When this privacy notice refers to “Embassy”, “Embassy Social”, “us”, “we” or “our”, it refers to Embassy Social, LLC, a Delaware limited liability company. We also occasionally refer to the Embassy Social software that helps you use our Services as the “Software”.
“You”, “your” and similar terms mean the person or legal entity accessing or using our Services.
Embassy Social is committed to protecting the privacy of all individuals who:
Taken together, we call the Website, the Publishing Services, the Hashtag Services, the Campaigns, and the Other Products the "Services". To be clear, however, we do not use the term Services to include any third-party services (such as Facebook’s, Instagram’s, our Twitter’s provided services) that are not specifically provided by Embassy Social (“Third-Party Services”), even though you may use these Third-Party Services in connection with our Services.
Any applicable Embassy Social terms of service are referred to as the “Terms”.
Embassy Social has two types of users: “Brands” and “Ambassadors”. Brands are those users who create and manage Campaigns, and who are billed according to how many Engagements their Campaigns receive. Ambassadors are those users who participate in Campaigns by joining Campaigns and then featuring Qualifying Hashtags in User Content on Supported Platforms. Taken together, we call Brands and Ambassadors our “Users”. These two groups of users can occasionally overlap, but we define a user by what Services they are using in our Software at a particular moment in time – a user can be considered a Brand in one instance and an Ambassador in a different instance, in other words.
We use the term “User Content” to refer to any and all information and data (such as text, images, photos, videos, audio, hashtags, and/or documents) in any format that is uploaded to, downloaded from, or appears on our Services.
We use the term “Engagements” to refer to any comments, likes, shares, retweets, reposts, favorites, hearts, comments, and/or replies that User Content receives, that is detected by our Hashtag Services, and that is displayed by our Services. We use the term “Qualifying Engagements” to refer to those Engagements generated by User Content on an Ambassador’s Linked Account that includes a Qualifying Hashtag in a joined Campaign, which can then be detected by our Hashtag Services and displayed by our Services.
Our Software currently allows Users to link their Facebook, Instagram, and/or Twitter accounts to their Embassy Social accounts. Taken together, we call these (i.e. Facebook, Instagram, and Twitter) our “Supported Platforms”. Once a User links their Embassy Social account with their account on a Supported Platform, we call that account a “Linked Account”.
Embassy Social offers Brands a way to create Campaigns that reward their Ambassadors for creating great content, and it offers Ambassadors a way to get rewarded for their content. Specifically, Brands create Campaigns using Embassy Social’s Software, and then assign those Campaigns specific Qualifying Hashtag(s). Ambassadors then choose to participate in Campaigns by joining Campaigns through the Software and then creating User Content that features the Qualifying Hashtag(s) on their Linked Accounts, which can then be recognized by our Hashtag Services. Our Software will then keep track of when an Ambassador has received enough Qualifying Engagements to qualify for certain Brand-defined rewards for reaching certain Brand-defined engagement goals, and will keep track of when a particular Campaign has met certain Brand-defined engagement goals (thus terminating the Campaign). Additionally, Brands not only gain trust and exposure through the Linked Accounts of their Ambassadors and the ability to manage their Campaigns through our Software, but they can also repost Ambassador User Content to their own Linked Accounts through our Software – raising the profile of both their own Brand and the Ambassador who created the User Content.
Personal information is information relating to an identified or identifiable natural person. An identifiable natural person is an individual that can be identified, directly or indirectly, be referenced to an identifier such as a name, an identification number, specific location data, an online identifier, or other attributes specific to that natural person. Personal information does not include information that has been anonymized or aggregated in such a way that it can no longer be used to identify a specific natural person, whether on its own or in combination with other information. The personal information that we collect falls into two broad categories: Account Data and Content.
Account data (“Account Data”) is personal information you provide us, or that we collect from you and your devices in connection with your access to and use of our Services (such as when you provide us information to register for an Embassy Social account, or information we collect about your browser when you connect to one of our Services, etc.).
