A. Definitions

The words whose initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in the singular or plural.

Account means a unique account created for you to access our Website or Apps.

Account Information refers to your name, email address, mailing address, date of birth, location and phone number, gender, job profession, company name, or similar information associated with your Account.

App refers to the Saltire Social mobile application.

Company (referred to as either “the Company,” “we,” “us”, or “our” in this Policy) refers to Waker Media & Technology Group. “WMTG”). Email: [email protected]. For the purpose of the GDPR, the Company is the Data Controller and Data Processor.

Consumer means a resident of a particular jurisdiction with applicable data protection laws.

Cookies are small files that are placed on your computer, mobile Device or any other Device by a website, containing the details of your browsing history on that website among its many uses.

Country refers to the United Kingdom / Scotland.

Data Controller refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.

Data Processor refers to the Company as the legal person which processes Personal Data.

Device means any device that can access the Website or Apps, such as a computer, a cellphone, or a digital tablet.

GDPR refers to the General Data Protection Regulation (EU) 2016/679. (Relatedly, U.K. GDPR refers to the United Kingdom’s privacy rules, which adopted the privacy compliance requirements of GDPR.)

Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to you, such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. Personal Data also includes “personal information” (as defined under CCPA), which means information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer.

Privacy Policy or Policy means this policy.

Sale means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal data to another business or a third party for monetary or other valuable consideration.

Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Website or Apps, to provide the Website or Apps on behalf of the Company, to perform services related to the Website or Apps or to assist the Company in analysing how the Website or Apps is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

Usage Data refers to data collected automatically, either generated by the use of the Website or the Apps or from the Website or the Apps infrastructure itself (for example, the duration of a page visit).

User Registration Data means data collected at the time of registration on the Website or Apps, including your email address, name, date of birth, phone number and location, as well as username and password for your profile and your Account.

Website refers to Saltire Social, accessible at https://saltiresocial.com/.

B. Information Collected and Received from You

We may receive or collect Personal Data from you when you utilise the Website and Apps or when you voluntarily provide Personal Data to us. This may include the following:

Account Information and User Registration Data

We collect and maintain Account Information. When you register or sign up on the Website or Apps for certain features, newsletters and/or special offers, you may provide us, and we may collect, your User Registration Data.
Information Collected and Received from You

You may elect to provide a variety of information during your interactions with us and the Website and Apps, such as emails you may send us, ads you respond to, comments, posts, or interactions that you may make through your Account, SMS or text messages that you may sign up for through the Website or Apps, and emails or newsletters that you sign up to receive from us. We, or third parties acting on our behalf, receive data from you whenever you provide us with this information.
Information as to your Device

When you access and use the Website or Apps from a computer, mobile phone, tablet, or other Device, we may use information about those Devices, including your browser type and Internet Protocol (IP) address. If you access the Website from a mobile phone, tablet, automobile, or other Device, we may collect and store information such as Device type, operating system version and type, wireless carrier, performance metrics of our Website or Apps, and other related information.
Information as to your Location

When you register for the Website or Apps, we may collect location information, derived from your IP address, from the Devices or web browsers you use while accessing the Website or Apps.
Usage Data

We may collect data on the pages of our Website or Apps you visit, the time and date of your visit, and time, frequency, and duration spent on those pages, as well as the particular features you use. Mobile Messaging consent will not be shared or sold to any third party unless required so by law.
Cookies

Saltire Social may collect Personal Data through the use of cookies or other tracking technologies. For complete information about our cookie policy, see Section E of this Privacy Policy.

Information that you post

Our Website and Apps store content you post until you delete it. Additionally, Saltire Social may store backup copies of content that you post through our Website and Apps for archival and data redundancy purposes.
Other Information

We may collect certain information through the use of log files and servers. These servers create log files as part of the process of setup and configuration. Information in a log file may include IP address (and associated geographic information), browser type, Internet service provider, date/time stamps, and other usage or statistical information.

