Privacy Policy
1. Who we are
Socialbear Limited (“Socialbear”, “we”, “us” or “our”) provides customer support, community management, social media moderation, crisis communications and AI-assisted support services.
Socialbear Limited is registered in England and Wales under company number 08775064.
Contact address:
Socialbear Limited
30 Churchill Place
London
E14 5RE
United Kingdom
For privacy enquiries or to exercise your data-protection rights, contact:
Email: privacy@socialbear.com
Telephone: +44 203 984 9410, +1 646 440 0601
Where Socialbear determines why and how personal data is processed, Socialbear acts as the data controller. When we process personal data solely on a client’s instructions while delivering services, the client normally acts as controller and Socialbear acts as processor.
2. Scope of this notice
This notice explains how we collect and use personal data relating to:
Visitors to our websites;
Prospective and existing clients;
Individuals who contact us or request information;
Suppliers, partners and business contacts;
Job applicants;
Users of our platforms and services; and
Individuals whose content or communications we process when providing customer support, moderation or community-management services for clients.
Where we process personal data on behalf of a client, that client’s privacy notice may provide additional information about the processing.
3. Personal data we collect
Depending on your relationship with Socialbear, we may process:
Identity and contact information, including names, job titles, organisations, telephone numbers and email addresses;
Information submitted through contact, enquiry, demonstration or recruitment forms;
Business correspondence, meeting notes and service requirements;
Account, authentication and access information;
Technical information such as IP addresses, device information, browser details, timestamps and security logs;
Website usage information and cookie identifiers;
Customer-support enquiries, social media comments, messages and other communications processed for our clients;
Service-quality, moderation, escalation and performance information;
Contract, billing and transaction information;
Recruitment information, including employment history, qualifications and application materials; and
Information necessary to investigate security, safeguarding, fraud or misuse concerns.
We do not intentionally request special-category or criminal-offence data through our general website forms. Such information may occasionally appear in communications or content submitted by individuals. Where it is processed, we apply appropriate legal and security safeguards.
4. How we obtain personal data
We may obtain personal data:
Directly from you;
From organisations for which you work;
From our clients when we provide services on their behalf;
Through authorised integrations with customer-support, helpdesk and social media platforms;
From suppliers and business partners;
From publicly available professional and business sources; and
Automatically through website, security and service technologies.
When we process content from social media or customer-support platforms for a client, access is limited to the information required to provide the contracted service.
5. How and why we use personal data
We process personal data for the following purposes and lawful bases:
Providing and managing services
We use information to respond to enquiries, provide demonstrations, establish accounts, deliver services, manage client relationships and provide support.
Our lawful bases are performance of a contract, taking steps before entering a contract and our legitimate interests in operating and improving our services.
Customer Support and Community Management
We may process messages, comments, support requests and related account information on behalf of clients to respond to enquiries, moderate content, escalate risks and provide agreed reporting.
This processing is generally performed on our client’s documented instructions. The client determines the applicable lawful basis.
Security and service integrity
We use account, device, access and log information to protect our systems, investigate incidents, prevent misuse and maintain service availability.
Our lawful bases are legitimate interests, compliance with legal obligations and, where applicable, performance of a contract.
Business administration
We process contact, contractual, billing and supplier information for financial administration, service management, governance and record keeping.
Our lawful bases are performance of a contract, compliance with legal obligations and legitimate interests.
Marketing and business communications
We may send relevant business communications where permitted by law. We rely on consent where required and otherwise on our legitimate interests in promoting our business to appropriate professional contacts.
You may opt out of marketing communications at any time.
Recruitment
We process application and recruitment information to assess candidates, communicate about roles and meet employment-related obligations.
Our lawful bases are taking steps before entering a contract, legitimate interests and compliance with legal obligations.
6. AI-assisted processing
Socialbear may use artificial intelligence and automation to support functions such as content classification, moderation, summarisation, analytics and preparation of suggested responses.
We apply data-minimisation, access-control and security measures to AI-assisted processing. Customer information is processed only for authorised service purposes and in accordance with applicable client instructions and contractual requirements.
Socialbear does not use client content to train its own general-purpose foundation models. Where third-party AI service providers are used, they are subject to appropriate contractual, privacy and security requirements.