There are two general categories of Account Data we collect in order to provide you with the Services.
The User Content which you upload, download, or view on our Services may, but does not necessarily, contain personal information. When we refer to “Personal Content” in this Policy, we mean the personal information in User Content that we process. We only process Personal Content at your direction. Our obligations and commitments as it relates to our processing of Personal Content on behalf of our users is outlined in Section VII, below, titled “Embassy Social’s Use of User Content”.
We use, store, and process Account Data to provide, understand, improve, and develop our Services, keep our Services safe, and to comply with our legal obligations. More particularly, we use it to:
a. Identify Our Users.
We use Account Data to identify you when you login to your account.
b. Provide Services.
We use Account Data to enable us to operate the Services and provide them to you, including to:
c. Improve & Optimize Our Services.
We use Account Data to:
d. Keep Our Services Safe.
We use Account Data to verify accounts and activity, maintain the integrity of our Services, and to keep the Services safe and secure.
e. For Legal Reasons.
We reserve the right to access, use, preserve, transfer, or disclose – at any time and without notice to you – any information reasonably necessary to:
Our legal basis for collecting and using Account Data will depend on the specific context in which we collect it. However, we will collect personal information from you where:
In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process Account Data, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide Account Data to comply with a legal requirement we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interest which are not already described in this notice, we will make clear to you at the relevant time what those legitimate interests are.
As a User, you may update or correct most of your Account Data by logging in to your account to edit your profile or organization record. To make a request to have Account Data returned to you, removed, or to make additional corrections, please e-mail our Privacy Officer, as outlined in Section VIII(G), below, titled “Contacting Us”. Requests to access, correct, or remove your information will be handled within thirty (30) days and may be subject to a fee as permitted by applicable law.
Depending on where you reside, you may have the right to exercise additional rights available to you under applicable laws with regards to the personal information Embassy Social holds about you, including:
If you would like to exercise such rights, please contact us. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
You also may have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
Most activity on Embassy Social is, by its very nature, public – including your account profile information, your User Content, Qualifying Engagements with your User Content, and any information you included in your User Content. If this information were not public, Embassy Social would not be able to provide you with the Services. You are responsible for your account profile information, your User Content, and other information you provide through our Services, and you should think carefully about what you make public, especially if it includes sensitive information.
You, as an Embassy Social User, have control over how Personal Content is generated, requested, submitted or published, and processed on our Services. When a Brand creates a Campaign, the Brand determines which Qualifying Hashtags will be used and requested, for instance, and Ambassadors determine which Campaigns they will participate in, through which Linked Accounts, and which User Content will feature Qualifying Hashtags. When you participate in a Campaign, you necessarily allow that – if your Linked Account includes User Content featuring a Qualifying Hashtag – the User Content that flows through our Services may include Personal Content of all types, including but not limited to the following categories:
As the User, you are the ultimate controller of your Personal Content and we are simply the processor of such Personal Content included in User Content featuring Qualifying Hasthags on Linked Accounts. Where we process Personal Content, we do so at your direction and on your behalf in accordance with the instructions you give us through the Services. When you connect your accounts on Supported Platforms through our Services, we only access, process, and use the Personal Content to provide our Services subject to the Terms and the various terms and conditions imposed by the Support Platforms or Third-Party Services. We may, in limited circumstances process Personal Content for the purposes of improving the Services and functionalities Users ask for as part of their Embassy Social experience.
If you are using the Services by invitation of an Embassy Social User, whether that User is your employer, another organization, or an individual, that User determines its own policies regarding storage, access, modification, deletion, sharing, and retention of Personal Content, which may apply to your use of the Services. Please check with the User about the policies and settings it has in place.
You should be aware that Embassy Social acts as a conduit between you and the various Supported Platforms. In several instances, the User Content published via Embassy Social will not be in Embassy Social’s custody, and any User Content that has been shared by you through any Supported Platform via the Services may continue to be available to third parties and the public at large, as this User Content is now under the control of the operators of the Supported Platforms.
