use your contact information such as your email address or phone number, to customise your account or enable certain account features, for example, for login verification or Social Circle via SMS. If you provide us with your mobile 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. If the Services enable you to identify a third party such as a manager, agent, parent or guardian as your preferred contact for other Social Circle users, we will nevertheless require you to provide your personal contact details which will be held for security purposes only, and not disclosed to third parties.
    3. Additional Information: You may choose to provide us with additional information to help us improve and personalise 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 Platform users you know, or help other Platform users find and connect with you. We may later tailor content, such as making suggestions or showing Platform user accounts for you and other Platform users, based on imported address book contacts. If you email us, we may keep your message, email address and contact information to respond to and otherwise deal with your request. When you connect your account on our Services to your account on another third party service in order to provide the Services with your user data or to cross-post between our Services and that third party service, the other third party service may send us your profile information or registration on that third party 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 third party service.
    4. Social Circle Profiles, Performance, Evaluation, Results Lists, Profile, and other Public Information: Social Circle primarily enables Platform users to track, trend, evaluate and report on engagement across social media platforms in order for Brands and Creators (as influencers) to reach fair and reasonable commercial arrangements or partnerings. If you are a Creator (an influencer) you acknowledge that the Profile information you provide to us through Social Circle is information you are expecting and requesting us to make available to Brands.
    5. Accordingly, Profile information you may provide to us will be made public on Social Circle, for example a biography, your location, your website, your blog, interest tags, date of birth, or any picture or image. Additionally, your information made public will include the content you create on your social media posts and via your engagements, together with any data accessed through any third party platform logins you have provided to us via Platform APIs. The latter may include audience demographics, engagements, when you posted and the client application or third party 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 third party provided digital media or social media platform (any or all of these we refer to in this Policy as your "public information").
    6. We may disseminate your public information to a wide range of users, customers, and services, including search engines, developers, and publishers that integrate Social Circle data or content into their services, and organisations such as universities, public health agencies, and market research firms that analyse the information for trends and insights. If you share information or content such as your user statistics, photos, images, videos, and links via the Services, you should think carefully about what you are sharing as it will become your public information and be made public by us.
    7. We will always make your public information which you provide to us through your use of the Services available to Brands (and representing agencies) for as long as you do not delete that information or you chosse to make the information private or restricted, but we may provide you optional settings or features to make the information more private if you choose to do so. 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 no such visibility setting is made apparent, that category of Profile information will be your public information. We may also provide you with time zone and language settings associated with your account at any time using your account settings.
    8. Non-Public and 121 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 Platform users such as between Creators and Brands, or between Creators. When you privately communicate with others through our Services, such as by sending and receiving 121's, we will store and process your communications, and information related to them. You acknowledge that if you share our content or stats created by us either via 121 or shared via any third party social media or third party digital channels, we may make those interactions that you have engaged in publicly available. While features like 121's are intended to be private, please remember that recipients may copy, store, and re-share the contents of your communications.
    9. Location Information: We may receive information about your current location through the Services. We may determine your location by using data from your Device, such as precise location information from GPS, information about wireless networks or cell towers near your Device, or your Device's IP address. We may use and store information about your location to provide features of our Services or to improve and customise the Services. If activated, you can turn off Location Information 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 that data.
    10. Links:  We may keep track of how you interact with links across our Services, including our email notifications, third-party provided 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 aggregated click statistics such as how many times a particular link was clicked on. Links, campaigns, lists and non-public communications like 121's shared on the Services will be processed and links shortened.
    11. Social Circle performance profiles, performance, evaluation, results and lists for Brands (and representing agencies): If you are a Brand (or an agency entity), we do not make publicly identifiable any lists, performance profiles, campaigns or any results of any campaigns or commercially sensitive information that you have reported on the Platform, without your prior written consent. Any of this data may however be anonymised to provide tools and features including but not limited to our Cost Per Engagement 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. In accordance with our Terms and Conditions of use, information provided to you as a Brand or an agency entity (represented by your account user) or your company on the Platform is not to be released to the public (ie to anyone outside of your organisation) without our specific prior written consent.
    12. Logins are not transferable and if a registered Brand (or agency) 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.
    13. We may associate any category of information with any other category of information and will treat the combined information as PII/personal data in accordance with this Policy for as long as it is combined.
    14. Third-Parties and Affiliates: We may receive information about you from third parties, such as other Platform users, other third party owned social media platforms, or our related companies that provide other services (our corporate affiliates). For example, other Platform 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 corporate 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. Note that our advertising partners may enable us to collect similar information directly from their websites or app's by integrating our advertising technology.
  2. COOKIES    
    1. We use cookies to distinguish you from other users of the Platform, the App, or any Service Site. This helps us to provide you with a good experience when you use the Platform, any App or browse any Service Site and also allows us to improve the functionality and operability of any of them.
    2. For detailed information on the cookies we use and the purposes for which we use them, see our cookie policy [HERE].
  3. OTHER INFORMATION WE COLLECT FROM YOUR USE OF THE SERVICES AND HOW WE USE THAT INFORMATION
    1. Log Data: 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 any Services Site, 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, for example to identify what topics you may be interested in, and to customise content we show you. We will use and retain Log Data in accordance with this Policy.
    2. Widget Data:  We may tailor the Services for you based on your visits to third-party websites that integrate with Social Circle. 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.
    3.  
  4. OTHER DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
    In addition to those disclosures referred to elsewhere in this Policy, you agree that we have the right to disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

