SocialSignin Ltd, trading as Orlo, is a private company limited by shares incorporated and registered in England and Wales with company number 08237170 and whose registered office is located at 7c, Centre City House, 5-7 Hill Street, Birmingham. B5 4UA, England, United Kingdom. Wherever used in these terms and conditions of business (“T&Cs”), “SocialSignIn”, “we”, “our” or “us” refer to SocialSignin Ltd (and our permitted successors and/or assigns). Wherever used in these T&Cs, “you”, “your” or similar terms mean the person utilising and/or accessing the Services (as stated in the order form), including persons for which you are responsible such as your employees and other permitted third parties (as applicable).
These T&Cs, together with the Data Protection Addendum and the order form (produced by us), constitute a binding legal agreement between SocialSignIn and you (the “Contract”). Any purported order by you for the Services shall not form a legally binding contract unless and until we countersign the order form (which has been signed by you) or commence providing the Services (whichever is the later). This Contract governs your access to and use of our products, software, services, and website (collectively “Services”), and any and all information, text, graphics, photos or other materials uploaded, downloaded, or appearing on the Services (collectively “Content”). By accessing and using the Services, you agree to be exclusively bound by the Contract to the exclusion of any other terms and conditions which seek to have effect, and you warrant that you have read, understood and accepted the terms of the Contract. If you do not agree to be bound by the Contract, you are not permitted to use the Services and/or Content under any circumstances.
In these T&Cs, the following rules apply:
(a)words in the singular include the plural and vice versa;
(b)reference to a person includes a natural person, corporate or unincorporated body (whether or not having a separate legal personality);
(c)reference to a party includes its personal representatives, successors or permitted assigns;
(d)an obligation to do something includes an obligation not to do something;
(e)these T&Cs are jointly and severally liable as amongst the obligors (someone who legally agrees to do something);
(f)reference to writing or written includes post and emails but not faxes; and
If you are subscribing to an Advanced Monitoring Stream, please note that you will also need to acquire a Web End-User License (WEUL) from the Newspaper Licensing Agency (NLA). This license will have to be purchased by yourselves and obtained directly from the NLA. It is a legal requirement that provides the permission needed to receive and access copyrighted online content, such as the results provided by our Advanced Monitoring service (news alerts and links to online newspaper articles). Please visit the NLA’s website for more information.
Forming part of and incorporated into the Contract between you and SocialSignIn.
This Addendum sets out the provisions that will govern the processing of personal data by the parties to the Contract and its provisions take precedence over every other term of the Contract unless expressly stated otherwise.
The following definitions have the meanings shown:
Controller, Processor, data subject, personal data and Processing each have the meaning given to them in the Data Protection Laws and Process and Processed will be construed accordingly.
Data Breach means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Data Protection Laws means all applicable privacy and data protection laws including the Data Protection Act 1998 (as replaced by the GDPR with effect from 25 May 2018) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (as amended) and all subordinate and ancillary legislation, directions of any competent privacy regulator, common law and other relevant court decisions that relate to privacy and/or data protection in each case as may be amended or replaced from time to time.
Data Security Measures means the technical and organisational security measures described in Annex 2 (as may be improved upon from time to time by SocialSignIn or which have been agreed by the parties in accordance with Annex 2) as being those required to be used by SocialSignIn and which have been approved by you as complying with the Data Protection Laws when Processing Your Data.
Deliverables means the goods, services, software, licences and any other deliverables to be provided by or on behalf of SocialSignIn under the Contract.
GDPR means the General Data Protection Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data which came into force on 24 May 2016 (together with any associated derogations and amendments imposed by the United Kingdom) and which will apply from 25 May 2018.
Personnel means any employee, officer, agent, consultant, auditor, subcontractor, Subprocessor or other third party acting on behalf of SocialSignIn in connection with the provision of the Deliverables.
Processing Requirements means your requirements for the Processing of Your Data by or on behalf of SocialSignIn under the Contract as described in Annex 1.
SocialSignIn Approved Subcontractor List means the internal list of subcontractors that have been approved by SocialSignIn to provide services that involve the subcontractor Processing Your Data.
Subprocessor means any third party engaged by SocialSignIn including any of its affiliates, subsidiaries and/or subcontractors or agents that may Process Your Data.
Your Data means all personal data relating to data subjects that are Processed in the course of using or providing the Deliverables and includes any copies included in back-ups made by or on behalf of SocialSignIn.
Your Instructions means your instructions for the Processing of Your Data as described in this Addendum and the Processing Requirements or otherwise agreed by you and SocialSignIn.
