Privacy Policy
Last updated 26/4/2023
Tagger Media, Inc. User Privacy Policy
This “User Privacy Policy” (or “Privacy Policy”) describes the privacy practices of Tagger Media Inc. and our subsidiaries and affiliates (collectively, “Tagger”, “we”, “us” or “our”) with respect to our processing of personal information about you. For the purposes of this Privacy Policy, “you” means any user who uses any of the services that we offer, including visitors to our website and mobile application, users of Tagger Media Analytics Platform and any other services we may offer from time to time (collectively, “Services”). This Privacy Policy applies to all users, including those users who use the Services via their employer or another company.
This User Privacy Policy provides information about the types of personal information we hold about you in connection with us and how we collect, use and share it. It also tells you about your rights and how they can exercise those rights.
We provide important information for users located in the European Union, European Economic Area and United Kingdom (collectively, “Europe” or “European”) in the Notice to European Users section of this policy. We provide important information for users who are residents of California in the Your California Privacy Rights section of this policy.
Please note that this User Privacy Policy does not apply to individual authors of content, or creators, in connection with our creator platform. You can find the Creator Privacy Policy here: https://www.taggermedia.com/legal/creator-privacy-policy
This User Privacy Policy also does not apply to any personal information in connection with which Tagger acts as a processor or service provider on behalf of our customers or others. For example, once you enter a contract or otherwise engage with one of our customers, the processing of your personal information by our customer is outside of our control and subject to our customer’s privacy policies, practices and any contract or other arrangement you or we may have with the customer. Should you have any questions or concerns concerning the processing of your personal information by one of our customers, please direct your enquiries to that customer.
Table of Contents
- Personal Information We Collect
- How We Use Your Personal Information
- How We Share Your Personal Information
- Use of Third-Party API
- Your Choices
- Security Practices
- International Data Transfers
- Children
- Changes to this User Privacy Policy
- How to Contact Us
- Your California Privacy Rights
- Notice to European Users
Personal Information We Collect
We may collect the following types of personal information about you in the following ways:
Services
If you register as a user of any of our Services, we may ask you to provide:
- your name,
- email address,
- contact telephone number (landline and/or mobile),
- the company you work for,
- a username and password
- and other information relevant to the Services we provide.
When providing information about yourself, pay special attention to the proper protection of username and password. If you are not an administrative user for your account, the same information about you may be provided by a colleague or other third party. We may also collect other information directly from you, from time to time.
If you contact our support services, we will collect the information we need to categorise your question and respond to it. We also use this information to track potential issues with our Services and customise our support responses to better serve you.
We collect information about you when you use any part of our Services. For example, if you are logged in to the Tagger Media Analytics Platform, we will collect information on how often it is used, what queries are created or amended, what mentions are looked at and other information about how you interact with our Analytics Platform. We may also collect information about how you interact with messages we send to you. We will not collect sensitive or excessive information from you. If you notice that sensitive information is collected from you, check it – maybe someone is impersonating our services.
We also infer information about you based on the information you have provided or made available to us. This may include personalising your experience of using our Services, suggesting different Services you may be interested in trying or other inferences about you.
We are constantly trying to improve our Services to you. This means that we are introducing new features of our Services regularly, some of which may result in the collection of new information from you. In this case, we will regularly inform you about it.
Tagger Media does not process special categories of personal data, as defined by Article 9 of GDPR, intentionally or otherwise. Tagger Media does not process special categories of personal data, as defined by Article 9 of GDPR, .
Website
In addition to the information that you provide to us, we may also collect information about you during your visit to our Services. We collect this information using automated tools that are detailed below. These tools may collect information about your behaviour and your computer system, such as your internet address (IP Address), the pages you have viewed and the actions you have taken while using the Services. Some of the tools we use to automatically collect information about you may include:
- Cookies. A “cookie” is a small data file transmitted from a website to your computer’s hard drive. Cookies are usually defined in one of two ways, and we may use both of them:
- session cookies, which do not stay on your computer after you close your browser, and
- persistent cookies, which remain on your computer until you delete them or they expire. Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Services’ features or lose access to some functionality.
- We differentiate between two categories of cookies: functional cookies, without which the functionality of our Website would be reduced, and optional cookies used for e.g. website analysis and marketing purposes.
- We only use optional cookies if we have obtained your prior consent.
- You may use our Website without any cookies being set. In your browser, you can at any time configure or completely deactivate the use of cookies. For example:
- When using Internet Explorer: click on the main menu, select “Tools/Internet Options”, then in the “Privacy” tab click “Advanced” and disable cookies.
