Emplifi offers Software as a Service (SaaS) solutions for social media marketing, social commerce, and customer service and care. As such, we understand the importance of privacy and we take our responsibility to protect personal information seriously.
This Privacy Policy (the “Policy”) describes the types of personal information the companies belonging to the Emplifi Group (“Emplifi”) may collect, how we may use and disclose the information, and certain rights and options individuals may have regarding their information. The Policy applies to information we collect through our website emplifi.io.
Emplifi Group, for the purposes of this Policy, represents the following companies:
Emplifi, Inc., 4200 Regent Street, Suite 200, Columbus, OH 43219, United States;
Emplifi Czech Republic a.s., Pod Všemi svatými 427/17, Severní Předměstí, 301 00 Plzeň, Czech Republic
Emplifi Canada Inc., 606 Cathcart, Suite 1007, Montreal, Qc, Canada, H3B 1K9, Canada;
Socialbakers UK Limited, 100 New Bridge Street, London EC4V 6JA, United Kingdom;
Socialbakers France, 8 rue d’Athènes, 75009 Paris, France;
Socialbakers Germany GmbH, Amelia-Mary-Earhart Straße 8, 60549 Frankfurt am Main, Germany;
Socialbakers Singapore PTE. LTD., 491B River Valley Road, #15-01 Valley Point, 248373 Singapore
Astute Solutions B.V., Sloterdijk Teleport Towers, Kingsfordweg 151, 1043GR Amsterdam, Netherlands;
Astute Solutions (Australia) PTY LTD, Level 10, 530 Collins Street, Melbourne, VIC 3000, Australia
Astute Solutions (Asia-Pac) Limited, 2003, 20/F, Tower 5, China Hong Kong City, 33 Canton Road, Tsim Sha Tsui, KLN, Hong Kong;
Astute Solutions (Shanghai) Co., LTD, No.24, Yangxin East Road, Pudong New District, Shanghai, China;
iPerceptions (Europe) Limited, SW6 4QP London, Harwood House, 43 Harwood Road, United Kingdom;
iPerceptions US Inc., 575 Madison Ave, Suite 1006, NY 10022-2511, United States;
Sym-Sys Ltd (trading as ‘Go Instore’), 3rd Floor 1 Ashley Road, Altrincham, Cheshire, United Kingdom, WA14 2DT, United Kingdom;
Wilke Global Limited, WA14 2DT Altrincham, Cheshire, 3rd Floor 1 Ashley Road, United Kingdom;
Pixlee TurnTo, Inc., 1013 Centre Road Suite 403-B, Wilmington, DE 19805, United States;
TurnTo Networks, Inc., 1013 Centre Road Suite 403-B, Wilmington, DE 19805, United States;
Pixlee TurnTo Ltd., Fieldfisher Riverbank House, 2 Swan Lake, London, United Kingdom.
Please review this Policy carefully before sharing information with us so you understand our privacy practices. By using our website, including communicating with us over the website, filling out forms on the website, or registering to receive information from us, you agree to the terms of this Policy.
1. Personal Information We Receive
For the purposes of this Policy, “personal information” means information relating to an identified or identifiable natural person. Below we describe the types of personal information that we collect directly through our website.
A. Information We Collect Directly
The types of personal information we may collect directly from website visitors may include the following categories.
Contact information – first name, last name, email address, job title, company name, location of your company and telephone number.
Marketing information – details regarding informational and promotional materials you may have requested or received from us, the services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
Communications information – copies of communications and inquiries you have submitted to us through features available on our website.
Device and usage information – details regarding how and when you use our website, including the device used to connect to our website, your IP address, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to the website, and information about your interaction with our website.
We typically determine the purposes and means of processing this information and, as such, are the “data controller” for such information under the EU’s General Data Protection Regulation (“GDPR”).
B. Anonymized and Third-Party Information
We may aggregate or anonymize the foregoing types of data such that they are no longer capable of identifying an individual, in which case they are no longer considered “personal information.” We may also collect information about you from third-party sources, such as identity verification and information about you that is publicly available.
2. Other Information We Receive
Like most companies, we use various technologies to automatically collect information about website visitors. The technologies we use, how we use them, and options for managing the technologies are described below.
A. Overview of Cookies and Other Technologies
Cookies. Cookies are small text files that a website transfers to a visitor’s device for
recordkeeping purposes. Cookies may be unique to the browser or mobile application you are using. We use cookies to personalize visitors’ experiences on our website, provide content that we may believe may be of interest, track visitor trends and patterns, identify specific pages that you click on and where you scroll, locate the country where you are visiting from, engage in marketing and advertising, and otherwise analyze our website traffic.Log Files and Device Identifiers. We use log files to track actions occurring on the website and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
Web beacons and other technologies. Our App may use other tracking tools, including web beacons (also known as clear gifs, pixel tags, and single-pixel gifs), which are small electronic images embedded in content and email messages that are not ordinarily visible to users. Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership.
