Privacy & Security Policy

February 29, 2024 

SocialToaster, Inc. (“STI”, “us”, “our”, or “we”) is pleased to offer its “SocialToaster” web-based social media networking software application and related services for use in connection with establishing, managing and optimizing social media networks and online marketing activities.

STI respects your privacy, recognizes your need for appropriate protection and management of your personal identifiable information that you share with us, and is committed to protecting it. STI has established this Privacy and Security Policy to inform you of our policies and practices regarding how we collect information from you, how we use and disclose it, and your rights with respect to such information. This Privacy and Security Policy (the “Privacy Policy”) is incorporated into and is subject to STI’s Terms of Service .

Collection of personal identifiable information

Broadly, “personally identifiable information” is defined as information that may be used to identify an individual, including, without limitation, your first and last name, your home or other physical address, your electronic mail address, age, gender, and other similar information. When you visit our web site located at www.socialtoaster.com and any co-branded or STI client site (the “Website”), STI may ask you for and collect personal identifiable information about you to provide certain products and services to you; to allow you participate in a fan program, to communicate with you; to send client messages to you, to provide customer service and support to you; to monitor and analyze trends, usage and activities in connection with STI services ; to detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of STI and others; to send promotional e-mails and information about our company; and for internal marketing and promotional purposes. For example, we may request personal identifiable information from you when you request information concerning our services. Unless otherwise noted on any form you may using to interact with our platform, STI limits the collection of your personally identifiable information as much as possible. In general, this is limited to your first and last name and electronic mail address, and in some instances will include your age and gender, and if you are participating in a program where there may be a physical prize awarded it may also include your physical address for prize fulfillment reasons. Please note that any of your personally identifiable information or any of the personally identifiable information of any third party posted for public viewing at your direction is not considered personally identifiable information and is subject to the terms and conditions of STI’s Terms of Service.

STI may collect personal identifiable information about you whenever you interact with us including, but not limited to, the following:

  1. Information we collect from you from applications, registrations and other forms;
  2. Information about your transactions with us, our business partners and our suppliers;
  3. Information we collect about you from your web-based social media services accounts with other third parties, including without limitation, such as Facebook, Instagram, YouTube, X (formerly Twitter), TikTok and LinkedIn, which you have authorized us to access to provide certain products and services to you; and
  4. Information we receive from our server logs from your browser, including your IP address, cookie information and the page you requested.


Disclosure and Sharing of Personal Identifiable Information

STI will not distribute, sell, rent or otherwise disclose your personal identifiable information to any third party except as follows:

  1. To STI clients when you sign up to participate in a fan program, including without limitation, your connection and data you have authorized to provide STI via web-based social media services such as Facebook, X (formerly Twitter), TikTok, LinkedIn and YouTube.
  2. Should you authorize YouTube through a fan program, STI is using YouTube API Services, and you are agreeing to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms) and YouTube Privacy Policy (https://policies.google.com/privacy) when engaging YouTube content and services through the Service. You will be asked to allow SocialToaster to manage your YouTube Videos and your YouTube account. SocialToaster will only use these permissions to allow you to like and watch later video. This information will be shared only with the fan program administrator. User data is stored and can be deleted upon request.  You can revoke our access to your data via the Google security settings page at https://security.google.com/settings/security/permissions at any time. If you have comments or questions about our Privacy and Security Policy, please contact us by sending an email to support@socialtoaster.com
  3. To business partners, suppliers and other third parties that help us to provide certain products and services to you, including without limitation, your connection to web-based social media services such as Facebook, X (formerly Twitter), TikTok, YouTube and LinkedIn;
  4. To business partners, suppliers and other third parties that help us to process payments;
  5. In special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with STI’s rights or property, or anyone else that could be harmed by such activities;
  6. In special circumstances, such as the sale or potential sale of STI or its assets or the bankruptcy of STI;
  7. When we believe in good faith that it is required or permitted by law; and
  8. When you have consented to such disclosure.


Opting Out and Other Rights

To keep you in control of your personal identifiable information and the communications directed to you, we allow you to edit your marketing preferences and/or to opt out of receiving communications from STI. We provide you with the opportunity to access, review and correct your personal identifiable information. You may contact us regarding any inquiry or request concerning such rights by sending an email to support@socialtoaster.com. STI reserves the right to send you certain communications relating to this Website that are considered part of your account, such as notifying you of changes to the Website and customer service purposes, without offering you the opportunity to opt out of receiving them. If you are accessing the Website from countries outside the United States of America whose laws regarding personal data protection differ from those of the United States of America, through your continued use of the Website, you acknowledge that you are transferring your personal information and you consent to such transfer.

Children’s Privacy (individuals under 13 years of age)

STI is committed to protecting the privacy of children and encourages parents and guardians to take an active role in their child’s online activities and interests. You must be at least 13 years of age to use this Website. STI does not knowingly collect, use or disclose personal identifiable information about visitors to our Website who are under 13 years of age.

