Privacy

Policy

Last updated: January 27, 2020


SOSA USA LLC (“SOSA”, “we” “our” or “us”) recognizes the importance of protecting the privacy of information we may receive from users of our website (the “Website”). For the purposes of this Privacy Policy, users include anyone who accesses the Website (together, “User”, “you” or “your”). This Privacy Policy, along with our Terms of Use, describes the information qe collect from Users, how we may use it and with whom we may share that information, the safeguards we use to protect such information and the choices you may make with respect to your personal information. Defined terms not otherwise defined herein shall have the same meaning as in our Terms of Use.

  1. Information We Collect

We have constructed the Website so that you may review information about our services, without revealing your identity or volunteering any personally identifying information. If you choose to contact us, request information, inquire about a service or subscribe to our newsletter, we will collect personally identifiable information (“PII”) from you, such as that indicated below, and this information may be combined, to provide you with information or service you request and to ensure that we maintain complete, current and accurate personal information. 

In order to receive information from the Website, you may be required to provide us with certain information, including, for example, your name and e-mail address.  Failure to provide such data may make it impossible for us to provide you with the requested information or service. 

  1. Cookies

The Website may deploy cookies.  A cookie is a unique text file that a website sends to your browser software. Cookies enable a website to tailor information presented to you based on your browsing preferences. We currently do not deploy cookies on our Website, but some cookies may be placed by our third-party service providers on your computer or device and provide information about your browsing habits (such as your visits to our Website and the pages you have visited).  For example, we use the services of Mailchimp in connection with our newsletters, and Mailchimp uses cookies in connection with the services it provides to us. To learn more about Mailchimp’s cookies practices, please visit Mailchip’s Cookie Statement at https://mailchimp.com/legal/cookies/. We do not control third party cookies.

  1. Use of Information We Collect

We may use PII or aggregate and/or de-identified data about Users (“Aggregate Information,” or “AI”) for various purposes, including:

  • administering and enabling use of the Website, including, but not limited to, communications at the email or physical addresses, or phone number provided by you, notification regarding the Website, such as any future amendments to its privacy practices or this Privacy Policy;
  • ensuring all Users follow our Terms of Use and other rules and policies; 
  • banning a User temporarily or permanently for failure to follow our Terms of Use, rules and policies, or for other misconduct or inappropriate behavior; 
  • responding to questions and comments from Users; 
  • enabling Users to receive newsletters, updates, and other materials related to us; 
  • monitoring and analyzing the Website (including, but not limited to, measuring Users’ interest in, and use of, various areas of the Website);
  • improving the functionality, design and quality of the Website;
  • performing the technical administration of the Website;
  • investigating cases of suspected abuse or fraud; 
  • preparing statistical and other summary analyses of our Users’ behavior; and
  • any other purpose that we determine at our discretion is related to the use, advertising, marketing, promotion or other of our, or the Website’s legitimate purposes

(Collectively, “Our Purposes”).

Information You Provide Through the Website

We will utilize PII you provide us through the Website for the purpose for which you submitted it to us, such as to respond to your inquiry, provide you with our newsletters, or any of Our Purposes. By voluntarily providing us with your PII, you are consenting that we may use such PII in accordance with this Privacy Policy. 

We do not collect or maintain PII for resale purposes or share your information with any other company or organization, except as indicated herein or to the extent such other company or organization is acting as our agent for purposes of communicating with you by mail, e-mail, or otherwise. In addition, we will not send promotional materials to Users who indicate that they do not wish to receive such messages.  

  1. Disclosure of Personal Information

We may share your personal information with our carefully selected vendors, third party service providers and agents where it is necessary for Our Purposes. These parties may include web analytics service providers, such as Google Analytics for web analysis purposes.

We will provide these companies only with the information they need to deliver the service we have requested, and they are prohibited from using that information for any other purpose.

We may also share PII when we believe it is necessary to:

  • Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law.  We may, without providing notice to you, disclose any information about Users, including PII, to government or law enforcement officials or private parties where we are required to do so by law, including, but not limited to, in response to a court order or subpoena.  We may also, without providing notice to you, disclose PII in response to a request by a law enforcement agency or other public agency or if we believe such disclosure may prevent or mitigate the threat of crime or harm to Users or others, facilitate an investigation related to a User’s safety or public safety, protect the security or integrity of our Website, or enable us to take precautions against liability;
  • Protect us, our business or our Users, for example to enforce our Terms of Use, prevent spam or other unwanted communications and investigate or protect against fraud;
  • Maintain the security of our Website, products and services

Service providers and other third parties

We may also share PII with third parties when you give us consent to do so.

Processing the data collected through the Website is carried out using computers and/or IT enabled tools, following organizational procedures and modes related to Our Purposes. We may employ third party companies and individuals to facilitate the operation of the Website, and to perform services related to administration of the Website (including, but not limited to, maintenance, hosting and database management services, web analytics and administration and legal services).  These third parties have access to Users’ PII and other personal data only to perform these tasks on our behalf. We may share AI, and reports based on AI, with third parties for industry analysis, demographic profiling, other commercial purposes, or to deliver targeted advertising about other products and services.  No such AI that we provide to third parties will contain PII.

Operation Transfers 

In connection with a sale of all or part of our operations, or sale or transfer of assets, or a merger, reorganization, or in the event of bankruptcy, we may transfer PII to a third party as part of the transaction, to the extent permitted by applicable law.

 

  1. Your Privacy Choices

If a User becomes aware that PII we maintain about them is inaccurate, incomplete, misleading, irrelevant or out of date, or if an individual would like to access, update or review their information, the individual is solely responsible for updating such information, and may do so by contacting us using the contact information below. We will attempt to provide the requested information or make requested changes to the extent allowable by applicable privacy laws. In any event, we will respond to you as soon as reasonably possible to advise you of the outcome of your request. You may request the removal of previously provided PII at any time using the contact information below. The deletion of such data, however, may affect our ability to provide you with our services.  We reserve the right to verify the identity of any person making an opt-out or correct/update request, but shall have no liability whatsoever resulting from false or erroneous requests.  You may update your PII, communications preferences, or opt out from receiving promotional materials at any time by contacting us at gcc@sosa.co.

  1. Retention

We retain PII for the period necessary to fulfil Our Purposes. In some cases, we retain PII for longer, if doing so is necessary to comply with our legal obligations, resolve disputes, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

  1. Updates to Our Privacy Policy/Notification of Changes

As a result of potential improvements to the Website, changes in the law and/or the changing nature of technology, our data practices may change from time to time. Accordingly, we reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. If and when our data practices change, we will post the revised Privacy Policy on the Website. Such changes to the Privacy Policy will become effective when posted. Unless stated otherwise, our current Privacy Policy applies to all PII that we have about you. We stand behind the promises we make, however, and will not materially change our policies and practices to make them less protective of PII collected in the past without the consent of affected individuals. Notwithstanding the above, your continued use of the Website after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy. We encourage you to check this Privacy Policy regularly.  

  1. Security

Please note that any information you share with us via email or via the internet is not completely secure. We take reasonable steps to protect the PII provided via the Website from loss, misuse and unauthorized access or disclosure, however, no internet or e-mail transmission is ever fully secure or error free. Due to the nature of the internet, there is a possibility that unsecured (unencrypted) email or internet transmissions could be intercepted and read by third parties. We assume no responsibility for interception of confidential information or personal information that you send in an unsecured (unencrypted) email message or other internet transmission to and from the Website. Therefore, you should take special care in deciding what information you send to us via the Website, e-mail or via another internet transmission.

You acknowledge and accept that, despite our efforts, there may be times or situations when your PII is inadvertently disclosed by us or by a third party to whom we have disclosed your PII.  You hereby accept that risk and waive any and all claims, causes of action, damages and liability against us in the event of such inadvertent or negligent disclosure of PII.

  1. Links to Third Party Sites

This Privacy Policy applies only to our Website.  The Website may at times contain links to other websites that are not owned or controlled by us. Please be aware that We are not responsible for the privacy policies of such other websites or how these websites operate or treat your personal information. 

In no event will we be responsible for the information contained in such links or websites, their practices or for your use of, or inability to use, such links or websites or their services, or transmissions received from such websites. By using the Website, you expressly relieve and discharge us from any and all liability arising from your use of any third-party website. We encourage you to be aware of this when you leave the Website and to read the privacy policies and terms of use associated with each of any third-party websites that may collect personal information.

  1. Your Choices and Opt-Outs

You can opt out of receiving marketing emails from us at any time. You can opt out of our marketing emails by clicking the ‘unsubscribe’ link at the bottom of our marketing messages.

Also, all opt out requests can be made by emailing us at gcc@sosa.co.  Please note that it may take up to 3 days to remove your contact information from our marketing communications lists, so you may receive correspondence from us for a short time after you make a request.

  1. Cross Border Transfers

This site is intended for use by persons and businesses located and operating in the United States.  If you visit the Website from a country other than the United States, your communications will likely result in the transfer of your PII across national borders. Our servers or offices may be located in countries other than the country from which you access the Website, also resulting in the transfer of your PII across international borders. If you provide your PII when visiting the Website from outside of the United States, you acknowledge and agree that this data may be transferred from your then current location to our offices and servers and to those of our affiliates, agents, and service providers located in the United States and in other countries. The United States and such other countries may not have the same level of data protection as those that apply in the jurisdiction where you live.

  1. Other Terms and Conditions

This Privacy Policy is incorporated into the Terms of Use. Your access to and use of the Website is subject to the Terms of Use. 

  1. Questions About Our Privacy Policy

If You have any questions about this Privacy Policy or concerns about the way we process your personal information, or require assistance in managing your privacy choices, please contact us using the contact information below.

149 Fifth Avenue, New York NY 10010, USA

gcc@sosa.co