Last Revised 7/10/2014
Social Media Platforms, Third-Party Applications and Connected Services
Information We Collect
Generally, we collect Profile Information about our users to create and maintain individual user accounts and we automatically collect information about the use of our Services. We collect information about user interactions with certain Social Media Platforms and third-party applications supported by our Services. We collect email addresses of those who communicate with us via email and contact information of users that communicate through other channels.
Personal information or personally identifiable information is data that uniquely identifies or that can be used to uniquely identify or contact a single person (“Personal Information”). In the course of using our Services, you may provide us with Personal Information directly and we may collect, generate or compile information and other data from your use of the Services that may be personally associated with you. We may collect Personal Information anytime you are in contact with us, through the Services or otherwise. We may also combine or associate Personal Information with other non-identifiable information to provide and improve our Services. To the extent permitted by applicable law, your consent to the collection, use and disclosure of your Personal Information may be expressed verbally, in writing or electronically, or implied by using our Services.
User Accounts and Personal Profile
To enable and authorize use of our Services, our Customers must provide authorized email addresses and other Personal Information on behalf of our users to initially create a Personal Profile, which is necessary and required to enable individual user accounts for their employees, contractors, agents and other authorized personnel to access the Services. For the purpose of this Policy, “Customer” may mean you or any other individual, company, employer, organization or other legal entity, including our partners and resellers, that authorizes your use of our Services on their behalf and that is subject to separate and distinct Subscription Agreement or other similar licensing agreement authorizing your use of our Services as an end user.
The Personal Information we collect for your Personal Profile includes, but is not limited to, your email address, your name, a profile picture, your title and subtitle with our Customer, along with other optional preferences. We will also create a unique rFactr ID, which is associated with your Personal Profile and your user of our Services. You and/or our Customer may access, review, update, or correct your Personal Profile information and preferences at any time. Personal Information may also include information you otherwise choose to supply to us concerning your preferences and interests expressed in the course of using our Services, particularly optional services and programs.
Social Media Content
Our Services may collect and process information, including Personal Information, which users create, provide, generate, or grant us access to, after giving their explicit consent to connect their respective Social Media Platform accounts to our Services. The information collected and processed may include information about individual user content and interactions created or processed on or through our Systems, including on or through their respective authorized Social Media Platforms. Information collected about such interactions may include, without limitation, the content of any posts, comments, messages, or other similar user generated content created or initiated by the users of our Services, including related metadata related to such content interactions, as well as similar information about corresponding and responsive events and activities like posts, comments, messages, shares, forwards, likes/dislikes, ratings or other similar actions made available to us from or through connected Social Medial Platforms (“Social Media Content”). Social Media Content is used to enable our Customers to facilitate and monitor social media interactions and other similar activity of its authorized users. We use the Social Media Content solely in order to provide our Services to you and the Customer authorizing your access and use of our Services.
MONITORING: OUR SERVICES MONITOR USER CONTENT CONTRIBUTED TO SUPPORTED AND AUTHORIZED SOCIAL MEDIA PLATFORMS IN ACCORDANCE WITH THE TERMS OF OUR LICENSE AGREEMENT WITH OUR CUSTOMERS AND OUR END USERS. OUR SERVICES PROVIDES SUPERVISION CAPABILITY FOR EACH CUSTOMER TO REPORT ON USER CONTRIBUTED CONTENT AND INTERACTIONS AND TO REVIEW CONTENT POSTED BY THEIR AUTHORIZED USERS WHO HAVE CONNECTED AND AUTHORIZED THEIR INDIVIDUAL ACCOUNTS THROUGH OUR SERVICES.
Collection and Use of Non-Personal Information
Automatically Collected Information
We automatically collect some information about you when your use our Services. For example, we will collect session data and information about your interactions and activity while using our Services. This automatically collected information is used to help us understand the interests of our users and to customize and enhance your user experience.
Our Services, Website, Platform, Applications, email messages, marketing programs and advertisements may use “cookies” and other technologies. These technologies help us better understand user behavior, tell us which parts of our Services people have used or visited, and facilitate and measure the effectiveness of our marketing and advertising programs. We use this information to understand and analyze trends, to administer our Services to learn about user behavior, and to gather important demographic information about our user base as a whole. We may use this information in our marketing and advertising programs.
