SocialPoint Audience Engagement Platform, including (without limitation) our website, application, and other interactive properties through which the services are delivered (collectively, the “Service”) are owned, operated and distributed by Interactive Meeting Technology, LLC (referred to in this Privacy Notice as “IMT” or “we” and through similar words such as “us,” “our,” etc.). This Privacy Notice outlines the personal information that IMT may collect, how IMT uses and safeguards that information, and with whom we may share it.
IMT encourages our Customers, visitors, business associates, and other interested parties to read this Privacy Notice, which applies to all Users. This Privacy Notice is not intended to fulfill your (Customer) obligations to individuals you are engaging through use of the Service’s games, quizzes, or other interactive properties (“Participants”). You are separately responsible for providing Participants notice or obtaining Participant consent, where required by law, prior to providing Participant personal information to IMT.
By using our Service or submitting personal information to IMT by any other means, you acknowledge that you understand and agree to be bound by this Privacy Notice, and agree that IMT may collect, process, transfer, use, and disclose your personal information as described in this Notice. Further, by accessing any part of the Service, you are agreeing to THE TERMS AND CONDITIONS OF OUR TERMS OF SERVICE (the “Terms of Service”). IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY NOTICE OR OUR TERMS OF SERVICE, PLEASE DO NOT USE ANY OF THE SERVICES.
What personal information does IMT collect?
Personal information (also commonly known as personally identifiable information (PII) or personal data) is information that can be used to identify you, or any other individual to whom the information may relate.
The personal information that we collect directly from those registering for the Service, includes the following categories:
- Name and contact information (e.g. address; phone number; email, fax);
- Billing Information (e.g. credit card, bank account, billing contact information);
- Order Information (e.g. current order/purchase information, purchase history);
- Company/employer information;
- Geographic or location information;
- Information contained in posts you may on the public forums and interactive features of the Service;
- Information as described in the below section titled “Cookies, Device Data, and How it is Used,” if such data is considered personal information under the laws of your state/country;
- Other information that may be exchanged in the course of engaging with the Service. You will be aware of any subsequently collected information because it will come directly from you.
When providing personal information to IMT as described in this Notice, that personal information is collected directly from you, and you will know the precise personal information being collected by us.
In addition to the above, the Service may collect certain personal information about Participants you are engaging through use of the Service’s games, quizzes, or other interactive properties. When you organize an activity through the Service, you will have the option to select what personal information is collected about Participants through those activities. Further, it is your responsibility to ensure any legal obligations toward Participants are met prior to providing their personal information to IMT, including but not limited to, notice or consent obligations regarding Participant personal information. You will find options to facilitate such notice or consent with Participants at the time you are setting up an activity within the Service.
Please note that you should not submit to IMT any sensitive personal information relating to your (i) racial or ethnic origin (ii) political beliefs (iii) philosophical or religious beliefs (iv) membership of a trade union or political party (v) physical or mental health or genetic makeup (vi) addictions, sexual life or (vii) the commission of criminal offences or proceedings and associated penalties or fines, unless you have previously sent to us your written consent that we may process such personal information, if IMT determines consent to be a requirement of applicable law. If you provide such sensitive personal information to IMT, that personal information will be promptly deleted.
Collection of User Generated Content
We may invite you to post content on the Service, including your comments and any other information that you would like to be available on the Service, which may become public (“User Generated Content”). If you post User Generated Content, all of the information that you post will be available to authorized personnel of IMT and may be made publicly available. You expressly acknowledge and agree that we may access in real-time, record and store archives of any User Generated Content on our servers to make use of them in connection with the Service. If you submit a review, recommendation, endorsement, or other User Generated Content through the Service, or through other websites including Facebook, Instagram, Google, Yelp, and other similar channels, we may share that review, recommendation, endorsement or content publicly on the Service.
In addition, Participants may have the opportunity to provides comments and feedback via the activities you execute on the Service (“Participant Generated Content”). As indicated in the previous section, it is your responsibility to provide any notice or consent required by law regarding Participant Generated Content.
How does IMT use personal information?
Subject to the terms of this Privacy Notice, IMT uses the above described categories of personal information in several ways. Unless otherwise stated specifically, the above information may be used for any of the following purposes:
- to administer the Service to you;
- to respond to your requests;
- to distribute communications relevant to your use of the Service, such as system updates or information about your use of the Service;
- as may be necessary to support the operation of the Service, such as for billing, account maintenance, and record-keeping purposes;
- to send to you IMT solicitations, product announcements, and the like that we feel may be of interest to you (you may “opt out” of receiving these marketing materials);
- in other manners after subsequent notice is provided to you and/or your consent is obtained, if necessary.
