Stikler, LLC Privacy Statement
‍Effective Date: May 1, 2024
‍INTRODUCTIONStikler LLC ("Company", "We", or "Us") is the owner and operator of the DoDilly™ a cloud computing platform as a service designed to monitor social media content compliance with U.S. laws and policies related to "truth in advertising" laws and regulations ("Platform"). This Privacy Statement describes how the Company may collect, use, maintain, protect, and disclose information on this website at www.dodilly.com (our "Website") and under a subscription agreement to use the Platform ("Users" or "Subscribers").
Additionally, this Privacy Statement describes how we collect, share, and use information about you and how you can exercise your privacy rights.Our Privacy Statement applies to all Website visitors and Platform Users. For further information on the terms which govern Users' use of the Platform, please see www.dodilly.com/saas-subscription-agreement or any other service order you may have signed with us.Please read this Privacy Statement carefully to understand our policies and practices regard your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or the Platform. If you have any questions or concerns about how we process your information or about this Privacy Statement, you can email us any time at privacy@dodilly.com. Additionally, if you wish to exercise your privacy rights, you can do so here [[HYPERLINK TO RIGHTS REQUEST PAGE]].
TABLE OF CONTENTS
Our Relationship to You
Information We Process
How We Use Your Information
How We Disclose Your Information
Protection, Storage, Transfer and Retention of Your Information
Other Important Information
Data Protection Rights
U.S. State Specific Data Protection Laws
International Data Privacy Matters
Company Privacy Management & Contact Information
OUR RELATIONSHIP WITH YOU
Where Website visitors elect to fill out their contact information in sections on the Website, we may contact you by email, postal mail, or phone regarding the Platform.Where Subscribers use the Platform, the Company serves as a data processor/service provider (a provider that process personal data on behalf of or at the direction of a controller, or other similar designation under the law) and our Users (usually a company or organization) is the controller/business (the entity that decides how and why information is processed) of the information provided to the Company via the use of the Platform. In all other cases, the Company is the controller of the information.For example, if you create an account with us:Your company or organization's name, corporate email address, website, telephone number, and the information stored in the Platform is your information data ("where Website visitors elect to fill out their contact information in sections on the Website, we may contact you by email, postal mail, or phone regarding the Platform.Where Subscribers use the Platform, the Company serves as a data processor/service provider (a provider that process personal data on behalf of or at the direction of a controller, or other similar designation under the law) and our Users (usually a company or organization) is the controller/business (the entity that decides how and why information is processed) of the information provided to the Company via the use of the Platform. In all other cases, the Company is the controller of the information.For example, if you create an account with us:Your company or organization's name, corporate email address, website, telephone number, and the information stored in the Platform is your information data ("User Data") and you are the controller of same.Use of the Platform through your company or organization with your company email address means your company or organization set up a Platform administrator and they are responsible for the accounts associated with your company or organization and can: restrict, suspend, or terminate your access to or ability to use the Platform, access information about you, access or retain information your company or organization store on its systems (including your log data and other aspect of your Platform use), and they can restrict your ability to edit, restrict, modify, or delete information associated with your use of the Platform.
INFORMATION WE PROCESS
We process information we receive directly from you, automatically collected when you use the Platform or visit our Website, and that is collected by the Company from third parties. However, please note that this Privacy Statement does not apply to the processing of your information by third parties through your use of the Platform. Please visit those third-party websites directly for more information on their privacy and data protection practices.
Information We Collect Directly from You: The types of information we collect directly from you varies based on your interaction with our Website and the Platform. For example, we collect information directly from you when you request, we contact you or when you register an account on the Platform, when we contact you offline or through email, when you contact with us on a customer service issue or to complete forms on the Website and offline. We also collect information that you send us via any medium, including, but not limited to, offline and through email. If you become a User, the Platform requires that we also collect information about you and your company, the characteristics of the social media campaigns and content creators to be monitored, such as their names, social media handle, username, profile, postings, and messages you exchange through the Platform.
‍Information We Receive from Users: This includes information that is needed for the Company to create an account for Users and manage their ability to log in and out of the Platform:Identifiers, including first and last name and email address.User account passwords-- unique, long, and strong, please.User account set up information, such as influencers and other content creators' identities and their information which may include monitored persons' names (first, last, and screen), social media handle, username, profile picture, biography, follower counts, website URL, and messages or communications with our Subscribers. We collect information from individuals employed by our Subscribers such as their contact information to provide our Platform.Information about your Platform plan and its usage.
‍Platform Users Information Collected by Third Parties: The Company does not collect, process, store, or otherwise have access to Users' financial information, including credit card information or bank account information.
Information You Provide Us by using the Platform: Information you provide in the Platform regarding content creators, content to be monitored, notes related to content reporting, and other features of Platform information needed to use the Platform's functionalities. Any other information you choose to provide while using the Platform that identifies or can be reasonably associated with you.
Information Collected Automatically When you visit our Website or use our Platform: We may collect certain information automatically from your device. This information may be considered personal information under applicable data protection laws. Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), third party webpages accessed via the Website and other technical information. We may also collect information about how your device has interacted with our Website (including the pages accessed and links clicked). Collecting this information enables us to better understand the visitors who come to our Website or use our Platform, where they come from, and what content and functionality is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors and to Users. Some of this information may be collected using technical and analytics cookies which are the only cookies the Website uses; that is, neither the Website nor the Platform involve third-party cookies for any advertising purposes.
HOW WE USE YOUR INFORMATION
‍We process information for business and commercial purposes in accordance with the practices described in this Privacy Statement. Our business purposes for collecting and using information, including in the last 12 months, include the following:
Operate and improve the Website and Platform; Provide Website visitors and Platform Users with access to established accounts and such other products and services a User may request as are available in the Platform;Facilitate subscription processing, reviews and analysis; Evaluate improvements of the Website and/or the Platform and make available other offers, products or services; Record calls with customers and Users for quality, training, and Platform improvement purposes (upon receipt of consent where required by applicable law); Evaluate the types of offers, products or services we make available to Users or potential users or customers; Monitor use of the Platform, including for troubleshooting and product improvement purposes; Provide customer support; Communicate and provide additional information that may be of interest to users through email or other means, such as special offers, announcements, and marketing materials; Conduct online research surveys regarding the Website and the Platform; Combine datasets to create aggregated data for internal evaluation and analysis; Send reminders, technical notices, updates, product announcements, security alerts and support and administrative messages, service bulletins, or marketing; Manage our everyday business needs such as Website and/or service administration, report management, fulfillment, analytics, fraud prevention, enforcement of our corporate reporting obligations, legal terms and any other contractual agreements relating to the Platform usage or to comply with the law; and Fulfill any other business or commercial purposes at Users directions or with your notice and/or consent. Additionally, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law. For information on your rights and choices regarding how we use information about you, please see "Your Data Protection Rights"
HOW WE DISCLOSE YOUR INFORMATION
‍We need to disclose the information we collect about you to contact you upon your request and to make the Platform services run smoothly and to operate our business under the following conditions:
Service providers and subprocessors. We may provide access or disclose your information to select third parties that use the information on our behalf to assist in providing Platform's services, Website, and features. These third parties provide a variety of services to us, including, without limitation, sales, marketing, provision of content and features, artificial intelligence enabled functionality, advertising, analytics, research, data storage, security, fraud prevention, and other services. You can find a list of our subprocessors here.
Because you ask us to disclose. We may disclose your information to third parties when you ask us to do so. This includes when you connect the Platform with other tools such as such application programming interfaces (APIs) connected to the Platform.
Consistent with your settings within the Platform. Please note the information you submit through and use on the Platform may be viewable by other users in your workspace, team, division, or organization, depending on the specific settings you have selected.
Business transfers. If the ownership of all or substantially all our business changes, or all or some of our assets are sold or other proceedings, we may transfer your information to the new owner so that the services can continue to operate. In such case, your information would remain subject to the promises and commitments contained in this Privacy Statement until the acquiring party updates it. If such transfer is subject to additional mandatory restrictions under applicable laws or agreements, the Platform will comply with those restrictions.
Compliance with legal obligations. To comply in good faith with a valid legal subpoena, request, or other lawful process. We will notify individuals or customers of that request unless: we are prohibited from doing so by law or court order; or there are exceptional circumstances, such as an emergency involving the risk of bodily injury or death to a person or group of people or potential harm to minors.
Your company's own Platform account administrator. If you're using the Platform in connection with an organization, academic institution, or company domain, your company's account administrator will receive compliance reports and other data associated with its Platform account as determined by the organization's Platform plan.We use and disclose the categories of information we collect from and about you consistent with the various business purposes we discuss throughout this Privacy Statement. We do not disclose your information to third parties for their own direct marketing purposes.
PROTECTION, STORAGE, TRANSFER, AND RETENTION OF YOUR INFORMATION
Security
‍We take technical and organizational measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access. However, no method of transmission over the Internet and no means of electronic or physical storage is absolutely secure, so we cannot ensure or warrant the security of that information. We are constantly updating and improving our safeguards and we will keep you informed about updates to our security practices through revisions to this Privacy Statement. We do not take responsibility for protecting Users' IDs or passwords and we encourage User administrators to secure such identifiers using, for example two-factor authentication where available.
