Anysocial is committed to providing quality services to you whilst respecting your privacy. This policy outlines our ongoing obligations to you in respect of how we manage your Personal Information that you have entrusted to us.
We have adopted the Australian Privacy Principles (“APPs”) that can be found here, and are also contained in the Privacy Act 1988 (Cth) (“the Privacy Act”) which can be found here. The APPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
This policy is incorporated by reference to and made a part of our Terms of Service as if it was set out fully in that document.
- Social Media Network: Third party websites and mobile applications where users can create, publish, and view private and public social media content (i.e. Facebook, Twitter, LinkedIn, Instagram, etc.)
- Posts: Content (including hashtags, written material, images, and videos) that is created published, or republished by Users on Social Media Networks that is accessible to other users of that network.
- Feed: The combined Posts scraped from the Social Media Networks selected by Users to embed and display on their Widget via the Service.
- Users: Users of the Anysocial Service responsible for deciding which scraped Posts to combine to create their Feed.
- Content Creator: The party (either the User or a third party) that created a Post displayed within a Feed. If User is aggregating public content that they themselves created on Social Media Networks, they are both the User and the Content Creator.
- Viewer: Anyone who views an embedded Anysocial Feed.
- Widget: The embedded application provided by Anysocial which displays the Feed.
- Privacy Act: the Privacy Act 1988 (Cth) (Australia)
- GDPR: the General Data Protection Regulation 2016/679 (European Union)
2. GDPR Compliance Statement
To ensure compliance with the EU General Data Protection Regulation (“GDPR”), we have incorporated the following practices and procedures:
- We verify that the third parties with which we share User information are GDPR compliant;
- We ensure that data is stored in a manner that facilitates our ability to locate and delete information pertaining to a specific user upon request;
- We perform security audits and retain outside consultants to help us ensure that we have employed sufficient measures to protect User information.
- If we modify any of the terms of this policy, we inform all of our Users via email and specifically ask EU Users to agree to the modified terms via e-mail or on the Anysocial website; and
- We have appointed an internal Data Protection Officer who is responsible for overseeing our privacy and data protection procedures and will serve as the individual point of contact for information access and deletion requests, and for the effective undertaking of the practices and procedures set out in 2(a)-(f) inclusive as above stated.
3. General Information
General Information consists of information that is anonymous in nature and does not identify you as an individual. This includes your computer IP address, unique mobile device identifier, browser type, ISP or carrier name, and the URL of the last webpage you visited before visiting our website. This information gives us insights on how our users use our site and our other products.
We collect this information by using “cookies”, which are small bits of computer code that are transferred to your computer’s hard drive via a web browser, which enable us to record the general information described above. We use this information to ensure that our service continues to appeal to our users.
3.1 What do we do with General Information?
- we use “session information” cookies to keep you logged in when using the Service;
- we use “preferred feed” cookies allow you to return to the latest Feed you modified; and
- we use “referral user” cookies to enable us to track how a User found our Service, (e.g. whether by referral link, through another feed, or through a reseller).
We also use services provided by Google Analytics which set cookies for each User when they visit our site or use our Service. Social Media Networks such as YouTube may also set cookies when a Viewer views a video on a Feed. None of these cookies collect Personal Data.
3.2 Where is General Information Stored?
General Information collected from Users outside and within Australia will be transferred and to and stored on Amazon Web Services servers located in Australia or as otherwise required by Amazon Web Services from time to time.
4. Personal Data
4.1 What is Personal Data?
Personal Data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
4.2 How do we obtain Personal Data?
Personal Data is obtained by us when you create your Anysocial Account. It may also be obtained via email or other correspondence with us, from cookies and from third parties. We do not collect Personal Data from Viewers. We may collect and compile Posts as part of the aggregation process, but we do not store those images on our own servers, and do not control which Posts are approved by the User. These Posts were made public by the Content Creators and generally do not contain Personal Data.
When you establish an account you must provide us with an email address and a password. If you sign up for a paid account, you must also provide your name and payment information (i.e., credit card or Stripe Account). We do not, however, store or “see” payment information, as it is passed directly to the applicable payment processing company listed in 5.1 of this policy.
