What this Privacy Notice covers
This Privacy Notice describes how Engagement Labs collects, uses, processes, protects, and discloses personal information collected through the performance of its Services (as defined below) and its access to personal information on instances of TotalSocial® Platform.
In this policy, “you” means any individual whose data is collected by a Third-Party Data Provider (“Provider”) and provided to Engagement Labs in the context of a supplier agreement between the Provider and Engagement Labs; “we” or “us” means Engagement Labs. In this Privacy Notice, “Engagement Labs” refers both to Engagement Labs, and Engagement Labs Ltd. “Engagement Labs’ Customer” or “Customer” means the individual(s) or organization(s) that have entered into a license agreement with Engagement Labs entitling them to received Services from Engagement Labs or use the TotalSocial® Platform, including free trial users and OEM partners. “TotalSocial® Platform” shall mean the managed cloud platform hosting services as defined in the TotalSocial® Platform Terms and Conditions. “Personal Information” is information about you that is personally identifiable by name or can be linked to you through a personal identifier like e-mail address, social media ID, or location. This definition is given here for this notice only, and some laws may use a different definition. If you are asserting your rights under law, the applicable legal definition governs your rights. “Services” means any services which may involve granting Engagement Labs access to Engagement Labs’ Customers’ information or records, such as support services, consulting, and business relations.
What data does Engagement Labs process?
Engagement Labs collects data from 2 types of third parties data controllers:
Online data: we collect data from online controllers such as Facebook, Twitter or YouTube. Data we collect is entirely publicly available and we are required to comply to these platforms public terms and conditions per our contract with them. As we are at least collecting social media user IDs, we consider our Online Data qualifies as Personal Data.
To be more specific, data is collected from major social media platforms, blogs and forums, and could includes information such as:
- Social media user ID (such as Twitter handle)
- Email (only when used as an identifier on a public blog post)
This information is used only to infer aggregated demographic traits such as gender or age that help our clients understand the characteristics of their audience. Personally identifiable information is never disclosed as such to our clients or partners, it is always processed and aggregated.
Offline data: we collect survey respondent data from data controllers such as Toluna. The data we collect there is not otherwise publicly available, but respondents have opted-in to share their data with us. We are also required to comply with public terms and conditions. Collected data includes traits such as age, gender, region, marital status, education and other. We cannot reasonably identify an individual using any combination of the traits collected from our survey data controller, and as such do not consider our Offline data is as Personal Data.
In any way, if you believe we have information from you that you do not want us to have, please contact us as described below and contact the data controller to whom you initially gave that information. We will delete your content upon your request in within a 30 days delay.
Disclosure of Personal Information to third parties
We do not disclose your Personal Information to third parties (except our service providers, as stated above), except under the following circumstances and for the following purposes:
- When required by law to respond to subpoenas, court orders, or legal process by public authorities, including disclosures required by national security or law enforcement agencies.
- When we need to establish or exercise our legal rights, or to defend against legal claims, or when we believe it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, data breaches, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
- If Engagement Labs is acquired by or merged with another company, Engagement Labs will come under the control of a new entity any rights and permission that Engagement Labs has to access your Personal Information may be assigned to the new entity.
Retention and Deletion of information
We may retain Information for any lawfully permitted period of time, and as necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate events and resolve disputes. In any way, if you believe we have information from you that you do not want us to have, please contact us as described below and contact the data controller to whom you initially gave that information. We will delete your personal information upon your request within 30 days.
Confidentiality, security, and data integrity
We take great precautions to protect the integrity of your Personal Information. However, no data transmission over the Internet or stored on any other network or system can be guaranteed to be 100% secure. While we strive to protect information on our systems and the TotalSocial® Platform, we cannot and do not guarantee the security of any information you transmit.
Contacting Engagement Labs about this Privacy Notice
Any inquiries, concerns, or requests regarding the use or disclosure of your Personal Information should be directed to us at: firstname.lastname@example.org.
Changes to this Privacy Notice