LAST MODIFIED: APRIL 5, 2017

SOCIAL SENTINEL, INC.

PRIVACY POLICY

Welcome to the Privacy Policy for the Social Sentinel® Service and Site.

1.      DESCRIPTION OF SERVICE.

Social Sentinel, Inc.'s ("SSI" or “we” or “our”) services include social media threat alert service to our clients (the "Service"). SocialSentinel.com (including live.socialsentinel.com and all other associated web pages) (the "Site") provides information regarding the Service and access to the Service for our clients. Use of the Service and Site, including any updates, enhancements, new features, and/or the addition of any new links, is subject to this Social Sentinel, Inc. Privacy Policy (“Privacy Policy”) and the Social Sentinel, Inc. Terms of Use. Please refer to your Social Sentinel Service Agreement with SSI for terms relating specifically to your use of the Service.

2.      PURPOSE.

We have created this Privacy Policy (“Privacy Policy”) to demonstrate our commitment to fully disclosing the information collection and use practices applicable to the Service and the Site. 

This Privacy Policy applies only to information collected by SSI through your use of the Site or the Service. SSI is not responsible for any third party information that you may access while using the Site or Service, including publicly available social media information made available by third party social media services. For policies applicable to third-party information that you may access while using the Service, see the privacy policies of such third parties.

This Privacy Policy is being provided to our clients and authorized users of the Service and Site, and it and is not intended to and shall not be construed to give any third party any interest or rights (including any third party beneficiary rights) with respect to or in connection with any representation or provision contained herein or contemplated hereby.

3.      ACCEPTANCE OF TERMS.

By accessing the Service and using the Site, you signify your agreement that your use of the Service and the Site is subject to the terms in this Privacy Policy. The terms “User” and “you” refer to any person who accesses Service or the Site. You are authorized to use the Service and the Site only if you agree to abide by all the terms in this Privacy Policy. Please read this Privacy Policy carefully. If you do not agree to the terms of this Privacy Policy, please immediately cease using the Service and the Site.

SSI reserves the right to, at any time, add to, change, update or modify this Privacy Policy simply by posting such change, update or modification on the Site and updating the “Last Modified” date at the top of this page. Any such change, update or modification to this Privacy Policy will be effective immediately upon availability on the Site. If at any point in the future SSI decides to collect and use Personally Identifiable Information, we may notify you by way of an e-mail or some other means. You agree that your continued use of the Service and the Site shall constitute your acceptance of such revised Privacy Policy. Since this Privacy Policy may change from time to time, it is important that you regularly review the Privacy Policy to ensure that you are updated as to any changes.

This Privacy Policy, and any posted revisions to its terms, shall remain in full force and effect while you use the Site.

4. TYPES OF INFORMATION AND METHODS OF COLLECTION.

This Privacy Policy applies to information collected from or about you through your use of the Service (“User Information”). Except as provided herein, this Privacy Policy DOES NOT apply to information that is publicly available from third party social media services (“Publicly Available Social Media Information”). SSI’s policies and procedures regarding the use of Publicly Available Social Media Information are set forth in Section 9 below.

Collection of User Information

·      By Browsing. As you browse the Site, the Internet protocol (IP) address of your computer, “cookies” (described below) and other standard tracking data SSI uses to evaluate Site traffic and usage patterns are collected. Such information is aggregated with tracking data from all Site visitors. If you only browse this Site, you are not required to identify yourself or provide any personally identifiable information. For purposes of this Privacy Policy, the term “Personally Identifiable Information” refers to any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains.

·      By User’s Voluntary Submission. When using any feature of the Service that allows for unilateral or multilateral communication between yourself and SSI or other users of the Service, you may choose to provide other User Information, including Personally Identifiable Information. If you publicly post Personally Identifiable Information anywhere on the Site, it may be available to third parties and you may receive unsolicited messages from those parties. SSI has no obligation to ensure the security or confidentiality of any information you choose to make publicly available through the Site that allows for unilateral or multilateral communication between yourself and other users of the Service. Also, SSI cannot ensure that parties who have access to such information will respect your privacy. Please exercise caution when deciding to publicly disclose Personally Identifiable Information.

·      By User’s Use of Local+ Feature. Our Local+ feature allows you to create lists unique to your local needs and issues and combine those lists with the appropriate, refined keywords from the Sentinel Search Library to create targeted searches. When using Local+ to specify an individual’s name, you must obtain documented consent from that individual and be able to provide this consent upon request.

·      By Use of Cookies. The Site uses a feature of your browser to set “cookies” on your computer. Cookies are small packets of information sent by the Site through your browser to your computer. These cookies can be deleted or modified through your browser Internet settings. If you do not want your browser to accept cookies, you can turn off the cookie acceptance option in your browser’s settings. You may modify your browser preferences to provide you with choices relating to cookies. You have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. If you choose to reject cookies you may not be able to utilize fully all of the Site’s features and information.

We do not track our users across third party websites and thus do not respond to Do Not Track (“DNT”) signals. However, some third party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, certain website browsers may allow you to set the DNT signal on your browser so that third parties know you do not want to be tracked.

