Meltwater Engage Supplemental Privacy Policy

Last updated: 11/05/2018

This Supplemental Privacy Policy supplements the Privacy Policy located at http://www.meltwater.com/privacy-policy/ (“Privacy Policy”) and the terms hereof are not intended to replace the Privacy Policy. The Privacy Policy and this Supplemental Privacy Policy shall collectively be referred to as the “Engage Privacy Policy” and they will govern your use of the Engage Service. If you register for a free trial of the Engage Service, the Engage Privacy Policy will also govern that free trial. To the extent of any inconsistency between this Supplemental Privacy Policy and the Privacy Policy, this Supplemental Privacy Policy shall control.

The Engage Service utilizes the Sprout Social, Inc. (“Sprout Social”) platform to provide the Engage Services.

Each of Sprout Social and Meltwater respects your right to privacy. This Supplemental Privacy Policy explains who we are, how we collect, share and use personal information about you and how you can exercise your privacy rights.

This Supplemental Privacy Policy applies to all users of the Engage Service and websites, including but not limited to www.engage.meltwater.com (depending on your use, the “Site” and/or the “Engage Service”). For further information on the terms which govern your use of the respective Service, see the following link: http://engage.meltwater.com/meltwater-terms-of-service.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided in the How to Contact Us section of this Supplemental Privacy Policy.

  1. What does Sprout Social do?

    Sprout Social is a US headquartered provider of software for social media-related management, social advocacy, social analytics, and social listening. For more information about Sprout Social, please see the “About Us” section of our website at https://sproutsocial.com/about.

  2. Information Collected

    We collect information about visitors to our Sites, employees of our customers and users of our customer's social media pages / properties.

    Such information is collected about you, including personal information, from the following sources:

    • Information We Collect Directly from You: The type of information that we collect directly from you varies based on your interaction with our Site and our Engage Service. We collect information directly from you when you register an account with us, liaise with us on a customer service issue, complete an application or other forms on the Site and/or software. We also collect information that you send us via any medium, including, but not limited to email, telephone, as well as social media interactions like your social media handle, username, profile, and messages with our customers; or
    • Information We Receive from Customers: We may receive information from customers in order to provide our Engage Service. Such information may include a user's social media handle, username, profile, biography and messages or communications with our customers. We collect information from individuals employed by our customers such as their contact information in order to provide our Engage Service.

  3. Information Collected Automatically

    When you visit our Site or use our Engage Service, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

    Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), third party webpages accessed via the Engage Service and other technical information. We may also collect information about how your device has interacted with our Site, including the pages accessed and links clicked, or Engage Service, including content accessed.

    Collecting this information enables us to better understand the visitors who come to our Site or use our Engage Service, where they come from, and what content and functionality is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Site and/or Engage Service to our visitors and users.

    Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology” below and in our Cookie Notice.


  4. Do-Not-Track

    Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this Supplemental Privacy Policy (e.g., by disabling cookies, or using ‘private’ browsing modes).

  5. Use of Personal Information

    Sprout Social processes your personal information for the following purposes:

    • Operate and improve the Site and Engage Service;
    • Provide users or customers with the Engage Service and other products and services that a user or customer may request or that a user or customer has expressed interest in;
    • Facilitate subscription processing, reviews and analysis;
    • Evaluate user interest and needs in order to improve the Engage Service and make available other offers, products or services;
    • Evaluate the types of offers, products or services we make available to users or customers and potential users or customers;
    • Monitor use of the Engage Service;
    • Provide customer support;
    • Communicate and provide additional information that may be of interest to users through email or other means, such as special offers, announcements, and marketing materials;
    • Conduct online research surveys regarding the Site and/or Engage Service;
    • Combine datasets to create aggregated data for internal evaluation and analysis;
    • Share anonymised or personalised tokens across the Sprout Social platforms in order to provide the Engage Service;
    • Send you reminders, technical notices, updates, security alerts and support and administrative messages, service bulletins, or marketing;
    • Provide advertisements to you through email messages; and
    • Manage our everyday business needs such as Site and/or Engage Service administration, forum management, fulfillment, analytics, fraud prevention, enforcement of our corporate reporting obligations, Supplemental Terms of Service and any other contractual agreement relating to our Engage Service or to comply with the law.

  6. To Whom We May Disclose Your Information

    We may disclose your information, including personal information, to the following categories of recipients:

    • to our affiliates third party services providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Site or Engage Service), or who otherwise process personal information for purposes that are described in this Supplemental Privacy Policy or notified to you when we collect your personal information. In a limited number of countries and only where permitted by applicable law we provide contact information of customers / potential customers to a reseller to market our Engage Service.
    • to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or court order or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
    • to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Supplemental Privacy Policy;
    • to any other person with your consent to the disclosure.

