Converseon, Inc. (“Converseon” or “the Company”) provides social and voice-of-customer data quality and programmatic insight through AI-powered technology, ecosystem partners and industry experience (est. 2001).
Converseon respects your privacy and is committed to protecting the personal information we hold about you. This Privacy Policy explains our practices with respect to personal information we collect and process about you. This includes information we collect through, or in association with, our website with a home page located at www.converseon.com, our platform and online tools that allow our customers to monitor, access, and manage Social Media Content (as defined below) relating to their brand, their activities, and their industry, and analyze trends in Social Media Content (collectively, the “Converseon Services”).
Please review the following to understand how we process and safeguard personal information about you. By using the Converseon Services and/or by voluntarily providing personal information to us, you acknowledge that you have read and understand the practices contained in this Privacy Policy. This Privacy Policy may be revised from time to time, so please ensure that you check this Privacy Policy periodically to remain fully informed.
Processing of Social Media Content
To provide Converseon Services, we process user-generated content from a variety of publicly available sources such as internet forums, weblogs, social blogs, microblogs, wikis, social networks, and social bookmarking sites (collectively, “Social Media Content”) provided by third-party platforms. In general, anyone can find the Social Media Content that we process via a standard Internet search engine or by visiting applicable websites themselves. We receive access to this data through agreements and partnerships with social listening companies. We do not circumvent technical controls in place to prevent unauthorized access, such as usernames and passwords or use of CAPTCHA technology.
Social Media Content may include information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). In addition, we may process data that is not identifiable to a particular consumer or household or otherwise associated with such, such as aggregated data, and is not Personal Information. To the extent this data is stored or associated with Personal Information, it will be treated as Personal Information; otherwise, the data is not subject to this Privacy Policy.
Use of Social Media Content
Converseon’s customers are responsible for their use of Social Media Content. We require our customers to use Social Media Content in accordance with our End User Licensing Agreement, the terms of service of the applicable website/platform from which the Social Media Content is obtained or derived, and applicable law.
Metrics
As part of Converseon Services, we display to our customers certain metrics relating to individual posts and the individuals associated with Social Media Content to the extent such information is publicly available and/or available via API from the relevant website operators/platforms. Examples of metrics applicable to any particular post include the number of comments, number of unique commenters, number of likes and number of followers. These metrics, and others, allow our customers to better analyze Social Media Content.
Analytics
We also provide various tools within Converseon Services that permit our customers to analyze Social Media Content, such as categorizing Social Media Content and displaying it through various graphs and representations as well as supplementing it with other data and insights. In some cases, we use third parties to provide additional analysis of and supplemental data for the Social Media Content. By third parties, we are referencing our business partners and/or vendors. We also provide our customers with the ability to conduct historic analysis on Social Media Content to the extent such data is available to us.
Collection of Personal Information
Converseon is provided with Personal Information from customers and clients in the course of their engagement with the Company. We will use Personal Information only in a manner compatible with specified and legitimate purposes related to his/her dealings with the Company including, but not limited to:
- Communicating with you about the Converseon Services;
- Accounts receivable and finance;
- Keeping accounts and records of business transactions;
- Monitoring and promotions of equal opportunity;
- Regulatory and professional requirements;
- Prevention and detection of crime;
- Quality control;
- Processing Personal Information on behalf of a client/customer;
- Complying with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, or for other purposes, as permitted or required by law; and
- As necessary or appropriate to protect the rights, property, and safety of our users, us, and other third parties.
Converseon shall provide the individual with the choice and means for limiting the use of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to the Company, or as soon as practicable thereafter, and in any event before the Company uses the information for a purpose other than for which it was originally collected. Converseon will offer individuals the opportunity to choose (opt-out) whether their Personal Information is to be used for a purpose other than for which it was originally collected or subsequently authorized by the individual.
Disclosure of Personal Information
We may be required to disclose an individual’s Personal Information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements, and/or to protect the integrity of the Converseon Services or our interests, rights, property, or safety, and/or that of our users and others.
Legal Basis for Processing Personal Information
We are able to legally collect and use your Personal Information either because:
- you have provided us with your consent to do so as explained above;
- collecting and using your Personal Information is necessary for us to carry out our legitimate business interests in order to carry out any requests or orders made by you via our website;
- collecting and using your Personal Information is necessary for the performance of a contract to which you are a party; and/or
- collecting and using your Personal Information is necessary for compliance with a legal obligation.
Security/Data Integrity
Converseon uses commercially reasonable physical, organizational, and technical safeguards to preserve the integrity and security of Social Media Content and Personal Information. The Company has put in place appropriate physical, electronic, and managerial procedures to safeguard and secure Social Media Content and Personal Information from loss, misuse, unauthorized access or disclosure, alteration, or destruction. Converseon cannot guarantee the security of Social Media Content or Personal Information on or transmitted via the Internet.
Data Retention
We retain Personal Information to the extent we deem necessary to carry out the processing activities described above, including but not limited to compliance with applicable laws, regulations, rules and requests of relevant law enforcement and/or other governmental agencies, and to the extent we reasonably deem necessary to protect our and our partners’ rights, property, or safety, and the rights, property, and safety of our users and other third parties.
Your Rights Regarding Personal Information
You may have certain legal rights regarding the collection and processing of Personal Information held by us (subject to limited lawful exceptions). You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Policy.
- Your California Privacy Rights
California’s “Shine the Light” law, permits our users who are California residents to request and obtain from us a list of what Personal Information (if any) we disclosed to third parties for their own direct marketing purposes in the previous calendar year and the names and addresses of those third parties. Requests may be made only once per year per person, must be sent to the email address below, and are free of charge. However, we do not disclose Personal Information protected under the “Shine the Light” law to third parties for their own direct marketing purposes.
- Your Nevada Privacy Rights
Nevada law permits our users who are Nevada consumers to request that their Personal Information not be sold (as defined under applicable Nevada law), even if their Personal Information is not currently being sold. Requests may be sent to the email address below and are free of charge.
- Your European Union, UK, and Switzerland Privacy Rights
Converseon Inc. complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Converseon has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Converseon has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
In compliance with the EU-US Data Privacy Framework Principles, Converseon commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles. European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact
Converseon Privacy
500 7th Ave, 8th Floor
New York, NY 10018
privacy@converseon.com
Converseon has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers for more information and to file a complaint. This service is provided free of charge to you.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2
Other Important Information About Personal Information and the Converseon Services
- Communications Opt-Out. You may opt out of receiving marketing or other communications from us at any time through a given communications channel by following the opt-out link or other unsubscribe instructions provided in any email message received. If you wish to opt out by sending us an email to the address provided below, please include “Opt-Out” in the email’s subject line and include your name and the email address you used to sign up for communications in the body of the email. Note that if you do business with us in the future, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g., e-commerce).
- Third-Party Websites and Services. As a convenience, we may reference or provide links to third-party websites and services, including those of unaffiliated third parties, our affiliates, service providers, and third parties with which we do business. When you access these third-party services, you leave our platform and we are not responsible for, and do not control, the content, security, or privacy practices employed by any third-party websites and services. You access these third-party services at your own risk. This Privacy Policy does not apply to any third-party services; please refer to the privacy notices or policies for such third-party services for information about how they collect, use, and process Personal Information.
- Collection of Personal Information from Children. You are not permitted to use the Converseon Services if you are under the age of 18. By using the Converseon Services, you represent that you are 18 years of age or older. While Social Media Content may include information related to children who are under the age of 18, the Company does not knowingly collect information from children, and the Converseon Services are not intended to be used or accessed by children.
- Business Transfer. We may, in the future, sell or otherwise transfer some or all of our business, operations or assets to a third party, whether by merger, acquisition or otherwise. Personal Information we obtain from or about you via the Converseon Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.
- International Use. Your Personal Information will be stored and processed in the United States. If you are using the Converseon Services from outside the United States, by your use of the Converseon Services, you acknowledge that we will transfer your data to, and store your Personal Information in, the United States, which may have different data protection rules than in your country, and Personal Information may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities in the United States.
Changes to the Privacy Policy
This Privacy Policy may be revised periodically without further notice to you and this will be reflected by a “last updated” date below. Please revisit this page to stay aware of any changes. In general, we only use your Personal Information in the manner described in the Privacy Policy in effect when we received that Personal Information. Your continued use of the Converseon Services constitutes your agreement to this Privacy Policy and any future revisions.
Applicability of this Privacy Policy
This Privacy Policy is subject to the Terms of Service that govern your use of the Converseon Services. This Privacy Policy applies regardless of the means used to access or provide information through the Converseon Services. This Privacy Policy does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Converseon Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.
Contact Information
If you have questions, comments, or concerns about this Privacy Policy or our processing of your Personal Information, please contact the Converseon Privacy Office at:
Converseon Privacy
500 7th Avenue, 14th Floor
New York City, New York, 10018
privacy@Converseon.com
Date Last Updated: October 10, 2023