Privacy Policy

Last revised: June 2021

Privacy Policy

This Privacy Policy applies to processing of personal data by Sociaro Limited (“Sociaro” or “we”) via use of Sociaro AI user touchpoint by you as representatives of our customers, as well as our business development and marketing activities, and etc.

What data do we collect

Sociaro AI is B2B service, thus we only collect and process data of its users that are employees or representatives of our customers. Sociaro AI is not intended for consumers and children under 16 years of age. We do not knowingly collect personal information from consumers and children under 16.

When you use or interact with Sociaro AI, we may collect several types of information directly from you or your entity or through your device use, including:

  • Personal information, such as name, email, contact details or any other personal content that you or your entity provide to us via registration of account, subscription to e-mail newsletters, support tickets and requests or any other communication (e.g., email, phone, messengers and etc.),
  • Technical data, such as user-agent, operating system, device type, IP address and other technical information received from a browser automatically when visiting or interacting with Sociaro AI through use of cookies and similar technologies, which allow us to analyse and improve the user experience within Sociaro AI.

Cookies

Cookies are small files that are stored on your desktop, notebook or mobile device while you visit a website. Most browsers are set to automatically accept certain types of cookies; however, you can usually change this setting in the browser preferences.

To control the user experience, we use Google Analytics provided by Google, Inc. Prior to transfer of data to Google, your IP address will previously be truncated by Google within the EU member states or EEA member states and will not be combined by Google with any other data.

You can delete stored cookies at any time, web/DOM storage and local shared objects can be deleted separately. If you decide to reject the use of cookies or delete them, you may not have access to all functions of our websites or individual functions may be limited. You may prevent the collection of the data by Google by downloading and installing a browser plugin that is available under the following link: http://tools.google.com/dlpage/gaoptout.

What data do we process under instructions

Sociaro AI involves provision of mobile analytics platform to our mobile application owners (the “Customers”). In connection with these services, we may process certain data from the end-users of such mobile applications ("End Users") under the agreements and upon instructions of the Customers and do not have any kind of direct relationship with the End Users.

Such data include:

  • Technical information on the End Users’ devices, including browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier;
  • Identifiers of the End Users’ devices, including: IP address (which by its nature may also provide general location information), user-agent, IDFA (Identifier-for-Advertisers), Android ID; Google Advertiser ID, any ID issued to an End User by the Customer and similar identifiers;
  • Information on interaction with mobile applications and campaign events, including: mobile applications’ features triggered by an End User, downloads and installations of mobile applications, engagement time, clicks on the Customer ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or mobile application from which such ads were displayed, and other interactions, events and actions that the Customer chooses to measure and analyze within their mobile applications.

Lawful basis and purposes for data processing

We only process your data under the following legal bases:

  • as a data processor under the instructions of the company that you represent,
  • your consent, whether you have given any,
  • our legitimate interests in improving our platform and user experience, analysing its usage for security purposes, saving your preferences in the interface and features,
  • the fulfilment of applicable legal obligations.

We use information that we collect about you or that you provide to us:

  • to present functionalities of the platform to you;
  • to provide our customers with analytics functionalities of the platform according to relevant service and data processing agreements;
  • to provide you with information, support and services requested by you or the company you represent;
  • to fulfil obligations and enforce our rights arising from any contracts entered into between you and the company you represent, including for billing and collection;
  • to notify you about any improvements and amendments to our platform or any services.

We may also use your data to contact you via e-mail, by phone or in messengers about products and services that may be of interest to you. Such communications will be sent to you when you have consented to receive such communication or when we have a legitimate interest to market our products and services.

We store your data as long as instructed by the company you represent. Whether you have consented to the processing, we process the data no longer that the term indicated under the consent provided. If we use the data on the basis of a legitimate interest, we process the data at most as long as your interest in deletion or anonymisation does not prevail. We store mobile application data as long as instructed by the data controller.

When do we share information

In order to provide our platform and conduct our business, we may share the information, including personal data, with various third parties, such as:

  • our subsidiaries and affiliates for the sole purpose of providing our services, and
  • third-parties that provide us with technical services in order to maintain the platform and its features, such as: Amazon Web Services EMEA SARL (5 rue Plaetis, Luxembourg, L-2338, Luxembourg), acting as the IaaS-provider for the Platform; Google Ireland Limited (Google Building Gordon House, Barrow St, Dublin 4, Ireland), acting as the provider of business support services; Stripe Payments Europe, Limited (The One Building, 1 Grand Canal Street Lower, Dublin 2, Co. Dublin, Ireland), acting as the payment provider; as well as other third-party solutions providers, which are authorized to use data information only as necessary to provide these services to us.

We may also disclose your personal data to comply with any court order, law requirement or legal process, including to respond to any government or regulatory request, or if we assess the disclosure as necessary or appropriate to protect the rights and legitimate interests of Sociaro or our customers.

Whether personal data is being transferred to countries outside the European Economic Area, we only transfer it to third countries (i) the EU Commission has confirmed an adequate level of protection or (ii) provided we can ensure the security of data processing by means of contractual agreements or other assurances, such as certifications or proven compliance with international security standards.

Your choices and rights as the data subjects

To control how we collect and process your data, you may consider the following mechanisms:

  • you can set your browser to refuse storing of cookie-files and/or use third-party plugins to prevent tracking of your behaviour as indicated above in the “Cookies” sub-section, however, please note that functionalities of the platform may be limited in this case;
  • you can at any time opt out of any marketing communications that we may address directly to you using the “Unsubscribe” links in marketing e-mails, however, please note that it may not apply to the non-promotional letters that you may receive as a representative of our customer.

As the data subject, you have a set of rights with regard to data processing:

  • the right of access to personal data,
  • the right to rectification of personal data,
  • the right to erasure of your personal data,
  • the right to restriction of processing of your personal data,
  • the right to object to processing of data in cases of direct marketing, or when we rely on legitimate interests as our lawful basis to process your information; and
  • the right to lodge a complaint against the processing of your personal data with the competent supervisory authority.

In addition, whether you have given a consent to the data processing, you can withdraw the given consent at any time. Such withdrawal affects the admissibility of the processing of your personal data after you make such revocation. You also have the right to data portability provided that the data is processed under your consent.

You may at any time file any concern regarding to processing of your data via privacy@sociaro.ai.

Security of processing

We have implemented appropriate technical and organizational measures to secure your personal data from accidental loss, unauthorized access, use, alteration and disclosure. We have established necessary security regulations and procedures to assure the security on information, physical, organizational and human levels. We store the data on premises of Amazon Web Services, provided that security measures are implemented both on server and platform sides and received sufficient warranties from service provider. To keep your personal account safe, please do not share your registration information with anybody.