PRIVACY POLICY
Last updated December 09, 2024
Third-Party Processors & Fulfillment Partners
We share personal information with carefully vetted third-party vendors and fulfillment partners solely to provide and support our Services to you and our clients. These parties act as our service providers or processors and must:
- Use the information only to perform services for us;
- Implement appropriate technical and organizational security measures;
- Not sell or share the information for their own marketing or other purposes;
- Apply equivalent protections to any sub-processors they engage.
Examples of categories of vendors we use (which may vary by project) include:
- Cloud infrastructure and email services (e.g., Google Workspace)
- CRM and automation platforms (e.g., GoHighLevel)
- Advertising platforms (e.g., Meta, Google Ads)
- Analytics providers (e.g., Google Analytics)
- Payment processors (e.g., Stripe)
- AI and automation tools (e.g., OpenAI-powered services)
- Specialized contractors (e.g., developers, designers, and intake service providers)
Where required, we execute Data Processing Agreements (DPAs) and Business Associate Agreements (BAAs) with such vendors to ensure compliance and confidentiality.
Advertising vs. Fulfillment
Sharing for client fulfillment is distinct from online advertising and analytics:
- Data shared for fulfillment purposes is limited to what is necessary for service delivery.
- Data used for advertising or analytics is governed by your cookie preferences and applicable opt-out rights (see the section “Do We Use Cookies and Other Tracking Technologies?”).
SBM does not sell personal data and limits the use of data to the purposes described in this Policy.
International Transfers & Onward Transfer
If personal information is transferred across borders (for example, to the United States or other countries where our vendors operate), we ensure an adequate level of protection through legally approved mechanisms such as Standard Contractual Clauses (SCCs) and Data Processing Agreements (DPAs). All vendors are required to maintain equivalent protections for any sub-processors they may use.
Minimum Necessary, Return/Deletion & Vendor Oversight
We disclose only the minimum data necessary to accomplish the specific project task. Vendors are required to delete or return personal information upon completion of services or when the information is no longer needed. SBM maintains a vendor-management program to evaluate security, confidentiality, and compliance with data-protection requirements. We may periodically request proof of vendor security controls and incident-response procedures.
SUMMARY OF KEY POINTS
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- names
- phone numbers
- email addresses
- mailing addresses
- job titles
- contact preferences
- contact or authentication data
- billing addresses
- debit/credit card numbers
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
- Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services
- Behavioral Data. Behavioral data refers to information collected about the actions and interactions of users, typically within a digital context such as websites, applications, or other platforms. This type of data captures the behaviors of users as they navigate and interact with digital environments, including: Clicks and Navigation: Tracking which buttons are clicked, how users scroll, and the paths they take through a site or app. Engagement Metrics: How much time users spend on specific pages or sections, how often they return, and their levels of interaction with content. Purchase History: Details of past purchases, including frequency, amounts, and types of products or services bought. Device and Usage Times: Information about the devices used to access services (like smartphones or laptops), as well as the times when services are most often accessed. Response to Marketing: How users react to different marketing campaigns, such as opening emails, clicking on ads, or participating in promotions. Behavioral data is invaluable for understanding user preferences, improving user experiences, personalizing content, optimizing website and app designs, and enhancing marketing strategies.
Google API
2. HOW DO WE PROCESS YOUR INFORMATION?
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
- To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.
- To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
- To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Send users information about special offers and discounts on our products and services
- Develop and display personalized and relevant advertising content for our users
- Analyze how our Services are used so we can improve them to engage and retain users
- Support our marketing activities
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
We may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location. GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, like indoors. This data helps Google Maps provide directions, but it is not always perfectly precise. We obtain and store on your device (“cache”) your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
- Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
Google Analytics
We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include: Remarketing with Google Analytics, Google Display Network Impressions Reporting and Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include http://optout.networkadvertising.org/ and http://www.networkadvertising.org/mobile-choice. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.
6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
Our AI Products
Our AI Products are designed for the following functions:
- AI automation
- AI bots
- AI applications
- AI development
- AI document generation
- AI insights
- AI research
- AI translation
- AI search
- IoT
- Image generation
- Machine learning models
- Natural language processing
- Video generation
- Video analysis
- Text analysis
- Blockchain
- Image analysis
- AI predictive analytics
- AI deployment
We believe in giving you the power to decide how your data is used. To opt out, you can:
- Contact us using the contact information provided
- Log in to your account settings and update your user account
7. HOW LONG DO WE KEEP YOUR INFORMATION?
8. HOW DO WE KEEP YOUR INFORMATION SAFE?
9. DO WE COLLECT INFORMATION FROM MINORS?
10. WHAT ARE YOUR PRIVACY RIGHTS?
11. CONTROLS FOR DO-NOT-TRACK FEATURES
12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
| B. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES |
| C. Protected classification characteristics under state or federal law | Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data | YES |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | YES |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | YES |
| G. Geolocation data | Device location | YES |
| H. Audio, electronic, sensory, or similar information | Images and audio, video or call recordings created in connection with our business activities | YES |
| I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us | NO |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics | YES |
| L. Sensitive personal information | NO |
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
- Category A – As long as the user has an account with us
- Category B – As long as the user has an account with us
- Category C – As long as the user has an account with us
- Category D – As long as the user has an account with us
- Category F – As long as the user has an account with us
- Category G – As long as the user has an account with us
- Category H – As long as the user has an account with us
- Category K – As long as the user has an account with us
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
Depending upon the state where you live, you may also have the following rights:
- Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota’s privacy law)
- Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law)
- Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota’s and Oregon’s privacy law)
- Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota’s privacy law)
- Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
- Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. Data Protection Commitment
Social Booster Marketing is committed to protecting the privacy and security of all client and user data. Our internal PII Policy and vendor agreements ensure that personal information is handled lawfully, securely, and only for legitimate business purposes
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.