Hootsuite Privacy Policy
Effective date: January 30, 2016
Introduction
Hootsuite Data and Customer Content
About this Privacy Policy
Hootsuite Data we receive or collect
How we use Hootsuite Data
Customer Content we process for our customers
Consent
Cookies and related technologies
When we may share personal information
Children
Security
Information storage and international transfers
Email preferences
Your rights
Contacting us
Introduction
Hootsuite Media Inc. and its a liates (“Hootsuite”) are committed to protecting the privacy of all individuals who:
visit Hootsuite’s website located at hootsuite.com, which includes all subdomains, present and future (the “Website”);
use the mobile applications that Hootsuite makes available from time to time (the "Applications");
use the Services including Hootsuite Free, Pro, Enterprise, Ow.ly, Amplify, Podium, Campaigns and other Hootsuite products and services (the "Platforms"); and
purchase Hootsuite-branded and other items from the Hootsuite Shop located at shop.hootsuite.com and other domains (the “Shop”). When we talk about “Personal Information”, we mean information relating to you or other identi able individuals.
To make this policy easier to read, we call the Website, the Applications, the Platforms, and the Shop together the "Services". When we talk about “Personal Information”, we mean information relating to you or other identi able individuals.
It is Hootsuite’s policy to respect your privacy and the privacy of all users of the Services. This Privacy Policy has been established to help you understand our commitment to protecting your privacy and personal data, and the steps we take to ensure it. By visiting and/or using any of the Services, you agree to be bound by the terms of the present Privacy Policy (the “Privacy Policy”). Where the present Privacy Policy refers to “Hootsuite”, it may refer to the Services or to Hootsuite Media Inc., depending on the context.
Hootsuite reserves the right, at any time, to modify or replace the Privacy Policy. The most recent version of the Privacy Policy is available at hootsuite.com/legal/privacy. Please check the Privacy Policy periodically for changes, though we will also notify you via email or other direct electronic communication method of any changes that, in our sole discretion, materially impact your use of the Services or the treatment of your Personal Information. Your use of the Services following the posting of any changes to the Privacy Policy constitutes acceptance of those changes.
Hootsuite’s Privacy Policy forms part of its wider terms of service. If you are a visitor to the Website or if you are a Hootsuite Free or Hootsuite Pro user, these terms of service are available at https://hootsuite.com/legal/terms. If you are a Hootsuite Enterprise user, these terms of service are available at https://hootsuite.com/legal/enterpriseterms. Additional terms may apply to other Services purchased. To make this policy easier to read, any applicable Hootsuite terms of service are referred to as the “Terms”. Both the Terms and the Privacy Policy apply to your use of the Services.
Hootsuite Data and Customer Content
We collect Personal Information (such as registration and account information) from our customers and users of the Services for our own purposes, such as to provide and administer the Services (“Hootsuite Data”). We’re the data controller in respect of this information. Hootsuite Data is also referred to as “Customer Information” in our Terms with our Enterprise Customers.
We also process Personal Information on behalf of our customers as their data processor, such as content generated, requested or published via the Platforms in accordance with the instructions our customers give us through the Services (including, for example, the information our customers monitor or collect from social media sites like Twitter and Facebook through the Services) (“Customer Content”). Our customers control how their Customer Content is collected and used by them. In legal terms this means that our customers are the data controller of their Customer Content. Accordingly, we only use Customer Content to provide the Services to our customers in accordance with the lawful instructions they give us through the Services.
About this Privacy Policy
This Privacy Policy describes how and when Hootsuite collects, uses and shares Hootsuite Data when you use the Services. Hootsuite receives your information through our Website, Platforms, Applications and Shop.
Whilst most of this Privacy Policy relates to Hootsuite Data, we also provide some information about how our customers choose to collect and use Customer Content through the Services.