Platform Structure and Storage
‍The Platform is built as a web-based software system and is hosted through a cloud service provider. The cloud service provider only provides limited data privacy and security to us. For Platform Users, it is the Users' responsibility to use effective access controls and credentialing protocols to minimize risks of unauthorized, misused, or other potentially harmful access to the Platform and User's account data.Except for your selected content creators' identifiers (real name and screen name, if applicable), social media handles, and email addresses, and digital representations of the Subscribers' reports related to monitored social media content compliance, the Platform does not directly store Users' account activities. Rather, we have contracted with AWS for cloud-based storage services to store such information and such information will be subject to such service provider's privacy practices which can be reviewed at: AWS Privacy (amazon.com)
‍Data Transfer
‍Our business operations are currently available only in the United States and we do not anticipate that Users' data or information will be transferred in or out of any foreign countries.
Data Retention and Disposal
‍User data and information will be retain for the time needed to supply the Platform services and to fulfill the purposes of this Privacy Statement.
‍OTHER IMPORTANT INFORMATION
Use by Children under 16
‍If you are under the age of 16, you may not have a Platform account or use our products or services. We do not knowingly process any information from, or direct any of our products or services to, children under the age of 16.
‍Categories of Third Parties With Whom We May Share Your Information
‍We share information we collect in accordance with the practices described in this Privacy Statement. The following are the categories of recipients:to our affiliates, service providers and partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website or the Platform), or who otherwise process information for purposes that are described in this Privacy Statement or for which we provide you notice when we collect your information. We share information with our affiliates for business and commercial purposes. We contractually prohibit our service providers from retaining, using, or disclosing information about you for any purpose other than performing the services for us, although we may permit them to use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.to our Subscribers (including information pertaining to Subscribers' internal personnel to provide social media management, social analytics, and social listening services and to manage the User relationship. For example, we share information with our Users to facilitate their order processing, maintaining, and administering their Platform accounts, responding to their questions and comments, complying with their requests, marketing and otherwise fulfilling our contractual obligations and complying with applicable laws.to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or court order or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.to a potential buyer (and its agents, investors, and/or advisors) in connection with any proposed or actual purchase, merger, or acquisition of any part of our business, if we inform the buyer it must use your information only for the purposes disclosed in this Privacy Statement.to vendors for business and commercial purposes, including analytics and advertising technology companies. Vendors may act as our service providers, or in certain contexts, independently decide how to process your information. For more information on advertising and analytics, see the "Cookies similar tracking technology, and analytics" section below. To any other person with notice to you and your consent to the disclosure.when you request or direct us to share information, such as when you choose to share information with a social network or other third-party platform about your activities on such platforms, which may require you to accept such third party's terms of use or privacy policies. Please think carefully before making information public as you are solely responsible for any information you make public. Once you have posted information, you may not be able to edit or delete such information, subject to additional rights set out in the "Data Protection Rights" section below.This list of data sharing activities is not exclusive. We may also share information that does not identify you (including information that has been aggregated or de-identified) except as prohibited by applicable law. For information on your rights and choices regarding how we share information about you, please see the "Data Protection Rights" section below. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Cookies, similar tracking technology, and analytics
‍We use only first party cookies for website analytics and specifically Google Analytics, to help us understand how users access and use the Website and the Platform. Google provides tools to allow you to opt out of the use of certain information collected by Google Analytics at https://tools.google.com/dlpagelgagptout and by Google Analytics for Display Advertising or the Google Display Network at https://www.google.com/settings/ads/onweb/ As indicated above, vendors may act as our service providers, or in certain contexts, independently decide how to process your information. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.
Global Privacy Control and Do Not Track
‍The Global Privacy Control or GPC is a user-enabled browser extension designed to signal a consumer's election to opt-out of websites selling or sharing personal information.Do Not Track is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our websites for third party purposes, and that is why we provide the ability to opt out, if needed, and adjust your cookies preferences.We do not currently recognize or respond to browser initiated DNT signals.
Artificial Intelligence
‍The Platform software includes an artificial intelligence (AI) assisted analytical tool to evaluate the compliance qualities of creator content, but only for the purpose of making suggestions to Users of the nature of these compliance or non-compliant qualities. This AI component is not making any decisions and it is not generative or otherwise learning from any reviewed data. If you have any questions regarding this AI element, please see the "Contact Us" section below.
DATA PROTECTION RIGHTS
‍Numerous countries and dozens of U.S. States have (or are in the process) enacted country and State-specific consumer data protections laws (generally referred to as "Data Protection Laws"). Each Data Protection Law is designed to protect the citizens and/or residents within the applicable country or State. Each Data Protection Law grants certain rights to these covered persons and imposes specific obligations on the business or organization that is the principal data collector or controller.
We encourage all our visitors and users to familiarize themselves with their own countries or States' Data Protection Laws to determine the scope of these rights.
