Introduction

SocialHP ("we," "our," or "us") is a web and application-based content sharing and employee advocacy service owned and operated by SocialHP that allows users to consume and share content created or approved by their employer internally or to their connected social media platforms.

SocialHP is a technology company headquartered in Toronto, Canada, which focuses on providing services to its clients.

For more information about our services, please refer to our How it Works page.

This Privacy Policy is applicable to SocialHP as related to our services, which collectively include:

This Privacy Policy is applicable to SocialHP as related to our services, which collectively include:

• the use of www.SocialHP.com ("website")
• the use of the SocialHP application ("application")
• social media messages and marketing campaigns and
• the use of our products and services.

This Privacy Policy also covers specific programs and services that we may offer such as application forms, posting submission forms and other documents that we enter with you which have legal and contractual effects.

This Privacy Policy sets out the essential details relating to your personal data relationships with SocialHP as:

• A website visitor
• An end user of the application ("end user")
• A prospective client
• A job applicant and
• Partners

The use of our application is contracted by our clients, and they give access to their employees and other third parties, as solely decided by them, by creating users who access the application with their email address and credentials. End users are assigned roles by the clients' administrators, which result in varying permissions and access rights to the information in the Client account.

WHEN

We may ask you to provide personal information when:

• You register for the SocialHP application
• You create or share a post.
• You use the SocialHP Mobile Application.
• You request a free trial or demo.
• You connect with us directly via phone calls or video conferencing platforms.
• We or Client Account Administrators grant you access to the application.
• You or Client Account Administrators upload or enter personal information into the application.
• You participate in a marketing/sales promotion.
• You register or attend a webinar or other event.
• You participate in chats.
• You pay for our services.

WHAT

We collect personal information that may include first and last name, business email address, password, phone number and/or company name.

As an end user of the application, we collect your name, business email address and any comments you make in the application.

In addition, we may collect data uploaded by you, your employer or other users of the application that may be required to use SocialHP services. We expect all users to follow their organization's privacy policy and any applicable regulatory requirements when uploading, accessing and using personal information into our application. The data uploaded may include personal information like:

• Employee names, email addresses and contractual agreements
• Vendor names, email addresses, contractual agreements or other personal data necessary for SocialHP services
• Customer names and email addresses used to provide services within SocialHP's platform
• Connected social media network profile picture URL
• Service activity dates and usage statistics such as the number of content reads, content shares, and clicks from connected social media networks.
• As a job applicant, we may also collect your resume and cover letter.

WHEN

We collect information about your visits to the website and the application when you land on any of our web pages through cookies and similar tracking technology. We will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed "Cookies".

When you interact with the Service, it automatically records information that your browser sends whenever you visit a website or perform certain actions. We collect this Data and use this information to monitor and analyze use of the Service and for the Service's technical Administration, to increase our Service's functionality and user-friendliness, and to better tailor it to our users' needs.

WHAT

The information collected includes:

• Date and Access times
• The pages you view
• The links you click on
• The search terms you enter
• Actions you take in connection with any of the visited pages
• Your device information such as IP address, location, browser type and language
• The uniform resource locator (URL) of the website that referred you to our website and
• The URL you browse away from our pages if you click on an external link

We may also collect information when you open email messages from us or click on links within those email messages.

Our Services may contain links to other websites. We do not have any control over those websites, and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

WHEN

We may combine the information we collect from your direct interactions with us with information obtained through other third-party sources.

SocialHP uses the Facebook API, LinkedIn API, Twitter API, GreenHouse.io, Hubspot, Workday, Marketo, Google Alert, Salesforce and YouTube API Services to pull in content from those channels. No personal data related to from those services is stored by SocialHP.

WHAT

The personal information collected includes your name, email address, business address, job title, company name.

