Privacy Policy

Privacy Notice

This Privacy Policy describes how Something to Say Communications collects, uses and discloses information and all related choices you have regarding that information. This Privacy Policy has been established to reflect recent changes in the European Data Protection Law.

Introduction
Something to Say Communications provides a web-based, social media, email and other digital marketing services through primary and through third-party platforms. At Something to Say Communications, we are concerned with the privacy and security of our customers, third parties and visitors, and the importance of confidentiality. This Privacy Policy demonstrates how Something to Say Communications processes information that can be used to directly or indirectly identify the data subject through the use of its website or third-party platforms.

We at Something to Say Communications collect e-mail addresses and specific personal information about clients who communicate with us via email or register with us. This Privacy Policy describes how we collect, process, use and share collected data and other useful information from our Clients and their Customers when they use our Website (www.s2scomm.com) and our Services. It also describes Client’s, and Customer’s choices regarding use, access, and correction of personal data.

If you do not agree with the data practices described in this Policy, you should not use the Website or our Services.

For the purposes of this Policy, Something to Say Communications wants to introduce new GDPR key definitions:

Personal Data: any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.

Processing: any operation or set of operations performed upon Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Controller: the natural or legal person, public authority, agency or any other body which alone or jointly with others determines the purposes and means of the processing of Personal Data; where the purposes and means of processing are determined by EU or Member State laws, the Controller (or the criteria for nominating the Controller) may be designated by those laws.

Processor: a natural or legal person, public authority, agency or any other body, which processes Personal Data on behalf of the Controller.

Any information stored on ’s platform is treated as confidential. All information is stored securely and accessed by authorized personnel only. Something to Say Communications implements and maintains appropriate technical, security and organizational measures to protect Personal Data against unauthorized or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.

Identification of the controller and data processor

Current European Data Protection Law distinguishes between the Controller and the Processor of the information. In general, the Client is the Controller of the Customer Data. As a general rule, Something to Say Communications is the Client’s Processor which processes Customer’s Personal Data on behalf of the Client.

EU-US Privacy Shield
Something to Say Communications complies with the EU – U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. If there is any conflict between the terms of this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

Something to Say Communications is responsible for the processing of Personal Data it receives, under each Privacy Shield Framework, and subsequently transfers to a Third Party (“Third Party”) acting as an agent on its behalf. Something to Say Communications complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to Personal Data received or transferred pursuant to the Privacy Shield Frameworks, Something to Say Communications is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Under certain circumstances, Something to Say Communications may be required to disclose Personal Data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

Any questions or complaints about our compliance with the Privacy Shield may be addressed to michael.donohoe@s2scomm.com.

Under particular situations, more fully described on the Privacy Shield website, they may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Legal Basis for Processing Personal Information (European Territory Visitors only)
If a visitor from the European Territories (European Economic Area and Switzerland) provides personally identifiable information, our legal position for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which it is collected

Something to Say Communications collects Personal Data from our Clients or their Customers where the processing is in our business interests, for example, administer services and fulfill obligations as a service provider. Personal Data is used to improve the content of our marketing entities.

Something to Say Communications position for processing Personal Data in certain circumstances will also be based on the consent Data Subject to do so or where we need the Personal Data to perform or enter into a contract with them. At times we may have a legal obligation to collect Personal Data from Data Subjects.

Something to Say Communications interest to process Personal Data is balanced against our Client’s and their Customer’s data protection rights and freedoms.

Information We Collect and Receive
Something to Say Communications may collect and receive Client or Customer Data in several ways:

Customer data. A Customer who may decide to sign for Client services or newsletter or products provides Something to Say Communications with an email address, a phone number, a password, a domain and/or any other details of similar accounts. Furthermore, Clients who purchase our Services will provide us with billing information, home or working address as well as credit card and banking information.

In such cases, Something to Say Communications may collect information automatically when Customers access or use the Website.