An individual who seeks access to, or who seeks to correct or, amend inaccuracies in, or delete User Content stored or processed by us on behalf of a User should direct his/her query to the Embassy Social User or to the Supported Platform(s) on which the User Content appears. Upon receipt of a request from one of our Users for us to remove the data, we will respond to their request within thirty (30) days. Please note, however, that we may need to retain certain information for as long as you maintain an account for our Services, for record keeping purposes, to comply with our legal obligations, to resolve disputes, enforce our Terms, or as required or authorized by applicable law. Please see Section VIII(B), below, titled “Retention of Personal Information” for additional information.
Except as provided in this Policy, Embassy Social does not share any personal information gathered via the Services with third parties. We may, however, share Account Data or User Content (including Personal Content) under the following circumstances:
We retain your Account Data for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, or enforcing our Terms.
We retain Content for as long as needed to provide the Services, or until you ask us to delete it pursuant to the Terms. We retain and use this Content as necessary to comply with our legal obligations, resolve disputes, and enforce the Terms.
Please note that certain personal information may need to be retained by Embassy Social for a period of time following the cancellation of your account where this is necessary for our legitimate business purposes or required or authorized by applicable law. Our specific retention periods for personal information are documented in our internal retention policies.
After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner, according to our data retention policies.
Embassy Social follows standard industry practices to protect personal information from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Account Data and User Content we collect, use, process and store, and the current state of technology.
Embassy Social, LLC, the entity which provides the Services, is an Alabama limited liability company with its headquarters in Birmingham, Alabama. The Services are mainly provided from our offices in Alabama. Embassy Social uses third-party service providers (such as managed hosting providers, card processors, CRM systems, sub-processors of Content and technology partners) to provide the necessary software, networking, infrastructure and other services that we use to operate the Services. At this time, we understand that all third-party service providers are processing or storing any personal information inside the United States. You understand and agree, however, that these third-party providers may process or store personal information on servers outside of the United States.
Also, by the very nature of the Services provided, the data that is viewed, collected, stored, or posted on or through the Services also needs to flow from wherever you are located in the world, to where our servers are located and/or wherever our Supported Platforms are storing the same data (in most cases, in the United States).
By using any of the Services, or submitting or collecting any personal information via the Services, you authorize Embassy Social and its authorized service partners to use and process User Content and Account Data (including any personal information) in these countries.
i. Processing of User Content
When we receive or access data from your Linked Accounts, we do so at your request and within each Supported Platform’s terms and conditions. As our User, you ultimately decide which Supported Platforms you want our Services to connect with and which Supported Platforms you want to share your data with. We process your User Content, at your instruction, acting as a conduit between you and the Supported Platform that you connect to our Services.
ii. Marketing E-mails
You may opt out of marketing communications sent by Embassy Social by managing your e-mail preferences on our Preferences Management page, or by following the unsubscribe instructions included in each marketing e-mail.
iii. Customized Advertising
We may use Account Data to customize advertising that we direct to you, utilizing third parties. To opt-out of customized advertising, you may manage your advertising preferences on our Preferences Management page.
iv. Children & Our Services
Our Services are not intended for use by children and should only be accessed by individuals who are old enough to: (a) consent to the processing of your personal data in your country or state, and (b) consent to participation in the Campaigns offered by our Brands.
v. Changes to This Privacy Notice.
Embassy Social reserves the right to make changes to its privacy notice at any time. Innovation in software happens quickly and laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our business. If we do make changes to the privacy notice, we will post them to this page, so we encourage you to stay informed by checking back here periodically.
Embassy Social is headquartered in Birmingham, Alabama, in the United States of America. You can contact our Privacy Officer via e-mail at firstname.lastname@example.org. Please include the word “Privacy” in the subject line of the e-mail.
Or via mail:
Attn: Embassy Social Privacy Officer
Embassy Social, LLC
1103 Old Forest Road
Birmingham, Alabama 35243
© 2021, Embassy Social, LLC