PERSONAL INFORMATION WE COLLECT
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
– “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
– “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
– “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
HOW DO WE USE YOUR PERSONAL INFORMATION?
To communicate with you; and, when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us improve and optimize our Site (for example, by generating analytics about how our users browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
Cookies also enable us to recognize you as a returning visitor and optimize your browsing experience, e.g. by remembering your settings or information entered into forms, or returning you to pages you previously visited.
If you decline or delete cookies, our Site will still function, however your browsing experience may be less optimized.
We use anonymized heat-mapping software like Hotjar in order to better understand our users’ needs and to optimize this service and experience. These technology services help us better understand our users’ experiences (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.), and enable us to build and maintain our service with user feedback. They store this information in pseudonymized user profiles.
All data collected on our public-facing Site will never be used to identify individual users or to match it with further data on an individual user (this does not apply to logged-in users within our non-public portals).
As a creator, if you are invited by one of CreatorIQ’s clients to use the “Creator Connect” portal, then we use a temporary cookie to authenticate your login using your email address. This cookie is strictly necessary for using the portal – without this cookie or if you have all cookies blocked by your browser, you will not be able to log in. This cookie expires when you close your session and will be reset when you log in again. This cookie is used exclusively to enable the login process and never to track or analyze your behavior. Please note that our clients are the “data controllers” and responsible for data use on their Creator Connect portal, and might use additional cookies and have data processing policies that differ from ours. Please check the applicable privacy notices when you enter the portal.
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described in Section 3 under Platform Data Processing, below. For example, we use Google Analytics to help us understand how our users use the Site — you can read more about how Google uses your Personal Information here:
You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
We may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising at the following links:
FACEBOOK – https://www.facebook.com/settings/?tab=ads
GOOGLE – https://www.google.com/settings/ads/anonymous
BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
DO NOT TRACK
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
PLATFORM DATA PROCESSING
1. The Data Controller of the personal data we process is: SocialEdge, Inc. dba CreatorIQ. You may contact us using the details at the end of this Policy, and our representative in the EU is:
Floor 11, Whitefriars
Bristol BS1 2NT
2. The purposes of our data processing are as follows:
|Category of data subject||Categories of data||Purpose||Source||Legal basis for data processing|
|Our clients’ business and IT contacts and registered users||Name, title, business email, business phone numbers, business address, login details||Managing provision of our services, permitting and controlling access to our platform, providing customer service||From our clients or directly from the individuals||This processing is necessary for the fulfillment of our contracts with our clients or for our legitimate interests in providing services to them. All this data is business data and its processing should have no negative impact on your privacy|
|Potential clients, suppliers and service providers||Name, title, business email, business phone numbers, business address, business interests, professional experience and qualifications||Growing and managing our business||Directly from you; or from other public sources (e.g. trade shows, professional websites)||This processing is based on our legitimate interests in developing and obtaining goods and services for our business. All this data is business data and its processing should have no negative impact on your privacy|
|Influencers and creators listed on our platform, and their followers||Names and handles, bio and interests, public posting activity, public conversations, engagement, followers and follower counts*||Providing our services and permitting clients to set up and manage campaigns on our platform||
Social Network platforms.
Also from clients**
|This processing is based on our legitimate interests in providing and managing our platform and services. This is information that has been made available publicly by the users, and its processing should have no negative impact on your privacy; we apply industry-standard security measures and also provide an easy means of opting out of inclusion in our platform as indicated in section 5 below.|
|Influencers and creators listed on our platform||Authenticated Data from social Network platforms: all available post and video activity and engagement data***||
More accurate statistical data and attribution of post/video/engagement activity to influencers and creators;
Improvement of our services (in aggregated and anonymous form only)
Social Network platforms.
Also from clients*
|This processing is based on your consent, which is collected when you voluntarily link one or more of your Social Network accounts to our platform which may be in respect of a particular client using our platform|
|Influencers and creators listed on our platform||Email addresses||Communicating with you regarding business opportunities with CreatorIQ clients/ advertisers||Influencers’ and creators’ public profiles or websites||This processing is based on our and our clients’ legitimate interests in communicating with you for business purposes, including introducing opportunities for influencer marketing arrangements or campaigns with them. For this we use contact information that has been made available publicly by you, and its processing should have no negative impact on your privacy; we apply industry-standard security measures and you can opt out of receiving such communications at any time.|
* We receive public data from Social Network Platforms via API connections, which we then store and process in our platform as set out in this Policy. This allows any of our clients that use the “discovery” features of our service to review and locate influencers and creators that could be of interest for their future campaigns. Clients may also review past posting activity, engagement, and past or current campaigns. Updated posts and metrics are obtained from the Social Network Platforms each time a client searches for posts in our system.
