Privacy Policy

[LEGAL ENTITY NAME], trading as Social Page, is the controller of the personal data described in this policy. Social Page is a customisable public profile platform for gamers: you sign in with Discord, build a page from links and content cards, and publish it at a public address.

This policy explains, in specific terms rather than generalities, what data we hold, why we hold it, who else sees it, how long we keep it, and what you can require us to do about it. We have written it against what the platform actually does, so you can verify our claims against your own experience of the product.

Controller

[LEGAL ENTITY NAME]

Registered office

[REGISTERED ADDRESS, CITY, POSTAL CODE, COUNTRY]

Privacy contact

[email protected]

Responsible person

[DATA PROTECTION OFFICER OR RESPONSIBLE PERSON]

EU representative

[EU ARTICLE 27 REPRESENTATIVE, NAME AND ADDRESS]

UK representative

[UK ARTICLE 27 REPRESENTATIVE, NAME AND ADDRESS]

This policy applies to https://social.page, to every public profile served on social.page and its subdomains, to profiles served on custom domains connected to the Service, to our APIs, and to the transactional emails we send you.

It does not apply to:

• Discord. Discord is our identity provider, not part of the Service. Your Discord account, and the data Discord holds about you, are governed by Discord's own privacy policy.
• Sites you link to. When a visitor clicks a link on a profile and leaves the Service, the destination site's own policy applies.
• Embedded third-party players. Where a profile embeds content from a platform such as Spotify or YouTube, that platform may process visitor data directly under its own policy.
• What a profile owner does with data you give them. If you send an AMA question or otherwise interact with a profile, the owner decides whether to publish it. Where an owner uses the Service to collect or publish other people's data, they act in their own right and are responsible for that activity.

The following is a complete description of the categories of personal data the platform holds. Where a field is optional, you control whether it exists at all.

Where the EU or UK General Data Protection Regulation applies, we must have a lawful basis for each purpose. The table sets out ours. Where you are outside those regimes, the purposes still describe exactly what we do.

Most of what we do does not run on consent, because it is either necessary to deliver the Service you asked for, necessary to keep it safe, or required by law. Where we do ask for consent, we will make the request specific and separate, and we will not bundle it into acceptance of the Terms.

• You can withdraw consent at any time, without giving a reason, and doing so is as easy as giving it. Withdrawal does not affect the lawfulness of processing already carried out.
• Authorising the Discord connection is consent to Discord sharing your data with us. You can revoke it in Discord's authorised applications settings at any time, which will prevent future sign-in.
• To withdraw any other consent, use the relevant setting where one exists, or write to [email protected].
• Where consent is required for a feature and you withdraw it, that feature will stop working, but the rest of the Service will continue.

Specifically, when your profile is published:

• Your username, display name, avatar, biography, location if you set one, links, cards, uploads, badges, like count and published AMA answers are visible to anyone.
• Search engines and other crawlers may index it, and it may then appear in search results and in their caches. We do not control how long a third party keeps a copy.
• We generate an Open Graph preview image and metadata so the page renders as a rich card when shared. Those previews are cached by the platforms your link is posted on.
• Anyone can screenshot, download, archive, mirror or repost your content, including services that archive the web automatically.
• Unpublishing or deleting content removes it from the Service, but does not remove copies already taken by third parties.

You control the exposure. You can leave your profile unpublished, choose not to appear in directory and discovery features, disable likes, disable AMA, disable analytics collection, and delete any individual card, link or upload at any time from your profile settings. Where a specific field is optional, the simplest privacy measure is not to fill it in.

If content about you appears on someone else's profile and you want it removed, use the reporting control on that profile or write to [email protected]. We treat publishing another person's private information without their consent as a serious violation of the Community Guidelines.

We use a deliberately small number of cookies, and none of them are advertising cookies. We do not deploy third-party marketing or profiling trackers.

Because our own cookies are strictly necessary to provide a service you have requested, we do not need consent for them under the ePrivacy rules, and there is no consent banner to dismiss. If we ever introduce a non-essential cookie, we will ask for your consent first and give you a way to manage it.

