PRIVACY NOTICE
Last updated March 17, 2021
Thank you for choosing to be part of our community at Social Multiplier
Pro ("Company", "we", "us", "our"). We are committed to protecting your
personal information and your right to privacy. If you have any questions
or concerns about this privacy notice, or our practices with regards to
your personal information, please contact us at
surewin@socialmultiplierpro.com.
When you visit our website http://socialmultiplierpro.com/ (the
"Website"), and more generally, use any of our services (the "Services",
which include the Website), we appreciate that you are trusting us with
your personal information. We take your privacy very seriously. In this
privacy notice, we seek to explain to you in the clearest way possible
what information we collect, how we use it and what rights you have in
relation to it. We hope you take some time to read through it carefully,
as it is important. If there are any terms in this privacy notice that
you do not agree with, please discontinue use of our Services
immediately.
This privacy notice applies to all information collected through our
Services (which, as described above, includes our Website), as well as,
any related services, sales, marketing or events.
Please read this privacy notice carefully as it will help you understand
what we do with the information that we collect.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when
you register on the Website, express an interest in obtaining information
about us or our products and Services, when you participate in activities
on the Website (such as by posting messages in our online forums or
entering competitions, contests or giveaways) or otherwise when you
contact us.
The personal information that we collect depends on the context of your
interactions with us and the Website, the choices you make and the
products and features you use. The personal information we collect may
include the following:
Personal Information Provided by You. We collect names; email addresses;
and other similar information.
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.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate
business interests, the fulfillment of our contract with you, compliance
with our legal obligations, and/or your consent.
We use personal information collected via our Website for a variety of
business purposes described below. We process your personal information
for these purposes in reliance on our legitimate business interests, in
order to enter into or perform a contract with you, with your consent,
and/or for compliance with our legal obligations. We indicate the
specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To send you marketing and promotional communications. We and/or our
third-party marketing partners may use the personal information you send
to us for our marketing purposes, if this is in accordance with your
marketing preferences. For example, when expressing an interest in
obtaining information about us or our Website, subscribing to marketing
or otherwise contacting us, we will collect personal information from
you. You can opt-out of our marketing emails at any time (see the "WHAT
ARE YOUR PRIVACY RIGHTS" below).
Deliver targeted advertising to you. We may use your information to
develop and display personalized content and advertising (and work with
third parties who do so) tailored to your interests and/or location and
to measure its effectiveness.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with
laws, to provide you with services, to protect your rights, or to fulfill
business obligations.
We may process or share your data that we hold based on the following
legal basis:
Consent: We may process your data if you have given us specific consent
to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably
necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with
you, we may process your personal information to fulfill the terms of our
contract.
Legal Obligations: We may disclose your information where we are legally
required to do so in order to comply with applicable law, governmental
requests, a judicial proceeding, court order, or legal process, such as
in response to a court order or a subpoena (including in response to
public authorities to meet national security or law enforcement
requirements).
Vital Interests: We may disclose your information where we believe it is
necessary to investigate, prevent, or take action regarding potential
violations of our policies, suspected fraud, situations involving
potential threats to the safety of any person and illegal activities, or
as evidence in litigation in which we are involved.
More specifically, we may need to process your data or 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.
4. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill
the purposes outlined in this privacy notice unless otherwise required by
law.
We will only keep your personal information for as long as it is
necessary for the purposes set out in this privacy notice, unless a
longer retention period is required or permitted by law (such as tax,
accounting or other legal requirements). No purpose in this notice will
require us keeping your personal information for longer than the period
of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal
information, we will either delete or anonymize such information, or, if
this is not possible (for example, because your personal information has
been stored in backup archives), then we will securely store your
personal information and isolate it from any further processing until
deletion is possible.
5. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system
of organizational and technical security measures.
We have implemented appropriate technical and organizational security
measures designed to protect the security of any personal information we
process. However, despite our safeguards and efforts to secure your
information, no electronic transmission over the Internet or information
storage technology can be guaranteed to be 100% secure, so we cannot
promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security, and improperly
collect, access, steal, or modify your information. Although we will do
our best to protect your personal information, transmission of personal
information to and from our Website is at your own risk. You should only
access the Website within a secure environment.
6. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children
under 18 years of age.
We do not knowingly solicit data from or market to children under 18
years of age. By using the Website, you represent that you are at least
18 or that you are the parent or guardian of such a minor and consent to
such minor dependent’s use of the Website. If we learn that personal
information from users less than 18 years of age has been collected, we
will deactivate the account and take reasonable measures to promptly
delete such data from our records. If you become aware of any data we may
have collected from children under age 18, please contact us at
surewin@socialmultiplierpro.com.
7. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, you have
rights that allow you greater access to and control over your personal
information. You may review, change, or terminate your account at any
time.
In some regions (like the European Economic Area), you have certain
rights under applicable data protection laws. These may include the right
(i) to request access and obtain a copy of your personal information,
(ii) to request rectification or erasure; (iii) to restrict the
processing of your personal information; and (iv) if applicable, to data
portability. In certain circumstances, you may also have the right to
object to the processing of your personal information. To make such a
request, please use the contact details provided below. We will consider
and act upon any request in accordance with applicable data protection
laws.
If we are relying on your consent to process your personal information,
you have the right to withdraw your consent at any time. Please note
however that this will not affect the lawfulness of the processing before
its withdrawal, nor will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than
consent.
If you are a resident in the European Economic Area and you believe we
are unlawfully processing your personal information, you also have the
right to complain to your local data protection supervisory authority.
You can find their contact details here:
http://ec.europa.eu/justice/data-
protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data
protection authorities are available here:
https://edoeb.admin.ch/edoeb/en/home.html.
If you have questions or comments about your privacy rights, you may
email us at surewin@socialmultiplierpro.com.
Account Information
If you would at any time like to review or change the information in your
account or terminate your account, you can:
Log in to your account settings and update your user account.
Upon your request to terminate your account, we will deactivate or delete
your account and information from our active databases. However, we may
retain some information in our files to prevent fraud, troubleshoot
problems, assist with any investigations, enforce our Terms of Use and/or
comply with applicable legal requirements.
Opting out of email marketing: You can unsubscribe from our marketing
email list at any time by clicking on the unsubscribe link in the emails
that we send or by contacting us using the details provided below. You
will then be removed from the marketing email list however, we may
still communicate with you, for example to send you service-related
emails that are necessary for the administration and use of your account,
to respond to service requests, or for other non-marketing purposes. To
otherwise opt-out, you may:
Contact us using the contact information provided.
8. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track ("DNT") feature or setting you can
activate to signal your privacy preference not to have data about your
online browsing activities monitored and collected. At this stage no
uniform technology standard for recognizing and implementing DNT signals
has been finalized. As such, we do not currently respond to DNT browser
signals or any other mechanism that automatically communicates your
choice not to be tracked online. If a standard for online tracking is
adopted that we must follow in the future, we will inform you about that
practice in a revised version of this privacy notice.
9. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted
specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The
Light" law, permits our users who are California residents to request and
obtain from us, once a year and free of charge, information about
categories of personal information (if any) we disclosed to third parties
for direct marketing purposes and the names and addresses of all third
parties with which we shared personal information in the immediately
preceding calendar year. If you are a California resident and would like
to make such a request, please submit your request in writing to us using
the contact information provided below.
If you are under 18 years of age, reside in California, and have a
registered account with the Website, you have the right to request
removal of unwanted data that you publicly post on the Website. To
request removal of such data, please contact us using the contact
information provided below, and include the email address associated with
your account and a statement that you reside in California. We will make
sure the data is not publicly displayed on the Website, but please be
aware that the data may not be completely or comprehensively removed from
all our systems (e.g. backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a
temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is
outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to
certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the
past twelve (12) months:
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
NO
B. Personal information categories listed in the California Customer
Records statute: Name, contact information, education, employment,
employment history and financial information
YES
C. Protected classification characteristics under California or federal
law: Gender and date of birth
NO
D. Commercial information: Transaction information, purchase history,
financial details and payment information
NO
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
NO
G. Geolocation data: Device location
NO
H. Audio, electronic, visual, thermal, olfactory, or similar information:
Images and audio, video or call recordings created in connection with our
business activities
NO
I. Professional or employment-related information: Business contact
details in order to provide you our services at a business level, job
title as well as 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 other 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
NO
We may also collect other personal information outside of these
categories 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.
How do we use and share your personal information?
More information about our data collection and sharing practices can be
found in this privacy notice.
You may contact us by visiting
http://socialmultiplierpro.com/contact.php, or by referring to the
contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt-out we
may deny a request if the authorized agent does not submit proof that
they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers
pursuant to a written contract between us and each service provider. Each
service provider is a for-profit entity that processes the information on
our behalf.
We may use your personal information for our own business purposes, such
as for undertaking internal research for technological development and
demonstration. This is not considered to be "selling" of your personal
data.
Social Multiplier Pro has not disclosed or sold any personal information
to third parties for a business or commercial purpose in the preceding 12
months. Social Multiplier Pro will not sell personal information in the
future belonging to website visitors, users and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data - Request to delete
You can ask for the deletion of your personal information. If you ask us
to delete your personal information, we will respect your request and
delete your personal information, subject to certain exceptions provided
by law, such as (but not limited to) the exercise by another consumer of
his or her right to free speech, our compliance requirements resulting
from a legal obligation or any processing that may be required to protect
against illegal activities.
Right to be informed - Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell your personal information to third parties;
the categories of personal information that we sold or disclosed for a
business purpose;
the categories of third parties to whom the personal information was sold
or disclosed for a business purpose; and
the business or commercial purpose for collecting or selling personal
information.
In accordance with applicable law, we are not obligated to provide or
delete consumer information that is de-identified in response to a
consumer request or to re-identify individual data to verify a consumer
request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy
Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to
determine you are the same person about whom we have the information in
our system. These verification efforts require us to ask you to provide
information so that we can match it with information you have previously
provided us. For instance, depending on the type of request you submit,
we may ask you to provide certain information so that we can match the
information you provide with the information we already have on file, or
we may contact you through a communication method (e.g. phone or email)
that you have previously provided to us. We may also use other
verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify
your identity or authority to make the request. To the extent possible,
we will avoid requesting additional information from you for the purposes
of verification. If, however, we cannot verify your identity from the
information already maintained by us, we may request that you provide
additional information for the purposes of verifying your identity, and
for security or fraud-prevention purposes. We will delete such
additionally provided information as soon as we finish verifying you.
Other privacy rights
you may object to the processing of your personal data
you may request correction of your personal data if it is incorrect or no
longer relevant, or ask to restrict the processing of the data
you can designate an authorized agent to make a request under the CCPA on
your behalf. We may deny a request from an authorized agent that does not
submit proof that they have been validly authorized to act on your behalf
in accordance with the CCPA.
you may request to opt-out from future selling of your personal
information to third parties. Upon receiving a request to opt-out, we
will act upon the request as soon as feasibly possible, but no later than
15 days from the date of the request submission.
To exercise these rights, you can contact us by visiting
http://socialmultiplierpro.com/contact.php, or by referring to the
contact details at the bottom of this document. If you have a complaint
about how we handle your data, we would like to hear from you.
10. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant
with relevant laws.
We may update this privacy notice from time to time. The updated version
will be indicated by an updated "Revised" date and the updated version
will be effective as soon as it is accessible. If we make material
changes to this privacy notice, we may notify you either by prominently
posting a notice of such changes or by directly sending you a
notification. We encourage you to review this privacy notice frequently
to be informed of how we are protecting your information.
11. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at
surewin@socialmultiplierpro.com
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to
request access to the personal information we collect from you, change
that information, or delete it in some circumstances. To request to
review, update, or delete your personal information, please visit:
http://socialmultiplierpro.com/contact.php. We will respond to your
request within 30 days.