The Services by their nature allow our customers to connect their accounts through the APIs of our various Supported Platforms (such as Twitter, Facebook...) and any applications developed by third parties that Hootsuite does not own or control (“Third-Party Apps”) that our customers choose to access. This Privacy Policy does not cover any information or other content you can view via the Services on Supported Platforms (but which was not posted there using the Services) or information you provide to Third-Party Apps accessed via the Services. While we attempt to facilitate access only to those Supported Platforms and Third-Party Apps that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of any Supported Platforms or Third- Party Apps. We encourage you to carefully review the privacy policies of any Supported Platforms or Third-Party Apps you access via the Services.
Hootsuite Data we receive or collect
When you rst register for a Hootsuite account, and when you use the Services, we collect some Personal Information about you such as:
your full name, username, and email address and other contact details
the geographic area where you use your computer and mobile devices
a unique Hootsuite user ID (an alphanumeric string) which is assigned to you upon registration
other optional information as part of your account profile
your IP Address and, when applicable, timestamp related to your consent and confirmation of consent
other information submitted by you or your organizational representatives via various methods (phone, email, online forms, surveys, in-person meetings, etc)
your billing address and any necessary other information to complete any nancial transaction, and when making purchases through the Services, we may also collect your credit card or PayPal information
user generated content (such as messages, posts, comments, pages, pro les, images, feeds or communications exchanged on the Supported Platforms)
images or other files that you may publish via our Services (including the Ow.ly services) information we may receive relating to communications you send us, such as queries or comments concerning our Services
information relating to an individual’s real time location
Hootsuite also automatically collects and receives certain information from your computer or mobile device, including the activities you perform on our Website, the Platforms, and the Applications, the type of hardware and software you are using (for example, your operating system or browser), and information obtained from cookies (see “Cookies and Related Technologies” below). For example, each time you visit the Website or otherwise use the Services, we automatically collect your IP address, browser and device type, access times, the web page from which you came, the regions from which you navigate the web page, and the web page(s) you access (as applicable).
How we use Hootsuite Data
Hootsuite uses Hootsuite Data for the following general purposes:
to identify you when you login to your account
to enable us to operate the Services and provide them to you
to verify your transactions and for purchase con rmation, billing, security, and authentication (including security tokens for communication with installed Third-Party Apps)
to analyze the Website or the other Services and information about our visitors and users, including research into our user demographics and user behaviour in order to improve our content and Services
to contact you about your account and provide customer service support, including responding to your comments and questions
to share aggregate (non-identi able) statistics about users of the Services to prospective advertisers and partners
to keep you informed about the Services, features, surveys, newsletters, o ers, contests and events we think you may nd useful or which you have requested from us
to sell or market Hootsuite products and services to you
to better understand your needs and the needs of users in the aggregate, diagnose problems, analyze trends, improve the features and usability of the Services, and better understand and market to our customers and users
to keep the Services safe and secure
We also use non-identi able information gathered for statistical purposes to keep track of the number of visits to the Services with a view to introducing improvements and improving usability of the Services. We may share this type of statistical data so that our partners also understand how often people use the Services, so that they, too, may provide you with an optimal experience.
Customer Content we process for our customers
Hootsuite is a social media management tool. By its nature, Services enable our customers to bring together their social networks and integrate with hundreds of business applications that they already use, all in one place.
Services help our customers manage social media campaigns, marketing and advertising; engaging audiences; scheduling and publishing messages; and analyze the results.
In particular, the various Services allow our customers to instantly connect to other third party services, including “Supported Platforms” such as Twitter, Facebook, etc. When our customers link a Supported Platform or a third party service (such as OpenID) to their Hootsuite account or when they register with a Supported Platform through their Hootsuite account, our customers can choose to instantly collect, process, share and access such third party services and Supported Platform via their Hootsuite account (subject to the terms of the license agreements with the Supported Platforms and other third party services).