You can block or delete cookies in your browser settings. Blocking our session cookies will prevent you from signing in. We also use ordinary web-server logs and hashed request fingerprints as described elsewhere in this policy; these do not rely on cookies.

Profile owners see how many times their page was viewed, how many of those views were unique, which sources traffic came from, and how often each link was clicked. We built this first-party rather than adding a third-party analytics product, precisely so that visitor data does not leave our systems.

Keeping a public publishing platform safe requires processing some data specifically for that purpose. We have set out what that involves so it is not a surprise.

• Automated scanning of uploads. Images and video are analysed by a cloud image-and-video moderation service before they are published, to detect explicit, violent or otherwise prohibited material. Uploads are also compared against a list of hashes of content we have previously removed.
• Reports. If you report content, we record who you are so that we can prevent malicious and automated reporting, follow up if we need more information, and identify retaliation. We do not disclose your identity to the person you reported, unless we are legally required to do so.
• Human review. Reports and automated flags enter a moderation queue. Reviewers can see the reported content, the surrounding profile, prior enforcement history on the account and the report metadata. Access is limited by role-based permissions.
• Enforcement and appeal records. We record what action was taken, why, by whom and when, together with your appeal and its outcome. These records are what allow you to challenge a decision and allow us to demonstrate that we applied our rules consistently.
• Evasion prevention. We use technical signals, including IP address and hashed fingerprints, to detect attempts to evade a suspension or ban with a new account. We retain the minimum needed for this purpose.
• Referral to authorities. Where we encounter material or conduct that we believe involves a serious risk to life or the sexual exploitation of a child, we will preserve the relevant evidence and report it to law enforcement or the appropriate authority, as the law requires or permits.

The actions available to us, the severity framework, and the 14-day appeal window are described in full in the Community Guidelines.

We disclose personal data only in the situations below. We do not disclose it for anyone else's independent marketing purposes.

The public

Anything you publish on your profile. This is the primary and intended disclosure, and it is under your control.

Service providers acting for us

The processors listed in the next section, each engaged under a written contract that restricts them to processing on our instructions, requires appropriate security, and prohibits use of the data for their own purposes.

Other users, in limited ways

A profile owner sees the questions submitted to them and whether an account has liked their profile. Reporters are not identified to the people they report.

Legal and regulatory recipients

Courts, law-enforcement agencies, regulators and other authorities, where we are legally compelled, or where disclosure is necessary to establish, exercise or defend legal claims, to comply with a valid legal request, or to prevent imminent harm to a person. We assess each request, require it to be lawful and specific, decline requests that are overbroad, and will notify you where we are permitted to do so.

Professional advisers

Lawyers, accountants, auditors and insurers, bound by professional duties of confidentiality, where necessary for advice or the conduct of our business.

Corporate transactions

A prospective or actual buyer, investor, merger partner or successor in a reorganisation, insolvency or sale of assets, under confidentiality obligations. Where personal data transfers to a new controller, we will notify you and the new controller will remain bound by commitments at least as protective as this policy, or you will be given a choice where the law requires one.

Aggregated or de-identified information

Statistics that do not identify any individual and cannot reasonably be used to re-identify anyone, for example total platform usage figures. We do not attempt to re-identify de-identified data and we contractually prohibit recipients from doing so.

The Service is built on the following providers. Each acts as our processor, except Discord and Stripe, which also act as controllers in their own right for the parts of the interaction they own.

We keep this list current. If we add or replace a processor that handles personal data, we will update this page, and we will notify you in advance where the change is material. You can request the current list, and confirmation of the safeguards in place, at [email protected].

• There is no advertising inventory on the Service.
• There is no third-party advertising, marketing-analytics or data-broker software development kit in the product.
• We do not build advertising profiles, audience segments or lookalike audiences, and we do not perform cross-context tracking of visitors.
• We do not use your content, your profile or your analytics to train generative or machine-learning models, and our Terms prohibit others from scraping the Service to do so.
• We do not disclose personal data of any person we know to be under 16 for money or for advertising purposes.

We and our providers operate internationally, so your personal data may be processed in countries other than your own, including the United States and other countries where our cloud providers run infrastructure. Data-protection law in those countries may differ from the law where you live.

