GaggleAMP

Privacy Policy

Effective as of: October 18, 2019

The following Privacy Policy governs your use of the GaggleAMP.com website and all content, services and products available at or through the website (\"Website\") by the user (\"user\" \"you\" \"your\" "Gaggle Member"). The Website is owned and operated by GaggleAMP Inc. (\"GaggleAMP\" \"we\" \"us\" \"our\"). This Privacy Policy may be updated from time to time for any reason. GaggleAMP sends an email notice to user(s) whenever updates to this policy are made. It is the responsibility of all users of GaggleAMP.com, however, to revisit this page to check for changes. Please read this Privacy Policy carefully before accessing or using the Website. By accessing or using any part of the Website, you agree to become bound by the terms and conditions of this Agreement. If you do not agree to this Privacy Policy, then you may not access the Website or use any services.

By using GaggleAMP.com you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing" means using cookies on a computer or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining, and disclosing information, all of which activities will take place in the United States. If you reside outside the U.S., your personally identifiable information will be transferred to the U.S., and processed and stored there under U.S. privacy standards. By visiting our Website and providing information to us, you consent to such transfer to, and processing in, the U.S. If you are a citizen of the European Economic Area, the United Kingdom, or Switzerland, please refer to our GDPR & Privacy Shield Statement.

GaggleAMP complies with the EU-US Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries, the United Kingdom, and Switzerland. GaggleAMP has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

The Federal Trade Commission (FTC) has jurisdiction over GaggleAMP's compliance with the Privacy Shield.

GaggleAMP has designated the Chief Technology Officer to oversee its information security policies and procedures, including its compliance with the EU and Swiss Privacy Shield program. The Chief Technology Officer shall review and approve any material changes to this policy as necessary. Any questions, concerns, or comments regarding this Privacy Policy or our use of your personally identifiable information, please contact us at privacy\@gaggleamp.com.

Information Collection and Use

Information Collected Upon Registration and Adding Social Media Accounts.

GaggleAMP may collect information about you, when you interact with the Website, including, your IP address, name, email address, location, time zone, billing information if you are a Gaggle Operator (as defined in the GaggleAMP terms and conditions, social media usernames, Log Data, and other data as specifically described herein.

You may provide us with this personal information when you:

  1. Create an account as a Gaggle Operator

  2. Register as a Gaggle Member

  3. Sign up for newsletters, email alerts, and special offers

  4. Submit a job application or inquiry;

  5. Submit information through any contact form on the Website;

  6. Request customer support or send GaggleAMP any other communication;

  7. Enter sweepstakes or contests;

  8. Sign up for, or redeem, special offers;

  9. Respond to surveys;

  10. Participate in any GaggleAMP referral, rewards or promotional programs;

  11. Make use of GaggleAMP's Social Media Widget features; and/or

  12. Participate in communications within a Gaggle.

If you send information through our contact forms, customer service, and/or chat functions on the Website. You will be asked to provide, your name and email. In communicating with us, You will also have an opportunity to share additional information with GaggleAMP, in your sole discretion, which may include personal information. This information is seen only by GaggleAMP and is not publicly available. Use discretion when sharing information through chat functions, emails, and contact forms.

You have the right to obtain our confirmation of whether we maintain personal information relating to you. You may access, review, update, erase, or block any information in your account dashboard on the Website, as permitted by applicable law and GaggleAMP policies. Deletion or removal of certain information may prohibit you from utilizing the Website or GaggleAMP services.

Use of Information.

GaggleAMP uses the information you provide to:

  1. Provide the features and functionality of the Website and to improve GaggleAMP's products and services;

  2. For GaggleAMP's internal business purposes, including, but not limited to data analysis, and audits;

  3. Provide paid for services to Gaggle Operators; and/or

  4. Contact you concerning your account activity.

GaggleAMP uses non-personally identifiable information to monitor the use and performance of the Website so that GaggleAMP can learn more about how people use the Website which helps us improve GaggleAMP's services and significantly enhance your experience on the GaggleAMP Website.

In addition to providing you services, we may use your contact information to market to you, and provide you with information about, our products and services, including but not limited to services on GaggleAMP.com. If you decide at any time that you no longer wish to receive such information or communications from us, please follow the unsubscribe instructions provided in any of the communications or in your Manager or Member dashboard.

Log Data.

When you visit the Website, our servers automatically record information that your browser sends whenever you visit a website ("Log Data"). This Log Data may include information such as your IP address, browser type or the domain from which you are visiting, the messages you share, the messages you decline, and any reward communication made with the Gaggle Manager. For most users accessing the Internet from an Internet service provider, your IP address will be different every time you log on. We use Log Data to monitor the use of the Website and of our Service, and for the Website's technical administration. We do not associate your IP address with any other personally identifiable information to identify you personally, except as required to enforce this Privacy Policy and the Terms of Use for the Website, or as necessary to protect the rights, property, or safety of GaggleAMP, its employees, customers, or other users.

Aggregate Information Accessible by Gaggle Manager.

Certain information is used in the aggregate to provide analytics to the Gaggle Manager. This information is not tied to you personally, but may contain demographic information about the Members of the Gaggle in part or as a whole. This aggregated information is also made available outside the Gaggle in order to provide overall Website demographic information. This aggregate and non-personally identifiable information may be used by GaggleAMP and shared with or sold to third-parties.

Personal Information Accessible by Gaggle Manager.

By becoming a GaggleAMP Member, you authorize your personal information in the form of your name, username, friend and follower count (where applicable, but not social media registration credentials or other personal information) and contact information (in the form of your email address) to be made available to the Gaggle Manager in part to facilitate Reward delivery and communication. Additional information generated through the use of this Site including shared content click rates and social engagements such as number of likes, comments etc. may be exposed to the Gaggle Manager to assist in marketing analytics and reports.

Member-Level Tracking Functionality

GaggleAMP offers Member-Level tracking functionality on a per Gaggle basis. This functionality is optional and at the election of the Gaggle Operator. If the Gaggle Operator for your Gaggle has Member-Level tracking functionality enabled, then the Gaggle Operator and Gaggle Manager will have access to additional information about your use of the Website as described below.

Through this functionality, Gaggle Member activity may be tracked in three ways: (1) via Custom UTM parameters, (2) via Member-level detailed activity reports, or (3) via Gaggle Member Message customizations reports.

When a Gaggle has Custom UTM tracking enabled, each social media post shared by a Gaggle Member through the Website has a unique identifier in the applicable URL. That identifier can be used to track how many third parties clicked on a link contained within the individual Gaggle Member’s social media posts. This functionality allows the Gaggle Operator/Gaggle Manager to see how clicks are distributed among the Gaggle Members.

When a Gaggle has Gaggle Member-level detailed activity reports enabled, the Gaggle Manager can access additional activity data for each Gaggle Member, that includes the URL to a Gaggle Member’s shared post (publicly available post on the third party social media platform), and the number of likes, comments, and/or clicks generated by that Gaggle Member’s shared post. The information contained in the Member-level detailed activity reports is limited to what is permissible by the applicable third-party social media platforms restrictions and policies.

When a Gaggle has Gaggle Member Message customization reports enabled, the Gaggle Manager will be able to see if a Gaggle Member changed the content of any shared post and what those changes were. Some Gaggle Operators, such as publicly traded companies or companies within certain industries, are required to track this information to fulfill their legal compliance obligations.

Personal Information Accessible by Third Parties.

GaggleAMP allows you to post and share content within your Gaggle. That Gaggle Member generated content can be seen by the Gaggle Manager and all other Gaggle Members. Gaggle Members may comment on and interact with such content within the Gaggle. The Gaggle Manager may utilize such content for the Gaggle Operator's purposes, including sharing such content publicly. If the content you contribute contains personal information, that information may be shared publicly. Use discretion when sharing content within your Gaggle.

Cookies.

GaggleAMP uses cookies on the Website to improve the quality of the Website and services to you. A cookie is a string of information that a website stores on a user's computer and the user's browser provides to the website each time the user returns. GaggleAMP uses cookies to help GaggleAMP identify and track users, their usage of the GaggleAMP Website, and their website access preferences. Cookies do not collect or store personally identifiable information. Rather, the cookie stores a token which uniquely identifies a particular user at a particular time. That token is then linked to the user information in GaggleAMP's secured databases. GaggleAMP visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using GaggleAMP's Website, with the drawback that certain features of GaggleAMP's Website may not be available to you or may not function properly without the aid of cookies. Do Not Track:

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. GaggleAMP does not recognize or respond to browser-initiated DNT signals, as the Internet industry is currently still working toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT.

GaggleAMP is committed to providing you with meaningful choices about the information collected on the GaggleAMP Website for third party purposes, and that is why GaggleAMP provides the opt-out links below.

These links lead to third party sites and may not always be functionaly and further, may not represent all opt-out options available or third parties collecting information via the Website.

• To opt-out of the double click and other Google advertising cookies, please visit the Google advertising opt-out page. • To opt-out of analysis via the Google Analytics cookie, please visit the Google Analytics opt-out page.

Your California Privacy Rights: 

If you live in California and have an established business relationship with us, you can request a list of the personal information we have shared with third parties for their marketing purposes. We will also give you a list of the third parties that have received your information. You can make a request one time each year. To exercise your rights, you can email us or write to us at the address below. Mention in your letter that you are making a \"California Shine the Light\" inquiry. We will respond within 30 days.

You may also request that we provide you with an accounting of your personal information held by GaggleAMP. You may submit that request to via email at privacy@gaggleamp.com, or toll free at (888) 677-4528. Upon verification of your identity and within 45 days, we will provide you with a paper copy of your personal information via the United States Postal Service.

Information Sharing and Disclosure.

Service Providers. We engage certain trusted third parties to perform functions and provide services to us, including, without limitation, hosting and maintenance, customer relationship, database storage and management, and direct marketing campaigns. We will share your personally identifiable information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data, by (i) agreeing to provide adequate protections for personally identifiable information that are no less protective than those set out in this Privacy Policy; and (ii) notifying GaggleAMP in the event that such third party is no longer able to provide sufficient protections.

The Service Providers engaged by GaggleAMP, and links to their individual privacy policies, are listed at: https://accounts.gaggleamp.com/subprocessors and may be updated from time to time.

If we ever were to engage in any onward transfers of your data with third parties for a purpose other than which it was originally collected or subsequently authorized, we would provide you with an opt-out choice to limit the use and disclosure of your personal data.

Pursuant to the Privacy Shield, GaggleAMP remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.

GaggleAMP also may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements. In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield or Swiss individuals received pursuant to the Swiss-US Privacy Shield, GaggleAMP is potentially liable.

Business Transfers.

GaggleAMP may sell, transfer or otherwise share some or all of its assets, including your personally identifiable information, in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy. You will be provided with notice in the event of such sale or transfer and have the opportunity to opt out of any such transfer.

Security.

GaggleAMP believes in the privacy of our website users. We safeguard the confidentiality of your personally identifiable information. We employ administrative, physical, and electronic measures designed to protect your information from unauthorized access. We will make any legally-required disclosures of any breach of security, confidentiality, or integrity of your unencrypted electronically-stored personal data to you via email or conspicuous posting on this Website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of government authorities, including to meet national security or law enforcement requirements or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Payment.

Our shopping cart is powered by Recurly Inc. based in San Francisco, CA. The company\'s ecommerce platform is PCI-compliant, adhering to standards and protocols for building and maintaining secure networks for financial transactions. For more information on Recurly\'s security policies click here and for Recurly's privacy policies click here. We use PayPal Pro as our merchant gateway to process credit card transactions. You do not need your own Paypal account to purchase from our online store. Through Paypal we accept Mastercard, Visa, American Express, and Discover. Located in San Jose, California, Paypal was founded in 1998 and acquired by eBay in 2002. PayPal has its own privacy policy regarding how they collect and use your information and what you can do to restrict that. Review their privacy statement here. GaggleAMP also uses Stripe as a merchant gateway to process credit card transactions. Stripe Inc. is based in San Francisco, CA.  Stripe's ecommerce platform is PCI compliant adhering to standards and protocols for building and maintaining secure networks for financial transactions.  For more information on Stripe's security policies click here. Through Stripe, you can use Mastercard, Visa, American Express and Discover.  Stripe has its own privacy policy regarding how they collect and use your information and what you can do to restrict that. Click here to review their privacy statement.

Links to Other Websites.

GaggleAMP.com and messages posted in any Gaggle may contain links or references to other websites. GaggleAMP.com cannot control and cannot be held responsible for the content that appears on those sites, and is not an endorsement, authorization, or representation of our affiliation with that third party. Furthermore, GaggleAMP is not responsible for the privacy policies of any third-party site or for how they treat information about their users. These third-party sites may place their own cookies on your computer, collect data, or solicit personal information. You may be consenting to those websites through use of ours. We encourage you to read the privacy policies or statements and terms of service for each of the other websites you visit.

How does GaggleAMP secure and store your information?

The security of your personal information is important to us. GaggleAMP uses an SSL Protocol to secure the Website. GaggleAMP employs industry standard precautions designed to protect your information from unauthorized access. GaggleAMP will make any legally-required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored personal data to you via email or conspicuous posting on this Website in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.  GaggleAMP cannot promise, and you should not expect, that your personal information or private communications will always remain private. GaggleAMP cannot guarantee complete security.

GaggleAMP currently stores user information via secure cloud-based web hosting services, provided by Amazon Web Hosting, and the information is stored on servers located within the United States.

Remember that no method of transmission over the internet or method of electronic storage is 100% secure. GaggleAMP cannot promise, and you should not expect, that your personal information or private communications will always remain private. GaggleAMP cannot guarantee complete security.

Retention of Data

GaggleAMP retains personal information when we have an ongoing legitimate business, legal, or compliance need to do so. Our retention periods will vary depending on the type of personal information. The general factors we consider in determining whether to retain personal information are:

• Whether we have a legal or contractual need to retain the information • Whether the information is necessary to provide our services or for functionality of Website features • Whether our Gaggle Operators, Managers, and/or account holding users have the ability to access and delete the information from their accounts

When GaggleAMP has no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, when personal information has been stored in backup archives), then GaggleAMP will securely store such personal information until deletion of such information is possible.

Disconnecting your Account from Third Party Websites

You will be able to connect your GaggleAMP account to third party accounts. BY CONNECTING YOUR GAGGLEAMP ACCOUNT TO YOUR THIRD-PARTY ACCOUNT, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE CONSENTING TO THE CONTINUOUS RELEASE OF INFORMATION ABOUT YOU TO SUCH THIRD PARTIES (IN ACCORDANCE WITH YOUR PRIVACY SETTINGS ON THOSE THIRD-PARTY SITES). IF YOU DO NOT WANT INFORMATION ABOUT YOU, INCLUDING PERSONALLY IDENTIFYING INFORMATION, TO BE SHARED IN THIS MANNER, DO NOT USE FEATURES UTILIZING CONNECTIONS WITH THIRD PARTY ACCOUNTS.Please be aware that the GaggleAMP Website, features, and functionality requires connections to third-party accounts.

Our Policy Towards Children.

The Website is not directed to persons under 18. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at privacy\@gaggleamp.com. We will take actions to promptly remove such data. We do not knowingly collect personally identifiable information from children under 18. If we become aware that a child under 18 has provided us with personally identifiable Information, we will delete such information from our files.

Disputes concerning this Privacy Policy.

In compliance with the EU-US Privacy Shield Principles, GaggleAMP commits to resolve complaints about your privacy and our collection or use of your personal information. European Union, United Kingdom, and/or Swiss individuals with inquiries or complaints regarding this privacy policy should first contact GaggleAMP at:

GaggleAMP, Inc. Attn: Chief Technology Officer 22 McGrath Highway, Suite 204 Somerville, MA 02143 euprivacy@gaggleamp.com

GaggleAMP has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

In addition to the above dispute resolution mechanisms, users may invoke binding arbitration if their complaint is not resolved by the BBB or by the Department of Commerce after referral from the relevant data protection authority in the EEA. For more information about binding arbitration, visit https://www.privacyshield.gov.

How can I change, delete, or update my information?

Most of your account information can be changed in your account dasboard on the Website. If you have any questions about what information is stored or would like to obtain a copy of such information, please contact us at privacy@gaggleamp or Privacy c/o GaggleAMP, 22 McGrath Highway, Suite 204, Somerville, MA 02143. After receiving proof of your identity, GaggleAMP will provide the information to you, and you may request that GaggleAMP delete or change any or all of the information.

Unless stated otherwise, GaggleAMP’s current Privacy Policy applies to all information that GaggleAMP has about you and your account.