- When using Mozilla Firefox: click on the main menu, select “Tools” and then “Options” and adjust the privacy level in the “Privacy” panel.
- When using Opera: click on the main menu, select “Tools” then from the “Preferences” tab select “Advanced” and then “Cookies”.
- When using Google Chrome: click on the menu on the right side of the screen, select “Options” then “Show advanced settings” and click on “Cookies”.
- Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behaviour. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of our third-party marketing partners may use Web Beacons to track your interaction with online advertising banners on our Services. This information is only collected in aggregate form and will not be linked to your personal information. Please note that any image file on a webpage can act as a Web Beacon.
- Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
- Third-Party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Services. For example, we may collect data where our banner advertisements are displayed on third-party websites.
Customer Data We Collect as a Service Provider/Processor. Our customers may supplement the personal information we make available to them via services with personal information about you that they have procured independently (“Customer-Procured Data”). Our customers input such Customer-Procured Data into our services, and we only use Customer-Procured Data to provide our webpage and services to that customer. However, this data is provided at the discretion of our customers and Tagger has no control over the input of such data. Such data may include additional (but non-public) information within the categories of data identified above.
In respect of this Customer-Procured Data, to the extent received solely from our customers and not otherwise, we act as a processor or service provider on behalf of our customers for their respective Customer-Procured Data. Our processing of any such personal information is outside the scope of this User Privacy Policy and is subject to our customers’ own privacy policies and practices and any contract or other arrangement you or we may have with such customer.
How We Use Your Personal Information
We may use your personal information for the following purposes and as otherwise described in this Privacy Policy:
To operate services and our business and to serve our customers. We use your personal information to operate services and our business and to provide our services to our customers, including to:
- present our services and its contents to you;
- provide you with information, products or services that you request from us;
- communicate with you about our services, including by sending announcements, updates, security alerts and support and administrative messages;
- understand your needs and interests, and personalise your experience with services and our communications;
- provide support for services and our business, including to respond to your requests, questions and feedback, and to otherwise correspond with you; and
- fulfil any other purpose for which you provide it.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and the personal information of other individuals. We may use this anonymous, aggregated or de-identified data and share it with our customers and other third parties for our lawful business purposes, including to analyse and improve our services and to promote our business.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, court orders and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your, our customers’ or others’ rights, privacy, safety or property (including by making and defending legal claims);1
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern our services; and
- prevent, identify, investigate and deter security threats and fraudulent, harmful, unauthorised, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
How We Share your Personal Information
To the extent permitted by applicable law and our contractual obligations, we may share your personal information with the following parties or as otherwise described in this User Privacy Policy or at the time of collection:
Buyer/Successor. We disclose your personal information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of the Company’s assets or equity securities, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding.
Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate our services (such as analytics and information technology services).
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. We may share your personal information with any third parties, including law enforcement, government authorities and private parties, as we believe in good faith to be reasonably necessary or appropriate for the compliance and protection purposes described above.
Business transferees. We may sell, transfer or otherwise share personal information with acquirers and other relevant participants in business transactions (or negotiations of, or due diligence with respect to, such transactions), including a corporate divestiture, merger, consolidation, acquisition, reorganisation or sale or transfer of some or all of our assets or equity securities, or in the event of bankruptcy, liquidation, dissolution or similar event.
With your consent or at your direction. We may share your personal information with any third party if you have provided your consent to such sharing or if you have otherwise instructed us to do so.
Use of Third-Party API Services
At Tagger, we utilise various third-party API services such as YouTube, Facebook, Instagram, TikTok, etc., to enhance the functionality of our platform. This privacy policy outlines how we collect, use and protect user information, including API data, as a result of using these services. By accessing or using our platform, you acknowledge and agree to the terms set forth in this privacy policy.
Notification of Third-Party API Services
Tagger uses YouTube API Services to provide users with video content on our platform. By using our platform, you acknowledge and agree to YouTube’s Terms of Service (https://www.youtube.com/t/terms) and Google’s Privacy Policy (http://www.google.com/policies/privacy).
In addition to Tagger’s normal procedure for deleting stored data, users can revoke Tagger’s access to their data via the Google security settings page at https://security.google.com/settings/security/permissions .
