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Last modified: December 9th, 2021
IMPORTANT NOTE: The Spanish version of this document will govern our relationship - this translated version is provided for convenience only and will not be interpreted to modify the Spanish version. For the Spanish version, please see the Influencity Legal Stuff page.
We take your privacy very seriously. Please do not hesitate to contact us with any doubts or questions you may have at the following e-mail address: firstname.lastname@example.org.
We periodically update this policy. If you have an active Influencity account, we will let you know when we do via an email or in-app notification.
Finally, we know privacy terms can sometimes be difficult to navigate, so we wanted to give you a roadmap of the Policy:
LIST OF CONTENTS
Who is the data controller for processing your data.
Which are the requirements for providing us with your personal data.
What data processing we carry out through the Website and what are its main characteristics:
What data is collected and how it is collected.
Purposes for the processing of your personal data.
What is the legal ground for the data processing.
How long data is kept.
To whom do we disclose your personal information.
Existence of transfers of your data to third countries.
Which rights you have and how you can exercise them.
How we guarantee the confidentiality of your information.
Modifications to this policy.
1. WHO IS THE DATA CONTROLLER FOR PROCESSING YOUR PERSONAL DATA?
Your personal data will be processed by the company INFLUENCITY, S.L. ("INFLUENCITY"), with Tax Identification Number ESB98684574 and contact details are as follows:
Address: Calle Ribera 1, Entlo. 1 y 2, Valencia, 46002, España
Contact email: email@example.com
Influencity’s role as a Data Processor:
Regarding the personal information included by our Customers when using our Platform and Services (excluding data for which Influencity is the controller), INFLUENCITY will process such data as a data processor, acting on behalf of that Customer.
2. WHAT ARE THE REQUIREMENTS FOR PROVIDING US WITH YOUR PERSONAL DATA?
2.1. Minimum age. To provide us with your personal data, you must be at least 18 years of age, and/or have sufficient legal capacity to use this Website.
2.2. Truthfulness. When you provide us with your data in order to use our services, you guarantee that the data and information provided is real, truthful, up to date and belongs to you and not to third parties.
In addition, you must notify us of any changes that occur in the data provided, in any case, responding to the veracity and accuracy of the data provided at all times.
2.3. Age and Veracity Control. INFLUENCITY reserves the right to verify your age and identifying information at any time, if necessary, including by requiring official proof of age or equivalent procedure and, in the event of fraud detection that proves or is suspected that you are under the age indicated, to delete, temporarily disable and/or terminate your account.
3. WHAT DATA PROCESSING DO WE CARRY OUT THROUGH THE WEBSITE AND WHAT ARE ITS MAIN CHARACTERISTICS?
Below, we explain how we process your personal information and provide you, in detail, with all relevant information regarding your privacy:
What are the data collection methods? We gather publicly available information obtained directly or indirectly via various data sources such as social media networks and other sources; and/or Registration form and use of the Platform.
What data do we collect? The publicly available information may include Identifying and contact information. We collect your identifying information (name, username), publicly available information regarding your social network profile and any other information made manifestly public.
When registering through our Platform, we may collect the same information as well as email address and password, and other identifying information you may include in your account voluntarily (gender, telephone number, date of birth, link to your social media accounts, rates for posting and creating content, profile description and images).
You may also be required to give us permission to collect personal information from your social media accounts via API.
Profiling: We collect and produce profiles about you as an influencer to create a classification based on: your reach (number of followers, audience, etc.); the context of your followers (country, demographic information, industry, activities or products you create content about, potential target audience) and other significant variables in relation to the social networks you are present on.
What are the purposes of the processing of your personal data? When registering in our Platform, we’ll process your data to manage your account and give you access to different functionalities available.
The main purpose for processing your personal data, through your account, is to allow our customers to find Influencers who may fit their values, public target and other requirements and help them connect with Influencers to create and manage marketing campaigns.
You may also be able to manage permissions for our various customers through your account, so that they can (i) view your personal information added to your account; (ii) contact you; and (iii) offer you to participate in their campaigns.
What is the legitimacy basis that allows us to process your data? Is it mandatory to provide these data? We collect and process your personal information based on our legitimate interests to enable our customers and you as an influencer to connect and create marketing campaigns. There is a mutual benefit to both companies and influencers when providing a channel for you to meet and communicate with each other through our platform. For more information regarding the balancing of legitimate interests in this case, please, contact us at firstname.lastname@example.org.
How long do we keep your information? All your personal information will be processed during the time it is necessary to fulfill the purposes indicated above. We may retain your personal information for longer if it may be the subject of a legal claim, or may otherwise be relevant for future litigation.
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4. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?
In general, INFLUENCITY will not communicate your data to third parties. However, in addition to the transfers that we specifically indicate in the section in which we explain the characteristics of the different operations (point 3), we inform you of the communications that we can make, in general, and that affect all previous treatments and their legitimate grounds.
i. Customers, certain personal information will be available to our customers so they can evaluate your suitability to participate in their campaigns. This information may include your name, public information of your social media account(s), and related estimated statistics.
ii. Service Providers, (for example, hosting companies or platforms for sending commercial communications). Notwithstanding the foregoing, these entities have signed the corresponding confidentiality agreements and will only process your data according to our instructions, and not being able to use them for their own purposes or apart from the service they provide us.
