SocketLabs General Privacy Policy

INTRODUCTION AND SCOPE
Your online privacy and trust are very important to us, so we are providing this Privacy Policy to inform you of our practices involving data collection, use, and disclosure. This Privacy Policy applies to your personal data collected online by SocketLabs Acquisition, LLC (“SocketLabs”, “we”, and “our”) through your use of its websites (such as but not limited to www.socketlabs.com, cp.socketlabs.com), products, applications and services (collectively, the “Company Services”) except that this Policy does not apply to and specifically excludes the following personal data which we receive from and processes on behalf of our customers through their use of our hosted SocketLabs On-Demand email service (“Email Service”): a) the personal data of senders and recipients or personal data otherwise provided within email messages processed by the Email Service and b) the personal data included in email recipient lists managed by the Email Service. Our privacy policy for these aspects of the Email Service is described in the SocketLabs Email Service Privacy Policy. We are providing this Privacy Policy to help you make an informed decision about whether to use or continue using the Company Services. By using the Company Services, you consent to the data processing practices described in this Privacy Policy. SocketLabs does not sell, rent or lease its customer lists to third parties.

DATA CONTROLLERSHIP
In the context of this Privacy Policy, we act as a data controller for the personal data that we process.

BASIS OF PROCESSING
Within the scope of this Privacy Policy, we may rely on one or more of the following legal grounds for processing of your personal data:

the need to perform our obligations under a contract or to perform related pre-contractual duties; or
the legitimate interests pursued by us, such as to offer our services to our customers.
Our reliance on the basis of the need to perform our obligations under a contract or to perform related pre-contractual duties, is limited to the personal data that we require in order to perform those obligations and duties.

RECEIVING PERSONAL DATA, TYPES OF PERSONAL DATA

User Provided Personal Data: You provide certain personal data to SocketLabs when choosing to participate in various activities available via the Company Services such as contacting us for further information, signing up for services, filling out a web form, purchasing products, or subscribing to newsletters or other mailing lists. Personal data collected by us typically includes:
contact information, such as email, and phone number;
biographical information, such as name;
billing and payment information;
Internet Protocol (“IP”) address; and
any other type of information you may choose to provide us with.
Cookies Information: When you utilize the Company Services, we may send one or more cookies – a small text file usually containing a string of alphanumeric characters – to your device that uniquely identifies information about you, your device or your software. We use cookies for a variety of purposes, including but not limited to saving your preferences and facilitating the proper function of the Company Services. Most web browsers, enable you to block or erase cookies; however, some features of the Company Services may not function properly if your ability to accept cookies is disabled.
Log Information: When you use the Company Services, our servers and devices automatically record certain information including but not limited to details of your request, IP address, software information, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time of your request, and one or more cookies that we previously stored on your computer.
Clear GIFs & Tracking Information: We may employ “clear GIFs” (a.k.a. Web Beacons) which are used to track your online usage patterns. In addition, when we send you an email message we may also use clear GIFs (or different mechanisms with a similar purpose) to track when you opened the email. We may also use mechanisms to track when you clicked on specific links in an email message.
CATEGORIES OF DATA SUBJECTS
The personal data collected typically concern SocketLabs’ prospects, customers, former customers, and vendors.

SOCKETLABS MAY USE PERSONAL DATA IN THE FOLLOWING WAYS
We may use both your personal data and non-personally-identifiable information to:

operate, maintain, improve, and provide the features and functionality of the Company Services;
facilitate chat, telephone and email communication with you;
provide technical support; and
collect leads, process leads, perform customer or market research, and follow-up with prospects.
We do not use your email address or other personal data to send commercial or marketing messages without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out. We may, however, use your email address without further consent for non-marketing or administrative purposes (such as notifying you of major changes to the Company Services or for customer service purposes).
SocketLabs may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your personal data is not transferred to the third party without your consent.
SocketLabs may keep track of user activity, including but not limited to the websites and pages our users visit, in order to determine what SocketLabs services are the most popular. This data is used to deliver customized content and advertising to users whose behavior indicates that they are interested in a particular subject area.
SocketLabs may also use your personal data to inform you of other products or services available from SocketLabs and its affiliates. SocketLabs may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
We may use both your personal data and certain non-personally-identifiable information (such as usage data, browser type, clickstream data, etc.) to improve the quality and design of the Company Services and to create new features, promotions, functionality, and services by storing, tracking, and analyzing user preferences and trends.
We use cookies, clear GIFs, and log information to: (i) remember information so that you will not have to re-enter it during your visit or the next time you use the Company Services; (ii) provide custom, personalized content and information; (iii) monitor the effectiveness of our marketing campaigns; and (iv) monitor aggregate metrics such as total number of visitors, pages viewed, etc.
SHARING PERSONAL DATA WITH THIRD PARTIES
SocketLabs may share personal data with our service providers, who process personal data on behalf of SocketLabs. Such service providers typically include those that provide: security services, cloud storage, colocation and web hosting services, email and document management, PPC marketing, analytics, CRM, providing help desk services, payment processing, serving ads, pixel retargeting, facilitating chat communication and accounting and invoicing services. Except as required by law, all such third parties are prohibited from using your personal data except to provide these services to SocketLabs and are required to maintain the security and confidentiality of your personal data. If we need to transfer your personal data to foreign countries, we will ensure that such transfers are subject to appropriate safeguards as required by applicable law.

