Social Media & Plugins

GDPR-Compliant Privacy Notice for Websites with Social Media Integration & Plugins

Information: This Model Notice is for websites that use social media plugins or pixels, which can lead to a "joint controllership" relationship with the social media company. It explains what data is processed, the purpose, and how the rights of your users are protected. This policy is designed to be used in conjunction with a Consent Management Platform (CMP) - see our note at the end of this page.

Last Updated: September 28, 2025

1. Summary: Core Principles

When you visit our website and interact with social media plugins or pixels, we act as a joint data controller with the social media provider (e.g., Meta/Facebook, Pinterest, LinkedIn). We process your personal data in this way to show you relevant advertising and to analyze the effectiveness of our marketing campaigns. The legal basis for this processing is your explicit consent.

2. Joint Data Controllership

As confirmed by the European Court of Justice (ECJ), the operator of a website that integrates social media plugins or pixels is a joint data controller with the social media provider. This means that we and the social media platform jointly determine the purposes and means of processing your personal data.

As required by the GDPR, we have entered into an agreement with the social media provider that outlines our respective responsibilities for data protection. Under this agreement, the social media provider is primarily responsible for ensuring the security of your data and responding to your data subject requests.

3. Types of Personal Data We Process

When you visit our website and interact with a social media plugin, the social media provider may collect personal data from you. This is done through cookies and similar technologies. The personal data processed includes:

• Online identifiers (e.g., your IP address).

• Browsing behavior on our site (e.g., which pages you visit, what you click on).

• Your social media user ID (if you are logged in to the social media platform).

This information is automatically transmitted to the social media provider, even if you do not click on the plugin.

4. Purposes and Legal Basis for Processing

The data collected through social media integrations is processed for the following purposes:

• Targeted Advertising: To show you personalized advertisements on social media platforms based on your browsing behavior on our website.

• Analytics and Audience Measurement: To analyze the effectiveness of our marketing campaigns and to better understand our audience.

The legal basis for these processing activities is your explicit consent, which is managed via our Consent Management Platform (CMP).

5. Recipients of Your Personal Data and International Transfers

We share your personal data with the social media platforms that provide the plugins or pixels used on our website. These platforms have their own privacy policies that govern how they use your data.

If your data is transferred to a country outside of the EU/EEA by either us or the social media provider, we will ensure that it is done using appropriate data protection safeguards, such as Standard Contractual Clauses (SCCs), to guarantee an adequate level of protection.

6. Your Rights

Under the GDPR, you have the right to:

• Access your data.

• Rectify inaccurate data.

• Erase your data (the "right to be forgotten").

• Restrict or object to processing.

• Withdraw your consent at any time.

You can withdraw your consent for social media plugins and pixels directly through our Consent Management Platform (CMP) as described below. For all other requests related to your rights, please contact us using the details provided. We may need to coordinate with our social media partners to fulfill your request.

Please note that while we do not use automated decision-making, the social media platform may. You should consult their privacy policies for more information.

7. How to Manage Your Consent

We use a Consent Management Platform (CMP) to provide you with granular control over your data. You can easily manage or withdraw your consent for social media plugins by clicking the "Cookie Settings" or "Manage Consent" link, which is typically found in the footer of our website.

8. Changes and updates to this policy

This GDPR-compliant Model Privacy Policy Notice is regularly reviewed by Joon Han Legal, who monitors changes in Data Protection Laws. Only the latest version, which is currently applicable, is published on the SME Privacy website (www.smeprivacy.org).

9. Contact Information and Supervisory Authority

For any questions or concerns regarding this Notice or our data processing activities, you can contact us at the email address provided in our Data Protection Clause. You also have the right to lodge a complaint with a Data Protection Authority (https://www.edpb.europa.eu/about-edpb/about-edpb/members_en).

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SME Privacy’s Recommended Data Protection Clause to be Embedded on your Website:

"Data Protection: we use a Privacy Policy for Websites with Social Media Integration & Plugins developed by SME Privacy. You can read it at https://www.smeprivacy.org/notice/social-media-plugins. This policy, along with the details below, explains how we process your personal data.

Specifics of Processing: We use social media plugins and pixels for analytics and advertising purposes. We are joint controllers with [Social Media Platform, e.g., Meta (Facebook)] and [Social Media Platform, e.g., Pinterest].

Controller: For all enquiries regarding your personal data, please contact [FULL NAME (sole proprietor) or COMPANY NAME (registered company)] at [EMAIL ADDRESS]."

Optional Clauses to be Included as Applicable:

• EU Representative: If you are based outside of the EU/EEA, please also mention the identity and contact details of the controller's EU Representative.

• Data Protection Officer: Where applicable, please also mention the identity and contact details of the controller's Data Protection Officer.

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Note: A Word on Consent Management

For websites that use analytics, advertising, or social media plugins, having a privacy notice alone isn't enough. The GDPR requires you to prove you have a user's explicit consent before processing their data for these purposes. This is where a Consent Management Platform (CMP) comes in. A CMP is a tool that allows you to easily display a cookie banner, collect valid consent, and give users a simple way to change their mind at any time. We highly recommend implementing a reputable CMP to ensure you are fully compliant and to protect your business.