** Please note that our clients may also enter certain personal data into our systems (e.g. in relation to particular influencers and creators they work with, or because influencers or creators have directly agreed to give them greater access to Authenticated Data – please see next paragraph). We are a data processor and not a controller of this data. We will normally need to pass any questions in relation to this data on to the relevant client for action or response.
*** Authentication of Data from Social Network Platforms:
Via the Links Accounts Page of your profile page, you may choose to opt-in and allow CreatorIQ to connect to one or more of your Social Network Accounts so that CreatorIQ may access additional data from the applicable Social Network platforms (e.g. the audience of the channel and additional metrics such as video annotation clicks, dark posts and geo-fenced posts, referred to as “Authenticated Data”). You may also be invited directly by a particular brand or client to give them access to Authenticated Data, in which case: (i) that permission relates only to their use of the data; and (ii) that data will only be visible in that client’s section of the CreatorIQ platform and CreatorIQ will not share that data with any other client.
You may revoke CreatorIQ’s ability to collect your Authenticated Data at any time through the opt-out feature in the Link Accounts Page or by contacting us (see section 5 below). You may also revoke access to your Authenticated Data via the Social Networks’ own settings panels, e.g. for YouTube via the Google security settings page at https://security.google.com/settings/security/permissions. If you opt into authenticating any of your Social Network Accounts with CreatorIQ, CreatorIQ will:
- Never post on your behalf to any of your authenticated Social Network Accounts (e.g. your Facebook Page or YouTube Channel).
- Never manage any of your Social Network Account ad campaigns (e.g. Facebook ad campaigns or YouTube ad campaigns) and will never alter any of your Social Network ad settings.
In relation to YouTube accounts, please visit YouTube’s Terms of Service: https://www.youtube.com/t/terms and Google’s Privacy Notice: http://www.google.com/policies/privacy. Please note that this may differ from the information you are given by the relevant Social Network at the time of authenticating. However, we will always process data in accordance with this Policy.
3. The recipients of the data are as follows:
Our platform and the personal data processed within it are hosted on our behalf by Amazon Web Services on servers located in the USA.
We also provide data to other companies in our corporate group and technical service providers inside and outside the EU (with Iceland, Liechtenstein and Norway, the “EEA”, and also including the UK) that require access to data in order to assist us in providing our services. In particular, we work with reputable external data processors, to which we provide certain data which may include personal data, in order to provide our platform and services, including for the purposes of storage, analysis, development, testing etc., and who are not permitted to use data processed on our behalf for any other purpose.
In each case we have in place safeguards that enable transfers from the EEA to happen in a way that ensures that data is handled in accordance with similar standards to those applicable in the EEA. These include: a decision from the European Commission indicating that the place of receipt has adequate data protection laws; and European Commission approved standard contract clauses for other transfers outside the EEA. A copy of these documents can be provided upon request.
We present posts and data received from the social networking platforms to our clients via our platform, as well as email addresses where you have made them publicly available.
Where data (which may include personal data) is entered by our clients we enable clients’ authorized users to access, update and process the data provided by that client.
Finally, if any authority, police force or regulator validly requested data from us, then we would normally comply with such request without having to notify you or other users.
4. We retain the data only as long as necessary for the purposes described in this Policy. When we no longer need to use the data for such purposes (or for us to comply with our legal or regulatory obligations), then we will either remove it from our systems or delete all personally identifying elements so that the data cannot be traced back to you or any other identifiable person.
5. EU data subjects have various legal rights in relation to their data including:
• To ask for access to it;
• To ask for errors in it to be corrected;
• To ask for it to be erased (the “right to be forgotten”);
• If not erased, then to ask us to restrict its processing;
• To object to its processing for specific purposes;
• To ask for a copy to take to another service provider.
Where we process any data based on consent that you have given in the past, then you are always allowed to withdraw your consent at any time (though the processing that took place before withdrawal will still be legal).
We are always available through the contacts at the end of this Policy to help resolve any issues or doubts you may have in relation to processing of your data. If you believe that your rights have not been respected at any time then you also have a right to complain to the Data Protection Supervisory Authority in your country (e.g. in the UK, the Information Commissioner’s Office) to ask them for a resolution.
The Site and our platform and services are not intended for children.
For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at email@example.com or by mail using the details provided below:
600 Corporate Pointe Suite 210, Culver City, CA, 90230, United States
Last updated: August 24, 2020