Privacy Statement

Thanks for entrusting Submit Social, LLC (“Submit,” “we,” “us” or “our”) with your personal data. This Privacy Statement explains our practices regarding the collection, use, and disclosure of your data, including any personal data we collect and process in connection with our website and any applications, software, products, and services provided by Submit, including any Beta Previews (collectively “Service”).

All capitalized terms have their definition in Submit’s Terms of Service, unless otherwise noted here.

The shortest version

Privacy is a foundational element of our Service. We do not sell or share your data with third parties.

The shorter version

We use your personal information as this Privacy Statement describes. No matter where you are, where you live, or what your citizenship is, you have the same high standard of privacy protection when using Submit’s products as all our users around the world, regardless of their country of origin or location.

Summary

1. Who is responsible for the processing of your information - Submit is the controller and entity responsible for the processing of your personal data in connection with the Website or Service.

2. What information Submit collects - Submit collects information directly from you for your registration, payment, transactions, and user profile. We also automatically collect from you your usage information, device information, subject, where necessary, to your consent. We only collect the minimum amount of personal data necessary from you, unless you choose to provide more.

3. How Submit uses your information - In this section, we describe the ways in which we use your information, including to provide you the Service, to communicate with you, for security and compliance purposes, and to improve our Website or Service or develop new features and functionality of our Website or Service. We also describe the legal basis upon which we process your information, where legally required.

4. How we share the information we collect - We do not share your information with third parties. We do not sell your information.

5. Your choices regarding our processing of your personal data - We provide ways for you to access, alter, or delete your personal information.

6. Cookies - We only use strictly necessary cookies to provide, secure, and improve our Website or Service or develop new features and functionality of our Website or Service.

7. How Submit secures your information - We take all measures reasonably necessary to protect the confidentiality, integrity, and availability of your personal data on Submit and to protect the resilience of our servers.

8. Communication preferences - We communicate with you by email. You can control the way we contact you in your account settings, or by contacting us.

9. Resolving complaints - In the unlikely event that we are unable to resolve a privacy concern quickly and thoroughly, we provide a path of dispute resolution.

10. Changes to our Privacy Statement - We notify you of material changes to this Privacy Statement 30 days before any such changes become effective.

11. License - This Privacy Statement is licensed under the Creative Commons Zero license.

12. Contacting Submit - Please feel free to contact us if you have questions about our Privacy Statement.

Submit Privacy Statement

Who is responsible for the processing of your information?

The data controller of your personal data is Submit Social, LLC.

What information Submit collects

The personal data we collect depends on how you interact with us, the services you use, and the choices you make. We collect information about you from different sources and in various ways when you use our Service, including information you provide directly and information collected automatically.

Information users provide directly to Submit

We collect personal data you provide to us. For example:

Registration information
We collect information such as your username, email address, password, and date of birth during account creation.

Personal and demographic Information
In some cases, we provide you with the opportunity to provide your gender, sexual orientation, interests, and similar personal and demographic details. We collect any of this information that you choose to provide.

Payment and billing information
If you make a purchase or other financial transaction, we collect credit card numbers, financial account information, and other payment details.

Content and files
We collect any photographs, videos, or other files you upload to our Service; and if you send us email messages or other communications, we collect and retain those communications. For example, you may choose to give us more information for your Account profile, such as your location, an avatar which may include a photograph, your biography, and a URL to a third-party website. Please note that depending on how you configure your Account, your profile information may be visible to other Users of our Service.

Information Submit automatically collects

When you visit or use our Service, we collect some information automatically. For example:

Transaction information
If you have a paid Account with us, or make a purchase using our Service, depending on the payment method you use, we automatically collect certain information about your transactions on the Service, such as your full name, address, region, state, country, zip code, the date, time, and amount charged.

Usage information
If you’re accessing or using our Service, we may automatically collect information about how you use the Service, such as the pages you view, the referring site, your IP address and information about your device, session information, the date and time of each request, and telemetry data (i.e., information about how a specific feature or service is performing) regarding your use of other features and functionality of the Service.

Cookies
As further described below, we automatically collect information from cookies (such as cookie ID and settings) in connection with our Service.

Device information
We may collect information about your device, such as its IP address, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer.

Geolocation information
In connection with certain features and depending on the functionality of the Service, we collect geolocation information such as through IP addresses or the location information you choose to provide in your Account profile.