1. Intellectual property rights. All intellectual property rights in and to Your Data will be and will remain vested in you.
2. Compliance with Data Protection Laws. Each of the parties will ensure that it complies with the Data Protection Laws when Processing Your Data under the Contract.
3. Causing breach. Each of the parties will not (and will ensure that none of the Personnel may) do anything that would cause itself or the other or any or any other person to be in breach of the Data Protection Laws.
4. Compliance with Your Instructions. When Processing Your Data on behalf your behalf, SocialSignIn will comply with Your Instructions. If SocialSignIn is unable, for any reason, to comply with Your Instructions, we will notify you promptly. If we believe any of Your Instructions infringes Data Protection Law, we will notify you as soon reasonably practicable.
5. Specific requirements and permitted Processing. SocialSignIn will ensure that, when it Processes Your Data, it will use the Data Security Measures. You have determined that compliance with the Data Security Measures when Processing Your Data by or on behalf of SocialSignIn is satisfactory to comply with the Data Protection Laws. If you require a change to our standard Data Security Measures, we reserve the right to charge for implementing, maintaining and operating as you require.
6. Processing limitations. SocialSignIn will not Process Your Data for any purpose beyond providing the Deliverables and the scope of Your Instructions or, to the extent otherwise necessary, to comply with the Data Protection Laws.
7. International transfers. SocialSignIn will not transfer or allow any other person to transfer Your Data outside the European Economic without your prior written approval.
8. Acknowledgement. You acknowledge and accept that access and use of the Deliverables by your authorised users may occur outside the European Economic Area and, in such circumstances, Your Data may be viewed outside the European Economic Area by the relevant user. SocialSignIn will not be in breach of paragraph 7 in such circumstances.
9. Personnel. SocialSignIn will: (i) take reasonable steps to ensure the reliability of Personnel that may have access to Your Data; (ii) carry out appropriate checks of its Personnel before allowing them to Process Your Data; (iii) ensure the Personnel are appropriately trained in the handling and secure Processing of Your Data.
10. Subcontracting. SocialSignIn will only appoint Subprocessors in connection with the Processing of Your Data where: (i) the Subprocessor has provided sufficient guarantees to ensure the Data Security Measures are met or exceeded; (ii) the Subprocessor is on the SocialSignIn Approved Subcontractor List; and (iii) the Subprocessor is appointed under a written agreement that complies with the Data Protection Laws. SocialSignIn will remain liable for the defaults of its Subprocessors as if it carried out the actions of the Subprocessors itself.
11. Confidentiality. SocialSignIn will ensure that: (i) any persons authorised by or on behalf of SocialSignIn to Process Your Data are bound by obligations to maintain the confidentiality of Your Data; and (ii) its disclosure of Your Data will be limited to the extent necessary to provide the Deliverables or as otherwise permitted under the Contract, by you or by applicable Data Protection Law.
12. Data subject rights. You and your users have full access to Your Data through the Deliverables and, as such, it is your responsibility to comply with the rights of data subjects under the Data Protection Laws. If, for any reason you need the help of SocialSignIn to comply, we will assist you but reserve the right to charge for the assistance at our then prevailing rate.
13. Regulator and other third-party correspondence. If we receive a communication from a regulator, other competent authority or any other person (each a Competent Person) in respect of Your Data we will, unless we are prohibited by the Competent Person or applicable laws, forward it to you for you to address and reserve the right to notify the Competent Person that we have done so. If SocialSignIn is required to respond to the communication directly, we will do so.
14. Data breach. SocialSignIn will maintain a Data Breach incident response plan that documents the procedures to be followed and contacts to be notified in the event of a Data Breach. In the event SocialSignIn suffers a Data Breach as a result of or in connection with the performance of its rights or obligations under the Contract, SocialSignIn will notify you of all material facts without undue delay after becoming aware of the Data Breach.
15. Data breach management. SocialSignIn will cooperate and assist you in handling the Data Breach referred to in paragraph 14, by investigating the Data Breach, facilitating meetings with those involved in the data breach and making available all relevant records, logs, files and data, reports including those regarding the facts relating to the Data Breach, its effects and the remedial action taken or to be taken. If the Data Breach is not attributable to SocialSignIn or any of its Subprocessors, we reserve the right to charge for the assistance at our then prevailing rate.
16. Confidentiality in respect of Data Breaches. Except as required by Data Protection Laws, neither party will do, say or report anything to any person that may affect the other’s reputation without the approval of such other party (such approval not to be unreasonably withheld or delayed).
17. Data protection impact assessments. SocialSignIn will cooperate, and provide reasonable assistance to you with, any data protection impact assessment that you are required by the Data Protection Laws to carry out in connection SocialSignIn’s Processing of Your Data. If such co-operation or assistance requires SocialSignIn or any Subprocessor to provide any additional professional services, SocialSignIn will notify you of the proposed charges and no work will be commenced until the parties have agreed the charges and the scope of work in writing.
18. Returning Your Data on termination or expiry. You are able to export Your Data at any time during the term of our contract. After expiry (or termination if that is earlier) we will delete Your Data (normally within one month) but will retain the shortened links you have created using our code so that your users are redirected to the correct location.
19. Demonstration of compliance. SocialSignIn will appoint an independent third party to carry out an annual assessment to verify SocialSignIn’s compliance with the terms of this Addendum. SocialSignIn will provide you with a copy of the latest report produced on request.
20. Audit. If a court or regulatory body requires us to give you access to our premises or systems, we will do so but will require you comply with our prevailing security and health and safety requirements.
You have appointed SocialSignIn to provide certain Deliverables (as specified in Contract. To facilitate the provision of these, SocialSignIn will need to Process Your Data in respect of which you are the Controller.
The Processing will continue for the term of the Contract (as the same may be terminated and/or extended in accordance with the terms of the Contract).
Your Data will be Processed for the purpose of providing the Deliverables to you in accordance with the terms of the Agreement.
The nature of our application is a mere repository for messages from your followers and users with the functionality for your users to manage those messages. As such, our provision of the Deliverables may require the Processing of any type of personal data.
The provision of the Deliverables may involve the Processing of personal data about any or all of the following data subjects:
– your users
– your customers and followers
– any other person that your users, customers or followers refer to in their messages or in our application
1. Knowledge and resources. SocialSignIn will ensure that it has the appropriate knowledge to Process Your Data and has the necessary resources to implement the technical and organisational measures required under this Addendum.
2. Security of Your Data. SocialSignIn will implement and maintain the following technical and organisational measures when Processing Your Data and you have determined and are satisfied that:
(a) these are sufficient to ensure compliance with the Data Protection Laws and the protection of the rights of data subjects; and
(b) they take into account the risks that are presented by the Processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, Your Data when it is transmitted, stored or otherwise Processed. Security measure and Details of the measure
We have internal policies and procedures that are kept under review, a designated privacy officer and external specialist data protection advisers to support our compliance.
All relevant personnel are trained to understand data protection and to apply its principles within their roles.
Network devices are managed within a secure management network and servers are secured by firewalls. In both instances SSL/TLS secure encryption protocols are used.
All of the servers we manage have antivirus and malware scanners installed and have updates applied frequently.
Data in transit is always encrypted to a minimum standard of 256 bit
We offer various options for you to choose from including:
– email / password
– strong passwords
– two-factor authentication
– SAML (Okta and OneLogin or any other agreed by us)
– Google Account Login
Each client’s data is logically separated from that of other clients in our databases. Our code automatically tests to ensure each client’s data is not mixed with that of another client.
Your Data is only accessible by a small number of personnel in our development team on a ‘need to know’ basis.
Our infrastructure is designed to be resilient. Our main database is ‘highly available’ such that, if one server goes offline, the other servers will pick up the work and contains replica data to ensure there is no downtime. All servers that serve our application are load balanced and can distribute load/requests to at least 3 servers.
We perform daily port scanning on public IP addresses to ensure there are no unexpected changes. Configuration management is dealt with by scripts with are kept and managed in our private version control system.
Our entire application is scanned by external technically skilled individuals to try to break, gain unsolicited access to, and “hack” our systems in a safe way in order to find flaws or potential weaknesses in our platform.
We have some continual end-to-end testing of our server cluster to ensure specific key indicators are working correctly and use software to log and track these with a combination of active checks and, for back-ups, passive checks. Team members are alerted if an expected behaviour has not executed as expected.
Our code is written to log any critical events for our developers to address.
Our databases are backed-up continuously. Whilst our main datastore holds replicas of data at all times, we also run our other databases with duplicate data in them ready to swap over should the need arise. Multiple snapshots of the entire database are taken daily and they are stored on a separate server from the one that holds live data. From these various back-ups, we are able to restore the entire database in the event of a physical or technical incident in a timely manner.
We maintain a disaster recovery plan to test our disaster recovery which is tested at least annually.
We currently use leading third parties to provide hosting services. They have all been vetted and authorised by a designated approver within SocialSignIn as part of our supplier on-boarding process and we have written contracts with each of them incorporating appropriate data protection provisions to protect your personal data.
Our software normally maintains a record of many of your users’ activities when using our application such as which user creates or edits a post, or created any free text notes on your followers messages. You can view these audit logs through the application.
If we agree any alternative or additional measures in writing specifically referring to this Annex 2 of the Addendum, we will implement and maintain these accordingly.
When you register for SocialSignIn we ask for information such as;
In Supporting You
The information we collect is used to improve the content of our Web pages and the quality of our service, and is not shared with or sold to other organizations for commercial purposes, except to provide products or services you’ve requested, when we have your permission, or under the following circumstances:
It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law.
SocialSignIn collects information about accesses (such as clicks) of every socsi.in Link created through the Services. This information includes, but is not limited to: (i) the IP address and physical location of the devices accessing the socsi.in Link; (ii) the referring websites or services; (iii) the time and date of each access; and (iv) information about sharing of the socsi.in Link on Third Party Services such as Twitter and Facebook. This information is used by SocialSignIn to improve their websites and services by, for example, providing value-added features, and to analyze clicks on socsi.in Links, for example to understand how, when and where socsi.in Links are clicked.
A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a web site’s computers and stored on your computer’s hard drive.
Cookies are required to use the SocialSignIn service.
SocialSignIn may disclose personally identifiable information under special circumstances, such as to comply with subpoenas or when your actions violate the Terms of Service.
You can manage your email preferences, such as opt-out or unsubscribe from emails sent by SocialSignIn, by adjusting your preferences in your account settings. You can also opt-out or unsubscribe from any future email communications from within each email correspondence that we send you.
SocialSignIn may periodically update this policy. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your SocialSignIn primary account holder account or by placing a prominent notice on our site.
The General Data Protection Regulation (GDPR) comes into effect on 25 May 2018. In line with the GDPR and to continue the provision of secure, reliable and compliant services, we have created these FAQs which set out our privacy obligations – both legal and contractual.
1. How is SocialSignIn structured to ensure data protection compliance?
The protection of our clients’ data is at the heart of our business. We have a strong culture of compliance, which is embedded within our software, systems and processes.
We have worked hard to establish a GDPR compliance framework with internal policies and procedures that are kept under review. Our personnel are trained to understand the importance of data protection and to apply its principles within their roles.
We have a designated privacy officer to guide our business on compliance and have specialist external advisers that we can call on for additional support.
Compliance is monitored through various activities, including internal auditing and analysis of incidents. We maintain records of our processing activities in compliance with Article 30 of the GDPR.
2. What is SocialSignIn’s role in respect of our data?
You are the data controller of all personal data held in our application under your account and SocialSignIn is merely your data processor in respect of all the services provided to you. Our processing of your personal data is only on your documented instructions as set out in the contract between us. We do not use any of your personal data for anything that is not in the contract.
3. What personal data is stored within the SocialSignIn application?
Our application only holds basic information about your authorised users, this being name, email address, password, last login, IP address, browser and device details. If you opt for two-factor authentication, we will also store the user’s mobile phone number.
Your social media followers may include any type of information (including personal data, images and videos) in their messages to you and your users can add free text to social contacts and messages. We don’t use any of this information for any of our own purposes other than to create aggregated statistics, which do not identify any individuals. Our system is merely a place to store their messages to you and to enable you to manage and retrieve them. You are the data controller of your followers’ messages and your users’ free- text additions. As such, it is your responsibility to ensure you use these in compliance with data protection and other laws.
4. Is our data held separately from that of other SocialSignIn clients?
Data is not physically separated within the SocialSignIn application but it is logically separated. We have security policies and code that is automatically tested with every deployment to ensure that your data is not mixed with other clients’ data.
5. Are the systems used by SocialSignIn GDPR compliant?
We carried out a Privacy Impact Assessment of our software, systems and services and have made changes to ensure we meet and, in some cases, exceed GDPR requirements.
Our system architecture was developed with data protection and data security in mind. The databases in which your personal data is stored are only accessible by a small division of the internal development team who are internally vetted and have worked for us for a substantial amount of time. We do not use live data for testing and it is never stored on local machines.
6 What does SocialSignIn do to protect login credentials?
We offer a number of log-in options:
Ultimately, you are responsible for ensuring your users keep your account log-in credentials secure and for any activities or actions occurring under your account. Our application offers the ability to require “strong” passwords (passwords that use a combination of upper and lower case letters, numbers and symbols) for your account. Administrators can disable email/password as a means of logging into the application and force one of the above options instead.