Tagger also uses Meta API Services and TikTok API Services. By using our platform, you acknowledge and agree to the following:
- Facebook’s Terms of Service and Meta’s Privacy Policy (https://www.facebook.com/privacy/policy)
- TikTok’s Terms of Service and TikTok’s Privacy Policy (https://www.tiktok.com/legal/page/us/privacy-policy/en)
User Information Collected
The API Client collects user information and API data when users interact with our platform, including but not limited to:
- User’s name, email and other contact information
- Social media profile information
- User’s IP address, browser type and device information
- Location data
- User’s interaction with our platform and third-party API services
Use of User Information
The API Client uses the collected user information for the following purposes:
- To enhance user experience by providing personalised content and advertising
- To optimise our platform and improve our services
- To provide customer support and respond to user enquiries
- To comply with legal obligations
Sharing of User Information
The API Client may share user information with third-party service providers who assist us in providing our services. We may also share user information with government authorities, legal counsel or law enforcement agencies if required by law.
Third-Party Content and Advertising
The API Client allows third-party advertisers to serve content, including advertisements, on our platform. These advertisers may collect user information and we encourage users to review their respective privacy policies.
Device Information Collection
The API Client may collect device information, including placing, accessing or recognising cookies or similar technologies on users’ devices or browsers, to improve our platform’s functionality and user experience.
We take user privacy seriously and strive to protect user information from unauthorised access, use or disclosure. By using our platform, you acknowledge and agree to the terms set forth in this privacy policy. If you have any questions or concerns regarding our privacy practices, please email us at [email protected].
Your Choices
All users, regardless of where they live, have the following rights:
- Access or Update Your Information. Provide you with information about our processing of your personal information and give you access to your personal information and update or correct inaccuracies in your personal information. If you would like to see or amend your personal information, please email us at [email protected].
- Opt out of the services. If you would like us to remove your personal information, please email us at [email protected].
If you are a resident of a jurisdiction that affords you additional rights by law with respect to your personal information, you may also have some or all of the following rights:
- Information
- Access
- Correction/Rectification
- Deletion/Erasure/To be forgotten
- Transfer
- Restriction of processing
- Objection to processing
- Non-discrimination
- Opt-out of certain sharing
- Opt-in to certain sharing (if we know that you are under 16 years of age)
Certain of these rights, as applicable, are described in the Your California Privacy Rights and Notice to European Users sections, below. You can exercise any of the above rights by emailing [email protected] or as otherwise provided in the Your California Privacy Rights and Notice to European Users sections, below, to the extent applicable.
Security practices
The security of your personal information is important to us. We employ a number of technical, organisational, physical and contractual safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfers
We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your country where privacy laws may not be as protective as those in your country.
Users in Europe should read the important information provided below about transfers of personal information outside of Europe.
Children
We do not knowingly collect personal information from children. We define “children” as follows:anyone under 16 years old, or the age needed to consent to the processing of personal information in your country of residence.
If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. If you are a parent or guardian of a child and believe we have collected the personal information of your child without your consent, please contact us to have this information deleted.
Changes to this User Privacy Policy
We reserve the right to modify this User Privacy Policy at any time. If we make material changes to this User Privacy Policy, we will notify you by updating the date of the policy and posting it on our website at https://www.taggermedia.com/. We may, and if required by law, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email (if we have your contact information). Any modifications to this User Privacy Policy will be effective upon our posting or as otherwise indicated at the time of posting. In all cases, your use of services after the effective date of any modified User Privacy Policy indicates your acceptance of the modified terms of the policy.
How to Contact Us
Please direct any questions or comments about this User Privacy Policy or privacy practices to [email protected]. You may also write to us via postal mail at:
2001 Wilshire Blvd. Suite 301
Santa Monica, CA 90403
Your California Privacy Rights
This section describes how we collect, use and share Personal Information of users that are California residents in connection with our services in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) / The California Privacy Rights Act (“CPRA”) and their rights with respect to that Personal Information. For purposes of this section, the term “Personal Information” has the meaning given in the CCPA/CPRA but does not include information exempted from the scope of the CCPA/CPRA.
Your California privacy rights. California residents have the rights listed below under the CCPA/CPRA. However, these rights are not absolute and, in certain cases, we may decline your request as permitted by law.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with which we share Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
- Access/Know. You can request a copy of the Personal Information that we have collected about you.
- Deletion. You can ask us to delete the Personal Information that we have collected from you, unless the CCPA/CPRA recognises an exception.
- Opt-out. You can opt out of certain sharing of your Personal Information, specifically for behavioural advertisement and “sale” under the CCPA/CPRA’s broad definition of that term. We do not knowingly share the Personal Information of consumers under 16 years of age.
- Right to correction. You can request to have your Personal Information and Sensitive personal information corrected if you find them to be inaccurate.
- Right to limit use of sensitive personal information. You can restrict use of this separate category of personal information, particularly around third-party sharing.
- Nondiscrimination. You are entitled to exercise the rights described above free from discriminatory treatment as prohibited by the CCPA/CPRA. Specifically, if you exercise your rights under the CCPA/CPRA, we will not deny you goods or services, charge you different prices or rates, provide you with a different level of service or quality of goods or services, or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, except as permitted by the CCPA/CPRA.