IMT does not sell, re-sell, or distribute for re-sale your personal information.
How do we share personal information with third parties?
We may provide any of the described categories of personal information to IMT employees, consultants, affiliates, or other businesses or persons for the purpose of processing such information on our behalf in order to provide the Service to you. In such circumstances, we require that these parties agree to protect the confidentiality of such information consistent with the terms of this Privacy Notice.
We will not share your personal information with other, third-party companies for their commercial or marketing use without your consent or except as part of a specific program or feature for which you have the ability to opt-in or opt-out.
In addition, we may release personal information: (i) to the extent we have a good-faith belief that such action is necessary to comply with any applicable law; (ii) to enforce any provision of the Terms of Service, protect ourselves against any liability, defend ourselves against any claims, protect the rights, property and personal safety of any user, or protect the public welfare; (iii) when disclosure is required to maintain the security and integrity of the Service, or to protect any user’s security or the security of other persons, consistent with applicable laws (iv) to respond to a court order, subpoena, search warrant, or other legal process, to the extent permitted and as restricted by law; or (v) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of our assets.
Retention of Data
IMT will retain your personal information only for as long as is necessary for the purposes set out in this Notice. We will retain and use personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
With regard to personal information collected about Participants through games or activities you execute through the Service, IMT will retain such information for your use for 60 days, after such time all Participant personal information associated with a particular activity will be deleted.
IMT will also retain usage data for internal analysis purposes as described in the next section. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of the Service, or we are legally obligated to retain this data for longer periods.
Cookies, Device Data, and How it is Used
When you use our Service, we may record unique identifiers associated with your device (such as the device ID and IP address), your activity within the Service, and your network location. IMT uses aggregated information (such as anonymous user usage information, cookies, IP addresses, browser type, clickstream information, etc.) to improve the quality and design of the Service and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user preferences and trends. Specifically, we may automatically collect the following information about your use of Service through cookies, web beacons, and other technologies:
- domain name;
- browser type and operating system;
- web pages you view;
- links you click;
- IP address;
- the length of time you visit the Sites, Portals, and/or Services;
- the referring URL or the webpage that led you to the Sites.
We may also collect information regarding application-level events, such as crashes, and associate that temporarily with your account to provide customer service. In some circumstances, we may combine this information with personal information collected from you (and third-party service providers may do so on behalf of us).
International Data Transfer
If you are located outside the United States, in particular if you are located in Switzerland, the United Kingdom, or the European Economic Area (“EEA”), please note that we and our servers are located in the United States. Any information that you provide to us may be transferred to and processed in the United States or other countries around the world where we do business. Although this may include recipients of information located in countries where there may be a lower level of legal protection for your personal information than in your country, we will protect your information in accordance with requirements applicable to the law in your particular jurisdiction and take steps to only share with third parties that offer similar protection. By using our Service, you unambiguously consent to your information being collected, processed, used, and transferred as disclosed herein.
European Union Data Privacy Rights
If you are located in EEA, the General Data Protection Regulation (“GDPR”) grants you certain rights under the law. In particular, the right to access, correct, and delete the personal information we hold about you. IMT will retain your personal information for the length of time you engage with our services as described in the retention section of this Notice or until you request deletion of such personal information.
In certain circumstances, you have the following data protection rights:
- The right to access, update or delete the personal information we have on you.
- The right of rectification. You have the right to have your personal information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to specific processing of your personal information.
- The right of restriction. You have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the personal information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your personal information.
In order make a request regarding your personal information, please contact firstname.lastname@example.org.
If you have a comment, question, or complaint about how we are handling your personal information, we hope that you contact us at email@example.com in order to allow us to resolve the matter. In addition, if you are located in the EEA, you may submit a complaint regarding the processing of your personal information to the EU data protection authorities (each a “DPA”). The following link may assist you in finding the appropriate DPA: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Legal Basis for Processing under GDPR
If you are from the EEA, our legal basis under GDPR for collecting and using the personal information described in this Notice depends on the personal information we collect and the specific context in which we collect it.
We may process personal information because:
- We need to perform a contract with you;
- You have given us consent to do so;
- The processing is in our legitimate interest to offer the Service, when that legitimate interest is not overridden by your rights;
- To comply with the law.
