Traackr

TRAACKR, INC. - PRIVACY NOTICE – INFLUENCERS

Welcome to Traackr, Inc.’s (“Traackr”, “we”, “us” or “our” in this privacy notice) privacy notice for influencers.

We collate publicly available information about influential individuals (“you” or “your” in this privacy notice if we have obtained information about you). This pooled information, or ‘personal data’, is made available on Traackr’s market-research database via Traackr’s Influencer Relationship Management platform (the “platform”) for its users to discover, evaluate and manage their engagement with influential people.

Traackr respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when it is used on our market-research database, your privacy rights and how the law protects you.

Purpose of this privacy notice

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your personal data. This privacy notice supplements the other notices and is not intended to supersede them.

Who we are

Traackr, Inc. is a company based in the United States of America. Our main office is 244 California Street, Suite 204 San Francisco, CA 94111, United States of America. We have developed and manage our market-research database, our ‘Influencer Relationship Management Platform’, which allows its users to manage, expand, validate and scale their networks with influencers.

Controller

Traackr is responsible for the protection of personal data that it collate from publicly available information and adds to its market-research database. As such, we are a controller under applicable data protection legislation for personal data which we obtain about you.

Further help

If you have any questions about this privacy notice, including any requests to exercise your legal rights referred to in ‘Your legal rights’ (paragraph 7 below), please contact our compliance team using the following email address: support@traackr.com.

If you are an individual located in the United Kingdom or any country in the European Economic Area (the “EEA”), you have the right to make a complaint at any time to the supervisory authority which regulates the processing of personal data in the country in which you are located. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us by emailing support@traackr.com in the first instance.

1. The data we process and how it is obtained

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collate, use, store and transfer different kinds of publicly available personal data about you which is obtained indirectly via secondary sources such as social media networks and other Internet sources. This personal data may include the following:

  1. your name, age and affiliated organization (if applicable);
  2. your social media handle; and
  3. messages which you have shared publicly on social media.
2. How we use your personal data

We will only use your personal data to the extent that the law allows us to do so. We will use your personal data where it is necessary to pursue our legitimate interests and your interests and fundamental rights do not override those interests.

As part of these legitimate interests, the platform may benefit you as an influencer by facilitating your connection with companies (and their brands) to enable those companies to expand your presence in the influencer marketing ecosystem and to enhance your subject-matter expertise. Influencers often reach out to us and request to be included on the platform. The platform also affords a mutual benefit to both brands and influencers by empowering brands and influencers to build meaningful relationships for their shared gain. Additionally, the platform affords a greater public benefit by facilitating the growth and development of, and insight into, the wider influencer marketing ecosystem.  

Purposes for which we will use your personal data

We process your personal data for the purposes of allowing users of our platform and associated market-research database to discover, evaluate and manage their engagement with influential people. In addition to allowing users to conduct market research, as noted above, we will use your personal data to connect you through our platform with companies (and their brands).

Opting out

You can ask us or third parties to stop processing your personal data. To do this, visit the following webpage: http://fr.traackr.com/data-opt-out.

3. Disclosures of your personal data

We may share your personal data with the persons and in the contexts set out below:

  1. users of our platform and associated market-research database;
  2. service providers who provide us with IT, system administration, and other services;
  3. professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
  4. persons to whom we are under a duty to disclose or share your personal data in order to comply with any legal obligation, including without limitation public authorities who may need to see your personal data to meet national security or law enforcement requirements, and regulators and other authorities who require reporting of processing activities in certain circumstances;
  5. third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice
  6. third parties with whom we may be required to communicate if we discontinue our business, or file a petition or have filed against us a petition in bankruptcy, reorganization or similar insolvency petition, application or proceeding;
  7. our Corporate Affiliates; for the purposes of this privacy notice: "Corporate Affiliate" means any person or entity which directly or indirectly controls, is controlled by or is under common control with Traackr, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise; and
  8. third parties with whom we may be required to communicate in order to enforce or apply the terms of our agreements; or to protect the rights, property, or safety of Traackr, our customers, or others.

We use reasonable efforts to ensure that all third parties respect the security of your personal data and to treat it in accordance with the law. Apart from users of our market-research database, who will separately be required to adhere to privacy laws when dealing with your personal data, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our documented instructions.

4. International transfers

Where we use certain service providers in circumstances requiring a transfer of your personal data from a country in the EEA to another country outside of the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA under the GDPR. If we rely on another basis to transfer your personal data outside of the EEA, we will keep you updated by way of updates to this privacy notice.

Please contact us by emailing support@traackr.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

5. Data security

We have put in place appropriate security measures intended to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Processors of your personal data acting on our documented instructions will only process your personal data in accordance with our instructions and are subject to a duty of confidentiality.

6. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which it was obtained. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

7. Your legal rights

Under certain circumstances, you have certain rights under data protection laws in relation to your personal data, including to:

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of any new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please visit the following webpages: http://fr.traackr.com/data-opt-out or http://fr.traackr.com/data-download. Please note that Traackr reserves the right to refuse any request to exercise such rights to the extent permitted by applicable law.

No fee usually required

You generally will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. Changes of purpose

We will only use your personal data for the purposes for which it was obtained, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by emailing support@traackr.com.

If we need to use your personal data for an unrelated purpose, we will update this privacy notice and explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

9. Changes to our privacy notice

Any changes we make to this privacy notice in the future will be posted to our website. Please check back frequently to see any updates or changes to this privacy notice.

Effective as of May 25, 2018. Last updated on May 24, 2018

Traackr, Inc.

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