Exercising your right to information, access and deletion. You may submit requests to exercise your right to information, access or deletion by calling us freephone on 1-(888) 201-4517, or via email to [email protected].
Exercising your right to opt out of certain sharing of your Personal Information. We share Personal Information with our customers as described in this User Privacy Policy. Because the CCPA/CPRA defines the term “sale” very broadly, such sharing could be considered a “sale” under the CCPA/CPRA. You can request to opt out of behavioural advertisement and the sharing of your Personal Information here: Do Not Sell Or Share My Personal Information.
Exercising your right to limit the use of your Personal Information. You can request to limit the use of your Personal Information here: Limit The Use Of My Sensitive Personal Information.
Verification of your Requests; Authorised Agents. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency. To verify your identity, you will need to provide us with the following information about you: full name, email and links to social media handles. Depending on the nature and scope of your request, we may also need to request additional information from you, which we will use only for the purposes of verification. Upon receipt of your request, we will notify you if we need additional information from you to verify your request. We do not charge a fee to process or respond to your 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.
Your authorised agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorised agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide the information we request to verify your identity and provide us with confirmation that you have given the authorised agent permission to submit the request.
Personal information that we collect, use and disclose. The chart below summarises the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this User Privacy Policy. The terms in the chart refer to the categories of information, sources, purposes and third parties described above in this User Privacy Policy in more detail. Information you voluntarily provide to us, such as in the content of your posts, content from chats you engage in with our customers or others, or data input into free-form webforms, may contain other categories of personal information not described below. In addition to the disclosures described in the chart below, we disclose Personal Information as described in the How we share your personal information section, above.
| Statutory category / Personal information we collect in this category | Source of PI | Business/commercial purpose for collection | Categories of third parties to whom we “disclose” PI for a business purpose | Categories of third parties to whom we “sell” PI |
|---|---|---|---|---|
Identifiers
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California Customer Records (as defined in California Civil Code §1798.80)
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Internet or other similar network activity
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Your California privacy rights. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to [email protected]. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and postal address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, postal mail or facsimile, and we are not responsible for notices that are not labelled or sent properly, or that do not have complete information.
Notice to European Users
The information provided in this “Notice to European Users” section applies only to individuals in Europe.
Personal information. References to “personal information” in this User Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller and representatives. Tagger Media Inc. is the controller of your personal information covered by this User Privacy Policy for the purposes of European data protection legislation. Our representative in the European Union is European Data Protection Office (EDPO). You can contact EDPO regarding matters pertaining to the GDPR:
- by using EDPO’s online request form: https://edpo.com/gdpr-data-request
- by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
Our representative in the UK is EDPO UK Ltd. You can contact EDPO UK regarding matters pertaining to the UK GDPR:
- by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request
- by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom
Data Protection Officer (“DPO”). We have appointed a DPO. Our DPO can be contacted at [email protected].
Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this User Privacy Policy are described in the table below.
| Purpose | Category(ies) of personal information involved | Why do we do this | Our legal basis for this use of data |
|---|---|---|---|
| To operate services and our business and to serve our customers. |
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| To create anonymous, aggregated or de-identified data. |
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| Compliance and protection. |
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Use for new purposes
We may use your personal information for reasons not described in this User Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Sensitive personal information
We ask that you not provide us with any sensitive personal information (e.g. information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through services, webpage or otherwise to us. If you provide us with any sensitive personal information when you use services, you must consent to our processing and use of such sensitive personal information in accordance with this User Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through services.
Profiling and automated decision-making
Profiling is the automated processing of personal information to evaluate certain things about an individual. Automated decision-making means decisions made solely by automated means without any human involvement. We do not currently use profiling or automated decision-making mechanisms when processing your personal information.
Retention
We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information we have collected about you, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymise your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Your rights
European data protection laws give you certain rights regarding your personal information. If you are located within Europe, you may ask us to take the following actions in relation to your personal information that we hold:
- Inform. Right to know about processing your personal information.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct/Rectification. Update or correct inaccuracies in your personal information.
- Delete/Erasure/To be forgotten. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts on your rights.
- Data portability. Obtain and reuse their personal information for their own purposes across different services.
You may submit these requests via email to [email protected]. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.
You will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Cross-Border Data Transfer
If we transfer your personal information out of Europe to a country not deemed by the European Commission and/or UK Government, as applicable, to provide an adequate level of personal information protection, the transfer will be performed subject to appropriate safeguards and otherwise in accordance with European data protection laws. You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.