Where personal information is processed based on consent, EU residents have the right to withdraw such consent at any time. To do so, please contact us as described in this Notice. If there is a different legal basis that would permit us to continue processing your personal information after withdrawing consent, we will notify you of that legal basis at the time of your request.
California Privacy Rights
Please note that the California Consumer Privacy Act (“CCPA”) is not fully applicable to personal information exchanged in all transactions (for example, CCPA does not fully apply in a business to business transaction). While IMT treats the personal information of all customers and users of the Service with the same degree of care, you may not be eligible for all the rights described herein depending on the nature of the business relationship and the personal information collected.
If you are a California resident, California law may provide you with certain rights with regard to your personal information under the CCPA. Throughout this Privacy Notice you will find information required by CCPA regarding the categories of personal information collected from you; the purposes for which we use personal information, and the categories of third parties your data may be shared with. This information is current as of the date of the Notice and is applicable in the 12 months preceding the effective date of the Notice.
As a California resident, the CCPA provides you the ability to make inquiries regarding to your personal information. Specifically, the degree to which the information is not already provided in this Privacy Notice, you have the right to request disclosure about the collection and use of your personal information over the past 12 months, including:
- The categories of personal information collected about you.
- The categories of sources for the personal information collected about you.
- The business or commercial purpose for collecting your personal information.
- The categories of third parties with whom your personal information was shared.
- The specific pieces of personal information collected about you.
- If your personal information was disclosed for a business purpose, the personal information categories disclosed and the categories of third parties to which the information was disclosed.
- If your personal information was sold in the past 12 months, the personal information categories sold and the categories of third parties to which the information was sold (Note: IMT DOES NOT SELL YOU PERSONAL INFORMATION).
Please note that you may only make the above requests twice in a 12-month period. You also have the right to request that any of your personal information collected and retained be deleted, subject to certain exceptions. Finally, you have the right to not receive discriminatory treatment by IMT or any business for exercising any of the rights provided under CCPA.
You may submit a request regarding your rights under CCPA by contacting us at firstname.lastname@example.org or 612-200-1010.
If we receive a CCPA request from you, we will first make a determination regarding the applicability of the law, and we will then take steps to verify your identity prior to responding. The steps to verify your identity may vary based on our relationship with you, but, at a minimum, it will take the form of confirming and matching the information submitted in the request with information already held by IMT and/or contacting you through previously used channels to confirm that you submitted the request (i.e. confirming identity through contact information that we have on file, not the contact information submitted to make the request).
Your rights as stated here can also be exercised by an authorized agent on your behalf. IMT will follow the standards set by the Attorney General of California regarding designation of an authorized agent to exercise rights under CCPA. You may review information available through the Attorney General website regarding how an individual can be designated as an authorized agent under CCPA.
In addition to CCPA, California Civil Code Section 1798.83 permits users of the Service who are California residents to request certain information regarding its disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us as described here.
Information Security and User Responsibility
IMT employs industry-standard security measures designed to protect the security of all information submitted through the Service. However, the security of information transmitted through the internet or via a mobile device can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data.
Users of the Service are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of the Service. In order to protect you and your information, we may suspend your use of any of the Service, without notice, pending an investigation, if any breach of security is suspected.
The Service may contain links to other websites maintained by third parties. Please be aware that we exercise no control over linked sites and IMT is not responsible for the privacy practices or the content of such sites. Each linked site maintains its own independent privacy and data collection policies and procedures, and you are encouraged to view the privacy policies of these other sites before providing any personal information.
You hereby acknowledge and agree that IMT is not responsible for the privacy practices, data collection policies and procedures, or the content of such third-party sites, and you hereby release IMT from any and all claims arising out of or related to the privacy practices, data collection policies and procedures, and/or the content of such third-party sites.
The Service is not intended for children under the age of 13, and IMT does not knowingly collect the personal information of children under the age of 13.
Changes to this Privacy Notice
IMT reserves the right to modify this Privacy Notice from time to time in order that it accurately reflects the regulatory environment and our data collection principles. When material changes are made to this Privacy Notice, IMT will post the revised Notice on our website. This Privacy Notice was last modified as of May 2020.
If you have any questions or comments about this Privacy Notice or the Service provided by IMT, please contact us at:
Interactive Meeting Technology, LLC
226 Colfax Avenue North
Minneapolis, MN 55405
IMT has engaged the following third-party Subprocessors to assist in providing the Services:
|Amazon Web Services (AWS)||California, United States|
|Twilio||California, United States|