OTHER DISCLOSURES OF YOUR PERSONAL DATA

We may disclose personal data and/or non-personally-identifiable information if required to do so by law, or in the good-faith belief that such disclosure is necessary to comply with applicable laws (including but not limited to U.S. copyright law or CAN-SPAM) or respond to a court order, subpoena, or search warrant. If we must disclose your personal data, in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your personal data will maintain the privacy or security of your personal data.
We also reserve the right to disclose personal data and/or non-personally-identifiable information that we believe, in good faith, is appropriate or necessary to enforce the terms of service which govern our provision of the Company Services to you, to investigate and defend SocketLabs, its partners, service providers and/or its users against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Company Services, and to protect the rights, property, or personal safety of SocketLabs, our users or others.
Notwithstanding anything to the contrary in this Privacy Policy, we may compile, use, distribute, disclose, publish, license and sell data collected through your use of the Company Services so long as all personal data is removed (“Anonymous Data”). By way of example without limitation, we may publish a report on the adoption of our services from different geographic reasons, or a report that shows which browser versions are most popular by our users. This Anonymous Data will be owned exclusively by SocketLabs.
COMMITMENT TO SECURITY OF DATA
SocketLabs uses commercially reasonable physical, organizational, and technical safeguards to preserve the integrity and security of your personal data to protect it from unauthorized processing, such as unauthorized access, disclosure, alteration, or destruction. We cannot, however, ensure or warrant the security of any information you transmit to SocketLabs and you do so at your own risk. Once we receive your transmission of information, SocketLabs makes commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or organizational safeguards.

DATA RETENTION
You may send a request to us to ask that we delete your personal data, subject to the limitations described in this Privacy Policy.

A NOTE ABOUT CHILDREN
The Company Services are not directed to individuals under the age of eighteen (18), and we request that these individuals not provide personal data to SocketLabs. SocketLabs will never knowingly request personally identifiable information from anyone we know to be under the age of eighteen (18). Any person who provides their personal data to SocketLabs through the Company Services represents that they are eighteen (18) years of age or older.

THIRD-PARTY SITES & SERVICES
Some third party sites or services may be accessible from the Company Services, including but not limited to sites and services accessible via links from our websites or links in an email message we send. We encourage you to review the privacy statements of these third-party sites and services so that you can understand how those sites and services collect, use and share your information. SocketLabs is not responsible for the policies or practices of third parties or third-party sites and services.

IN THE EVENT OF SALE, MERGER, ACQUISITION, OR BANKRUPTCY
In the event that SocketLabs is acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the personal data we have collected from you and our users as part of such merger, acquisition, sale, or other change of control.

ACCESS, CORRECTION, AND DELETION
If you are a data subject about whom we store personal data, you may have the right to request access to, and the opportunity to update, correct, or delete such personal data. To exercise this right, you may email us at the email address found in the Contact Information section of this Privacy Policy. We will implement your requested changes, as soon as we reasonably can, subject to certain limitations such as the need to confirm and verify your identity.

RESTRICTION OF AND OBJECTION TO PROCESSING, DATA PORTABILITY
If you are a data subject whose personal data we process, you may have the right to ask that we limit our processing of your personal data, as well as the right to object to our processing of your personal data. You may also have the right to receive your personal data processed by us in a structured, commonly used, and machine-readable format. To exercise such rights, where applicable, please contact us using the information in the Contact Information section of this Privacy Policy.

SUPERVISORY AUTHORITY OVERSIGHT
If you are a data subject residing in the European Union whose personal data we process, you may also have the right to lodge a complaint with a data protection regulator in one or more of the European Union Member States.

MODIFICATIONS AND UPDATES TO THIS PRIVACY POLICY
SocketLabs may modify this Privacy Policy at any time by posting a revised version and updating the “Effective” date above to reflect the date on which the new Privacy Policy became effective. The revised Privacy Policy will become effective immediately upon posting to this page, or to a page linked to from the Company Services. It is your responsibility to revisit this page or periodically review the Privacy Policy to stay aware of any changes. Your continued use of the Company Services after the Privacy Policy has been revised constitutes your agreement to the revisions.

CONTACT INFORMATION
Please contact SocketLabs with any questions or comments about this Privacy Policy.

SocketLabs Acquisition, LLC
700 Turner Industrial Way, Suite 100
Aston, PA 19014 USA
[email protected]

Please allow up to 30 days for us to reply.