When you use our Services, our servers automatically record information that your browser or device sends whenever you interact with our Services and store it in log files. This information may include, but is not limited to, your computer or device’s Internet Protocol (IP) addresses, browser type and language, Internet Service Provider (ISP), referring and exit pages, operating system, date/time stamp, and clickstream data or information you search for on our Website. To the extent that IP addresses or similar identifiers are considered Personal Information by applicable law, we also treat these identifiers as Personal Information.
In some of our email messages, we may use a “click-through URL” linked to content on our Website or within our Services. When you click one of these URLs, you may pass through a separate web server before arriving at the destination page. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.
A “Web Beacon” (also known as clear gifs, pixel tags or Web bugs) is a small (often invisible) graphic image or other web programming code embedded in a web page or email. We use Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors, to monitor how users navigate our Services and to count how many e-mails sent were actually opened. This helps us measure the effectiveness of our content and other offerings and to analyze, improve, optimize reduce or eliminate messaging.
Session and Persistent Cookies
Our Services use “session cookies”, which improve your user experience by storing certain information from your current visit on your device, such as log-in information. Session cookies enable us to remember your log-in session so you can move easily within and use our Services and are required for us to be able to provide our Services to you. Our session cookies have limited functionalities and expirations, and you will be required to re-enter your log-in information after a certain period of time to protect you and your account from unauthorized access. Our Services may use “persistent cookies” or “tracking cookies” for user authentication, faster and more convenient access to and navigation of our Services, to store user preferences and to customize our Services for our users.
Although our Sites currently do not display ads from third-parties, we may work with network advertisers, ad agencies, third-party traffic measurement services and other vendors to provide us with information regarding traffic on our Sites and through our Services, to serve our advertisements on other websites, within third-party applications, and across the Internet, and to provide us with information regarding the use of our Services and the effectiveness of our advertisements. In connection with providing analytics and advertisement services, our service providers may collect certain information about your visits to our Sites or other websites. We do not share Personal Information with these service providers, but they may set and access their own tracking technologies on your computer or device (including cookies and web beacons) and may otherwise collect or have access to information about you. Cookies and web beacons, including those set by third-party network advertisers, may be used to, among other things, target advertisements, prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you. We may share Usage Information about visitors with third-party advertising companies, analytics providers and other vendors for similar purposes. While we may use a variety of service providers to perform advertising and analytics services, you may wish to visit the Network Advertising Initiative (“NAI”), which provides information regarding this practice by NAI members, including the “opt-out” procedures for NAI members.
We use the information we get from Google Analytics only to improve our Services. Google Analytics collects only the IP address assigned to you on the date you use our Services, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with Personal Information. By using our Services, you consent to the processing of data about you by Google in the manner and for the purposes set out above. You may opt-out of Google’s advertising tracking cookie or use a browser plugin to opt-out of all Google Analytics tracking software
Other Non-Personal Application and Mobile Application Data
We collect additional information through Applications that cannot be used to personally identify you (“Non-Personal Application Data”). Non-Personal Application Data ordinarily includes aggregate, summary, or other anonymous data. We also collect information about your device when you use our Applications, particularly our Mobile Applications, including the manufacturer of your device, the device model, the operating system used, the version of the application, and the International Mobile Equipment Identity (IMEI) number. We also collect Non-Personal Application Data from your device such as screen usage data in aggregated form to improve our Applications and Services.
How We Use Information
Generally, Personal Information we collect and process is used to improve the content, performance and quality of our Services and to contact users.
Personal Information is or may be used for the following purposes: (i) to keep you posted on the latest announcements, updates, and news about our Services; (ii) to develop, deliver, provide and improve our Services; (iii) to administer your use of our Services; (iv) to enable you to enjoy and easily navigate our Services; (v) to better understand your needs and interests; (vi) to entertain and fulfill requests you may make; (vii) to personalize and customize your experience; (viii) for internal purposes such as auditing, data analysis, and research; (ix) to administer marketing programs like newsletters, sweepstakes, contests or similar promotions that you may sign-up for or enter; (x) to send important communications and notices about our Services, such as transactional email and notifications about changes to our terms, conditions, and policies and because this information is important to your interaction with us, you may not necessarily opt-out of receiving these communications; (xi) to provide you with further information and offers from us or third-parties that we believe you may find useful or interesting, including newsletters, marketing or promotional materials and other information on services and products offered by us or third-parties. If you decide at any time that you no longer wish to receive any promotional materials or similar communications, please follow the “unsubscribe” instructions provided in any of the communications sent to you or update your preferences as available.
Information Sharing and Disclosure
As otherwise described herein, your Personal Information may be shared with the Customer that authorizes your use of our Services on their behalf (“your Company”) as necessary and required to provide our Services to you and your Company.