    We do not share personal information with third parties for their own marketing purposes.


  7. Legal basis for processing personal information (EEA visitors / users only)

    If you are a visitor or user from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

    However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

    If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

    Similarly, if we collect and use your personal information in reliance of our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

    If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the How to Contact Us heading below.

  8. Cookies and similar tracking technology

    We use cookies and similar tracking technology (collectively, "Cookies") to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Policy.


  9. Your Data Protection Rights

    You have the following data protection rights:

    • If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting us using the contact details provided under the How to Contact Us heading below. Note that if you submit a request to delete your personal information, this may prohibit you using the Site and/or Engage Service.
    • In addition, if you are a resident of the European Union, you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information. Again, you can exercise these rights by contacting us using the contact details provided under the How to Contact Us heading below. Note that if you submit such a request, this may prohibit you using the Site and/or Engage Service.
    • You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the How to Contact Us heading below.
    • Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
    • You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

    We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Where we process your personal information solely on behalf of a customer, we may be legally required to forward your request directly to our customer and social media business partners for their review / handling.


  10. Security & User ID/Password

    Our Site and/or Engage Service utilizes various appropriate technical and organizational security measures, which include, but are not limited to, network and host security controls (e.g., firewalls, intrusion detection systems, etc.), data encryption (both at rest and during transmission), and operating procedures that are designed to protect your personal information. You should protect your user ID and password and NOT share it with anyone. Additionally, enabling two-step verification, where available, is also recommended. If you believe your user ID and password have been compromised or you have trouble changing your user ID/password on the Site or Engage Service, please contact our technical support department [email protected].

  11. Data retention

    We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).

    When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, in the limited circumstances where this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

  12. CAN-SPAM Compliance Notice (U.S. and Canadian users only)

    We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the unsubscribe or opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any service you have requested or received from us.

  13. California Privacy Rights

    Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of Personally Identifiable Information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. In particular, the law provides that companies must inform consumers about the categories of Personally Identifiable Information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by Sprout Social pursuant to Section 1798.83 of the California Civil Code, please contact us via email at [email protected].

  14. International Transfers

    Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

    Specifically, our servers are located in the United States, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries.

    However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Supplemental Privacy Policy. These include our participation in the E.U. - U.S. Privacy Shield Framework, additional details of which are set out below.

  15. EU - US Privacy Shield Framework and Swiss - US Privacy Shield Framework

    Sprout Social complies with the EU - U.S. Privacy Shield Framework and the Swiss - U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Sprout Social has certified to the Department of Commerce that it adheres to that its processing of personal information from EU member countries, European Economic Area and Switzerland is in accordance with the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability (the "Principles"). If there is any conflict between the terms in this Supplemental Privacy Policy and the Principles, the Principles shall govern. To learn more about the Privacy Shield program and to view our certification, please visit https://www.privacyshield.gov/list. Sprout Social is subject to the investigatory and enforcement authority of the Federal Trade Commission.

  16. Contacting Us, Complaints and Dispute Resolution

    EU and Swiss individuals who have questions or complaints about how we process their personal information may contact us at [email protected]. We will work to resolve your issue and will respond within 45 days of receipt.

    Sprout Social has further committed to refer unresolved privacy complaints under the EU-U.S. and Swiss - U.S 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 acknowledgement of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

    Individuals may also submit complaints through their local Data Protection Authority (DPA). We will work with the Department of Commerce to resolve any complaints forwarded by a DPA. Finally, if we are unable to resolve any complaints through any of the above methods, an EU or Swiss individual may invoke binding arbitration in accordance with the Privacy Shield Framework.

  17. Privacy Complaints in Brazil

    In circumstances in which Brazil law is controlling, we commit to resolve complaints about your privacy and our collection or use of your personal information. We have further committed to refer unresolved privacy complaints to an independent dispute resolution mechanism.

  18. Children

    Consistent with the federal Children's Online Privacy Protection Act of 1998 (COPPA), we will never knowingly request personally identifiable information from anyone under the age of 13 without requiring parental consent. Any person who provides their personal information to us through our Site or Service represents that they are older than 12 years of age.

  19. Updates to this Supplemental Privacy Policy

    We may update this Supplemental Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

    You can see when this Supplemental Privacy Policy was last updated by checking the "last updated" date displayed at the top of this Supplemental Privacy Policy.

  20. How to Contact Us

    If you have any questions or concerns about our use of your personal information, please contact us using the following details: [email protected].