In the case where you are a User and a Content Creator, you may also disclose Personal Data to us (and others) in the content of your Posts. In addition, when you link your Social Media Network accounts to your Anysocial account, you are granting us permission to access and use certain information about you as permitted by the Social Media Network APIs. For example, if you link your Facebook account, it may provide us with access to whatever information you choose to include in your Social Media Network public profile and Posts (via your Settings on the respective Social Media Network), such as friends’ names, pictures, genders, user IDs, connections, and any other shared content, and you will be making this information available to other Viewers regardless of whether they are connected to you via Facebook.
When the User (you) logs on to your Anysocial account, we will record your IP address and/or unique mobile device identifier and may tie it to your specific account. Under ordinary circumstances, an IP address recorded in isolation is not Personal Data under the standard definition of the term. However, it may become Personal Data when it is combined with other information.
4.3 What do we do with your Personal Data?
We do not use Personal Data for marketing or advertising purposes, nor do we share it with third parties for that purpose.
We use your email and password to enable you to create and log in to your Anysocial account, and use the Service.
We also use your email address to send you account related notices and other information that we believe may be of interest to our Users.
We use your IP address to identify your location in order to provide you with notices and other information that may be required by your local regulatory authority.
Where this information is considered Sensitive Information as defined by section 6 of the Privacy Act it will only be used by us:
- For the primary purpose for which it was obtained; or
- For a secondary purpose that is directly related to the primary purpose; or
- With your consent; or
- Where required or authorised by law.
4.4 Where is your Personal Data Stored?
All Personal Data collected from Users outside and within Australia will be transferred and to and stored on servers located in Amazon Web Services servers located in Australia or as otherwise required by Amazon Web Services from time to time.
5. Sharing of Data
We will not share Personal Data with third parties for marketing purposes without your consent. We will share Personal Data with certain third parties in the following ways:
5.1 Service Providers
We utilize the following third-party service providers to perform certain functions on our behalf, and must share certain information (including Personal Data) with them in order for them to do so. However, the information that is shared is limited to that which is necessary to perform their specific functions:
5.2 Law Enforcement
If required by the laws of the jurisdiction referred to in our Terms of Service including the law enforcement authorities, courts, or regulators of that jurisdiction, we may disclose any information we have about our users. We also may disclose your Personal Data to exercise or protect legal rights or defend against legal claims.
5.3 Public Information
If information that we use is already out in the public domain or has already been disseminated by your prior written consent, it may be disclosed by us without first obtaining your consent. In that event, you release us and indemnify us from any claim or demand whatsoever with respect to the information so disseminated.
5.4 Bulk Asset Transfers
In some cases, we may choose to buy or sell assets. In these business transfers, customer information, including Personal Data, is typically one of the business assets that are transferred. Moreover, if all or substantially all of our business assets were acquired, or in the unlikely event that we go out of business or enter into bankruptcy, customer information (including your Personal Data), would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any assets may continue to be used according to your Personal Data as set forth in this policy.
5.5 Other Third Parties
We may reserve and have the right to disclose any information about you or your use of our Service without your prior permission, if we in good faith believe that such action is necessary to protect and defend the rights, property or safety of our company or its affiliates, other Users of the Service or the public.
6. Data Security
Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized or unlawful access, modification or disclosure. We also limit access to User information to employees who reasonably need access to it in order to do their jobs. However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we may have collected from or about you. In addition, we have no control over the security of other web sites that you might visit even when a link may appear to those web sites site from our Site. If you share your computer or use a computer that is accessed by the general public, remember to log off and close your browser window when you have finished your session.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.
7. Your Options and Rights
All users may request that we stop sending you non-account related emails by clicking the “unsubscribe” link that is included at the bottom of non-account related emails.
You may access the Personal Information we hold about you and to update, correct and/or delete it, subject to certain exceptions. If you wish to access your Personal Information, please contact our Data Protection Officer in writing.
Anysocial will not charge any fee for your access request, but may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information we may require identification from you before releasing the requested information.
7.1 EU Citizens
If you are an EU citizen, you may request that we provide you with (or delete) all the information we collected from and about you, or otherwise exercise your rights under the GDPR by contacting our Data Protection Officer. Data reporting and deletion requests will be processed free of charge within thirty (30) days.
8. Policy Updates
If you ever have any questions about this policy or the Personal Data and General Information we have collected please contact our Data Protection Officer. We respect your rights and privacy, and will be happy to answer any questions or concerns you might have. Their contact details are as follows: