MACH9 LLC PRIVACY POLICY

MACH9 LCC. is a provider of social media management, social advocacy, social data analytics, and social listening software based in the United States. For more information about MACH9 LCC, please see the “About Us” section of our Website at https://mach9.com/about/

We collect information about visitors to our Site, our customers and their end users of the Service, job applicants, and end users of our customers’ social media/property pages. This information is collected from the following sources:


• Information collected directly from you this type of information varies based on your interaction with our Site and Service. For example, we collect information directly from you when you create an account with us, contact us about a problem through customer service, apply for a job, and fill out an application or other form on the Site and/or Service. We also collect information that you send to us through any means, including but not limited to your e-mail address and phone number. In addition, we collect information about you through social media interactions owned by third parties, such as your handle, username, profile, posts, and messages exchanged with our customers on social media.
• Information received from customers: we receive information from customers to provide our Service. Such information may include an end user’s handle, username, profile picture, biography, follower count, website URL, first and last name (if provided by the user), and posts or communications with our customers on social media. We collect information, such as contact information, from people employed by our customers to provide our Service.

We also collect information from other sources. Below are the categories of sources from which we collect information:

• Information brokers or resellers from whom we purchase data to verify and supplement the data we collect.
• Social networks when you interact with our content, browse our Site or Service, or authorize us to access information from social networks.
• Partners who offer co-branding services, sell or distribute our products, or engage in collaborative marketing activities.
• Customers who provide us with information that we process as a service provider.

MACH9 LCC processes information for business purposes in accordance with the practices described in this Privacy Policy. Our business purposes for collecting and using information, include the following:

• Manage and improve the Site and the Service
• To provide users or customers with the Service and other products and services that may be requested or in which interest has been expressed;
• Facilitate the processing, verification and analysis of subscriptions;
• Assess user interest and needs in order to improve the Service and make other offers, products or services available;
• Evaluate the types of offers, products or services we make available to existing or potential users or customers;
• Monitor the use of the Service, including for purposes of troubleshooting and product improvement;
• Providing customer service;
• Communicate and provide additional information of potential interest to users through e-mail or other means, such as special offers, announcements, and marketing materials;
• Combine data sets to create aggregate data for internal evaluations and analysis;
• Send the user reminders, technical alerts, updates, product announcements, security alerts, administrative and support messages, service bulletins, or promotional materials;
• Sending the user advertising materials by e-mail
• If necessary, consider your application for open job positions, process your work experience and education, resume, writing samples, and references;
• Manage our day-to-day business needs, such as Site and/or Service administration, forum management, compliance, analysis, fraud prevention, enforcement of corporate statement obligations, legal terms, and any other contractual agreements regarding our Service or compliance with the law;
• Fulfilling any other business purpose at your direction or with your notice and/or consent.

We share the information we collect in accordance with the practices described in this Privacy Policy. Below are the categories of recipients:

• Our affiliates, service providers, and partners who provide data processing services to us (for example, to support delivery, offer functionality, or help improve the security of our Site or Service), or who otherwise process information for purposes described in this Privacy Policy or for which we will give notice to you at the time of information collection. We share information with our affiliates for commercial purposes. We contractually prohibit our service providers from retaining, using, or disclosing information about you for purposes other than performing services for us, however we may allow them to use information that does not identify you (including aggregated or anonymized information) for any other purpose, except as prohibited by applicable law.
• Customers (including information about end users and internal customer personnel) to provide effective social advocacy services, social data analysis, social listening services, and customer relationship and social media management. For example, we share information with our customers in order to facilitate their orders, manage and administer their online accounts, respond to questions and comments, fulfill their requests, advertise and publish user listings, and comply with our contractual obligations and applicable law;
• Local information technology resellers in countries where permitted by applicable law. We may provide the contact information of customers or potential customers to these resellers to market our Service.
• To any law enforcement agency, regulatory authority, governmental authority, court, or other third party in cases where we believe disclosure is necessary (i) in connection with applicable laws, judicial orders, or regulations, (ii) to exercise, establish, or defend our legal rights, or (iii) to protect the vital interests of you or any other person;
• Prospective purchasers (and their agents, investors and/or advisors) in connection with any proposed or actual purchase, merger or acquisition of any part of our business. We will be responsible for informing the buyer that they should use your information only for the purposes stated in this Privacy Policy;
• Suppliers for commercial purposes, including analytics and advertising technology companies. Providers may act as our service providers or, in certain contexts, decide for themselves how to process user information;
• Any other person after notifying the user and receiving consent for disclosure;
• When you make information public through the Site or Service, such as profile information, posts, and comments on public bulletin boards, including through social media, your information is publicly visible. You are advised to think carefully before making information public, as you are solely responsible for such information. Once information is published, you may not be able to edit or delete it, remaining subject to the additional rights set forth in the “Data Protection Rights” section below;
• When you request or contact us to share information, such as when you choose to share information regarding activities on the Service through a third party social network or platform. This may require your acceptance of the terms of use or privacy policy of such third parties.

We retain information we collect from you if there is a legitimate business need to do so (such as to provide a service you have requested or to comply with applicable legal, tax, or accounting requirements)..

For visitors and users from the European Economic Area, our legal basis for collecting and using the personal data described above will depend on the personal data involved and the specific context in which it was collected. However, we usually collect personal data from you only if we have consent to do so, when we need the personal data to enter into a contract with you, or if the processing is in our legitimate interest and does not override your data protection interests or your fundamental rights and freedoms. In some cases we may also have a legal obligation to collect personal data from you. For any questions or further information about the legal basis on which we collect and use your personal information, please contact us using the contact information provided in the “How to Contact Us” section above.

We offer parts of our Service through websites, platforms, and services managed or controlled by separate entities. We also integrate technologies managed or controlled by separate entities into parts of our Site and Service. Following are some examples:

• Our affiliates, service providers, and partners who provide data processing services to us (for example, to support delivery, offer functionality, or help improve the security of our Site or Service), or who otherwise process information for purposes described in this Privacy Policy or for which we will give notice to you at the time of information collection. We share information with our affiliates for commercial purposes. We contractually prohibit our service providers from retaining, using, or disclosing information about you for purposes other than performing services for us, however we may allow them to use information that does not identify you (including aggregated or anonymized information) for any other purpose, except as prohibited by applicable law.
• Customers (including information about end users and internal customer personnel) to provide effective social advocacy services, social data analysis, social listening services, and customer relationship and social media management. For example, we share information with our customers in order to facilitate their orders, manage and administer their online accounts, respond to questions and comments, fulfill their requests, advertise and publish user listings, and comply with our contractual obligations and applicable law;
• Local information technology resellers in countries where permitted by applicable law. We may provide the contact information of customers or potential customers to these resellers to market our Service.
• To any law enforcement agency, regulatory authority, governmental authority, court, or other third party in cases where we believe disclosure is necessary (i) in connection with applicable laws, judicial orders, or regulations, (ii) to exercise, establish, or defend our legal rights, or (iii) to protect the vital interests of you or any other person;
• Prospective purchasers (and their agents, investors and/or advisors) in connection with any proposed or actual purchase, merger or acquisition of any part of our business. We will be responsible for informing the buyer that they should use your information only for the purposes stated in this Privacy Policy;
• Suppliers for commercial purposes, including analytics and advertising technology companies. Providers may act as our service providers or, in certain contexts, decide for themselves how to process user information;
• Any other person after notifying the user and receiving consent for disclosure;
• When you make information public through the Site or Service, such as profile information, posts, and comments on public bulletin boards, including through social media, your information is publicly visible. You are advised to think carefully before making information public, as you are solely responsible for such information. Once information is published, you may not be able to edit or delete it, remaining subject to the additional rights set forth in the “Data Protection Rights” section below;
• When you request or contact us to share information, such as when you choose to share information regarding activities on the Service through a third party social network or platform. This may require your acceptance of the terms of use or privacy policy of such third parties.

Please note that when you interact with other entities, including outside of our Site or Service, those entities may independently collect and solicit information about you. The information collected and stored by such entities remains subject to their disclosures, terms and practices, including the information they share with us, your rights and choices about their services and devices, and the location of information storage in the United States or elsewhere. We encourage you to become familiar with and review their privacy policies and terms of use.

Information may be transferred to and processed in countries other than your country of residence. For example, if you are a resident of a European Economic Area (EEA) country, your personal information may be transferred to the United States for processing. These countries may have different data protection laws than your country. Specifically, our servers are located in the United States and group companies and third-party service providers operate around the world. This means that when we collect information we may process it in one of these countries. However, we have taken appropriate safeguards to ensure that your information remains protected in accordance with this Privacy Policy and applicable legal requirements. If information is transferred to and processed in countries for which the EU Commission has pronounced an adequacy assessment (such as for the U.S.), the substantial equivalence of regulatory systems and the Commission’s judgment provide a solid basis for assurance that Holders supplement with instructions and specific technical and organizational measures on a case-by-case basis. If the information is transferred and processed outside the European Union in countries that have not received an adequacy assessment from the EU Commission, the processing will be regulated by the Controller in accordance with the provisions of Chapter V of the GDPR Regulation. Therefore, all necessary precautions will be taken in order to ensure adequate protection of personal data as possible by basing such transfer: a) on adequate guarantees expressed by the third-party recipient in accordance with Article 46 of the Regulation; b) on the adoption of standard contractual clauses or ad hoc contractual clauses, c) on the adoption of binding corporate rules, so called “Corporate binding rules“.

The GDPR allows you to exercise a number of rights, here are in brief what they are and what they are for:

• Right of access-allows people to request information about what personal data is being processed by the data controller and to obtain access to it;
• Right of rectification – allows you to request correction and updating of inaccurate data and to be notified of rectification;
• Right of deletion – under certain conditions, allows you to request the permanent deletion of your personal data, with the right to notice of the deletion;
• Right to restriction – under certain conditions, allows you to ask the owner to restrict the processing of your personal data, with the right to notice of restriction;
• Right to object – allows you to object at any time to the processing of your Data carried out on the basis of a legitimate interest, unless there are legitimate reasons to proceed with the processing that override those of the data subject, for example, for the exercise or defense in court;
• Right to portability-allows you to ask the data controller who processes your data by electronic means-on the basis of your consent or for the performance of contractual obligations-to obtain the data in digital format and, if necessary, to transmit it to another data controller indicated by you.

In case you would like to learn more, all the rights provided are listed and (legally) described in Articles 15 to 22 GDPR. You can send us inquiries regarding your rights to the contact details listed in the “How to contact us?” section.

Despite our focus on Data Protection, it is still possible that you may feel that your rights have been violated or that the way we treat your Data seems contrary to or inconsistent with regulations. In such cases, if you want you can make a complaint or report to the national authority in your country of residence that oversees compliance. In any case, you can always contact us before going to the authorities for clarification and to confront us with your requests.