Something to Say Communications contracts with Third Parties (companies and people) to provide services to our Clients and their Customers and may need to share information with them to provide information, products or services to them. In general, Third Party Services integrates with our Services and they may share information with Something to Say Communications.

Third Party may also receive information from organizations, industries, website visitors, marketing campaigns, and affiliates. Something to Say Communications may combine data collected with the previous information and collect new information.

Sharing Personal Information

Personal Data is not shared with or sold to other organizations for commercial purposes. However, under the following circumstances, it might be possible to share Personal Data:

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.

To comply with applicable legislation. If we receive a request for information, we may disclose Information if we believe it is reasonable to disclose this information in accordance with the requirements of applicable legislation, regulations and legal procedures.

During a change in  Something to Say Communications business status. Something to Say Communications may participate in a merger, acquisition, bankruptcy, dissolution, reorganization, financing, acquisition of all or part of our company. Then, in such activities, some or all of Personal Data may be shared or transferred, in accordance with standard confidentiality agreements.

Using Personal Information

The Website is not intended for or targeted at children under 13 and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information of a child under 13, in order to delete the information, please contact us at michael.donohoe@s2scomm.com.

Client’s and Customer’s testimonials on our Website are pre-approved by the writer as they might contain personal information. We collect each Client’s or Customer’s consent via email prior to posting their names and testimonials.

Something to Say Communications acknowledges the right of its Clients’ and their Customers to access their Personal Data stored on its platform, which can be amended, deleted or updated at any time.

Data Subject’s Rights (Visitors from Europe Only)
Clients and Customers who provide us with their personal information should be informed of the following rights that they may exercise at any time:

The right of access – The right to obtain from the Controller confirmation as to whether or not their Personal Data is being processed.

The right of rectification – The right to obtain from the Controller, without undue delay, the rectification of inaccurate Personal Data concerning them.

The right to erasure – The right to obtain from the Controller the erasure of their Personal Data without undue delay.

The right to the restriction of processing – The right to obtain from the Controller restriction of processing their Personal Data.

The right to object – The right to object at any time to the processing of their Personal Data.

The previously stated rights are not unconditional. The exercise of Data Subject rights must meet precise conditions included in the General Data Protection Regulation.

In order to exercise the previous rights, requests must be sent directly to the Controller. Once it receives the request, Something to Say Communications will process the request on behalf of the Controller.

Changes and Modifications to the Policy
Something to Say Communications may modify this Policy at any time. Legislation, regulations and industry standards progress,  changes may be necessary; or could be due to changes in our processes. We will post the changes on this page to review our Policy to stay informed. Should changes occur that substantially adjust your privacy rights, Something to Say Communications will provide additional notice. If you do not agree with the changes in this Policy, you will be unable to properly use Something to Say Communications Services and Website.

Data Security
Something to Say Communications takes the security of its Clients and Customers’ data seriously and strives to protect information provided us with loss and misuse, as well as against disclosure or access. These measures take into account the sensitivity of the information we collect, process and store.

Data Retention
Something to Say Communications will keep the Client Data in accordance with the agreed-upon instructions, including any terms applicable in the Agreement with the Customer and in the use of the functionality of the Services by the Client, as well as in accordance with the provisions of the applicable legislation.

We will retain any Personal Data for a period of time consistent with the original purpose of collection, including to pursue our legitimate business activities, comply with our legal obligations, resolve disputes and enforce agreements.

The Executive Producer, acting as the Processor on behalf of the Controller, has the duty of limiting the period for which Personal Data is stored and will periodically review and evaluate that time period in order to respect data privacy expectations.

Contact Us
If you have any questions, concerns, or complaints regarding this Privacy Notice or the way we collect and handle your information, please contact our Executive Producer,  acting as the Processor on behalf of the Controller, by email at michael.donohoe@s2scomm.com. All inquiries will be handled within 72 business hours of receiving.