Where we transfer personal data out of the European Economic Area, the United Kingdom or Switzerland, we rely on one or more of the following safeguards:

• An adequacy decision by the European Commission, the UK government or the Swiss authorities in respect of the destination country.
• The European Commission's Standard Contractual Clauses, together with the UK International Data Transfer Addendum or the UK International Data Transfer Agreement, and the Swiss equivalent where relevant.
• Certification of the importer under the EU-US Data Privacy Framework and its UK and Swiss extensions, where the importer participates.
• A transfer-impact assessment, and supplementary technical and organisational measures such as encryption in transit and at rest, access controls and data minimisation, where the assessment shows they are needed.
• A derogation permitted by law, such as your explicit consent or the necessity of the transfer for the performance of a contract with you.

You may request a copy of the relevant transfer mechanism, with commercially confidential terms redacted, by writing to [email protected].

We keep personal data only as long as we need it for the purpose we collected it for, plus any period required by law or necessary to defend a legal claim. The following are our standard periods.

We apply technical and organisational measures appropriate to the risk, including:

• Encryption of traffic in transit using TLS, and encryption of stored data at rest by our infrastructure providers.
• AES-256 encryption of the Discord OAuth refresh token in the database, so a database copy alone does not yield usable tokens.
• No user passwords for ordinary accounts, because authentication is delegated to Discord. Internal staff credentials, where they exist, are stored as bcrypt hashes.
• Server-side sessions with HTTP-only cookies, so session identifiers are not readable by page scripts.
• Role-based access control and a permission matrix that limits staff to the minimum data their role requires, with moderation access restricted to trained reviewers.
• Audit logging of consequential staff and account actions.
• Rate limiting, abuse trip-wires and automated content scanning.
• Segregation of the public application, the internal administration panel and the API, with separate session cookies.
• Dependency and error monitoring, and prompt patching of known vulnerabilities.

No system is perfectly secure. We cannot guarantee absolute security, and you play a part: keep your Discord account secure, enable two-factor authentication there, and sign out on shared devices.

If you are in the European Economic Area, the United Kingdom or Switzerland, you have the rights below. We extend the substance of these rights to all users wherever they live, because it is simpler and fairer to run one standard.

Access

To be told whether we process your personal data and, if so, to receive a copy of it together with information about the purposes, recipients, retention and safeguards.

Rectification

To have inaccurate personal data corrected and incomplete data completed. Most profile data you can correct yourself in the editor.

Erasure

To have personal data deleted where it is no longer needed for the purpose, where you withdraw the consent it relied on, where you successfully object, or where it has been processed unlawfully. This right does not extend to data we must retain for a legal obligation, for the establishment or defence of legal claims, or to enforce a ban.

Restriction

To have processing limited while a dispute about accuracy or a pending objection is resolved.

Portability

To receive the personal data you provided to us, in a structured, commonly used and machine-readable format, and to have it transmitted to another controller where technically feasible.

Objection

To object to processing based on legitimate interests, including our first-party analytics. We will stop unless we can demonstrate compelling legitimate grounds that override your interests. Where processing is for direct marketing, the right to object is absolute.

Withdrawal of consent

To withdraw any consent you have given, at any time, without affecting the lawfulness of prior processing.

Human review of automated decisions

Not to be subject to a decision based solely on automated processing that produces legal effects or similarly significantly affects you. See the Automated processing section for how this applies to content moderation.

Complaint to a supervisory authority

To lodge a complaint with the data-protection authority in your country of residence, place of work or the place of the alleged infringement. Our lead supervisory authority is [LEAD SUPERVISORY AUTHORITY]. We would appreciate the chance to address your concern first, but you are not required to come to us before going to a regulator.

This section supplements the rest of the policy for residents of United States states with comprehensive privacy laws, including California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky and Rhode Island, as those laws come into force.

The Service is not directed at children. You must be at least 13 years old to hold an account, or at least the local age of digital consent, which is 16 in a number of European countries. The Terms of Service contain the country-by-country table.

