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Privacy Policy

Last updated: January 1, 2020

Actisona Inc. and its affiliates (collectively, “Actisona”) are committed to protecting your privacy and complying with applicable data protection laws. This Privacy Policy explains who we are, how we collect, share and use information about you and how you can exercise your privacy rights.

1. What does Actisona do?

Actisona offers a suite of social media management tools (available in multiple plans) that are accessible via our websites. 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; engage with your audiences; schedule and publish messages; and analyze the results of these activities. Collectively, we refer to these tools as our “Services”.

2. Information Collected

  • Personal information we may collect: The type of information that we collect directly from you varies based on your interaction with our Site and our Service. We collect information directly from you when you register an account with us, liaise with us on a customer service issue, apply for a job, and complete an application or other forms on the Site and/or Service. We also collect information that you send us via any medium, including, but not limited to email and telephone. In addition, we collect information about you from your social media interactions on third party social media properties, such as your social media handle, username, profile, postings, and messages you exchange with our customers.
  • Personal information provided by you: We receive information from customers in order to provide our Service:
    • Registration: To have access to certain restricted sections of the Site or request to receive marketing materials, you may be required to become a registered user, and to submit the following types of Personal Information to Actisona: your name, email address, phone number, full user name, password, city, and time zone.
    • Social Media: We may ask you to provide your username, account ids, social handle, timezones, and email address, in order to be able post to your connected social media platforms.
    • Making a Payment: When you make payments through the Service, you will need to provide Personal Information such as your credit card number and billing address.
    • Miscellaneous: We may also collect your contact details when you provide them in the context of our customer, vendor, and partner relationships.

3. Information from Other Sources

We also collect information from other sources. The following are the categories of sources we collect information from:

  • Personal Information Collected from Connected Social Media Accounts
    • Facebook: Actisona may allow you to connect a Facebook page, group or profile to your Actisona account, in which case we will access certain information from Facebook regarding your account. In particular, we may collect profile image, display name, username / page ID, group ID or profile ID, access tokens, sent posts. This includes the content of your post and engagement data (such as click rates, likes, re-shares, impressions, as well as general engagement counts), to the extent permitted by applicable law. This data will only be used by Actisona to provide you with the Service you expect and will not be shared with any third parties.
    • Twitter: Actisona may allow you to connect a Twitter profile to your Actisona account, in which case we will access certain information from Twitter regarding your account. In particular, we may collect profile image, display name, username / profile ID, access tokens, and sent posts. This includes the content of your post and engagement data (such as click rates, likes, retweets, re-shares, impressions, as well as general engagement counts), to the extent permitted by applicable law. This data will only be used by Actisona to provide you with the Service you expect and will not be shared with any third parties.
    • Instagram: Actisona may allow you to connect an Instagram profile to your Actisona account, in which case we will access certain information from Instagram regarding your account. In particular, we may collect profile image, display name, username / profile ID, access tokens, and sent posts. This includes the content of your post and engagement data (such as click rates, likes, re-shares, impressions, as well as general engagement counts), to the extent permitted by applicable law. This data will only be used by Actisona to provide you with the Service you expect and will not be shared with any third parties.
    • Pinterest: Actisona may allow you to connect a Pinterest page or profile to your Actisona account, in which case we will access certain information from Pinterest regarding your account. In particular, we may collect profile image, display name, username / profile ID, access tokens, sent posts, and profile boards. This includes the content of your post and engagement data (such as click rates, likes, re-shares, re-pins, impressions, as well as general engagement counts), to the extent permitted by applicable law. This data will only be used by Actisona to provide you with the Service you expect and will not be shared with any third parties.
    • LinkedIn: Actisona may allow you to connect a LinkedIn personal profile, or LinkedIn company page to your Actisona account, in which case we will access certain information from LinkedIn regarding your account. In particular, we may collect profile image, display name, username / profile ID, access tokens, and sent posts. This includes the content of your post and engagement data (such as click rates, likes, re-shares, impressions, as well as general engagement counts), to the extent permitted by applicable law. This data will only be used by Actisona to provide you with the Service you expect and will not be shared with any third parties.
  • Personal Information Automatically Obtained from Your Interactions with the Service
    • Cookies and Similar Technologies: We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Policy.
    • Links: Our Site contains links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We are not responsible for the content, privacy and security practices, and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to read the privacy policies or statements of the other websites you visit.

4. Do-Not-Track

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this Privacy Policy (e.g., by disabling cookies, or using ‘private’ browsing modes).