7. What does SocialSignIn do to keep customer data secure?
We have a suite of security measures in place. These are kept under review and, wherever we consider it appropriate, they are enhanced. These are:
We use Cloud KMS (a cloud-hosted key management service), which lets us manage encryption keys for our services. This allows us to generate, use, rotate and destroy AES256 encryption keys.
For all administration based services, 2FA is enabled.
We have some continual end-to-end testing of our server cluster to ensure specific key indicators are working correctly and use software to log and track with a combination of active checks and, for some things, such as back-ups, passive checks. Our set up allows use to detect unexpected behaviour early and team members are alerted if an expected behaviour has not executed as expected.
Our code is written to log any critical events for our developers to address.
8. What back-ups does SocialSignIn take?
SocialSignIn carries out backup continuously. Whilst our main datastore holds replicas of data at all times, we also run our other databases with duplicate data in ready to swap over should the need arise.
Multiple snapshots of the entire database are taken every day and we store them on a separate server from the one that holds live data.
From these various back-ups, we are able to restore the entire database in the event of a major incident. We test our disaster recovery at least annually.
9. Will you need access to our systems?
We do not need access to your systems to provide our services to you.
10. Does SocialSignIn rely on third parties to provide its services?
To date SocialSignIn has not used external developers and intends to use only in-house developers moving forward. This may change in the future but, if so, external developers would be given only limited access to code bases, no access to live data and all code/contributions would be vetted before been deployed.
We use Cloud KMS to manage encryption keys for our services. We currently use leading providers, Rackspace, Amazon Web Services, Google Cloud Services, SendGrid, Loggly and Twilio to provide hosting services. They have all been vetted and authorised by a designated approver within SocialSignIn as part of our supplier on-boarding process and we have written contracts with each of them incorporating appropriate data protection provisions to protect your personal data.
11. What audit trails are maintained to protect our data?
Our software normally maintains a record of your users’ activities in our application such as which of your users created a post to send out, who edited the post, and who created any free text notes on your followers’ messages. You can view these audit logs through the application.
12. What procedures does SocialSignIn have in place to deal with data breaches?
We are proud of our record of having no reportable data breaches to date. However, we know the importance of being prepared for an incident.
All security incidents and platform wide issues will be recorded in a Major Incident Report which will cover: the nature of the incident, the impact on your business and data subjects the resolution and any preventative action planned to avoid recurrence. We will also make an assessment as to whether the breach must be reported to the Information Commissioner and/ or affected individuals.
In the event of a data breach affecting your personal data, we will report this to you without undue delay through our normal support process.
13. Where will our personal data be processed by SocialSignIn?
We use three of the leading providers to host our data and applications, Rackspace, Amazon Web Services and Google Cloud Services. All of the live data is stored within the UK and a limited number of back-ups are stored within the EU.
Where our designated staff are permitted access to your data to fulfil their roles, they do so only from our premises.
14. What happens to our data at the end of the contract?
You are able to export your social inbox whenever you wish during your contract term. Our reports are printable and downloadable.
Once our contract with you has ended, we expunge all of your data (other than your shortened links) which then propagates through our backups. The deletion process can take up to a month to be completely removed from backups.
We retain your shortened links after our contract so that any social posts created from within our application using our link shortening service continue to redirect users to the correct location. No other information is retained or stored.
15. Will SocialSignIn help us comply with data subject rights?
You have full control over your user data and data from followers so you should be able to manage all data subject rights yourself just by using the application. If you need any specific guidance on how to do this, you can use our ‘help’ feature in the application or consult our user guide or use our online chat facility.
16. Will we be able to audit SocialSignIn premises and systems for compliance?
You will appreciate how important it is that our systems and premises ensure confidentiality for all of our clients and we do not normally allow clients to have access. We do, however, engage an external specialist to check our systems and provide a report on compliance each year and we are happy to make that available to you for your peace of mind.
Of course, if a court or regulatory body requires us to give you access, we will honour that requirement but will require you comply with our security and health and safety requirements in doing so.
17. What changes can we expect to see in our contract and services?
Your services will continue unchanged although you may see some new features within our application and we may make additional security checks when you seek our support.
The GDPR requires you, as a data controller, to include additional things in your contracts with data processors. We have, therefore, prepared new data protection provisions, which will replace those in our current contract with you. We will be in touch with each of our clients to provide details of the changes so that we can all be satisfied that we are meeting our legal obligations.