Analytics. Our website may also use third-party analytics tools such as Google Analytics. Analytics are used to create reports and statistics on the performance of our website and present you with content tailored to your interests. Analytics can be used to collect information such as IP address, type of device, operating system, referring URLs, country information, date and time of page visits, and which pages you visit the most. You can find more information about how data is collected and processed in connection with the Google Analytics service here. You can also read Google’s privacy policy here.
The information collected through these technologies may be combined with personal information or aggregated with other information on website visits. We may share information about your use of our website with our advertising and analytics partners, who may combine it with other information that you previously provided to them.
B. Specific Types of Cookies
We use the following types of cookies on our website. Other than “strictly necessary cookies,” we will only place these cookies on your computer or device where you have consented to us doing so. Note some of these cookies are temporary and deleted as soon as you close your browser. These are known as “session cookies.” Other cookies are stored on your computer or device until they expire or you remove them. These are known as “persistent cookies”.
Strictly Necessary Cookies. These cookies are necessary for our website to function and cannot be turned off in our system or preference center. These cookies are usually only set in response to specific actions you take on the site. For example, we use them to remember your cookie preferences.
Performance Cookies. These cookies allow us to count visits and traffic sources to our website, so that we can measure and improve its performance. They assist us in understanding how visitors interact with our website. For example, they allow us to see which pages are the most and least popular on our website, the frequency of visits to specific pages, how visitors come to our website (e.g., whether they clicked a link from a search engine), and information on the devices and browsers used to access our site. The information collected by these cookies is aggregated and, therefore, anonymous. If you do not permit these cookies, we will not be able to know when you visit our website.
Functional Cookies. These cookies enable the website to provide certain functionality and personalization. They may be set by us or third-party providers whose service we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Targeting Cookies. These cookies may be set through our site by advertising partners. They may be used to create a profile of visitors’ interests and to show relevant advertising to visitors when they are on other websites. These cookies are able to identify your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Social Media Cookies. These cookies are set by social media services that have been added to the site to enable you to share content with your social media network. These cookies track your browser across other sites and can be used to build a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.
C. How You Can Manage Cookies
You can manage your cookie preferences in our privacy preference center. In addition, most web browsers provide options for turning off or disallowing cookies. The specific method for doing so depends on the web browser you are using. For further information about changing your browser setting to turn off or disallow cookies, including how to refuse cookies, please visit https://www.allaboutcookies.org/manage-cookies/ , which includes links to instructions for specific browsers. Please note that if cookies are disabled, you may not be able to enjoy certain features of our website.
3. How We Use Personal Information
We use the personal information we collect for the following purposes:
a. Optimizing your experience on our website and ensuring that our content is presented to you in the most effective manner;
b. Sending promotional or marketing communications and solicitations, tracking your
marketing preferences, and for our internal marketing purposes;
c. Responding to inquiries submitted through our website, providing you with information that you may request about our business and services, and otherwise communicating with you about our services;
d. Inviting you to seminars, webinars, or similar events that we are hosting or sponsoring;
e. Preventing or detecting fraud, hacking activities, security breaches, or safety risks in connection with our website;
f. Notifying you about changes to our website and material changes to this Policy; and
g. Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.
For more information about your options relating to your personal information and your communication preferences, see “Your Choices Regarding Your Information” below.
4. Disclosure of Personal Information
When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.
In addition, we may share your information with the following types of entities:
Service providers and third-party vendors that we use to support our business, including companies that perform work necessary for us to provide our website services. For example, we may share your information with our email service and IT security providers.
Marketing and advertising vendors that may assist with lead generation, hosting information relating to clients and potential clients, marketing automation, advertisement placement, and targeting, and marketing campaigns and communications.
Analytics vendors in order to understand our website traffic and usage patterns, optimize our website, and identify potential new clients.
Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
Other parties for any purpose we disclose at the time you provide the information. To request a current list of all processors and subprocessors, please use the contact information at the end of this Policy.
Finally, we may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or other lawful requests for information we receive, or to otherwise protect our rights.
5. Choices About the Collection and Use of Personal Information
Consistent with any legal requirements, we may communicate with you or send you promotional and informational communications about our services, provided we have any necessary permissions to do so. If we ever send you promotional emails, you can stop receiving those emails by clicking the “unsubscribe” link in the email. We endeavor to promptly process any unsubscribe requests. We also have a “preference center” on our website where you can manage your communication preferences. Alternatively, you can contact us using the details provided at the end of this Policy to change your marketing communication preferences, including the withdrawal of your consent. You can also choose not to provide us with information we may request through our website, but that may result in you being unable to use certain features of our website, request information from us, or initiate other interactions with us via the website.
6. Protection of Personal Information
We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification. Such measures may include, without limitation, taking reasonable steps to ensure the reliability of employees or service providers having access to your data limited access rights and access controls; appropriate authentication procedures; security and privacy training for employees; appropriate data back up, recovery, and incident management procedures; restrictions on storing, printing and disposal of personal data; and software protection of devices on which personal data are stored. Nevertheless, please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.