We use your personal information to:

• Deliver the contracted services and allow full use of the application functionality as purchased by the clients.
• Deliver training and support to our application end users and/or carry out the transactions you have requested.
• To communicate with you directly through emails, calls, chats, video conferencing.
• Process payments for application subscriptions.
• Send communications to you about:
• New application features and upgrades.
• Our services and offerings.
• Event announcements.
• Product notices and changes to our terms and policies.
• Particular programs in which you have chosen to participate.
• Promotional offers and surveys.
• Scheduling demos and managing free trials.
• Advertise and market our products and services, including delivering interest-based advertisements on this website and other sites or content syndication platforms and websites.
• Carry out market research to understand how to improve our services and their delivery.
• Create and manage marketing campaigns.
• Generate sales leads and increase our market share.
• Analyze user clicks and usage of the application and website to improve user experience and maximize usage of our services.
• Manage our website and application to maintain and deliver the contracted functionality and services.
• Enforce our website and application terms and/or separate contracts (if applicable) with you
• Prevent fraud and other prohibited or illegal activities.
• Protect the security or integrity of the website, application, our business or services.
• Or otherwise, as disclosed to you at the point of collection or as required or permitted by law.

We do not sell your information to any third party.

Our Application and Services

If you are an end user of our application, your personal information may be viewed by other users with access to the application.

Service Providers

We use third parties to help us provide our services. They will have access to your information as collected by the website or the application, as reasonably necessary to perform the contracted tasks on our behalf. We sign contractual agreements to obligate them to protect the personal information, only use it to deliver the contracted services to us, prohibit them from selling it and not disclose it without our knowledge and permission.

It is possible that we may need to disclose personal information when required by law, subpoena or other legal processes as identified in the applicable legislation. We attempt to notify our clients about legal demands for their personal data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency.

We may utilize anonymized information to improve the product.

If required, we may disclose your personal information in the Application (but will not disclose details of your social networks):

• to your organization
• to persons for whom you have provided your consent (including through your chosen social networks).
• as otherwise required by law.

Changes of business ownership and control

We can also share your personal data as part of a sale, merger, change in control or in preparation for any of these events.

Any other entity which buys us, or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

We are committed to protecting the security of all the personal information we collect and use. We use a variety of physical, administrative and technical safeguards designed to help protect it from unauthorized access, use and disclosure. We have implemented best-practice standards and controls in compliance with internationally recognized security frameworks. We use encryption technologies to protect data at rest and in transit. We restrict access to personal information to those employees, contractors, and agents who need to know that information in order to process it for us, and who are subject to confidentiality obligations.

For safety, you should protect your user ID and password and not share it with anyone. If you believe your user ID and password have been compromised and you have trouble changing your user ID/password, please contact our technical support department (info@socialhp.com).

We provide the same suite of services to all of our clients and end users worldwide.

We offer the following rights to all individuals regardless of their location or applicable privacy regulations. However, if you are a resident or are otherwise located in the territory of Europe, this section provides additional details about the personal data we collect about you, and your rights granted by the EU General Data Protection Regulation ("GDPR").

For personal information we have about you, you can:

Access your personal information or request a copy.

• You have the right to obtain information about what personal information we process about you or to obtain a copy of your personal information.
• If you have provided personal information to us, you may contact us to obtain an outline of what information we have about you or a copy of the information.
• If you are an end user of the application, you can log in to see the personal information in the account or approach your employer for more information.

You have the right to be notified of what personal information we collect about you and how we use it, disclose it and protect it.

• This Privacy Policy describes what personal information we collect and our privacy practices. We may also have additional privacy notices and statements available to you at the point of providing information to us directly.

Change or correct your personal information.

• You have the right to update/correct your personal information or ask us to do it on your behalf.

You can edit your information through the user account in the application or ask us to change or correct it by contacting us at Info@socialhp.com

Delete or erase your personal information.

• You have the right to request the deletion of your personal information at any time. We will communicate back to you within reasonable timelines the result of your request.

Object to the processing of your personal information.

• You have the right to object to our processing of your personal information for direct marketing purposes. This means that we will stop using your personal information for these purposes.

Ask us to restrict the processing of your personal information.

• You may have the right to ask us to limit the way that we use your personal information.

Export your personal data.

• You have the right to request that we export to you in a machine-readable format all the personal information we have about you.

Please note that we reserve the right to send you other communications, including service announcements and administrative messages relating to your SocialHP account, without offering you the opportunity to opt-out of receiving them. We do not process personal information through the use of automated means. If you would like to exercise any of the rights described above, please contact us at Info@socialhp.com. You also have the right to lodge a complaint with the supervisory authority in charge of enforcing the privacy legislation applicable in your territory. If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the EU GDPR, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

We retain information as long as it is necessary to provide the services to you and our clients, subject to any legal obligations to further retain such information.