In this way, our customers can obtain, use and analyze public Personal Information from Supported Platforms and third party services of their choosing, and also create, input, submit, post, transmit, store, view or display Personal Information through the functionality in the Services. Such information can include Personal Information of all types, including but not limited to the following categories:
user generated content (such as messages, posts, comments, pages, pro les, images, feeds or communications exchanged on the Supported Platforms)
contact details (such as name, email address, telephone number)
additional individual information (such as age, gender, employer, profession, geographic location, education information, nancial status, habits and preferences)
information relating to individual’s real time location
Consent
By using any of the Services, or submitting or collecting any Personal Information via the Services, you consent to the collection, transfer, storage disclosure, and use of your Personal Information in the manner set out in this Privacy Policy. If you do not consent to the use of your Personal Information in these ways, please stop using the Services.
Cookies and related technologies
Hootsuite uses tracking technology (“cookies”) on the Website, in the Applications, and in the Platforms, including mobile application identi ers and a unique Hootsuite user ID to help us recognize you across di erent Services, to monitor usage and web tra c routing for the Services, and to customize and improve the Services. By visiting the Website or using the Services you agree to the use of cookies in your browser and HTML-based emails. Cookies are small text les placed on your device when you visit a web site, in order to track use of the site and to improve your user experience.
Session Cookies
The Services use “session cookies”, which improve your user experience by storing certain information from your current visit on your device, such as log-in information. These enable us to remember your log-in session so you can move easily within the Website or the other Services. Without these session cookies, we wouldn’t be able to provide the Services to you. These session cookies have limited functionalities and expirations, and you will be required to re-enter your Hootsuite log-in information after a certain period of time has elapsed to protect you against others accidentally accessing your account contents and related Personal Information. Other examples of our use of session cookies include to track the number of visits by a particular visitor to a page and to store items in an online shopping cart for the Shop.
Performance and Remarketing Cookies
Partners who help us serve advertising on and o the Website and analytics companies may also put cookies on your device. We use several third-party vendors to help deliver ads for relevant Hootsuite products and services to you when you visit certain pages on our Website and then visit certain third- party sites. We may share with third-party ad partners a cryptographic hash of a common account identi er (such as an email address), to help us measure and tailor ads and services provided to you. Below is information about one such vendor. Please note that this Privacy Policy covers only our use of cookies and does not include use of cookies by any third parties.
i) Google Analytics
Hootsuite uses a speci c cookie in order to facilitate the use of Google Universal Analytics for users logged-in to the Applications or the Platforms (“Logged-In User). If you are a Logged-In User, Hootsuite may use your Hootsuite user ID in combination with Google Universal Analytics and Google Analytics to track and analyze the pages of the Services you visit. We do this only to better understand how you use the Website and the other Services, with a view to o ering improvements for all Hootsuite users; and to tailor our business and marketing activities accordingly, both generally and speci cally to you. Google Analytics cookies do not provide Hootsuite with any Personal Information.
Learn more about privacy at Google and to opt-out of this feature by installing the Google Analytics Opt-out Browser Add-on.
ii) Google Display Advertising
Additionally, Hootsuite uses Google Analytics code that allows for certain forms of display advertising and other advanced features. Subject to change, the Google Display Advertising features Hootsuite currently uses are Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting.
These features are used to advertise online; to allow third-party vendors, including Google, to show you advertising across the Internet; to allow Hootsuite and third-party vendors, including Google, to use rst-party cookies (such as the Google Analytics cookie) and third-party cookies together to inform, optimize, and serve ads based on your past visits to the Website and to report how ad impressions, uses of ad services, and interactions with these ad impressions and ad services are related to visits to the Website. Data from Google's interest-based advertising or third-party audience data (such as age, gender, and interests) is also combined with Google Analytics to better understand the needs of Hootsuite users and to improve the Services.
You may opt out of such display advertising at any time by visiting your Google Ads Settings page or by installing and running the Google Analytics Opt-out Browser Add-on .
Hootsuite uses other third-party performance and remarketing cookies, and further information on those third-party cookies can be obtained by contacting us.
Hootsuite may also use related technologies including web beacons, bugs, pixels, and software tokens in order to facilitate your use of the Services. Most notably, the Services use software tokens (stored securely on Hootsuite-controlled servers) in order to facilitate the logging in to and the functioning of both the Supported Platforms and Third-Party Apps.
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. The Network Advertising Initiative has also developed a tool that may help you understand which third parties have currently enabled cookies for your browser and opt-out of those cookies. Further information can be found at http://www. networkadvertising.org/managing/opt_out.asp. Please note however that, by blocking or deleting cookies, you may not be able to take full advantage of the Website, Applications, Platforms, and/or Shop. If you do not want to receive tracking pixels, you will need to disable HTML images in your email client, and that may a ect your ability to view images in other emails that you receive.
When we may share Personal Information
Except as provided in this Privacy Policy, Hootsuite does not divulge any Personal Information gathered via the Services (including Customer Content) to third parties.
Notwithstanding anything in the Privacy Policy to the contrary, we may share any information we have collected about you or Customer Content:
(1) when you explicitly consent to the disclosure of such information to a third party when connecting to a third-party service that asks you if you consent to such sharing;
(2) where we are legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands;
(3) if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person;
(4) if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure or the Internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Website infrastructure or the Services generally);
(5) to a parent company, subsidiaries, joint ventures, or other companies under common control with Hootsuite;
(6) if we are acquired by or merged with another entity (in which case we will require such entity to assume our obligations under this Privacy Policy or inform you that you are covered by a new privacy policy); and
(7) if this information is not private, is aggregated or is otherwise non-Personal Information, such as your public user pro le information and related public data (such as Tweets, likes, etc.) or the number of users who clicked on a particular link (even if only one did so).
Subject to obligations consistent with this Privacy Policy, we may also disclose information to our a liates, agents, contractors, and service providers in order to facilitate the functioning of the Services or to perform tasks that are integral to the Services, such as processing transactions, ful lling requests for information, or providing support services or other tasks, from time to time. Information may also be transferred from Hootsuite to the third parties in control of the Supported Platforms, but only to the extent required in order for the Services to function properly.
Children
Protecting the safety of children when they use the Internet is very important to us. Our Services should only be accessed by individuals of Minimum Age. “Minimum Age” may mean di erent ages in di erent countries, depending on where the individual accesses the services. For reference, “Minimum Age” shall mean (a) 14 years old for the United States, Canada, Germany, Spain, Australia, and South Korea; and (b) 13 years old for all other countries. However, if applicable law requires that you must be older than such ages in order for Hootsuite to lawfully provide the Services to you (including the collection, storage, and use of your information in accordance with this Privacy Policy), then the Minimum Age would be such older age. The Services are not designed nor intended for use by children or anyone else under the age of 13.
Security
We use industry best practices to keep any information collected and/or transmitted to the Supported Platforms or Third-Party Apps secure. This includes the use of HTTPS with TLS (Transport Layer Security), which encrypts all transmitted data, and OAuth 2.0 protocols for authentication and data transfer to Supported Platforms and Third-Party Apps.
Certain Personal Information, most notably Hootsuite log-in details, is encrypted during transmission using TLS. Once validated within our system, passwords are deleted from our system. In addition, Hootsuite uses third-party vendors and hosting partners such as Amazon to provide the necessary hardware, software, networking, storage, and related technology required to run the Services. These vendors have been selected for their high standards of both physical and technological security, including ISO and SSAE16 certi cations.
When payments are processed via credit card, Hootsuite uses third-party vendors that are PCI-DSS Compliant. At no point does Hootsuite have access to your credit card information.
You should bear in mind that submission of information over the Internet is never entirely secure. We cannot guarantee the security of information you submit via the Services whilst it is in transit over the Internet and any such submission is at your own risk, and this risk is speci cally disclaimed in our Terms.
