SocialPass Privacy Policy

SocialPass and its affiliates (collectively, “SocialPass”) are committed to protecting your privacy and complying with applicable data protection laws. This Privacy Policy outlines how SocialPass collects, uses, discloses, and safeguards information about you. We also describe the choices you have about your information.

This Privacy Policy was updated and is effective on August 16, 2019. These updates are designed to make it easier to understand how we use your information, whether you are browsing our websites or using our Services. 

We regularly make updates to our Privacy Policy to help you more easily find information relating to our privacy practices and we have simplified some of the language. However, we have made no substantive updates to the manner in which we handle your information. 

1. Our Services

SocialPass offers a suite of social media management tools (available in Free, Professional and Business plans) that are accessible via our website. These tools allow you to bring together all of your social media accounts for easy access and management through a single online portal. Through this portal, you can manage your social media, marketing, and advertising campaigns; engage with your audiences; schedule and publish messages; and analyze the results of these activities. Collectively, we refer to these tools as our “Services”. 

Any collection, use, and management of personal information by the social networks, including Facebook, Instagram, Twitter, and LinkedIn (collectively, the “Social Networks”) are governed by their respective privacy policies and terms. When using Social Networks, you are required to comply with their privacy policies and terms. We recommend you carefully review their privacy policies and terms, as SocialPass is not responsible for the Social Networks.

Our Services also enable you to customize and connect your SocialPass account to third-party services (“Third-Party Services”), including through apps you can access in the App Directory or which may be available to you via our portal/dashboard. The collection of your information by these third parties is governed by the Third-Party Services’ privacy policies and terms. We recommend you carefully review their privacy policies and terms, as SocialPass is not responsible for Third-Party Services.  

Our Services are not intended for use by children and should only be accessed by individuals who are at least 18 years old and are using the Services for business purposes.

2. What information do we collect?

We collect information about you as reasonably necessary for the following activities:

Using our Services

We collect the following information when you use our Services:

Account information:
  • Your contact and profile information including your name, email address, organization name, and address; your preferences such as language, time zone, and the types of communication you would like to receive from us; and image (if you choose to provide this). We may also obtain this information if you choose to use a social login service, such as Facebook Login, to create or access your account.
  • Billing and other payment information (if you sign up for a paid service), including payment method details, such as credit card number.
  • The Services you have acquired from us, including the type of plan, number of team members, and transaction information related to the Services.

Content:
  • Your social profile information for Social Networks you choose to connect to the Services. For example, your Facebook profile information may include your Facebook username and profile image.
  • A specific location such as an address, a city, or a place (for example, a restaurant) if you choose to share this information.  
  • Your messages, posts, comments, images, advertising, and other material you curate on and upload to the Services; and information that is collected from the Social Networks that you choose to connect to and which is displayed on our Services.  
  • Content that you may send and receive through Social Networks may contain personal information that SocialPass does not directly collect or process. This may include information such as: names, photos, age, gender, geographic location, opinions, preferences, and phone numbers. 

Logs, usage, and support data:
  • Log data, which may include your IP address, the address of the web page you visited before using the Services, your browser type and settings, your device information, the date and time when you used the Services, information about your browser configuration, language preferences, unique identifiers, and cookies.
  • Usage data and analytics, which may include the frequency of login, and the different types of activity undertaken by users.
  • General Location information, such as IP address and the region in which you are located when you are logging in and using the Services.  
  • Customer support questions, issues, and general feedback that you choose to provide.


Browsing our websites

When you browse our websites, we collect information about you as described below, some of which is collected automatically:

  • When you use automated chat functionality (chatbots) to make an inquiry or other request, we may collect information about you such as your name and email address, your specific request, and information related to your use of our Services. 
  • SocialPass use cookies and other similar tracking technologies on our websites and Services including pixels, and software tokens. These are described in our Cookie Notice.

3. How do we use your information?

We use your information for the purposes described below:

Providing and securing our Services
  • We need to identify and authenticate our users to ensure, for example, that only those authorized users are able to use the Services for their organization, and to make changes to their accounts.
  • We use information that you provide when signing up to set up your account, process payments, contact you regarding the Services, and manage your account.
  • We use your contact information and information related to your request to respond to your inquiries, manage our contract with you, respond to your questions and requests, and send you updates and information about the Services.
  • We use logging and other data such as general location information—for example, the IP address of your browser or device, to help us manage the performance, security and compliance of the Services. 
  • Where you have chosen to share your specific location information, we use this information to provide location based features, such as enabling you to share your location on your posts for Social Networks that support this functionality, and to use any functionality that relies on location information. 
  • We analyze usage information, your feedback, support queries, and survey responses to help us understand and make improvements to our Services.

Communicating with you

We use your contact information where appropriate to send you information about our Services, marketing communications and notifications you sign up for when setting up your account. We also use email statistics, such as open rates, to assess the effectiveness of, and to make improvements to our communications. 