We may also retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our Terms of Service and take other actions permitted by law.

The information we retain will be handled following this Privacy Policy.

Information connected to you that is no longer necessary and relevant to provide our services may be de-identified or aggregated with other non-personal data. This information may provide insights that are commercially valuable to SocialHP, such as statistics of the use of the services. For example, if you decide to cancel and/or unlink your social media account, we delete your social media token and no longer have access to that social media account. We may retain the Postings you have previously created and/or shared, including the text of such Posting and any statistical information we have collected related to such Posting.

We process data in locations United States and Canada. and rely on legally provided mechanisms to lawfully transfer data across borders, such as contracts incorporating data protection and sharing obligations.

We will only collect and process your personal data where we have a lawful reason for its collection.

When you visit our website and provide us with your personal information, we collect and use it with your consent.

As an application end user, you consent to our collection of your personal information when you log in for the first time. However, your employer has control of the account and may upload and share additional personal information. Your employer's responsibility is to ensure that collecting, using and sharing the personal information uploaded to the application complies with all applicable legislation.

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us at info@socialhp.com

How to select your communications preferences

You may choose to receive or not receive marketing communications from us. Please click the "Unsubscribe" link in the email we sent you to stop receiving marketing communications.

You may choose which information we collect automatically from your device by controlling cookie settings on your browser or by selecting your preferences through our Cookie Policy. See section called "cookies" for more details

Even if you opt-out of receiving marketing communications, we may still communicate with you regarding security and privacy issues, servicing your account, fulfilling your requests, or administering any promotion or any program in which you may have elected to participate.

You may contact us to exercise any of your rights or ask for more information about your personal information and our privacy practices by contacting us by email at info@socialhp.com or by mail at 219 Dufferin Street Unit 18C, Toronto, Ontario, Canada, M6K 3J1 ATTN: Privacy Office, Legal.

This is our entire Privacy Policy, and it supersedes any earlier version. You agree to it every time you use the Website and/or the Application. From time to time we will update this Privacy Policy. Before we do so we will inform you by email or by placing a prominent notice on our website. By continuing to use our website and/or our application you agree to be bound by such changes to this Privacy Policy. Your only remedy, if you do not accept the terms of this Privacy Policy, is to discontinue use of the Website and the Application. If you have any questions about this Privacy Policy, please feel free to contact us anytime at info@socialhp.com.

A.1 For Individuals Based in the European Union (EU), European Economic Area (EEA) and Switzerland.

If you are based in one of these jurisdictions, SocialHP is the controller of your personal data collected in the following instances:

• When you visit our website
• When we process your personal data for sales and marketing purposes

SocialHP is a processor of all personal data processed on the application, on behalf of our clients. We only process the personal data under their direction. Please contact your employer or the organization that granted you access to the application for details on their privacy practices.

We only process personal data if we have a lawful basis for doing so. The lawful bases applicable to our processing as controller are:

• Consent: We will ask for your express and informed consent every time we collect your personal data on this legal basis.
• Contractual basis: We process the personal data as necessary to fulfil our contractual terms with you or our clients.
• Legitimate interest: We process the names, contact details, job titles, companies of our existing and prospective clients for our marketing purposes, including market research and sales leads generation.

You have the following rights under the GDPR:

• Be informed about the collection and use of your personal data
• Access your personal data
• Correct errors in your personal data
• Erase your personal data
• Object to the processing of your personal data.
• This right is also available to individuals whose personal data is processed by us for direct marketing purposes. If you object to the processing of your personal data for direct marketing purposes, we shall stop processing within 30 days of receipt of your request.
• Export your personal data
• Restrict our processing of your personal data for specific reasons, including any of the purposes supported by the legitimate interest legal bases (see the section above).

We process personal data in United States and Canada. and share it with our service providers in United States and other jurisdictions. We use standard contractual clauses as the data transfer mechanism of transferring EU data to countries subject to data transfer requirements. See the table of our service providers in table 1 above.

You may contact us at info@socialhp.com or you may contact our EU Data Representative at: https://ico.org.uk/.