Use of Cookies

Cookies are data text files that a web site transfers to a visitor’s computer for record-keeping purposes. Cookies allow web site operators like STI to facilitate and customize your visit by saving your preferences while tracking information about your visit to a web site. We use the data collected by cookies to retrieve certain information previously provided by you and to help us provide our visitors with a better experience at our Website. Many improvements and updates to the Website are based on the data collected by cookies. Information that we track with cookies includes, without limitation, the total number of visitors and pages viewed and which areas of our Website you visited. Although most browsers are initially set up to accept cookies, you can reset your browser preferences to indicate when a cookie is being sent or to refuse all cookies. However, note that if you refuse cookies, you may have difficulty accessing cookie-enabled services available at our Website.

Links to Other Sites

Visitors to our Website should be aware that when they are on the Website, they could be directed to other web sites that are beyond our control. There are several links to other web sites from the pages on our Website that take you outside our service. Many of these other web sites may send their own cookies to users, collect data, or solicit personal information. STI has no control over these web sites or how they collect, distribute or otherwise use any personal information, and we do not guarantee the security of any information that you may disclose. STI is not responsible or liable for the policies, actions or content of such web sites. These web sites are linked only for your convenience and you access them at your own risk. We encourage you to review the terms of service and privacy policies available at these other web sites.

Data Retention

We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.

Information About International Transfers

If you are visiting a Website from outside the United States, please be aware that you are sending the information (including personally identifiable data) to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your personally identifiable data will at all time continue to be governed by this Privacy Policy.

Security

STI takes great care in providing secure transmission of your information over the Internet. All data transmitted to us over the Internet is encrypted using industry-standard best practices for encryption. Once we receive your transmission, we make our best effort to ensure its security on our systems. STI conforms to the SOC 2 compliance security standard. STI uses encryption and security software to secure all sensitive information, including without limitation, credit card numbers, that is transmitted to us over the Internet. Credit card numbers are used for processing payments and for no other purposes.

To access and use certain online services on the Website, we may require you to select a unique user name and password. We encourage you to protect against unauthorized access to your password and computer. To further prevent such unauthorized access, you should sign off when you have finished accessing or using the Website or using your computer.

Changes to This Policy

STI reserves the right, at any time and from time to time, to change or modify the privacy and security practices that are described herein. If we make changes, we will notify you by revising the date at the top of the policy. In general, STI only uses your personal identifiable information in the manner described in the Privacy and Security Policy in effect when STI receives the personal identifiable information provided by you. Your continued use of the Website constitutes your agreement to the terms and conditions of the revised Privacy and Security Policy.

Contacting Us

If you have comments or questions about our Privacy and Security Policy, please contact us by sending an email to support@socialtoaster.com

Your Acceptance of These Terms

By using this Website, you acknowledge and agree to the terms and conditions of this Privacy and Security Policy. If you do not agree to these terms, please do not use this Website.

Residents of the European Economic Area

If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.

Legal Basis for Processing

If you are a resident of the EEA, when we process your personal data, we will only do so when we have a legitimate interest in processing your personal data, such as to perform our responsibilities under our contract with our customers and to provide the STI services you have requested.

Data Subject Requests

If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, please contact us at support@socialtoaster.com

Questions or Complaints

If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm

CALIFORNIA CONSUMER PRIVACY ACT NOTICE AT COLLECTION

The California Consumer Privacy Act (“CCPA”) requires SocialToaster, Inc. to notify you of the personal information we collect for consumers who reside in California. Additional information about how we collect, use and share your personal information can be found in our Privacy Policy located at https://www.socialtoaster.com/privacy-policy/.

We collect the following information from consumers to allow consumers to participate in fan programs:

Category Purpose Collected

Category A & B– Identifiers

Examples: Name, postal address, Internet Protocol address, email address, or other similar identifiers.

STI may ask you for and collect personal identifiable information about you to provide certain products and services to you; to allow you participate in a fan program, to communicate with you; to send client messages to you, to provide customer service and support to you; to monitor and analyze trends, usage and activities in connection with STI services ; to detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of STI and others; to send promotional e-mails and information about our company; and for internal marketing and promotional purposes 

Category C – Characteristics of protected classifications under California

or federal law, specifically, gender.

STI may ask you for and collect personal identifiable information about you to provide certain products and services to you; to allow you participate in a fan program, to communicate with you; to send client messages to you, to provide customer service and support to you; to monitor and analyze trends, usage and activities in connection with STI services ; to detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of STI and others; to send promotional e-mails and information about our company; and for internal marketing and promotional purposes 
Category G – geolocation data STI collects your location to serve geographically pertinent information to you or restrict programs based on your location.

Category F – Internet or other similar network activity

Examples: Access history and information on your interaction with our application.

Information on a consumer’s interaction with a website or application.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • Our business or commercial purpose for collecting that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).

 

Deletion Request Rights

You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at support@socialtoaster.com.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
  • We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.


Response Timing and Format

We endeavor to respond to a verifiable consumer request within 2 business days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you use of our Services.
  • Provide you a different level or quality of Services.