AI-generated suggestions may be subject to human review before external action, depending on the service configuration and client requirements. Socialbear does not use solely automated processing to make decisions about individuals that produce legal or similarly significant effects unless this has been specifically disclosed and an appropriate lawful basis and safeguards apply.
7. Sharing personal data
We may share personal data with:
Employees and authorised contractors who require access for their work;
Cloud hosting, communications, security, analytics and business-software providers;
Customer-support, helpdesk, social media and integration providers;
Approved AI and technology service providers;
Professional advisers, auditors and insurers;
Law-enforcement bodies, regulators, courts or public authorities where required; and
Prospective purchasers or advisers involved in a legitimate corporate transaction.
When Socialbear acts as a processor, subprocessors are appointed in accordance with our contractual obligations to the relevant client.
We do not sell personal data.
8. International transfers
Socialbear operates internationally and may use suppliers or personnel located outside the United Kingdom.
Where personal data is transferred internationally, we use an applicable lawful transfer mechanism. This may include UK adequacy regulations, the UK International Data Transfer Agreement, the UK Addendum to the EU Standard Contractual Clauses or another legally permitted safeguard.
Information about applicable safeguards may be requested using the contact details in this notice.
9. Retention
We retain personal data only for as long as necessary for the purpose for which it was collected, including contractual, legal, security and dispute-resolution requirements.
Retention periods are determined by considering:
The nature and sensitivity of the information;
The purpose of processing;
Contractual requirements and client instructions;
Applicable limitation periods;
Legal, regulatory and accounting obligations; and
Security and operational requirements.
Personal data processed solely on behalf of a client is returned or securely deleted in accordance with the applicable agreement and client instructions.
10. Security
Socialbear applies organisational and technical measures designed to protect personal data against unauthorised access, alteration, disclosure, loss or destruction.
Measures include access controls, authentication, encryption where appropriate, logging and monitoring, secure development, supplier assessment, incident response, staff training, business continuity and data-minimisation controls.
No method of electronic storage or transmission is completely secure. We continually review our safeguards in light of risk and operational changes.
11. Your rights
Depending on the circumstances, you may have the right to:
Request access to your personal data;
Request correction of inaccurate or incomplete information;
Request deletion of your personal data;
Request restriction of processing;
Object to processing based on legitimate interests;
Object to direct marketing;
Request transfer of information in a portable format;
Withdraw consent where processing is based on consent; and
Raise concerns about automated decision-making where applicable.
These rights are not absolute and may be subject to legal conditions or exemptions.
To exercise a right, contact aprivacy@socialbear.com. We may request information reasonably necessary to verify your identity.
Where Socialbear processes information solely for a client, we may refer your request to that client or assist the client in responding.
12. Right to object
You have the right to object at any time to the use of your personal data for direct marketing.
You may also object to processing based on legitimate interests. We will stop that processing unless we demonstrate compelling legitimate grounds that override your interests, rights and freedoms or the processing is required for legal claims.
13. Complaints
Please contact us first if you have concerns about how we use personal data so that we can attempt to resolve them.
You also have the right to complain to the Information Commissioner’s Office:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom
Website: https://ico.org.uk/make-a-complaint/
Telephone: 0303 123 1113
If you are located outside the United Kingdom, you may also have the right to contact your local data-protection authority.
14. Cookies
Our website may use strictly necessary cookies required for security and operation. Subject to your choices and applicable law, it may also use analytics or similar technologies to understand website use and improve our services.
Non-essential cookies should not be placed until the required consent has been obtained. More information should be provided through our cookie notice and website consent controls.
15. Links to other websites
Our website may contain links to third-party websites or services. Socialbear is not responsible for the privacy practices of those third parties. You should review their privacy information before providing personal data.
16. Children
Our website and business services are not directed at children. We do not knowingly collect children’s personal data through our general website forms.
When content involving children or vulnerable individuals is processed as part of a client service, it is handled according to client instructions and applicable safeguarding, contractual and legal requirements.
17. Changes to this notice
We review this notice regularly and update it when our processing, services or legal obligations change. The current version will be published on our website with its last-updated date.
Material changes will be communicated where required.