How Submit uses your information

We may use your information to provide, administer, analyze, manage, and operate our Service. For example, we use your information for the following purposes:

• Provide our products and deliver our services including troubleshooting, improving, and personalizing features on the Service.
• Business operations such as billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations.
• Improve and develop our products and services including to develop new services or features.
• Personalization of our Service by understanding you and your preferences to enhance your experience and enjoyment using our Service.
• Provide customer support and respond to your questions.
• Send you information, including confirmations, invoices, technical notices, updates, security alerts, support and administrative messages.

How we share the information we collect

We share personal data as described below, including with your consent or as necessary to complete your transactions or provide the services you have requested or authorized.

Public Information
You may select options available through our Service to publicly display and share your personal data, such as your profile, demographic data, content and files, or geolocation data. For example, if you would like your location to remain private, you can adjust your setting for your location to be private in your user profile.

Please note that we prohibit the collection of any User data through our Service, for any reason. Collecting, scraping or otherwise trying to source public data for any purpose through our Service will result in the immediate termination of the associated Account and legal consequences.

Third-party applications
We do not share your personal data with third parties.

Organizations with which you engage
You may indicate, through your actions on Submit, that you are willing to share your personal data. If you become a member of an Organization, then its Account owners may receive your personal data. When you accept an invitation to an Organization, you will be notified of the types of information owners may be able to see.

Service Providers
We share your personal data with service providers who process the information on our behalf to provide our Service. For example, our service providers may perform payment processing, customer support ticketing, network data transmission, and other similar services.

For security purposes
We will disclose personal data if we believe it is necessary to:

• protect our customers and others, for example to prevent abuse, exploitation, sexual abuse, prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
• operate and maintain the security of the Service, including to prevent or stop an attack on our systems or networks; or
• protect the rights or property of ourselves or others, including enforcing our agreements, terms, and policies.

For legal disclosure
Submit may disclose personal data or other information we collect about you to law enforcement or other governmental agencies if required in response to a valid legal process.

No selling of personal data
We do not sell your personal data for monetary or other consideration.

Your choices regarding our processing of your personal data

We provide choices about the personal data we collect about you.

Access, correction, and deletion. As a Submit user, you may access, update, alter, or delete your basic user profile information by editing your user profile. You can control the information we collect about you by limiting what information is in your profile.

We retain and use your information as described in this Privacy Statement, but barring legal requirements, we will delete your full profile within 7 days of your request.

You can adjust the settings on your Account regarding the display of your personal data or personal data processed in connection with Community Features (such as activity feeds, groups, followers, tasks, and training).

Additionally, if you are unable to access certain personal data we have via the means described above, you can request access by contacting us as described at the bottom of this privacy statement.

Data portability
As a Submit User, you can always take your data with you. You can use our Data Portability tools to download information we have about you.

Communication preferences
We use your email address to communicate with you, if you’ve said that’s okay, and only for the reasons that you’ve said that’s okay. For example, if you contact our Support team with a request, we respond to you via email. You have control over how your email address is used through our Service. You may manage your communication preferences in your communication settings.

Depending on your email settings, Submit may occasionally send notification emails, for example, about messages you receive, new features, requests for feedback, important policy changes, or to offer customer support. We may also send marketing emails, based on your choices and in accordance with applicable laws and regulations. There’s an “unsubscribe” link located at the bottom of each of the marketing emails we send you.

Please note that you cannot opt out of receiving important communications from us, such as emails from our Support team or system emails, but you can configure your notifications settings in your communication settings to opt out of other communications or control their frequency.

European Data Protection Rights

If the processing of personal data about you is subject to European Union data protection law, you have certain rights with respect to that data:

You can request access to, and rectification or erasure of, personal data; if any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format; If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing; You can object to, or obtain a restriction of, the processing of personal data under certain circumstances; and for residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests, please use the contact information at the bottom of this statement.

We rely on different lawful bases for collecting and processing personal data about you, for example, with your consent and/or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our sytems and our users, or fulfill other legitimate interests.

Our use of cookings and tracking technologies

Cookies and tracking technologies

Submit uses cookies to provide, secure and improve our Service or to develop new features and functionality of our Service. For example, we use them to (i) keep you signed in, (ii) remember your preferences, (iii) identify your device for security and fraud purposes, including as needed to maintain the integrity of our Service, (iv) compile statistical reports, and (v) provide information and insight for future development of Submit.

The length of time a cookie will stay on your browser or device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay until they expire or are deleted. The expiration time or retention period applicable to persistent cookies depends on the purpose of the cookie collection and tool used.

What are cookies and similar technologies?
We use cookies and similar technologies, such as local storage, and mobile analytics, to operate and provide our Services.

Cookies are small text files stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.

Mobile identifiers for analytics can be accessed and used by apps on mobile devices in much the same way that websites access and use cookies.