Improving our websites and applications

We use information about you to help us understand usage patterns and other activities on our websites and applications so that we can diagnose problems and make improvements, including enhancing usability and security.

4. What are your rights regarding the information about you?

Services information

When using our Services, you may access, update, or correct most of your Account information by logging in to your account to edit your profile or organization record. 

If you have requests that cannot be carried out by logging in to your account, such as accessing additional information or deleting information about you, please email us. Please note that we may need to retain certain information about you for as long as you maintain an account for our Services, to provide you with our Services, for record keeping purposes, for payment processing, to comply with our legal and regulatory obligations, to resolve disputes, or to enforce the applicable terms of service or other agreement in place between you (or your organization) and SocialPass (the "Terms of Service").

Requests to access, correct, or delete your information will be handled within thirty (30) days unless they are unusually extensive or complex, in which case we will advise you of the expected timeline for handling your request. 

You can contact our Support team for other general requests about your account by filling out this form.

Our Services retrieve and display Content from Social Networks. Beyond temporary storage for performance reasons, we do not store Content unless you take specific action in relation to such Content (such as using our Services to prepare draft Content for publication on Social Networks). In some cases, Content may continue to exist on the Social Networks even after you or we delete it from our Services, and you will need to contact the relevant Social Network directly if you want it to delete this Content.

Marketing emails, advertising and website browsing

For marketing communications, you may opt out of marketing communications sent by SocialPass by clicking on the unsubscribe link in the marketing email you receive.

SocialPass participates in interest-based advertising (where you may have visited our websites or another website which allows us to display advertising relating to our Services). The Network Advertising Initiative has developed a tool that may help you understand which third parties have currently enabled cookies for your browser and how to opt out of those cookies. For more information and to opt out of interest-based advertising, you can visit this page

5. Who has access to your information?

SocialPass does not rent or sell your information. We restrict access to your information to authorized employees and we do not share your information with third parties except in the circumstances explained below.

Employees and Authorized Contractors

Our employees and authorized contractors may need to access information about you when they require this to perform their job. For example, a customer support representative would need access to your account to validate your identity and respond to your question or request; our email communications team would need access to your contact information to ensure this information is sent correctly and any unsubscribe requests are properly managed; and our security staff would need to review information to investigate attempted denial of service attacks, fraudulent account activity, or other attempts to compromise the Services. 

All our employees and contractors are required to agree to maintain the confidentiality and protect the privacy of your information.  

Service Providers and Partners

We will share limited information about you to authorized service providers we use for marketing services, communicating with you, managing our customer database, the provision of professional services, and providing and managing the Services (including hosting data centers, securing our Services, and payment processing). The third-party service providers we use to help us deliver the Services are referred to as “sub-processors” and are listed on this page. 

When sharing your information with any of these service providers partners, we ensure they agree to obligations consistent with this Privacy Policy and any other appropriate confidentiality and security measures, and only use your information to carry out the Services and your requests.

Social Networks and Third-Party Services

Whenever you are using our Services and have chosen to connect your Social Networks to the Services, or if you authorize a Third-Party Service to access your account, you are agreeing to provide information about you to the Social Networks and the Third-Party Services under their respective terms and privacy policies.

Customer Organizations

Where your employer or an entity has purchased Services on your behalf, we may disclose information about you such as your name and email address, and some usage information including whether a user has logged in to the Service, frequency of login, time spent using the Services, and enrollment and completion of SocialPass Academy courses to assist your employer or the entity in managing its use and maximizing the value of the Services.

Successor Entities

If we are acquired by or merge with another entity (in which case we will require such entity to assume our obligations under this privacy policy), if we are involved in a bankruptcy, or if the ownership or control of all or part of our Services or their assets changes, information about you will be transferred to such entities.

Law Enforcement, Government Agencies, and Professional Advisors

We may need to disclose information about you where we believe that it is reasonably necessary to comply with a law or regulation, or if we are otherwise legally required to do so, such as in response to a court order or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands.

In addition, we may be required to disclose information about you if we believe it is necessary to investigate, prevent, or take action: (a) against illegal activities, fraud, situations involving potential threats to our rights or property (or to the rights or property of those who use our Services), or to protect the personal safety of any person; or (b) regarding situations that involve the security of our Services, abuse of the Services infrastructure, or the Internet in general (such as voluminous spamming, or denial of service attacks).

6. What international data transfers occur at SocialPass?

Under the General Data Protection Regulation (GDPR) and other data protection laws, information about you may only be transferred from your region to other regions if certain requirements are met. For instance, under the GDPR, information about you may be transferred from the European Economic Area (EEA) to outside the EEA if adequate data protections are in place. 

SocialPass also uses third-party service providers, such as managed hosting providers, credit card processors, and technology partners to provide the software, networking, infrastructure and other services required to operate the Services. These third-party providers may process or store personal data on servers outside of the EEA and Switzerland, including in Canada or the US. We rely on adequacy, the service provider’s registration in the EU-US Privacy Shield and Swiss-US Privacy Shield (if sent to the US), and/or standard contractual clauses (if sent to the US or onward to other countries) to ensure that information about you is lawfully transferred under EU law.