Information on Children. SSI does not knowingly collect any information from children under the age of 13. The Service is intended for use by persons to access information related to public safety and security. If SSI learns that it has collected Personally Identifiable Information from a child under the age of 13, SSI will delete that information from its systems where reasonably possible. SSI encourages parents and guardians to monitor children’s online device usage. Parental control protections, such as mobile device hardware, software or filtering services, are commercially available to limit the access to material that is harmful to minors.

5. HOW COLLECTED INFORMATION MAY BE USED.

Subject to any terms of use that govern ownership and use of information collected by and through the Service, User Information is owned solely by SSI. User Information collected by and through this Site may be used by SSI, its divisions, subsidiaries, and affiliates, or other entities that are involved in the operation of this Site for SSI’s purposes. SSI may use User Information collected and provided, individually or in an aggregate form, as follows:

·      to contact you about the Service;

·      to assess or improve use of the Service;

·      to compare and otherwise use data entered by users for any purpose including consulting, research and marketing;

·      to evaluate products and services SSI or third parties could offer to you;

·      to monitor compliance with SSI’s Terms of Use Agreement;

·      to provide special offers to you from SSI and/or its affiliates and subsidiaries;

·      to send you promotional material on behalf of SSI and/or its affiliates and subsidiaries.

6. WITH WHOM COLLECTED INFORMATION MAY BE SHARED.

At times, we may share User Information with third parties for certain purposes. While we will seek to require those third parties to follow appropriate privacy policies and security measures, we do not bear responsibility for any actions or policies of third parties. The following outlines the ways in which User Information may be shared with others:

·      User Data: We may share User Information that is not Personally Identifiable Information for any purpose. Except as provided herein, SSI will not, without your prior permission, share such information in a form that allows other members or third parties to link it to any Personally Identifiable Information.

·      Aggregate Information: We may share User Information in aggregate form, such as general demographics and Site and Service usage statistics, with third party advertisers, sponsors or other organizations. We do not share specific demographic information.

·      Business Transfers: The Service, Site, SSI and/or a subsidiary or division of SSI may be sold along with its assets, or other transactions may occur, in which your Personally Identifiable Information is one of the business assets transferred. In such a case, your User Information may be one of the business assets we transfer.

·      Legal Process: SSI reserves the right to disclose User Information, including your Personally Identifiable Information, as required by law and when SSI believes that such disclosure is necessary to protect SSI’s rights and/or comply with a judicial proceeding, subpoena, court order or other legal process served on SSI. The disclosure of this information may be without notice to you.

7. SECURITY AND ENCRYPTION.

While there is no such thing as “perfect security,” SSI takes commercially reasonable precautions to protect User Information. Our security policies are reviewed periodically and revised as required. It is important to remember, however, that whatever you transmit or disclose online can be collected and used by others or unlawfully intercepted by third parties. No data transmission over the Internet can be 100% secure.

8. THIRD PARTY LINKS, WEBSITES, AND COOKIES.

Our Site may contain external links to third party websites. We have no control over, and are not responsible for, the content of or information gathered by these other websites. Any Personally Identifiable Information collected by such third parties is subject to such third parties’ privacy policy. Companies that may advertise on the Site do not have access to Personally Identifiable Information that you do not post using any feature of the Site that allows for unilateral or multilateral communication between yourself and other users of the Site. Those advertisers may set their own cookies on your mobile device and access those cookies if you allow them to do so. Third parties’ use of cookies is subject to their own privacy policies.

9. USE OF PUBLICLY AVAILABLE SOCIAL MEDIA INFORMATION.

This Section 9 applies to Publicly Available Social Media Information that you may access as part of the Service.

SSI has no intention, nor the capability, to gather private information of social media authors that is not publicly available from the social media services they use. Generally, the Service enables SSI’s clients to aggregate and assess threats shared publicly on social media and blog streams for potential threats in the areas of security, public safety, harm, wellness or acts of violence. These results will be shared with SSI’s clients to allow those clients to conduct assessments of potential harm, self-harm and acts of violence, and to determine what further steps should be taken, if any, to address such concerns. SSI also may share these results in response to a valid law enforcement request or legal process, to protect SSI’s rights and property or those of third parties, or as otherwise permitted or required by law.

Social media data feeds are provided to SSI by social media services and third-party data aggregators. These third-party data aggregators obtain their feeds from the online services of social media companies. The algorithms SSI applies to Publicly Available Social Media Information do not attempt to, and indeed cannot, discern any Personally Identifiable Information that is not already included in the data feeds SSI receives from social media services and third-party data aggregators.

10. ORDER OF PRECEDENCE. 

If you are an SSI client, in the event of an inconsistency or conflict between this Privacy Policy and your Social Sentinel Services Agreement, your Social Sentinel Services Agreement shall prevail.

11. CONTACT INFORMATION.

If you have questions regarding this Privacy Policy, please email us or contact us by mail or telephone:

Liz Kleinberg
General Counsel
lkleinberg@socialsentinel.com
(802) 861-1380
Social Sentinel, Inc.
128 Lakeside Avenue, Suite 302
Burlington, Vermont 05401-4939