• We do not knowingly collect personal data from anyone below the applicable minimum age, and we do not knowingly permit them to hold an account.
• If we learn that an account holder is below the applicable age, we will disable the account, unpublish the profile and delete the associated personal data, except any minimal record needed to prevent the account being recreated.
• A parent or legal guardian may ask us to review, delete or stop the collection of their child's personal data by writing to [email protected]. We will verify the relationship proportionately and act promptly. There is no charge.
• We do not sell or share the personal data of any user we know to be under 16, and we do not use it for advertising, because we do not run advertising at all.
• Where a minor uses the Service with parental consent, the parent or guardian is responsible for supervising that use, including what the minor publishes on a public page.

We use automation in three places, and we want to be precise about what it does and does not decide.

Upload scanning

Images and video are scanned automatically before publication. A scan can block publication of a specific file. This is a content decision about a file, not a profiling decision about you, and it is necessary to stop illegal and prohibited material appearing on a public page. If a file is rejected in error, you can re-upload a compliant version or contact support.

Hash matching

Uploads are compared against fingerprints of material we have previously removed. A match blocks the upload. Matching is deterministic and does not profile you.

Abuse and rate-limit trip-wires

Automated signals can rate-limit a request, queue an item for review, or temporarily restrict an action where the pattern strongly indicates abuse. These are protective and reversible.

Consequential enforcement decisions about your account — a warning, a suspension, disabling a profile, a shadowban or a permanent ban — are made or confirmed by a human reviewer, not by an algorithm acting alone. You are notified, given the reason, and given the right to appeal to a human within the appeal window. We do not carry out automated decision-making that produces legal effects concerning you within the meaning of Article 22 of the GDPR, and we do not engage in profiling for advertising, credit, employment or insurance purposes.

Browsers can send a "Do Not Track" header, but there is still no common industry standard for how a site should respond, so we do not act on it differently: we already do not track you across sites or for advertising.

We recognise the Global Privacy Control signal as a valid opt-out of sale and sharing where applicable law requires it. Since we do not sell or share personal information for cross-context behavioural advertising, there is nothing for the signal to switch off, and honouring it changes nothing about how we treat you.

Profiles are built to point outwards. When you click a link on a profile, you leave the Service and the destination's own privacy policy applies. We do not control those sites and are not responsible for their practices.

Where a profile embeds a third-party player or widget, that third party may receive your IP address, set its own cookies and collect usage data directly when the embed loads, under its own policy. If you would rather avoid this, use a browser that blocks third-party content, or avoid interacting with the embed.

We will update this policy when our practices, the Service or the law change. The current version is always published at https://social.page/privacy with a version number and a last-updated date.

• Where a change is material — a new purpose, a new category of data, a new class of recipient, a materially longer retention period, or a reduction in your rights — we will give prominent advance notice by in-app notification, email or a notice on the Service, and where the law requires consent we will ask for it before the change takes effect.
• Clarifications, corrections and updates to contact details take effect on publication.
• You can request the version of this policy that applied on a given date from [email protected].

If you have a question about this policy, want to exercise a right, or are unhappy with how we have handled your data, contact us first — we would like the chance to put it right.

Controller

[LEGAL ENTITY NAME]

Registered office

[REGISTERED ADDRESS, CITY, POSTAL CODE, COUNTRY]

Privacy and data rights

[email protected]

Trust and safety

[email protected]

Legal notices

[email protected]

General support

[email protected]

Responsible person

[DATA PROTECTION OFFICER OR RESPONSIBLE PERSON]

EU representative

[EU ARTICLE 27 REPRESENTATIVE, NAME AND ADDRESS]

UK representative

[UK ARTICLE 27 REPRESENTATIVE, NAME AND ADDRESS]

If you are not satisfied with our response, you may complain to your data-protection authority. In the European Economic Area, that is the authority in your country of residence, place of work or the place of the alleged infringement, and our lead authority is [LEAD SUPERVISORY AUTHORITY]. In the United Kingdom, it is the Information Commissioner's Office. In Switzerland, it is the Federal Data Protection and Information Commissioner. Residents of United States states with a comprehensive privacy law may contact their state attorney general. You do not need our permission, and we will not retaliate.