Privacy & Cookie Policy

Updated: 4th May 2022

This privacy policy provides an overview about how we process “personal data” or “personally identifiable information” (collectively as “data”) at SocialFlow.

Our contact details:

SocialFlow, Inc.
111 S Independence Mall East
Suite 950
Philadelphia, PA 19106

(“us“ or “we“ or “SocialFlow”).

The Group Data Protection Officer (DPO) of Piano Group can be reached by using the following contact details:

by email: dpo@piano.io 

by post:

Attn: Piano Software Group DPO

Address: Štefánikova 14

City: Bratislava

ZIP: 811 05

Country: Slovakia (EU).

Introduction

SocialFlow provides social distribution and monetization solutions for publishers and media companies. SocialFlow owns and operates the SocialFlow and Trib.al websites (the “Sites”). The Sites, together with the content and tools available there, are collectively referred to as the “Services”.  Services enable our customers to post content such as a news story, a picture and/or a video onto social media platforms such as Twitter and Facebook, and to better understand how such SocialFlow customer posts are interacted with by Users. Individuals, who visit one or both of these Sites or use our Services, by clicking on or otherwise interacting with a link operated by Trib.al, are referred to as “Users”. We also process data within our general business activities outside the scope of Services.

Please note that SocialFlow is now part of Piano Group (www.piano.io) (“Piano”) and our Services are now provided via Piano Platform in strict compliance with EU General Data Protection Regulation (“GDPR”), ePrivacy regulations as well as California Consumer Privacy Act (“CCPA”) and any other applicable privacy and data protection regulations. We are adhering to the highest data protection standards now as part of Piano Group. The following Piano Privacy Policies apply to SocialFlow as well:

• Piano Platform Privacy Policy – https://piano.io/privacy (related to our Services)
• Piano Corporate Privacy Policy (related to our internal business purposes such as HR, security, legal agenda, etc.)

If you are an EU-based customer, please note that in these Piano Privacy Policies you will find all necessary information in respect to cross-border transfers of personal data from EU to 3^rd countries.

What is our position when providing Services?

Within provision of our Services, SocialFlow acts as a data processor / vendor acting on customers’ behalf when processing any data based on data processing agreement or similar contract in place. We do not maintain controllership or ownership over any customer data nor any direct contractual relationship with Users. We also do no not sell or rent personal data / data collected from our Sites.

Piano Platform Privacy Policy – https://piano.io/privacy fully applies to provision of our Services and contemplates this privacy policy. Please see Piano Platform Privacy Policy for more detailed information.

What is our position when not providing Services?

We primarily act as joint controllers together with other Piano Group affiliates when sharing our (non-customer) data for internal purposes. Please refer to Piano Corporate Privacy Policy that provides a more detailed overview.

Information under California Consumer Privacy Act

Please note that information that needs to be provided under the CCPA is also described in Piano Privacy Policies mentioned above, as similar information needs to be provided under GDPR as well. For example, under CCPA, Californian residents have these basic rights:

• Right to know;
• Right to delete;
• Right to opt-out from sale;
• Right to non-discrimination.

For more information, please see – https://oag.ca.gov/privacy/ccpa.

However, we do not sell or rent personal data collected from our Sites.

Your California Privacy Rights: We do not share personal data with third parties for their own direct marketing purposes with your consent. California residents under 18 years old, in certain circumstances, may request and obtain removal of personal information or content that you have posted on our Sites and/or Platform. Please be mindful that this would not ensure complete removal of the content posted by you on our Sites and/or Platform. To make any request pursuant to California privacy law, please contact us using the information provided above.

DATA SUBJECT RIGHTS: The GDPR, CCPA, and many privacy laws around the world empower data subject rights on personal data. For example, under the CCPA you have the right to request access to the personal data that we collect, use, and disclose about you. As a California data subject, if you make a subject access request as set out in this policy, you are entitled to see and delete the personal information that we have about you. We will confirm your request within 10 days and make a good faith attempt to fulfil your request within 45 days. GDPR generally mandates 1 month for replying on data subject request, period which can be prolonged by additional 2 months. To exercise your rights for data collected via our Sites, please contact our Data Protection Officer (contacts above). We do not discriminate against you if you exercise any of the above rights. Moreover, we may not be able to honor a right if doing so would violate applicable law.

We may take reasonable steps to verify your request.  We will fulfil requests we are able to verify so long as we are not prohibited from doing so by applicable law and/or the information is not essential for us for billing, fraud prevention or security purposes (see Piano Corporate Privacy Policy). We will share our reason(s) for denying your request in the event that we are unable to fulfil your request.

Cookie Policy

SocialFlow uses cookies in order for our Sites and Services to function correctly. In order to use the SocialFlow Sites we place small data files called cookies on your device. Most big websites do this too.

A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another. As part of Piano Group we strive to comply with EU ePrivacy rules on cookies as well as case law of the CJEU’s leading “cookies” judgement (C-673/17, Planet 49).

This list provides an overview of how we use cookies on our Sites: 

In order to understand the scope of the Piano cookie usage please also refer to our documentation http://docs.piano.io/piano-cookie-descriptions.

How to control cookies?

You can control and/or delete cookies as you wish – for details, see aboutcookies.org . You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit a site and some services and functionalities related to the use of our features may not work.

What are your choices regarding cookies?

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly. We will use cookies only for a time of the validity of your consent to our use of cookies.

Note Regarding Children

We do not knowingly collect personal data from children under 16. If we learn that we have collected personal data of a child under 16 (or older as required by applicable law), we will take steps to delete such information from our files as soon as possible.

Changes

SocialFlow reserves the right, at its sole discretion, to modify or replace this Privacy Policy, in whole or in part, at any time. From time to time, SocialFlow may amend the terms of this Privacy Policy and will post such changes here. Continued use of the Service following such notice of any change to the Privacy Policy constitutes your acceptance of those changes.