Privacy Policy - Política de Privacidad

I. Introduction

A. Statement of Purpose and Scope

This Privacy Policy ("Policy") describes how Netsocs LLC and its affiliates and subsidiaries ("Netsocs," "we," "us," "our") collect, use, disclose, and protect information related to you ("you," "your," "user"). This Policy applies to all information we collect through our services ("Services"), which includes, but is not limited to, our websites, mobile applications, software-as-a-service (SaaS) platforms, and any other online products or services that link to this Policy. This document constitutes a legally binding agreement between you and Netsocs.

B. Consent

By accessing, registering for, or otherwise using our Services, you consent to our Privacy Policy and agree to its terms and conditions. If you do not agree with the terms of this Policy, you should not use our Services.

C. Key Definitions

To ensure clarity and legal precision, the following terms shall have the meanings specified below:

• Personal Data: Refers to any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This broad definition includes obvious identifiers like name, email address, and phone number, as well as indirect identifiers such as Internet Protocol (IP) addresses, device identifiers, browsing history, purchase records, geolocation data, biometric information, and any inferences drawn from other personal data to create a profile about a consumer.
• Sensitive Personal Data: A subcategory of Personal Data that includes, but is not limited to, social security numbers, driver's licenses, passport numbers; financial account credentials; precise geolocation; racial or ethnic origin, religious or philosophical beliefs; the contents of private communications; genetic data; biometric data processed for the purpose of uniquely identifying a consumer; and information concerning a consumer's health or sex life. This category of data is subject to stricter protection and consent requirements.
• Processing: Any operation or set of operations which is performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• Controller and Processor: For the purposes of this Policy, Netsocs acts as a "Controller" for the Personal Data we collect directly from users for our own purposes (e.g., account management, billing). However, when our business customers use our Services to process data about their own end-users ("Customer Data"), the customer is the "Controller" and Netsocs acts as a "Processor" on their behalf. In such cases, the processing of Customer Data is governed by the data processing agreement with our customer and their privacy policy. Any data subject requests related to Customer Data should be directed to the relevant customer. This distinction is critical for delineating legal responsibilities.

II. Information We Collect and Data Sources

Transparency is a cornerstone of our privacy strategy. The following summarizes our data collection, use, and disclosure practices over the past 12 months, in compliance with laws such as the California Consumer Privacy Act (CCPA), as amended.

A. Information You Provide to Us Directly

We collect Personal Data that you voluntarily provide to us when you interact with our Services.

• Account and Registration Information: When you create an account, we collect information such as your name, company name, email address, phone number, job title, and password.
• Payment and Billing Information: For paid Services, we collect billing information, such as billing address and payment method details. Importantly, we do not store full credit card numbers on our servers. We use secure, PCI-DSS compliant third-party payment processors (e.g., Stripe, PayPal) to handle all payment transactions. Your payment information is provided directly to these third parties, and its use is governed by their respective privacy policies.
• Communications with Us: If you contact us for customer support, participate in a survey, or otherwise interact with us, we will collect the content of your communications, including any attachments and any other information you choose to provide.
• User-Generated Content: We collect the information and content that you upload, create, or transmit through our Services. You are solely responsible for the nature and sensitivity of the data you choose to upload. Our obligations regarding such content are outlined in our Terms of Service.

B. Information Collected Automatically

When you use our Services, we automatically collect certain information through various technologies.

• Usage Data and Log Files: Like most online services, our servers automatically record information when you access our Services. This log data may include your IP address, browser type, operating system, device information, referring/exit pages, date/time stamps, and clickstream data.
• Cookies and Tracking Technologies: We use cookies, web beacons, pixels, and similar technologies to operate and administer our Services, gather usage data, and for advertising purposes. These technologies help us recognize you, remember your preferences, and personalize your experience. We comply with legal requirements in applicable jurisdictions by recognizing Global Privacy Control (GPC) signals as a valid request to opt out of the "sale" or "sharing" of your personal information for targeted advertising.

C. Information We Obtain from Third-Party Sources

We may receive Personal Data about you from other sources.

• Partners and Third-Party Services: We may obtain information from our business partners, third-party marketing lists, and services that integrate with our platform.
• Publicly Available Sources: We may collect information from publicly accessible sources, such as social media profiles, company websites, and other public databases, to supplement the information we hold about you.

III. How and Why We Use Your Information

We use the Personal Data we collect for legitimate business purposes, which are described below. Our use of information adheres to the principle of "purpose limitation," meaning we only process data for the specific, explicit, and legitimate purposes communicated to the user.

• To Provide and Maintain the Services: To create and manage your account, process your transactions, provide customer support, authenticate users, and ensure the technical functioning of the Services.
• To Improve, Personalize, and Develop the Services: To analyze how users interact with our Services, identify usage trends, customize content and user experience, and develop new features, products, and functionality.
• To Communicate with You: To send you important administrative communications, such as updates to our terms, policies, or services, security alerts, and support messages. We may also communicate with you for marketing purposes, subject to your opt-out preferences.
• For Marketing and Advertising: To market our Services, which may include showing you targeted ads on third-party websites. This use is directly tied to your right to opt out of the "sale" or "sharing" of your information, as described further below.
• For Security and Fraud Prevention: To protect the security and integrity of our Services, systems, and users; to detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
• To Comply with Legal Obligations and Protect Our Rights: To comply with applicable laws, regulations, legal processes, or governmental requests; to enforce our Terms of Service and other agreements; to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and to allow us to pursue available remedies or limit the damages that we may sustain.
• With Your Consent: For any other purpose for which we obtain your explicit consent.