How do we use cookies and similar technologies?
The Submit Services use cookies and similar technologies for a variety of purposes, including to store your preferences and settings, enable you to sign-in, analyze how our Services perform, track your interaction with the Services, develop inferences, combat fraud, and fulfill other legitimate purposes.

The table below provides additional information about how we use different types of cookies:

Retention of personal data

We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requests, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because the needs can vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable user to delete data, and our legal or contractual obligations. For example, we may retain your personal data for longer periods, where necessary, subject to applicable law, for security purposes.

How Submit secures your information

Submit takes reasonable measures necessary to protect your personal data from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of your personal data. To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.

In addition, if your account has private content, you control the access to that Content. Submit personnel does not access private content except for

• security purposes,
• automated scanning for CSAM or other content known to violate our Terms of Service,
• to assist the content owner with a support matter,
• to maintain the integrity of the Service,
• to comply with our legal obligations if we have reason to believe the content is in violation of the law,
• or with your consent.

Submit will provide notice regarding private content access where not prohibited by law or if in response to a security threat or other risk to security.

Resolving complaints

If you have concerns about the way Submit is handling your personal data, please let us know immediately. We want to help. You may contact us by filling out the Privacy contact form. You may also email us directly at (privacy [at] submit [dot] gg) with the subject line “Privacy Concerns.” We will respond promptly — within 45 days at the latest.

Dispute resolution process

In the unlikely event that a dispute arises between you and Submit regarding our handling of your User Personal Information, we will do our best to resolve it. Additionally, if you are a resident of an EU member state, you have the right to file a complaint with your local supervisory authority.

Changes to our Privacy Statement

Although most changes are likely to be minor, Submit may change our Privacy Statement from time to time. We will provide notification to Users of material changes to this Privacy Statement through our Website at least 30 days prior to the change taking effect by posting a notice on our home page or sending email to the email address specified in your Submit account.

License

This Privacy Statement is licensed under the Creative Commons Zero license.

Contacting Submit

Questions regarding Submit’s Privacy Statement or information practices should be sent via email to (privacy [at] submit [dot] gg).

Submit’s notice to California residents

The California Consumer Privacy Act of 2018, (Cal. Civ. Code §1798.100 et seq., as amended, “CCPA”) gives California residents rights and controls over their personal information. Submit provides this statement to those residents (“you”) in accordance with requirements under the CCPA to make certain disclosures about the collection and processing of their personal information. This is Submit’s California-specific description of consumers’ privacy rights under the CCPA. For information about how we’ve extended the CCPA core rights to control personal information to all of our users in the United States, please see our Privacy Statement.

Our handling of personal information

While the table below contains information about the categories of personal information we collect, process and share, please see the Submit Privacy Statement for full details.

We use the categories of personal information described above for the purposes listed in the “How Submit uses your information” section of our Privacy Statement. We also disclose the categories of personal information lists above for business purposes. Please see “How we share the information we collect” section of our Privacy Statement for additional details.

We do not sell your personal information

Under the CCPA, a business that sells California residents’ personal information to others: 1) must give notice to California residents before selling their personal information to others; and 2) must provide the right to opt out of the sale of their personal information. Submit does not sell personal information.

Your rights under the CCPA

The CCPA provides California residents with certain rights related to their personal information. To submit a request based on these rights, please contact us via our Privacy contact form.

When receiving a request, we will verify that the individual making the request is the resident to whom the personal information subject to the request pertains. California residents may exercise their rights themselves or may use an authorized agent, designated in writing or through a power of attorney, to make requests on their behalf. If you use an authorized agent to submit a request, we may require that you provide us additional information demonstrating that the agent is acting on your behalf, and we may need you to verify your identity directly with us. With respect to your personal information, California residents may exercise the rights described below.

Right to Know.
You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this privacy statement. You can use Submit’s Data Portability tools to access and download your data. You may also make such a “request to know” by contacting us via our Privacy contact form.

Right to Request Deletion.
You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to delete, you can use Submit’s Data Portability tools or contact us via our Privacy contact form.

Right to Opt-Out.
You have a right to opt-out from future “sales” of personal information. Note that we do not “sell” personal information as defined by the CCPA and have never done so.

Right to Non-Discrimination
You have a right to not be discriminated against for exercising your CCPA rights. We will not discriminate against you for exercising your CCPA rights.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us. Further, to provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to submit the request from the email address associated with your account or requiring you to provide information necessary to verify your account. Finally, you have a right to receive notice of our practices at or before collection of personal information.

Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law. California Customers may request further information about our compliance with this law by emailing (privacy [at] submit [dot] gg). Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.