If you are a Logged-in User, it is advisable that you log out of your account at the end of every session and not leave a logged-in account unattended for any period of time, particularly if you use a shared computer or device.
Information storage and international transfers
Hootsuite Media Inc., the entity which provides the Services, is a Canadian company with its head- o ce located in Vancouver, British Columbia. For the purposes of EU data protection law, Canada is considered a country which provides adequate protections for Personal Information, as con rmed by the European Commission in Commission Decision 2002/2/EC.
The Services are mainly provided from our o ces in Canada. However, by the very nature of the Services, the data that is viewed, collected, stored or posted on or through the Services also needs to ow from wherever you are located in the world, to where our Supported Platforms are storing the same data (i.e. in most cases, in the United States). In addition, Hootsuite uses third-party service providers (such as managed hosting providers, card processors, CRM systems, sub-processors of Customer Content and technology partners) to provide the necessary hardware, software, networking, storage and other services that we use to operate the Services. These third party providers may process, or store, the same Customer Content on servers outside of the EEA, including in Canada or the US.
By using any of the Services, or submitting or collecting any Personal Information via the Services, you authorize Hootsuite and its authorized service partners to use and process Customer Content and Hootsuite Data (including any Personal Information) in these countries. Please be aware that the privacy protections and the rights of authorities and Government agencies to access your Personal Information in some of these countries may not be equivalent to those in your country.
For our customers with a principal location in the EU:
If you primarily use the Services within the EU, we will process Customer Content (which may include Personal Information) as a data processor on your behalf. Under EU law, you are considered to be the data controller of the Customer Content, and as such you are responsible for complying with applicable data protection laws in respect of the processing of Customer Content and the lawful instructions you give us.
To facilitate the lawful transfer by you of your Customer Content (as a data controller) through the Services to outside the EEA, Hootsuite is o ering its EU customers a data processing agreement as an addendum to their existing Hootsuite agreement (“Data Processing Addendum”). This incorporates the European Commission’s Standard Contractual Clauses (processors) of 2010 (also known as “model processor clauses” or "SCC 2010”).
Please note that the Data Processing Addendum only applies to the extent there is not another legal basis in place to validate the transfer of Personal Information to outside the EEA.
The Data Processing Addendum and some FAQs are available to all of our Customers. If you would like to incorporate the Data Processing Addendum into your existing agreement with Hootsuite, please email us and we will promptly send you Hootsuite’s Data Processing Addendum for you to complete, sign and return to us.
If you have any questions, please feel free to contact us.
Email preferences
Hootsuite uses email as the primary mode of communications with our users. We want to respect your privacy by only sending emails of interest to you. You can manage your email preferences, such as opting-out or unsubscribing from emails sent by Hootsuite, by adjusting your preferences in your account settings. You may also opt out or unsubscribe from any future email communications from within a link provided in each email correspondence that we send you.
Your rights
You can contact us to obtain a copy of the Personal Information held about you by us. This may be subject to a fee not exceeding any prescribed fee permitted by applicable law. You can also ask us to correct and, where relevant, erase that information. Please note that certain Personal Information may need to be retained by Hootsuite for a period of time following cancellation of your account where this is necessary for our legitimate business purposes or required or authorized by applicable law. As mentioned above you have a right to change your email preferences at any time.
You should be aware that Hootsuite acts as a conduit between our users and the various Supported Platforms and Third-Party Apps. In several instances, the content published via Hootsuite will not be in Hootsuite’s custody or control, and any content that has been shared by you through any Supported Platform or Third-Party Apps via the Services may continue to be available to third parties and the public at large, as this content is now under the control of the operators of the Supported Platforms and/or the Third-Party Apps.
Contacting us
If you have any questions about this Privacy Policy, please contact:
General Counsel, Hootsuite Legal Services
or:
General Counsel, Hootsuite Legal Services c/o Hootsuite Media Inc. 5 East 8th Avenue Vancouver, BC V5T 1R6 Canada
© Hootsuite Media 2015