IV. Disclosure and Sharing of Information

We do not sell Personal Data in the traditional sense of the word (i.e., for monetary consideration). However, some privacy laws define "sale" or "sharing" more broadly to include the exchange of information for targeted advertising. The circumstances under which we may share your information are described below.

A. Service Providers

We share information with third-party service providers who perform services on our behalf, such as cloud hosting, payment processing, data analytics, email marketing services, and customer support. These providers are contractually obligated to maintain the confidentiality of your information and are prohibited from using it for any purpose other than providing services to Netsocs.

B. Affiliates and Subsidiaries

We may share information within our corporate family of companies for purposes consistent with this Privacy Policy.

C. Business Partners

We may share information with trusted business partners to offer integrated products or services or for co-marketing efforts, provided you have consented to this.

D. Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will make reasonable efforts to notify you of any change of control that affects your Personal Data.

E. Legal Requirements and Law Enforcement

We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to: (a) comply with a legal obligation; (b) protect and defend the rights or property of Netsocs; (c) act in urgent circumstances to protect the personal safety of users of the Services or the public; or (d) protect against legal liability.

F. With Your Consent

We may share your information with any other third party when we have your explicit consent to do so.

V. Data Security and Retention

A. Security Measures

We have implemented and maintain "reasonable" administrative, technical, and physical security measures designed to protect the Personal Data under our control from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. These measures include, but are not limited to, encryption of data in transit and at rest, strict access controls, and regular security audits.

B. Data Retention

We retain Personal Data for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of our relationship with you and the provision of the Services.
• The existence of a legal obligation to which we are subject (e.g., tax and accounting laws).
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation, or regulatory investigations).

VI. Your Privacy Rights and Choices

A. General Choices

• Accessing and Updating Account Information: You can review and update your account information by logging into your account and visiting the settings page.
• Opting Out of Marketing Communications: You may opt out of receiving our marketing email communications at any time by clicking the "unsubscribe" link found at the bottom of every email, in accordance with the CAN-SPAM Act. Please note that you will still receive transactional or administrative emails related to your account and our Services.
• Managing Cookies: You can manage your cookie preferences through our cookie consent banner and your browser settings.

B. Notice for Residents of Specific U.S. Jurisdictions

The data privacy landscape in the United States is a patchwork of evolving state laws. To simplify compliance and offer a high standard of protection to all our U.S. users, we have chosen to adopt the stricter standards, such as those set by the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), and extend these rights to our users nationwide where feasible. This proactive approach shields us from regulatory complexity and demonstrates our commitment to user privacy.

If you are a resident of a U.S. state with a comprehensive privacy law (such as California, Colorado, Virginia, etc.), you may have the following rights regarding your Personal Data:

• Right to Know: The right to request that we disclose the categories and specific pieces of Personal Data we have collected about you, the categories of sources from which it was collected, the business purpose for collecting, selling, or sharing the information, and the categories of third parties with whom we share it.
• Right to Delete: The right to request the deletion of Personal Data that we have collected from you, subject to certain exceptions (e.g., where the information is necessary to complete a transaction, comply with a legal obligation, or for internal purposes compatible with your expectations).
• Right to Correct: The right to request the correction of any inaccurate Personal Data we maintain about you.
• Right to Opt-Out of Sale or Sharing: The right to direct us not to "sell" or "share" your Personal Data with third parties for cross-context behavioral advertising. Additionally, we recognize Global Privacy Control (GPC) signals as a valid opt-out request.
• Right to Limit Use of Sensitive Personal Information: The right to direct us to limit our use and disclosure of your Sensitive Personal Data to that which is strictly necessary to perform the Services or provide the goods reasonably expected by an average consumer.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights, including by denying you goods or services, charging you different prices or rates, or providing you a different level or quality of goods or services.

How to Exercise Your Rights

To exercise the rights described above, please submit a verifiable consumer request to us through one of the following methods:

• Email at: info@netsocs.com

Only you, or a person registered with the applicable Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. We will describe our verification process when we receive your request, which may require you to provide information to confirm your identity.

VII. Additional Important Policies

A. Children's Privacy

Our Services are not directed to children under the age of 13 (or 16 in certain jurisdictions), and we do not knowingly collect Personal Data from children in violation of the Children's Online Privacy Protection Act (COPPA). If you become aware that a child has provided us with Personal Data without parental consent, please contact us at info@netsocs.com, and we will take steps to remove such information.

B. International Data Transfers

Netsocs is based in the United States. If you use our Services from outside the United States, your information will be transferred to, stored, and processed in the United States. Data protection laws in the United States may be different from those in your country. When we transfer Personal Data outside of certain jurisdictions (such as the European Economic Area), we rely on legally-valid data transfer mechanisms, such as Standard Contractual Clauses (SCCs), to ensure your information is adequately protected.

C. Links to Third-Party Sites

Our Services may contain links to third-party websites or services that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

D. "Do Not Track" Signals

Some web browsers may transmit "Do Not Track" (DNT) signals. Due to the lack of an adopted industry standard for DNT, we do not currently respond to DNT signals. However, as detailed above, we do honor Global Privacy Control (GPC) signals as a valid opt-out mechanism under applicable state privacy laws.

VIII. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Policy, we will notify you by posting the updated policy on our Services and updating the "Last Updated" date. We may also provide notice to you by email or through other communications within the Services. Your continued use of our Services after the revised policy has become effective indicates that you have read, understood, and agreed to the terms of the revised policy.

IX. Contact Information

If you have any questions, comments, or concerns about this Privacy Policy or our data practices, or if you wish to exercise your privacy rights, please contact us using the information below: