Later / Victory Square Media
Effective date: January 17, 2024
Victory Square Media Inc. ("us", "we", or "our") operates the https://later.com website as well as http://www.later.com website, http://www.latergram.me website, http://www.lat.gr website, http://app.later.com website, http://www.linkin.bio website, http://www.submit.media and the Later mobile application (the "Social Media Management Solution").
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Social Media Management Solution and the choices you have associated with that data. For clarity, these policies do not apply to your use of Later’s Influencer Marketing Solution by Mavrck including the https://mavrck.co website, Mavrck LLC (“Mavrck”)’s proprietary influencer marketing platform, or other influencer marketing and promotional services (the “Influencer Marketing Solution”). The Influencer Marketing Solution is owned and operated by Mavrck LLC and is subject to the Influencer Marketing Solution Privacy Policy.
We use your data to provide and improve the Social Media Management Solution. By using the Social Media Management Solution, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Definitions
Personal Data
Personal Data means data about an individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Social Media Management Solution or from the Social Media Management Solution infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small pieces of data stored on a User’s device.
Data Controller
Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.
For the purpose of this Privacy Policy, we are a Data Controller of your data.
Data Processor (or Social Media Management Solution Providers)
Data Processor (or Social Media Management Solution Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.
We may use the services of various Social Media Management Solution Providers in order to process your data more effectively.
Data Subject
Data Subject is any individual who is the subject of Personal Data.
User
The User is the individual using our Social Media Management Solution. The User corresponds to the Data Subject, who is the subject of Personal Data.
Information Collection And Use
We collect several different types of information for various purposes to provide and improve our Social Media Management Solution to you.
Types of Data Collected
Personal Data
While using our Social Media Management Solution, we may ask you to provide us with Personal Data including:
Email address
First name and last name
Social Network Authentication
We may also collect certain information automatically through cookies and similar tools (see Usage Data and Tracking & Cookies below.
We use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
Usage Data
We may also collect information that your browser sends whenever you visit our Social Media Management Solution or when you access the Social Media Management Solution by or through a mobile device ("Usage Data").
This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Social Media Management Solution that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Social Media Management Solution by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
We use cookies and similar tracking technologies to track the activity on our Social Media Management Solution and hold certain information.
Cookies are files with small amounts of data which may include a unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Social Media Management Solution.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Social Media Management Solution.
Examples of Cookies we use:
Session Cookies.We use Session Cookies to operate our Social Media Management Solution.
Preference Cookies.We use Preference Cookies to remember your preferences and various settings.
Security Cookies.We use Security Cookies for security purposes.
Some of our service providers also use cookies and tracking tools. See Analytics and Behavioural Remarketing below.
Use of Data
Victory Square Media Inc. uses the collected data:
To provide and maintain our Social Media Management Solution
To notify you about changes to our Social Media Management Solution
To allow you to participate in interactive features of our Social Media Management Solution when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our Social Media Management Solution
To monitor the usage of our Social Media Management Solution
To train machine learning models
To detect, prevent and address technical issues
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information
Retention of Data
Victory Square Media Inc. will retain your Personal Data on our servers or those of our service providers only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
Victory Square Media Inc. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Social Media Management Solution, or we are legally obligated to retain this data for longer time periods.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computer systems owned or controlled by us or our service providers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside Canada and choose to provide information to us, please note that we transfer the data, including Personal Data, to Canada and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Victory Square Media Inc. will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure Of Data
Business Transaction
If Victory Square Media Inc. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Disclosure for Law Enforcement
Under certain circumstances, Victory Square Media Inc. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
Victory Square Media Inc. may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation
To protect and defend the rights or property of Victory Square Media Inc.
To prevent or investigate possible wrongdoing in connection with the Social Media Management Solution
To protect the personal safety of users of the Social Media Management Solution or the public
To protect against legal liability
Service Providers
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Social Media Management Solution. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Firebase
Firebase is an analytics service provided by Google Inc.
You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy
We also encourage you to review the Google's policy for safeguarding your data: https://policies.google.com/privacy
Mixpanel
Mixpanel is provided by Mixpanel Inc
You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page:https://mixpanel.com/optout/
For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel:https://mixpanel.com/terms/
Behavioral Remarketing
Victory Square Media Inc. uses remarketing services to advertise on third party websites to you after you visited our Social Media Management Solution. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Social Media Management Solution.
Google AdWords
Google AdWords remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on -https://tools.google.com/dlpage/gaoptout- for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/ Canada
http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/ For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
Pinterest remarketing service is provided by Pinterest Inc.
You can opt-out from Pinterest's interest-based ads by enabling the "Do Not Track" functionality of your web browser or by following Pinterest instructions:http://help.pinterest.com/en/articles/personalization-and-dataYou can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page:https://about.pinterest.com/en/privacy-policy
Payments
We may provide paid products and/or services within the Social Media Management Solution. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
Apple
Their Privacy Policy can be viewed at: https://www.apple.com/legal/privacy/data/en/apple-pay/
Stripe
Their Privacy Policy can be viewed at: https://stripe.com/us/privacy
Profitwell
Their Privacy Policy can be viewed at: https://www.profitwell.com/privacy-policy
YouTube API
Linking your YouTube account to the Social Media Management Solution involves using YouTube’s API connection. You can revoke the Social Media Management Solution’s access to this data through the Google security settings page, here: https://myaccount.google.com/connections?filters=3,4&hl=en.
Legal Basis for Processing
We rely on one or more of the following legal grounds (as appropriate) to process Personal Data:
To enter and perform a contract with you or to perform any steps you require from us before entering into a contract.
To pursue our legitimate business interests in establishing, managing or concluding our business relationship with you.
Where you have specifically consented to us processing your Personal Data.
To comply with our legal obligations and establish, exercise or defend our legal rights.
Where Personal Data is processed with consent, you may (subject to contractual and legal restrictions) refuse to provide your consent, or choose to withdraw your consent by contacting us as described below. Note that if you refuse to consent, or withdraw your consent, to certain processing of your personal information, we may not be able to provide certain of our services.
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. Authorized employees, representatives and agents will have access to your Personal Data for the purposes described in this Privacy Policy.
Your Rights
Victory Square Media Inc. aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
Whenever made possible, you can update your Personal Data directly within your account settings section. If you are unable to change your Personal Data, please contact us to make the required changes.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the right:
To access and receive a copy of the Personal Data we hold about you
To rectify any Personal Data held about you that is inaccurate
To request the deletion of Personal Data held about you
You have the right to data portability for the information you provide to Victory Square Media Inc.. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.
Please note that we may ask you to verify your identity before responding to such requests.
Links To Other Sites
Our Social Media Management Solution may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Children's Privacy
Our Social Media Management Solution does not address anyone under the age of 13 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Children have provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Security Vulnerabilities
If you wish to report a security vulnerability, please contact us with:
Sufficient details of the vulnerability to allow it to be understood and reproduced.
HTTP requests and responses, HTML snippets, screenshots or any other supporting evidence with personal data removed
Proof of concept code (if available).
The impact of the vulnerability.
Any references or further reading that may be appropriate.
Changes To This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Social Media Management Solution, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Contact Us
If you have any questions about this Privacy Policy, please contact us:
By email: hello@later.com
10. Social Media
Through the Later Influence Services, you may choose to access certain Social Media Services. When you elect to access and use the Social Media Services, you will be sharing your information (which will include Personal Data) with those Social Media Services. As with other External Sites, the information that you share with the Social Media Services will be governed by the privacy policies and terms of service of the providers of such Social Media Services and not by the Later Influence’s policies and procedures. You may also be able to modify your privacy settings with these Social Media Services to, for example, control what information the Social Media Services disclose to other entities, including Later Influence.