5. Use of Information

Actisona processes information for business and commercial purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, including in the last 12 months, include the following:

  • create and manage your account, provide our Service, process payments, and respond to your inquiries;
  • communicate with you to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance, including by periodically emailing you service-related announcements;
  • manage account authentication such as two-factor authentication
  • tailor our Service (e.g., we may use cookies and similar technologies to remember your preferences);
  • publish your content, comments or messages on social media platforms;
  • provide tailored advertising, for Actisona services, via Google AdWords, Facebook Ads;
  • aggregate your Personal Information for analytical purposes;
  • send you marketing communications about products, services, offers, programs and promotions of Actisona, and affiliated companies;
  • provide customer support
  • operate, evaluate and improve our business (including by developing new products and services; managing our communications; determining the effectiveness of our advertising; analyzing how the Service is being accessed and used; tracking performance of the Service; debugging the Service; facilitating the use of our Service);
  • manage our customer, service provider and partner relationships;
  • ensure the security of our Service.
  • enforce our agreements related to our Service and our other legal rights; and
  • comply with applicable legal requirements, industry standards and our policies.

6. Legal basis for processing personal data (EEA visitors / users only)

If you are a visitor or user from the European Economic Area, our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.

However, we will normally collect personal data from you only where we have your consent to do so, where we need the personal data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal data from you.

If we ask you to provide personal data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).

Similarly, if we collect and use your personal data in reliance of our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

7. To Whom We May Share Your Information

We share information we collect in accordance with the practices described in this Privacy Policy. The following are the categories of recipients:

  • Social Media Platforms: Our primary purpose for using information is to publish your content on social platforms, allow you to track metrics for analytical purposes, and engage with customers through public replies and conversations (direct messages or “DMs”). We may allow you to link your account on Actisona with an account on a third party social network platform, such as Twitter or Facebook, and to transfer your information to and from the applicable third party platform. Once you share your content to a social media platform, its use will be governed by that platform’s privacy policy.
  • Service Providers: We engage certain trusted third parties to perform functions and provide services to us, including hosting and maintenance, error monitoring, debugging, performance monitoring, billing, customer relationship, database storage and management, and direct marketing campaigns. We may share your Personal Information with these third parties, but only to the extent necessary to perform these functions and provide such services. We also require these third parties to maintain the privacy and security of the Personal Information they process on our behalf.
  • Compliance with Laws and Law Enforcement: Actisona cooperates with government and law enforcement officials or private parties to enforce and comply with the law. To the extent permitted under applicable law, we may disclose any information about you to government or law enforcement officials or private parties as we believe is necessary or appropriate to investigate, respond to, and defend against claims, for legal process (including subpoenas), to protect the property and rights of Actisona or a third party, to protect Actisona against liability, for the safety of the public or any person, to prevent or stop any illegal, unethical, fraudulent, abusive, or legally actionable activity, to protect the security or integrity of the Service and any equipment used to make the Service available, or to comply with the law.
  • Business Transfers: Actisona may sell, transfer or otherwise share some or all of its assets, including Personal Information, in connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, or in the event of insolvency or bankruptcy. You will have the opportunity to opt out of any such transfer if the new entity’s planned processing of your information differs materially from that set forth in this Privacy Policy.
  • Other Third Parties: We may share Personal Information with our headquarters and affiliates, and business partners to whom it is reasonably necessary or desirable for us to disclose your data for the purposes described in this Privacy Policy. We may also make certain non-Personal Information available to third parties for various purposes, including for business or marketing purposes or to assist third parties in understanding our users’ interest, habits, and usage patterns for certain programs, content, services, advertisements, promotions, and functionality available through the Service.

8. How we protect your personal information

Our Site and/or Service implements and maintains various reasonable and appropriate administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. These security safeguards include, but are not limited to, network and host security controls (e.g., firewalls, intrusion detection systems, etc.), data encryption (both at rest and during transmission), and operating procedures that are designed to protect your information. You should protect your user ID and password and NOT share it with anyone. If you believe your user ID and password have been compromised or you have trouble changing your user ID/password on the Site or Service, please contact our technical support department (support@actisona.com). Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you.

We also take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

9. Your rights and choices

If you decide at any time that you no longer wish to receive marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. You may also opt out from receiving commercial email from us by sending your request to us by email at hello@actisona.com. Please be aware that, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Service.

In certain jurisdictions you have the right to request access and receive information about the Personal Information we maintain about you, to update and correct inaccuracies in your Personal Information, to restrict or object to the processing of your Personal Information, to have the information blocked, anonymized or deleted, as appropriate, or to exercise your right to data portability to transfer your Personal Information to another company. Those rights may be limited in some circumstances by local law requirements. For example, California residents can refer to the separate California Resident Privacy Notice to learn more about their California privacy rights. In addition to the above-mentioned rights, you also have the right to lodge a complaint with a competent supervisory authority subject to applicable law.