Service Providers, Business Partners and Others
We may share Personal Information with companies, business partners and individuals who provide services to facilitate our Services, to provide the services on our behalf, to perform related services (including but not limited to data storage, maintenance services, database management, web analytics, payment processing, and improvement of the Services features) or to assist us in analyzing how the Services are used. These third-parties have access to your Personal Information only for purposes of performing these tasks on our behalf, are obligated to protect your information and may be located wherever we operate.
It may be necessary for us to disclose your Personal Information. We may disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate or as required by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence.
We may also disclose information about you, including Personal Information, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect you, our operations or users, including to protect the property and rights of rFactr or a third-party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.
We will use email as the primary mode of communications with you. You may not opt-out from receiving certain important communications and notices about our Services, such as transactional email and notifications about changes to our terms, conditions, and policies, because such information is required for your continued use of our Services. Otherwise, if you decide at any time that you no longer wish to receive non-transactional messages from us, you may follow the “unsubscribe” instructions provided in any such communication or adjust your email preferences in your account settings as available.
Accessing Your Own Personal Information and Retention
You may obtain information about the Personal Information held about you by us. You may access, review, update, or correct the Personal Information provided in your Personal Profile at any time. We will make good faith efforts to provide you with access to your Personal Information as requested. You may access your Personal Information that we control and request that we correct or update any information that may be obsolete, incomplete or incorrect. We may need to validate your identity in order to implement such a request to ensure that we do not provide your information to anyone who does not have the right to that information. In some cases, we will not be able to provide the information we hold about you if it contains reference to other persons; except where those persons have given their consent to the disclosure or the disclosure is reasonable without their consent or it is subject to privilege recognized under applicable law.
At your request, we will remove or disassociate your Personal Information if we are not required to retain it by law or for legitimate business purposes related to our Series. We may decline to process requests that are unreasonably repetitive, require disproportionate technical effort or would unreasonably interfere with the provision of our Services, jeopardize the privacy of others, are extremely impractical, or for which access, correction or deletion is not otherwise required by local law. Access, correction, or deletion requests can be made to email@example.com.
rFactr acts as a conduit between our users and certain supported Social Media Platforms and third-party applications. Some content published via our Services will no longer be within our care, custody or control after publication on any Social Media Platform. Any content that has been shared by you through any Social Media Platforms or third-Party applications via the Services may continue to be available to third-parties and the public at large, as this content is now under the control of the operators of those Social Medial Platforms and/or the third-party applications.
To request access to your Personal Information or to file a privacy request, please contact us at firstname.lastname@example.org.
International Users and Transfer of Information
“Safe Harbor” is a program that provides a way for US businesses to demonstrate that they provide adequate protection for Personal Information transferred to it according to certain international data protection standards. While rFactr itself is not presently Safe Harbor certified by the US Department of Commerce, rFactr believes in and aligns itself with principles of the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries and Switzerland and the transfer and other processing of personal data transferred from the European Economic Area (“EEA”) or Switzerland to the United States (the “Principles”). Further information on Safe Harbor and the Principles is available from the US Department of Commerce’s website at see http://export.gov/safeharbor/.
Data Storage and Location
Protection of Personal Information and Security
To make sure your Personal Information is secure we communicate our privacy and security guidelines to our employees, representatives, service providers and strategic partners and strictly enforce privacy safeguards within and across our company. We employ industry best practices to keep Personal Information collected or transmitted through our Services secure. We maintain commercial reasonable controls to protect against unauthorized review and use of Personal Information, including electronic safeguards such as security protocols, encryption, software and firewalls. In addition, we use qualified third-party vendors to provide the necessary hardware, software, hosting, networking, storage, and related technology required to provide our Services. These vendors utilize similar industry standard physical, electronic and technological security measures and are obligated to protect your information. Except as otherwise described herein, access to Personal Information is restricted to our authorized employees only.
Submission of information over the Internet or through any network is never entirely secure and we cannot ensure or warrant the security of the information you transmit to us, and you do so at your own risk.
California Privacy Rights
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request certain details about what Personal Information a company shares with third-parties for the third-parties’ direct marketing purposes. We do not share your Personal Information with third-parties for their own direct marketing purposes unless we receive your permission. If you are a California resident and would like to make such a request, please submit your request in writing to: 222 South Church Street, Suite 401, Charlotte, NC 28202.
Questions and Contacting Us
222 South Church Street, Suite 401
Charlotte, NC 28202