7. Links to Third-Party Websites
Our website may contain links to third-party websites. Such websites have separate privacy policies that you should review. We cannot take responsibility for the content of linked websites or those companies’ data-handling practices.
8. International Transfers
Please be aware that Emplifi is headquartered in the United States and has operations globally. As a result, your information may be transferred to the United States or jurisdictions where Emplifi has operations. The data protection laws in these locations may be different from your home country.
Please note that if we transfer personal information from the EU to the United States or any other country, we will implement appropriate legal mechanisms to ensure an adequate level of personal data protection consistent with the GDPR’s requirements. For example, if the recipient country has not received an Adequacy Decision from the EU, we will rely on European Commission’s Standard Contractual Clauses(SCCs) as the lawful mechanisms for such transfers. Further, we have entered into appropriate data processing agreements signed with all non-EU (sub)processors which contain SCCs and define security standards and measures to be employed by each of our (sub)processors (including state of the art encryption). We also contractually require our (sub)processors to provide us prompt notice of any data breach or security incident concerning processed data.
9. EU / UK Residents
A. Rights Under GDPR
The GDPR affords certain rights to individuals in the European Economic Area (“EEA”) regarding their personal information. If you are located in the EEA, you have the rights to:
withdraw consent to data processing at any time;
access your personal information;
request a copy of your personal information;
correct any inaccuracies in your personal information;
erase your personal information;
data portability, meaning to request a transfer of your personal information from us to any other person or entity as chosen by you;
restrict the processing of your personal information; and
object to the processing of your personal information.
You will not typically need to pay a fee to exercise any of these rights. But we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Subject to exceptions, if you wish to exercise one of the rights identified above with regard to personal information subject to this Policy, you may do so by submitting a request to dataprivacy@emplifi.io. Once we have received your request, we will review it and contact you within 30 days of our receipt of your request, but we will notify you of any delay and, in any event, will reply within three (3) months. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights).
Lastly, if you are located in the EEA and have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in the EEA. Emplifi’s EU operations are mainly located in the Czech Republic. The contact information for the Czech Republic’s data protection authority is Úřad pro ochranu osobních údajů, at Pplk. Sochora 2Z, 170 00 Praha 7, Czech Republic.
B. Lawful Basis Under GDPR
As a “controller,” our lawful basis for processing your information is typically either to (1) fulfill our legitimate business interests (such as ensuring the safety, security, and functionality of our website), (2) comply with a legal obligation, or (3) conduct processing to which you have specifically consented.
When we process your personal information for the purposes described in Section 3.a, and 3.e–3.g above, our lawful basis is our legitimate interest to present and optimize our website, detect and prevent potential security issues on our website, and develop and improve on service offerings. Likewise, when we process your personal information for the purposes described in Sections 3.c – 3.d, our lawful basis is our legitimate interest to monitor the efficacy of our marketing efforts, respond to inquiries about our business and services, and promote our service offerings. When we send promotional communications to you as described in Section 3.b, our lawful basis is typically your express consent. Where we use your personal data for our legitimate interests, we evaluate any potential impact of the processing on your rights and freedoms as required by the GDPR.
10. California Residents
If you are a California resident, please refer to our Privacy Notice for California Residents for a description of rights available to you under California Law.
11. Children’s Privacy
Our website is a general audience site and is not directed at, or intended for use by, children under the age of 16 years. Accordingly, we do not knowingly collect personal information from children under age 16. Should we discover that a child under the appropriate age provided his or her personal information, we will use that information only to respond to that child and inform him or her that we must have parental consent before receiving such information.
12. Data Storage and Retention
We keep your personal information for as long as necessary to fulfill your requests or the purposes for which it was obtained. The criteria used to determine our retention periods include (i) for as long as we have an ongoing relationship with a particular website visitor or potential customer, (ii) as required by a legal obligation to which we are subject, and (iii) as necessary to comply with legal obligations.
13. Do-Not-Track Disclosure
Please note that we do not alter our website’s data collection and use practices when we see a “Do Not Track” signal from your device.
14. Changes to this Policy
Please note that we may change this Policy from time to time. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this website after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check the Policy periodically for updates.
15. Contact Information
For more information about our privacy practices or if you have questions, please contact us by e-mail at dataprivacy@emplifi.io or by using the contact information provided below:
Emplifi Group
For the attention of our Group DPO Sarah Jarman
Legal@emplifi.io
Postal Address:
US
Emplifi Inc.
4400 Easton Commons, Suite 250
Columbus, OH 43219
UK and global
3rd Floor 1 Ashley Road,
Altrincham, Cheshire,
United Kingdom,
WA14 2DT
EU
Emplifi Czech Republic a.s.,
Pernerova 53,
186 00 Praha 8,
Czech Republic