The third-party service providers we use to help us deliver the Services are referred to as “sub-processors” and are listed on this page.  

By its nature, social media data can be shared with people around the globe. The Social Networks and Third-Party Services that you choose to integrate with our Services may collect, store, and process your information from various locations around the world according to their own terms and privacy policies.

7. How do we safeguard your information?

SocialPass maintains industry standard security safeguards to protect your information. This includes ensuring our employees receive appropriate security and privacy training and guidance so they are aware of the measures they need to implement to protect your information.  

Access controls are in place to limit access to your information to those who need it to perform their jobs. For example, information about you may be provided to our customer support specialists to help you with your requests. Individuals who are permitted to handle your information must adhere to confidentiality obligations.

We encrypt data where appropriate to ensure that your information is kept private. We undertake vendor security and privacy reviews to ensure that vendors follow our stringent requirements to safeguard your information, and we also enter into data protection agreements with our vendors. All payment information is fully encrypted and handled only by PCI certified organizations.

8. How long do we retain your information?

We retain your information only as long as required to provide the Services requested by you, for record keeping purposes, to comply with our legal obligations, resolve disputes, and enforce the terms for the Services.

After it is no longer necessary for us to retain information about you, we will dispose of it in a secure manner or anonymize the information.

9. SocialPass’s roles under the GDPR and UK data protection laws

Depending on the situation and the type of data involved, SocialPass may act as a data controller or a data processor.

SocialPass as a data controller 

SocialPass acts as a data controller when we are:
  • Collecting information from you to set up and administer your SocialPass account (for example, Account information such as your name and email address);
  • Monitoring usage information on our website; 
  • Managing your contact and other related information to send marketing, Services, and other communications to you; 
  • Responding to a support or general inquiry.

Legal bases for processing when SocialPass is a data controller

The legal bases for processing information about you include:
  • Your consent (for example, when you have provided your information to sign up for an account). Where we rely on your consent to process personal data, you have the right to withdraw your consent at any time. 
  • It is necessary to perform a contract (for example, we may need your information to fulfill our obligations of providing Services to you under the terms relevant to the Services you have acquired).
  • Legitimate interest (for example, to provide and maintain the Services to you, to maintain the security of the Services, and to attract new customers to maintain demand for the Services, all of which are described in the “How do we use your information?” section above).
  • In some cases, we may have a legal obligation to process your personal data to comply with relevant laws (for example, processing payroll and tax information to comply with relevant employment and tax legislation); or processing is necessary to protect your vital interests or those of another person (for example, obtaining health-related information during a medical emergency).

Your rights when SocialPass is a data controller

Where SocialPass is acting as a data controller, we have outlined certain rights in the section “What are your rights regarding the information about you?”.
In addition, you may have the following rights: 
  • Right to object to processing: you may request that SocialPass stops processing information about you (for example, to stop sending you marketing communications).
  • Right to restrict processing: you may request that we restrict processing information about you (for example, where you believe that this information is inaccurate).
  • Right to data portability: you may request that we provide you with information SocialPass has about you in a structured, machine-readable, and commonly used format, and you may request that we transfer this information to another data controller.
If you would like assistance on any of the above requests, please email our privacy team with details of your request so that we may consider how we can help you.

SocialPass as a data processor

Where you are using our Services and making decisions about the personal data that is being processed in the Services (including selecting the Social Network accounts you wish to connect to the Services, or uploading and using Content), you are acting as a data controller and SocialPass is acting as a data processor.

There are certain obligations under the GDPR that you have as a data controller, including being responsible for managing Content on the Services. As a data processor, SocialPass will only access and process Content to provide you with the Services in accordance with your instructions (which you provide through the Services), the Terms of Service, the Social Networks’ terms, and applicable laws. As part of delivering the Services, we may process Content to further improve the Services, such as enhancing usability and developing new features.

If you, as a data controller, require SocialPass to agree to data protection requirements under Article 28, GDPR, or under UK data protection laws, SocialPass makes available a data processing addendum that meets these requirements. Please email our Privacy team here to request this document.

If you are using the Services as an authorized user of a SocialPass customer (whether that customer is your employer, another organization, or an individual), that customer determines its own policies (if any) regarding storage, access, modification, deletion, sharing, and retention of personal information and Content, which may apply to your use of the Services. Please check with that customer about the policies and settings it has in place.

10. Changes to this Privacy Policy

We may make changes to this privacy policy at any time to reflect updates to our Services, applicable laws, and other factors. We will include a prominent notice on this website and/or our Services if we make any material changes, but we encourage you to stay informed by reviewing this policy periodically.

11. How to contact us

If you have any questions, concerns or feedback, please email our Privacy team. If we are unable to resolve your concerns, you also have the right to contact your local data protection authority.