PRIVACY POLICY

Effective Date: March 16, 2017

This Privacy Policy is incorporated by this reference into the Social Native LLC General Visitor Terms of Use and Creator Terms of Use (each, a “TOU”). All other terms not defined in this Privacy Policy will have the meanings set forth in the applicable TOU. The terms “Social Native,” “we,” “us,” and “our” include Social Native LLC and our affiliates and subsidiaries. This Privacy Policy applies to our website located at www.socialnative.com and all related subdomains (collectively, “Site”). This Privacy Policy explains how Social Native may collect, use, and disclose information we obtain through the Site.

WHEN SOCIAL NATIVE COLLECTS YOUR INFORMATION

Registration.

Creators. When you register an Account with us to use the Site as a Creator, you must provide us with your name, email address, geographic location and information about what kinds of Content you often create. You also may choose to provide us with additional information, such as your gender and information about your Campaign preferences.

Brand Users. When you use the Site on behalf of a Brand (each, a “Brand User”), you must provide us with your email address.

Third Party Platforms. When you use the Site as a Creator, the following terms apply to you:

Log In. You may log in to the Site with the credentials that you use to log in to certain Third Party Platforms. When you do so, we may collect the information you have made available on the applicable Third Party Platform. For example, if you use your Instagram or YouTube credentials to log in to the Site, then we may collect the information you have made available on Instagram or YouTube.

Campaigns.

Engagement Rate” means the total number of instances when an item of Campaign Content is liked, viewed, clicked or commented on by users on the applicable Third Party Platform, divided by the total number of followers for the applicable Creator on that Third Party Platform.

We collect information about any audiovisual Campaign Content that you post on a Third Party Platform in connection with a Campaign, such as the Engagement Rate and the number of instances when this Content was commented on, viewed and liked on the applicable Third Party Platform.

Similarly, we collect information about any photographic Campaign Content that you post on a Third Party Platform in connection with a Campaign, such as the Engagement Rate and the number of instances when this Content was commented on and liked on the applicable Third Party Platform.

Sentiment Analysis. We also may collect information about your user profile and post captions or commentary on each Third Party Platform.

Using the Site. We collect information about your use of the Site. For example, we collect information about any Content that you Post, and we collect information about how Brand Users engage with Campaign Content and otherwise administer Campaigns.

Communications. We collect information that you provide to us through your communications with us on or through the Site, such as any communications you send to us in connection with any job advertised on the Site or customer-support needs or issues.

Cookies, Automatic Data Collection, and Related Technologies. The Site collects and stores information that is generated automatically as you use it.

When you visit the Site, we and our third party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Our service providers may collect information about your online activities over time and across different online services. Cookies are small text files placed on your computer browser when you visit a website. Most browsers allow you to block and delete cookies. However, if you do that, then the Site may not work properly.

By using the Site, you are authorizing us to gather, parse, and retain data related to the provision of the Site.

HOW SOCIAL NATIVE USES YOUR INFORMATION

Internal and Site-Related Usage. We may use and retain any information that we collect to provide, maintain and improve the Site and our products and services and to otherwise conduct our business. For example, this includes using information collected about Creators to help select them for Campaigns, and using information collected about Brand Users and Brands to provide a more useful and customized experience in using the Site.

Communications. We may use your information to communicate with you, including to provide you with information about Social Native, the Site and/or Campaigns, and for operational purposes, such as account management, customer service, or system maintenance. Further, when you use the Site as a Creator, we may send you electronic mail to the address you provide to us during Account registration to help us collect more optional information about you so we can better match you with Campaigns. You are not required to provide any of this information to us.

Aggregate Data. We may de-identify and aggregate data collected through the Site and use it for any lawful purpose.

SOCIAL NATIVE MAY DISCLOSE YOUR INFORMATION

We Use Vendors and Service Providers. We may share any information that we receive through the Site with vendors and service providers retained in connection with the provision of the Site, including for data analytics purposes. One of the service providers that we use for data analytics is Google Analytics. If you do not want Google Analytics to collect and use information about your use of the Site, then you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/).

Advertising Partners. We do not share personal information (as defined by California Civil Code § 1798.83) with other people or nonaffiliated companies for their direct marketing purposes. We may disclose your information to our third party advertising partners to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. Some of these third parties may use cookies and other technologies to collect information about your online activities on the Site and other online properties over time to show you ads that may interest you. You may be able to opt out of receiving personalized advertisements from advertisers or advertising networks who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out sections on the websites of each of those organizations.  Links to those services are here:

Network Advertising Initiative: http://www.networkadvertising.org/choices/

Digital Advertising Alliance: http://www.aboutads.info/choices/

DO NOT TRACK

Some web browsers incorporate a “Do Not Track” feature. Because there is not yet an accepted standard for how to respond to Do Not Track signals, our Site does not currently respond to such signals.

As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information, if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) enforce this Privacy Policy or the applicable TOU; (c) respond to your requests; or (d) protect your, our or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. The use of your information following any of the foregoing events will be governed by the provisions of the version of this Privacy Policy in effect at the time such information was collected by Social Native.

With Your Consent. We may also disclose your information with your permission.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use personal information, as defined by the Federal Trade Commission’s Children’s Online Privacy Protection Act Rule, from children under 13 years of age, and no part of the Site is directed to children under the age of 13. If you learn that your child has provided us with personal information without your consent, you may alert us at info@socialnative.com. If we learn that we have collected any personal information from children under 13, then we will promptly take steps to delete such information.

INTERNATIONAL USERS

If you visit the Site from the European Union or other regions with laws governing data collection and use, then please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information to the Site, you consent to any transfer and processing in accordance with this Policy.

CHOICES YOU HAVE WITH YOUR INFORMATION

Your Information. You can contact us at info@socialnative.com to update the information that you have provided to us.

Opt-out. You can unsubscribe from promotional emails from us and emails from us inviting you to participate in Campaigns via the unsubscribe link provided in the email.

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on the Site, and update the “Effective Date” above. If you are concerned about how your information is used, then bookmark the applicable page on the Site and read this Privacy Policy periodically. Your continued use of the Site after changes to the Privacy Policy constitutes your acceptance of the new terms of the Privacy Policy.

New Uses of Information. From time-to-time, we may desire to use information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, then we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.

Contact Information

Social Native LLC

9935 S. Santa Monica Boulevard, Beverly Hills, CA 90212

info@socialnative.com