The current list of processors is included in the following link: https://influencity.com/legal/sub-processors-list
iii. Public Bodies. We may disclose to the competent public authorities the data and any other information in our possession or accessible through our systems when there is a legal obligation to do so, as well as when required, for example, when the purpose is to prevent or prosecute abuse of services or fraudulent activities through our Website or web page. In such cases, the personal data you provide to us would be kept and made available to administrative or judicial authorities.
iv. In the event of a corporate transaction: In the event of a merger, acquisition, sale of all or part of its assets, or any other type of corporate transaction involving a third party, we may share, disclose or transfer user data to the successor entity (including during the pre-transaction phase).
v. To third parties after aggregation or anonymization: We may disclose or use aggregated or anonymized data (i.e., data that cannot be linked to an identified or identifiable natural person) for any purpose.
5. ARE YOUR PERSONAL DATA TRANSFERRED TO THIRD COUNTRIES OUTSIDE THE ECONOMIC AREA?
Some of our service providers are located in countries outside the European Economic Area ("EEA").
The location of these companies outside the EEA implies the existence of an international transfer of your personal data, which could lead to a lower level of protection than that provided for in European legislation. However, INFLUENCITY has implemented measures to ensure that such transfers do not result in a lower level of protection of your personal data.
In this regard, service providers outside the EEA have signed the corresponding standard contractual clauses approved by the European Commission ("STC"), an agreement signed between the two entities by which the non-EU company guarantees that it applies European data protection standards.
Therefore, the use of these providers does not result in a lesser degree of protection of your personal data than the use of providers located in the European Union. You can consult the content of the TCHs in the following link: https://ec.europa.eu/info/law/law-topic/data-protection/publications/standard-contractual-clauses-controllers-and-processors_en
6. WHAT ARE THE RIGHTS YOU CAN EXERCISE AS A DATA SUBJECT AND HOW CAN YOU EXERCISE THEM?
You can exercise the rights that the law guarantees you in relation to the processing of your personal data by contacting us via email at email@example.com.
Any claim we receive will be resolved as soon as possible and, in any event, within the maximum time limit established by law from the time we receive it. In some cases, it may be necessary to ask for a copy of your identity document or other identification document if we need to verify your identity.
The rights that correspond to you as an interested party are the following:
i. Right to withdraw consent given
You can revoke your consent in connection with all processing based on it. However, we remind you that the withdrawal of consent will not affect the lawfulness of processing based on consent prior to withdrawal.
ii. Right of access
You have the right to know what data is being processed, if any, and, if so, to obtain a copy of it, as well as to obtain information relating to:
the origin and recipients of the data;
the purposes for which they are processed;
whether there is an automated decision-making process, including profiling;
the data retention period; and
the rights provided for by law.
iii. Right of rectification
You have the right to request the deletion of your personal data if it is no longer necessary for the purpose for which it was collected or if we are no longer authorised to process it.
iv. Right of Withdrawal
You have the right to request the deletion of your personal data if it is no longer necessary for the purpose for which it was collected or, as the case may be, if we are no longer authorised to process it.
v. Right to data portability
You have the right to request data portability in the case of the processing of your data based on your consent or the execution of a contract, as well as when the processing is carried out by automated means. If you exercise this right, you will receive your personal data in a structured format, commonly used and readable by any electronic device. However, you can also request, where possible, that your data be transmitted directly to another company.
vi. Right to limit the treatment of your personal data
You have the right to limit the processing of your data in the following cases:
a) When you have requested the rectification of your personal data during the period in which we verify the accuracy of them.
b) When you consider that we are not authorized to process your data. In that case, you can ask us to limit its use instead of requesting its deletion.
c) When you consider that it is no longer necessary for us to continue processing your data and you want us to keep them for the purpose of exercising or defending claims.
d) In cases where there is processing based on our legitimate interest and you have exercised your right to object, you may ask us to restrict the use of your data during the verification of the prevalence of such interests over yours.
vii. Right to object
You have the right to object at any time to the processing of your personal data based on our legitimate interest, including profiling.
viii. Right to lodge a complaint with the Supervisory Authority
Remember that, at any time, and in the event that you consider that we have violated your right to the protection of your data, you will be able to lodge a complaint with the corresponding Control Authority in Data Protection, in the case of Spain, the Spanish Data Protection Agency (http://www.agpd.es).
ix. Information from your social media
Influencity uses authorized data from Instagram, YouTube, Google, Facebook, Instagram, LinkedIn, Twitter, and other platforms (“Social Platforms”). Such data is collected and stored to power Influencity features. You can request your authorized data be deleted from Influencity by contacting firstname.lastname@example.org. For example, Influencity uses YouTube, Google, Facebook, Instagram, LinkedIn, Twitter, and other Social Platforms’ APIs to collect authorized data. You can learn more about each respective Social Platform’s terms of service and privacy policies via the links below:
Social Platforms Terms of Service:
YouTube API Client: https://developers.google.com/youtube/terms/api-services-terms-of-service
Social Platforms Privacy Policies:
Google & YouTube: http://www.google.com/policies/privacy
You can also withdraw INFLUENCITY’s permission to access your data from social media platforms at any time via each respective social media platform’s setting. Consider that, by withdrawing your authorization, your experience in our Platform may be limited and certain functionalities will be removed.
YouTube & Google: https://security.google.com/settings/security/permissions
Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance, if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initially requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
7. HOW DO WE GUARANTEE THE CONFIDENTIALITY OF YOUR INFORMATION?
The security of your personal data is a priority for us. Therefore, INFLUENCITY has implemented all necessary security measures to ensure effective use and processing of personal data provided by the user, safeguarding their privacy, confidentiality and integrity of them.
Consequently, we comply with the recommended safety standards to protect your data. However, it is impossible to fully guarantee your security due to the nature of the Internet and because there may be fraudulent actions by third parties beyond our control.
We are committed to acting quickly and diligently if data security is compromised or compromised, and to inform you of this where relevant.
8. MODIFICATIONS TO THIS POLICY