Where required by law, we obtain your consent for the processing of certain Personal Information collected by cookies or similar technologies, or used to send you direct marketing communications, or when we carry out other processing activities for which consent may be required. If we rely on consent for the processing of your Personal Information, you have the right to withdraw it at any time and free of charge. When you do so, this will not affect the lawfulness of the processing before your consent withdrawal.

10. International data transfers

Actisona is based in the United States. Personal Information that we collect may be transferred to, and stored at, any of our affiliates, partners or service providers which may be inside or outside the European Economic Area (“EEA”) and Switzerland, including the United States. By submitting your personal data, you agree to such transfers. Your Personal Information may be transferred to countries that do not have the same data protection laws as the country in which you initially provided the information. When we transfer or disclose your Personal Information to other countries, we will protect that information as described in this Privacy Policy.

Individuals Located in the EEA, the UK or Switzerland

If you are located in the European Economic Area (“EEA”), the United Kingdom, or Switzerland, we comply with applicable legal requirements for the transfer of Personal Information to countries outside of the EEA, the United Kingdom, and/or Switzerland. In particular, we rely on your explicit consent to transfer your Personal Information to Actisona in the U.S. The U.S. is considered not to provide a similar level of data protection as the EEA, the United Kingdom and Switzerland. You can at all times revoke your consent simply by contacting us at hello@actisona.com.

11. Children's privacy

The Site is not directed to persons under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at hello@actisona.com. We do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.

If you are a California resident under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make a request, email us at the email address hello@actisona.com with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

12. Updates to this Privacy Policy

The Site is not directed to persons under 16. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at hello@actisona.com. We do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.

If you are a California resident under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make a request, email us at the email address hello@actisona.com with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed. We will make reasonable good faith efforts to remove the post from prospective public view, although we cannot ensure the complete or comprehensive removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

13. How to contact us

If you have any questions or concerns about our use of your information, please contact us using the following details: privacy@actisona.com.

If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us at privacy@actisona.com.

14. Your California privacy rights

This California Resident Privacy Notice supplements the information and disclosures contained in this Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under California law.

Notice of Collection:

In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:

  • Identifiers, including name, email address, phone number account name, IP address, and an ID or number assigned to your account.
  • Customer records, billing and shipping address, and credit or debit card information.
  • Commercial information, including purchases and engagement with the Service.
  • Internet activity, including your interactions with our Service.
  • Audio or visual data, including pictures or videos you post on our Service.
  • Employment and education data, including information you provide when you apply for a job with us.
  • Inferences, including information about your interests, preferences and favorites.

Actisona does not generally sell information as the term “sell” is traditionally understood. However, to the extent “sale” under the CCPA is interpreted to include advertising technology activities such as those disclosed in the Cookies, similar tracking technology, and analytics sub-section as a “sale,” we will comply with applicable law as to such activity. Actisona discloses the following categories of personal information for commercial purposes: identifiers, demographic information, commercial information, internet activity, geolocation data and inferences. We use and partner with different types of entities to assist with our daily operations and manage our Service. Please review the To Whom We Share Your Information section for more detail about the parties we have shared information with.

Roles.

If you are an authorized user of a Actisona customer, you represent and warrant that you will only provide information and use the Service acting in your capacity as an employee, owner, director, officer, or contractor of a company, partnership, sole proprietorship, nonprofit or other legal entity, and that your communications and transactions with Sprout Social (on and off the Service) occur solely within the context of Actisona providing the Site and Service to the company, partnership, sole proprietorship, nonprofit or other legal entity that you represent.

Right to Know and Delete.

Consumers who are California residents (and not representatives of businesses, whether those businesses are our customers or others) have the right to delete the personal information we have collected from you and the right know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information was collected;
  • The categories of personal information about you we disclosed for a business purpose or sold;
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
  • The business or commercial purpose for collecting or selling the personal information; and
  • The specific pieces of personal information we have collected about you.

To exercise any of these rights, please email us at privacy@actisona.com, submit a request through our online form available on our Help Center if you are a customer or user. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

If personal information about you has been processed by us as a service provider on behalf of a customer and you wish to exercise any rights you have with such personal information, please inquire with our customer directly. If you wish to make your request directly to us, please provide the name of our customer on whose behalf we processed your personal information. We will refer your request to that customer, and will support them to the extent required by applicable law in responding to your request.

Verification.

Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please provide us with the email address associated with your Actisona account and the last 4 four digits and expiration date of the payment card that’s linked to the Actisona account. If you are a non-paying customer please provide us with the email address associated with your Actisona account and the phone number used for two-step authentication.