C. Information Collected and Received from Others

We may receive or collect information about you from third parties or others when we use an outside service provider to display ads on the Website or Apps. Where these ads contain cookies that store your Personal Data, your Personal Data may be collected and stored on our servers with other information we may have already received or collected from you. This Personal Data is used to serve relevant ads to you and is based on items that may be considered Personal Data under the law, such as your IP address, browser type, time and date, and subject of advertisements clicked or interacted with. These third parties may provide us with certain information about their customers for the purposes of serving advertisements and/or marketing offers to their customers on the Website or through the Apps. We are not responsible for, and will assume no liability, if a business partner or other entity collects, uses, or shares any information about you in violation of its own privacy policy or any applicable laws, rules, or agreements. You are directed to review the privacy policies of any third parties that advertise on or through the Website or Apps.

D. How We Use Information

We may use your User Registration Data, Account Information, Personal Data, as well as data which we derive or infer from combinations of the foregoing, for a variety of purposes and situations, such as:

To facilitate the creation of and secure your Account on the Website or Apps.
To provide and improve the Website and Apps, and to develop new products and services.
To customise and personalise the advertising and other content we deliver to you both on the Website and Apps, and on other services offered by our publishing partners. We use this information to provide you with relevant and interesting advertising and other content.
To fulfil your requests for certain products and services, such as distributing electronic newsletters and enabling you to participate in surveys and public forums.
To send you information that you requested or agreed to receive. To alert you to the latest developments and features on our Website and Apps, and to notify you of administrative information, such as security or support and maintenance advisories.
To invite you to participate in events or special promotions related to products we think you may like or in which you may be interested. To advertise and market to you, which includes sending promotional communications and advertisements.
To allow our business partners to offer you certain products, services or promotions.
To transfer Personal Data in the event of a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
To measure, analyse, and improve our services.

We do not sell or give your Personal Data to companies, including political candidates or campaigns, for their own marketing purposes without your permission. We do use Personal Data, however, to contact you, provide you with technical support, send you notices about the Website and Apps or other promotional offers you have elected to receive, and to serve you with ads that are more relevant to your interests. If you provided your Personal Data as part of your use of the Website, the Apps or your Account, we may use your Personal Data to update you on new features and products. You may contact us at any time to request that we cease using your Personal Data.

E. Information Collection Technologies/Cookies

Saltire Social may collect Personal Data through the use of cookies or other tracking technologies. Cookies and other tracking technologies help Saltire Social understand how you use the Saltire Social Website and Apps and provide us with an understanding of how our users utilise our services. Saltire Social’s use of cookies aids in developing or improving our services in response to your needs and wants and to provide you with relevant offers from our advertisers, where applicable. Saltire Social may use session or persistent cookies. Session cookies are only stored on your computer or mobile Device while you use the Saltire Social services and are automatically deleted when you close your web browser or cease using the Apps. If you are located in Canada, the United Kingdom, or the European Union, Saltire Social requests your consent before storing session cookies on your computer or mobile Device.

Persistent cookies can be read by the website or mobile applications that placed the cookie when you revisit the website or mobile application. Persistent cookies authenticate you as a user and track your behaviour on the website or through the mobile application. Persistent cookies thereby allow a fast, consistent user experience tailored to your preferences. Saltire Social requests your consent to utilise persistent cookies when you register a user account with Saltire Social and agree to its Terms of Use Agreement and Privacy Policy.

If you object to Saltire Social’s use of cookies, you can clear your web browser cache and stop using the Website or App to remove session cookies. To remove persistent cookies, clear your web browser, delete your user account, and stop using the Website or Apps.

Saltire Social uses third-party session cookies provided by Cloudflare’s Bot Management technology to protect its website from harmful automated attacks. To understand how Cloudflare uses information collected from you through this session cookie, please review Cloudflare’s Cookie Policy at the following link: https://www.cloudflare.com/cookie-policy/.

F. Retention of Your Personal Data

We will retain your Personal Data only for as long as we determine is necessary to achieve the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Your Account Information will be retained by us while your Account and profile is active. We will retain and use this information for the purposes for which it was collected (as specified in this Policy or as we disclose to you outside of this Policy), including to provide information and products to you, comply with our legal obligations, resolve disputes, and enforce our agreements.

G. Transfer and Processing of Your Personal Data

Your Personal Data is processed at our offices and data centres or the offices and data centres of our third-party partners. This means that this information may be transferred to — and maintained on — computers located outside of your province, country or other governmental jurisdiction where the applicable data protection laws may differ from those of your jurisdiction. Your consent to this Privacy Policy, followed by your submission of such information, represents your agreement to that transfer. We will take all steps reasonably necessary to ensure that your Personal Data, is treated securely and in accordance with this Privacy Policy and that no transfer of your Personal Data will take place to an organization or a country unless there are adequate access and security controls in place to maintain the same level of protection as is provided under this Privacy Policy.

H. Sharing Information with Others

We may share information that we collect with our subsidiaries, successors, or related companies for the purposes described in our respective privacy policies, and to offer, provide, and improve services and products offered both individually and jointly with these companies.

We may share information that we receive or collect, such as when you give us permission through an affirmative election (for example, clicking “yes” in response to a message or email inquiring as to whether to “share my email with this advertiser”). We may also share information if we partner with a third party to provide services on our behalf, such as credit card processors, customer support, advertising services, or bulk email processors who may send out emails on our behalf.

These companies are authorised to use your Personal Data only as necessary to provide these services to us. They are not authorised to use your Personal Data for their own, unrelated purposes.

We may also share your Personal Data in good faith belief that such action is necessary to:

Comply with a legal obligation, such as upon receipt of a duly authorised subpoena or court order or in the event of an audit.
Protect and defend the rights or property of Saltire Social or the legal rights of third parties or our employees, agents, and contractors (including under our agreements).
Prevent or investigate possible wrongdoing in connection with the Website or App.
Protect the personal safety of users of the Website or App or the public.
Protect against legal liability.

Additionally, we may share information we gather from Devices you use to access the Website or App with third-party vendors, manufacturers, service providers or advertising entities. We share this information for a variety of purposes, such as tracking advertising, estimating the number of users, security and fraud detection, debugging problems, and for providing you with more relevant advertisements on the Website and App.

If there is a transfer or sharing of your Personal Data in accordance with this Policy, we will seek assurances from the recipients of such information (prior to the transfer) that they will safeguard the information in a manner consistent with this Policy.

I. Direct Messaging

Saltire Social offers users the ability to send direct messages to their followers, allowing for more private, one-to-one communications. Saltire Social does not encrypt these direct messages. When you communicate with others by sending or receiving Saltire Social’s direct messages, we will save the messages along with certain information necessary for processing them.

In the event that a user reports a message for a violation of Saltire Social’s rules or any applicable law, Saltire Social typically will keep the reported message and associated portions of the related conversation for ninety (90) days after reporting.

Remember that when you use Saltire Social’s Direct Messages to communicate, recipients retain their own copy. Recipients may duplicate, store, or re-send your messages. If you delete your copy of a message sent from your account, you will delete that message in your recipient’s account as well, but Saltire Social will retain the message for the time periods described above. Salitr Social does not use information collected from direct messages for advertising purposes.

J. Account Management and Settings

You will have the ability to access and modify your Account Information on your Account, which you may do through the settings section of our Website or App at any time. You have control through settings on your Account and on your profile to limit the data we collect from you and how we use it. You can also download the information you have shared with the Website and App.

Upon your registration of an Account on the Website or App, you may elect to receive promotional, marketing, or other similar emails tailored to your interests. You may change this election at any time. Additionally, you may also unsubscribe from any promotional, marketing, or other similar emails you receive. We will send you confirmation emails and other Website-related or App-related announcements when it is necessary to do so.

K. Security Measures

When necessary, we have implemented security measures designed to protect against the loss, misuse, and alteration of the information we collect or receive from you. Nevertheless, no security measures are impenetrable, and there are always security risks.

We will use the information we collect in ways that are relevant and compatible with the purpose for which that information was collected or provided to us as disclosed in this Policy. We will use safeguards to ensure that all information collected, processed, and/or stored is protected from loss, destruction, or use in a manner inconsistent with our policies or the purpose for which we received it.