‍We present a summary of the major data privacy rights granted by some Data Protection Laws below.Upon your request, and subject to applicable legal exceptions, we will:provide access to and/or a copy of certain information we hold about you provide you with information about categories of information we collect or disclose about you, the categories of sources of such information, the business or commercial purpose for collecting your information, and the categories of third parties to which we disclose your information. For your convenience and so you don't have to request it, we've included that information in this Privacy Statement.prevent the processing of your information for promotional purposes (including any direct marketing processing based on profiling)update information which is out of date or incorrect delete certain information which we have about you restrict the way that we process and disclose some of your information transfer your information to a third party provider of services revoke your consent for the processing of your information. If you request these rights, we will need to verify your identity and may need to verify your relationship with us (for example, if you're an administrator of an organization, division, or workspace and you're making a request on behalf of another individual) for security and to prevent fraud. You may be able to designate an authorized agent to make requests on your behalf. For an authorized agent to be verified, the authorized agent must present signed, written permission to make such requests or a power of attorney. We may also contact you to verify your identity before processing the authorized agent's request.We may take additional steps to verify that you are authorized to make the request. If you are an internal end user of a User and not a direct Subscriber to the Platform (for example, your company uses the Platform and you're an employee or authorized representative of that company), you should direct requests relating to your information to the administrator of your company's Platform account. We will redirect you to your administrator or notify the administrator directly. To exercise your privacy rights, please make a request by filling out this form.
‍COMPANY PRIVACY MANAGEMENT & CONTACT INFORMATION
Updates to this Privacy Statement
‍We may update this Privacy Statement from time to time in response to changing legal, technical, or business developments. When we update our Privacy Statement, we will take appropriate measures to inform you, consistent with the significance of the changes we make, such as sending you an email notifying you of such updates. We will obtain your consent to any material Privacy Statement changes if and where this is required by applicable data protection laws.You can see when this Privacy Statement was last updated by checking the "last updated" date displayed at the top of this Privacy Statement.
How to Contact Us
‍If you have any questions about this Privacy Statement or our privacy practices, please contact us at contact@dodilly.com.
‍U.S. STATE SPECIFIC DATA PROTECTION LAWS
‍As of the Effective Date of this Privacy Statement, several U.S. States have enacted comprehensive consumer data protection laws, which currently include the following:the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CPRA), (collectively, CCPA);the Colorado Privacy Act (CPA);the Connecticut Act Concerning Personal Data Privacy and Online Monitoring;the Delaware Personal Data Privacy Act (DPDPA) ( (effective January 1, 2025);the Florida Digital Bill of Rights (FDBR) (effective July 1, 2024);the Indiana Consumer Data Protection Act (INCDPA) (effective January 1, 2026);the Iowa Consumer Data Protection Act (ICDPA) (effective January 1, 2025);the Montana Consumer Data Privacy Act (MCDPA) (effective October 1, 2024);the Oregon Consumer Privacy Act (OCPA) (Section 5(4), (effective July 1, 2024);the Tennessee Information Protection Act (TIPA) (effective July 1, 2025);the Texas Data Privacy and Security Act (TDPSA) (effective July 1, 2024);the Utah Consumer Privacy Act (effective December 31, 2023); andthe Virginia Consumer Data Protection Act.Again, we encourage all our users to familiarize themselves with their own countries or States' Data Protection Laws to determine the scope of these rights.
NOTICE TO CALIFORNIA RESIDENTS.
Categories of information collected and disclosed:If you are a California resident, you have certain rights under the California Consumer Privacy Act ("CCPA") as it has been amended under the California Privacy Rights Act ("CPRA"), and augmented by rules adopted thereunder, and we want to provide you with the following additional information about the purpose for which we use each category of personal information we collect (as defined by CCPA), the categories of third parties to which we disclose personal information for a business purpose or for cross-context behavioral advertising, which includes our use of third-party analytics services and online advertising services. These are described in detail in our Cookies Notice [[INSERT HYPERLINK]] and may result in the disclosure of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information).Specifically, your contact information (including email) or internet network and device information (including cookie data and IP address) may be disclosed to online advertising and analytics partners.For more information about each category of personal information, purpose of use, and third parties to which we disclose personal information, please see the Information
We Process, How We Use Your Information, and How We Disclose Your Information sections of our Privacy Statement.Your choices regarding online advertising and related activities:You have the right to opt out of the disclosure of your personal information for purposes of online cross-context behavioral advertising and related activities and can do so by clicking here: privacy@dodilly.com
‍Other CCPA rights: We do not offer any financial incentives in exchange for your personal information. If we ever do, we will provide you with additional disclosures regarding those incentives at the time they are offered. The CCPA also allows you to limit the use or disclosure of your sensitive personal information (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.Please see information under Data Retention in the Protection, Storage, Transfer and Data Retention Sections of our Privacy Statement.
California "Shine the Light" disclosure:The California "Shine the Light" law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. We do not currently disclose your personal information to third parties for their own direct marketing purposes.