This policy is effective as of June 26, 2013.
Sprinklr is a social media management system (a “SMMS”). The Sprinklr system is a tool that enables companies and organizations, or Sprinklr “Customers”, to process and manage publicly available information about their brand on the Internet.
This means that the Sprinklr system aggregates and saves a record of public information that is available about your interaction with a company or organization on the Internet.
Sprinklr proactively encourages each Customer to engage in privacy best practices. While Sprinklr cannot guarantee that is Customers will abide by the best practices in user privacy, it does its best to make sure that everyone that is a part of its ecosystem is aware of those practices and has received concrete guidance concerning implementation. Of course, Sprinklr Customers are responsible for their own use of the Sprinklr platform. Please review the Customer’s individual terms of service and privacy policies for information on their privacy practices.
Although the information collected within our platform is primarily publicly available, Sprinklr complies with the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal data from the European Union (concerning our Customers whose use of the Sprinklr system may constitute a cross-border transfer of data). The following are Sprinklr’s promises to each Customer:
1) Notice. When Sprinklr collects your personal information, we give you timely and appropriate notice describing what personal information we are collecting, how we will use it and the types of third parties with whom we may share it. This notice is located in this policy. Sprinklr has advised its Customers to provide similar notice to their unique customers and partners of their use of the Sprinklr system.
2) Choice. Sprinklr will give you choices about the ways we use and share your personal information, and we will respect the choices you make. Please recognize that Sprinklr is a system used by Customers and, as such, we advise and encourage our Customers to take appropriate action with respect to their own privacy standards as it relates to social media management.
3) Relevance. Sprinklr will collect only as much personal information as is required to meet the specific, identified purposes of Customer contracts, and we will not use it for other purposes without obtaining your consent.
4) Retention. Sprinklr will keep your personal information only as long as we need it for the purposes for which we collect it, or as permitted by law.
5) Accuracy. Sprinklr will take appropriate steps to make sure access to your personal information in our records is accurate, as much as is within the power of Sprinklr as a system used by its Customers.
6) Access. Sprinklr will provide ways for you to access your personal information as quickly as possible upon request, as required by law, so you can correct inaccuracies.
7) Security. Sprinklr will take appropriate physical, technical and organizational measures to protect your personal information from loss, misuse, unauthorized access or disclosure, alteration and destruction. Sprinklr and its Customers enter into agreements requiring that Sprinklr use the highest industry standards with respect to storage of data and the security of its system.
8) Sharing. Except as described herein, Sprinklr will not share your personal information with third parties without your consent. As standard policy, Sprinklr’s Customer agreements prohibit the sharing of information beyond communication with a specific Customer.
9) International Transfer. If Sprinklr is used to transfer your personal information to another country, Sprinklr will take appropriate measures to protect your privacy and the personal information transferred.
10) Enforcement. Sprinklr will regularly review how we are meeting these privacy promises, and we provide an independent way to resolve complaints about our privacy practices (see below).
Sprinklr complies with the U.S.-Swiss Safe Harbor framework set forth by the Department of Commerce in addition to the U.S.-EU Safe Harbor program. To learn more about the Safe Harbor program, and to view Sprinklr’s certification, please visit http://www.export.gov/safeharbor/.
To access your information, ask questions about our privacy practices or issue a complaint, contact us at:
Sprinklr Privacy Compliance
29 W. 35th St. 8th Floor
New York, NY 10001
To learn more about our Privacy Policies for the Sprinklr platform, please read below.
Notice Concerning Content Shared Online by Children
Sprinklr does not direct any of its business practices or system outputs directly or indirectly towards children. We are committed to respecting the privacy of children online and ensuring that Sprinklr is compliant with the Children’s Online Privacy Protection Act (COPPA). If Sprinklr learns that the information of a child under the age of 13 is stored within its platform, Sprinklr will promptly notify Customer representatives and delete any personal information in that user’s account or any other profile information that Sprinklr has been used for.
Sprinklr’s indexing of publicly available information will include information from public websites and profiles that may have in error granted accounts to children under the age of 13. Sprinklr is not accountable for the faulty verification practices deployed by third party websites or social channels.
How the Sprinklr Platform Works
Sprinklr provides tools to allow its Customers to manage the publicly available information on Internet users primarily through social media. The use of Sprinklr by its Customers generally falls into five categories: Analytics, Audience, Engagement, Governance and Integration. The core capabilities and functionality that Sprinklr provides its customers are outlined below – greater detail and a more comprehensive list of features and functionality can be provided upon request:
1) Analytics features allow Customers to:
- Analyze and report on individual, group and overarching brand performance;
- Associate outgoing messages with campaigns, keywords and other variables for brand analysis;
- Rapidly build and share dashboards and reports with pre-configured widgets;
- Compare analytics across social channels, campaigns, and persistent searches;
- Customize reporting across various KPIs such as engagement, reach and activity;
- Integrate reporting with external data systems; and
- Export reporting to CSV file format.
2) Audience features allow Customers to:
- Perform multi-channel, multi-function and multi-division support for engagement, reporting and monitoring;
- Simplify inbound content workflows with queues, message assignment for notifications and/or escalation;
- Identify and profile audience members that require routing for notification or escalation based on influence;
- Develop an holistic view of performance and integrate this data with a Customer’s existing web analytics platforms;
- Optimize messages to target specific audiences; and
- Manage conversations in multiple languages.
3) Engagement features allow Customers to:
- Rely on multi-channel, multi-function and multi-division support for engagement, reporting and monitoring across Facebook, Twitter, YouTube, LinkedIn, Google+, SlideShare, Instagram, Vkontakte, Sina Weibo, RenRen, QQ and other social channels as they emerge and are added to the Sprinklr channel portfolio;
- Identify and profile audience members that require routing for notification or escalation based on influence, sentiment, tone, past engagement and other custom variables;
- Create customized approval workflows based on user permissions;
- Simplify inbound content workflow with queues, message assignment and notifications;
- Identify and profile brand advocates and key influencers;
- Filter messages to identify and delete spam, and the “spammers” propagating undesirable conversations and content, using our proprietary “Spam Index”;
- Determine most active members via our “Participation Index”;
- Search, filter and analyze audience members and create rules to automatically tag, segment, and profile them; and
- Determine sentiment via automated and manual scoring through our Natural Language Processing system.
4) Governance features allow Customers to:
- Manage access at the division, social account, and user role levels;
- Track interaction and activity enterprise-wide;
- Assign message approvers and change permissions and passwords;
- Configure multi-user, group or individual routing, queues, notifications and escalation procedures;
- Define automated, customizable and flexible rules, filters, actions and alerts.
- Standardize reporting metrics;
- Maintain a global content schedule and calendar via the Sprinklr Planner;
- Create templates for Social apps with object “lock down” in the Social App Suite;
- Centralize digital asset inventory and management; and
- Establish automated and manual workflow options.
5) Integration features allow Customers to:
- Shorten URLs via bit.ly or your own domain URL;
- Implement domain white-labeling;
- Build and deploy custom widgets for your corporate intranet;
- Integrate with web analytics tools for holistic measurement;
- Connect with CRM systems; and
- Employ the Social Bar as an interstitial that frames posted links with customized content.
Sprinklr Customers use the platform to perform functions with the system as outlined above. Sprinklr has provided each of its Customers with suggested guidelines, Sprinklr’s Privacy Guidelines for Customers, which fall in line with the Sprinklr policies that are outlined in this document.
The Content the Sprinklr Platform Allows Customers to Index
Sprinklr is a social media management system that lets companies manage and measure social media content. A monitoring dashboard enables users to track keywords, influencers and competitors. Dashboards can be shared across the organization to improve operational efficiency. The intent of Sprinklr is that the information that Sprinklr is indexing can be found by anyone online using a search engine.
Sprinklr’s Customers use the Sprinklr system to aggregate publicly available content on the Internet. This includes, but is not limited to:
- Sina Weibo;
- RenRen; and
Sprinklr does not circumvent any of your personal privacy settings on any of the platforms that it indexes content from. The Sprinklr system is intended for the use of publicly available information. Sprinklr does not bear responsibility for its Customers use of the platform with non-public information. Sprinklr has implemented security practices to account for this use of the platform as a safeguard.
How Sprinklr Uses Your Content
Sprinklr is a social media management system deployed and used primarily by its Customers. As such, Sprinklr’s Customers are the ones who are indexing content using the Sprinklr tool. Sprinklr requires each one of its customers to sign agreements with Sprinklr that align with Sprinklr’s privacy practices. We also require as part of these agreements that Sprinklr Customers agree to abide by the policies of third-party websites, such as Facebook and Twitter, as well as comply with all US, European Union, Swiss and Canadian privacy laws.
The Sprinklr system allows its Customers to communicate with Internet users who post content publicly on social networking services and other sites. Again, Sprinklr customers are given privacy guidelines for these types of communications and agree to abide by the policies of third-party websites, such as Facebook and Twitter, as well as comply with all applicable US, European Union, Swiss and Canadian privacy laws.
Any private communications between Sprinklr Customers and Internet users through the Sprinklr platform are maintained in accordance with the Sprinklr Terms of Service.
The Sprinklr platform allows Customers to monitor Internet users who interact with the Customer through publicly available content.
For example, if an Internet user Tweets about the fictitious brand “Joe’s Shoes” and their Tweets are set to “public” in their Twitter privacy settings, Joe’s Shoes would have the ability, by using the Sprinklr system, to track this Internet user to determine if these actions and sentiments lead the Internet user to become a customer, make a purchase or in some other ways interact with the Joe’s Shoes brand.
The Sprinklr platform also allows its customers to post advertisements and campaigns. Sprinklr’s Privacy Guidelines for Customers provides guidelines for use of this feature so that it may be used in compliance with the Federal Trade Commission’s .com Disclosures guidelines to avoid engaging in unfair and deceptive marketing practices. Sprinklr urges all of its Customers to be as transparent as possible in their use of the Sprinklr system.
Accessing Your Information Stored on the Sprinklr Platform
You have the right, upon written request, to access the publicly available information that Sprinklr processes. If such content is found, Sprinklr will inform you about such content (limited by others’ privacy interests or legal rights), how it is being used and other information as required under applicable law. This obligation is only in relation to content that is directly held by Sprinklr, not in any information that is held by its Customers and not Sprinklr.
To make a request, please send a letter or an email to Sprinklr Privacy Compliance. Please include the following information in your request:
1) Your Name;
2) Your Contact Information, including phone number, address and email; and
3) The Precise nature of your request.
Such requests can be sent to email@example.com or be mailed to:
Sprinklr Privacy Compliance
29 W. 35th St. 8th Floor
New York, NY 10001
Sprinklr’s Mobile Application for Customer Use
Sprinklr’s mobile application (offered for Android and iOS) is available for download and use in the iTunes Store and Google Play Store. Sprinklr’s applications are only for use by Customers of Sprinklr. If you are not a Customer of Sprinklr, you should un-install the application from your device immediately.
Sprinklr’s Full U.S.-EU Safe Harbor and U.S.-Swiss Safe Harbor Policy
There is a distinction between the use of public information, public record information and non-public information through the Sprinklr system. Sprinklr is used by its Customers for a variety of purposes.
“Personal Information” or “Information” means information that (1) is transferred from the EU or Switzerland to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.
“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.
Sprinklr shall inform an individual of the purpose for which it collects and uses the Personal Information and the types of non-agent third parties to which Sprinklr discloses or may disclose that Information. Sprinklr shall provide the individual with the choice and means for limiting the use and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Sprinklr, or as soon as practicable thereafter, and in any event before Sprinklr uses or discloses the Information for a purpose other than for which it was originally collected.
Sprinklr will offer individuals the opportunity to choose (opt out) whether their Personal Information is (1) to be disclosed to a third party, or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, Sprinklr will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Sprinklr shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.
Prior to disclosing Personal Information to a third party, Sprinklr shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Sprinklr shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is required by the Principles and agree in writing to provide an adequate level of privacy protection.
Sprinklr shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Sprinklr has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Sprinklr cannot guarantee the security of Information on or transmitted via the Internet.
Sprinklr shall only process Personal Information in a way that is compatible with and relevant to the purpose for which it was collected or authorized by the individual. To the extent necessary for those purposes, Sprinklr shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.
Sprinklr shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual may be violated.
If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using the European data protection authorities (EU DPAs) and Swiss Federal Data Protection and Information Commissioner (FDPIC) as a third party resolution provider.
Information Subject to Other Policies
Sprinklr’s Security Controls
The completion of the SOC 1 Type I examination typifies Sprinklr’s continued commitment to create and maintain the most stringent controls needed to ensure the highest quality and security of services provided to its Customers.
General Amendments and Updates to this Sprinklr Social Media Management System Policy