Our Website and App, as well as advertisements on our Website and App, may include links to other websites whose privacy practices may differ from ours. If you submit Personal Data to any of those websites, the privacy statements and practices of those websites govern their use of your information. Please be sure to review the privacy statement of any website you visit.

Other third parties or advertisers may utilise framing techniques to serve content to and from webpages accessible through our Website and App while preserving the look and feel of our website. Please note that you may be providing your Personal Data to this third party (and not to us) in this situation.

L. GDPR Privacy

This Privacy Policy addresses the concerns set forth by the GDPR, including what and how we collect your data, how we use and store your data, marketing, data protection rights, cookies and how we use them, relevant privacy policies of other websites, how we change our Privacy Policy, and how to contact us and appropriate privacy authorities. For information about these topics, please consult the relevant sections of this Policy.

Legal Basis for Processing Personal Data under GDPR. We may process Personal Data under the following conditions:

Consent: You have given your consent for processing Personal Data for one or more specific purposes.
Performance of a contract: Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
Legal obligations: Processing Personal Data is necessary for compliance with a legal obligation to which we are subject.
Vital interests: Processing Personal Data is necessary in order to protect your vital interests or those of another natural person.
Public interests: Processing Personal Data is related to a task that is carried out in the public interest or in the exercise of official authority vested in us.
Legitimate interests: Processing Personal Data is necessary for the purposes of the legitimate interests pursued by us.

In any case, we will gladly help to clarify the specific legal basis that applies to the processing, and in particular, whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Your Rights under the GDPR. We undertake to respect the confidentiality of your Personal Data and to guarantee that you can exercise your rights. You have the right under this Privacy Policy, and by law if you are within the EU, to:
- Request access to your Personal Data. The right to access, update, or delete the Personal Data we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your Account settings section. If you are unable to perform these actions yourself, please contact us to assist you. This right also allows you to receive a copy of the Personal Data we hold about you.
- Request rectification or correction of the Personal Data that we hold about you. You have the right to have any incomplete or inaccurate Personal Data we hold about you corrected.
- Object to the processing of your Personal Data. You have the right to object to the processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing of your Personal Data, and there is something about your situation that makes you want to object to our processing of your Personal Data on this ground. You also have the right to object when we are processing your Personal Data for direct marketing purposes.
- Request erasure of your Personal Data. You have the right to ask us to delete or remove your Personal Data when there is no good reason for us to continue processing it.
- Request the transfer of your Personal Data. You have the right to request the transfer of your Personal Data. We will provide to you, or to a third-party that you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
- Withdraw your consent. You have the right to withdraw your consent to the processing or use of your Personal Data. If you withdraw your consent, we may not be able to provide you with access to certain specific functionalities of the Website or App.
Exercising your GDPR Data Protection Rights. You may exercise your rights by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible. You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.

M. Changes to our Privacy Policy

Our Privacy Policy will be periodically reviewed and evaluated in connection with new products, new services, new technologies, changes in law, and your needs. We may make changes or modifications to our Privacy Policy as a result thereof. Our Privacy Policy will be updated from time to time. If we make any material changes to this Privacy Policy, we will post the updated terms of the Privacy Policy on the Website and the App. Notice of such changes may include notice by email through a message sent to the email address you use to access the Website and App, or to register as a user on the Website and App or posting a message on the Website or App. You are responsible for updating your Account Information to provide us with your most current email address, as the email notice constitutes effective notice of said changes.

O. Miscellaneous

From time to time, we may conduct compliance audits of our relevant privacy practices to verify adherence to this Privacy Policy and that said Privacy Policy is current and accurate. Any employee that we determine is in violation of this Privacy Policy may be subject to disciplinary action.

Any complaints or disputes as to the collection or use of Personal Information or Personal Data under this Policy shall be completely investigated to seek a resolution or cooperate with dispute resolution procedures, if applicable to the dispute.

P. Contact Us

If you have any questions about this Privacy Policy, our privacy practices or how we collect or process your personal data, please contact us - Attn: User Support at [email protected]