    We will disclose your personal information to third parties:
    1. In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets in connection with that sale or purchase.
    2. If Social Climbers Limited or substantially all of its assets are acquired by a third party, in which case personal data held by Social Climbers Limited about its users/customers will be one of the transferred assets.
    3. If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
    4. In order to:
      1. enforce or apply our Terms and other agreements or to investigate potential breaches; or
      2. protect the rights, property or safety of Social Climbers Limited our users/customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
  5. WHERE WE STORE YOUR PERSONAL DATA
    The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by personnel operating outside the EEA who work for one of Social Circle's suppliers, or for Social Circle. These personnel may be engaged in the fulfilment of any request, instruction, communication or order, and/or the processing of your payment details and/or the provision of support services.

    By submitting your PII/personal data, you agree to this transfer, storing or processing. Social Climbers Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.

    All information you provide to us is stored on our secure servers.

    Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using an industry standard platform.

    Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Platform and/or App and/or Services Site(s), you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

    Unfortunately, the transmission of information via the internet/other communications networks is not completely secure. Although we will do our best to protect your PII/personal data, we cannot guarantee the security of your data transmitted to the Platform and/or App and/or Services Site(s); any transmission is at your own risk.

    Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

    We again caution you to ensure that when using Social Circle's features that you do not submit any PII/personal data that you do not want to be seen, collected or used by other users of the Platform and/or Platform Services.

  6. YOUR RIGHTS
    You have the right to ask us not to process your PII/personal data for marketing purposes.

    We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing at any time by contacting us or by sending an email to privacy.support@socialcircle.media 

    Our Platform and/or App and/or Services Site(s), may from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Platform, the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any PII/personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any PII/personal data to these websites or use these services.

  7. ACCESS TO INFORMATION

    The Data Protection Act 1998 (as amended) gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act.

    Accessing and Modifying Your Personal Data:
    1. If you are a registered user of our Services, we will notify you when we make available tools and account settings features under "security and privacy settings" (available at socialcircle.media/settings) to access, correct, delete, or modify the personal data you provided to us or which is associated with your account.
    2. Until we notify this to you, you can request such correction, deletion or modification to that personal data by emailing us at privacy.support@socialcircle.media
    3. You can download certain account information on request by contacting our user support team at privacy.support@socialcircle.media
    4. You can also permanently delete your SocialCircle Profile and account. Please contact creatorsupport@socialcircle.media for your account to 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.
    5. 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 Services or deactivated your account.
  8. CHANGES TO PRIVACY POLICY
    Any changes we may make to our Policy in the future will be posted on this page and, where appropriate, notified to you either by email or by SMS or when you log onto socialcircle.media (or any Services Site). The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Services and/or App and/or any Services Site.
  9. CONTACT
    Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to the Data Protection Officer at Social Circle, Unit B Jacks Place,6 Corbet Place London E1 6NH, alternatively emailed to us at privacy.support@socialcircle.media.
This Policy was last amended on 10th August 2017