PRIVACY POLICY
This privacy policy (“Privacy Policy”) applies to information collected through App, whether accessed via the Approved Devices or other technology. This Privacy Policy explains what information we may collect through the App, how such information may be used and/or shared with others, how we safeguard it and how you may access and control its use in connection with our marketing communications and activities. Please read this Privacy Policy carefully, prior to using and/or accessing the App. By using and/or accessing the App or any other of our services, you are acknowledging that you understand and agree to the terms hereof as well as the Terms set forth on the App. We pledge to meet fully, and where possible exceed, internationally recognized standards of personal data privacy protection, with special regard to the General Data Protection Regulation. In doing so, we will ensure compliance by our staff with the strictest standards of security and confidentiality. The most important data protection principles we follow are as follows:
INFORMATION TO DATA SUBJECTS
The personal information provided to or collected by our App is controlled by UNIFY SOCIAL S.R.L. (hereinafter referred to as “UNIFY SOCIAL”, We", "Us" or "Our") a company incorporated and existing under the laws of Romania, having its principal place of business at 5D Dimitrie Pompeiu Blvd., apartment 35, 2nd District, Bucharest, Romania, registered with the Trade Registry under number J40/24829/2022, sole registration number 47352844, email address: [email protected]).
The details of the data protection officer of UNIFY SOCIAL are as follows:
Postal address: 5D Dimitrie Pompeiu Blvd., apartment 35, 2nd District, Bucharest, Romania.
Email address: [email protected]
THE LEGAL BASIS FOR OUR DATA PROCESSING
INFORMATION WE COLLECT Our Privacy Policy applies to any INFLUENCER. We collect certain data, information when you use our App. If you have any concern about providing information to us or otherwise used in any manner permitted in this Privacy Policy and the Terms, you should not become a user of our App. If you have already registered, you can request Us to close your profile. We collect the following types of your personal information and in the following ways. Information you provide us directly When you register with us, you provide us your full name, username, password, postal address, e-mail address, age, interests, phone number, bank details, revenues, and applicable taxes and contributions. You may provide additional information on a voluntary basis (for example gender, website, biography, images, pictures) to help you build your profile and to provide you more customized Campaigns. Communications between you and UNIFY SOCIAL qualify as personal information you provide us with. For example, we may send you service-related emails (e.g., account verification, confirmation, settlement, changes/updates to features of the App, technical and security notices, invitations to participate in a Campaign etc.). Note that you may not opt out of service-related e-mails. Service-related emails are vital part of the App we provide and are also essential tools of confirmation and settlement. Supplementary upon the registration in the App we may collect, in part, browser type, operating system, device type, an estimation of your geographic location associated with your IP address, the page served, the time, referring URLs and other information normally transmitted in HTTP requests. This statistical data provides us with information about the use of the App, such as how many visitors visit a specific web-page on which the App is used, how long they stay on that page, the type of content on that page. We may also automatically collect the internet protocol (“IP“) address or other identifier (“Device Identifier“) for each computer, mobile device, technology or other device (collectively, “Device“) you use to access the App. Our App uses several different technologies to collect Usage Information, including Device Identifiers. These may include, without limitation:
Cookies - Cookies are small text files placed on a Device when the Device is used to visit the App. We may place cookies or similar files on your Device for security purposes, to facilitate site navigation and to personalize your experience while using the App, such as showing you specific offer(s) that we think will be of interest to you. We also use cookies in order to keep you logged in to the App if you register with us. Cookies allow us to collect technical and navigational information, such as browser type, time spent on the App and pages visited. Cookies may include a Device Identifier along with information about the particular type of content in which you have shown interest. Cookies also allow us to select which content is most likely to appeal to you and display that content while you are using the Service. When interacting with the App, if you click on a link to one of our promoted offer(s), the customer sponsoring the promoted link may place a cookie on your Device as well, in which case you will be subject to their privacy policy..
Log Files - As is true of most web sites, we may gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and clickstream data. We use this information, which does not identify individual users, to detect fraud, administer the site, to track users’ actions around the App and to gather demographic information about our user base as a whole.
Pixels - A pixel tag is a transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or e-mail has been viewed. In addition, a pixel tag may tell your browser to get content from another server.
HOW WE USE THE INFORMATION WE COLLECT We use the information we collect about and from you for a variety of business purposes, including for example: to respond to your questions and requests; to provide you with access to the App or to certain functions and features of the App; to provide and maintain your platform account(s); to verify your identity; to communicate with you about your account and activities using the App and, in our sole discretion for marketing or solicitation purposes, to communicate changes to one of our policies; to tailor content or offer(s)/invitation Campaign we serve you; to improve the App for internal business purposes; to process applications and transactions; and for other lawful purposes we may disclose at the time you provide your Personal Information or to which you otherwise consent.
SHARING OF INFORMATION We may disclose Personal Information as follows:
TRANSFER PERSONAL DATA TO THIRD COUNTRIES Your personal data which we collect is stored within the European Union (“EU”) and the European Economic Area (“EEA”). In addition, your personal data may be transferred to, and stored at, a destination outside the EU and EEA. When your personal data is transferred from your own country to another country, the laws and rules that protect your personal data in the country to which your information is transferred to may be different (or less protective) from those in the country in which you work. It is our intention not to transfer your personal data outside the EEA unless adequate protections are in place, including: (i) an adequacy decision by the European Commission in respect of the recipient country or countries; (ii) appropriate binding corporate rules; (iii) an approved code of conduct together with binding and enforceable commitments of the controller or processor in the country outside the EU and EEA; (iv) an approved certification mechanism together with binding and enforceable commitment of the controller or processor in a country outside the EU and EEA to apply the appropriate safeguards; or (v) EU standard contractual clauses approved by the European Commission. We may transfer personal data to a third country based on our services and the seat or address of Brands and / or INFLUENCERS. The basis of such transfers is nor an adequacy decision (Article 45 of GDPR) or an appropriate safeguards (Article 46 of GDPR), nor binding corporate rules (Article 47 of GDPR).The basis of such transfer is Article 49 of GDPR:
YOUR PRIVACY RIGHTS AND CHOICES (a) The right to information, namely the right to receive details of the data processing activities performed by UNIFY SOCIAL; (b) The right of access to your personal data, namely the right to obtain confirmation from UNIFY SOCIAL regarding the processing of your personal data, as well as details of the processing activities; (c) The right to rectification, namely the right to obtain data rectification of inaccurate your personal data by UNIFY SOCIAL, as well as the completion of incomplete data; (d) The right to delete your personal data ("the right to be forgotten"), to the extent that the conditions provided by the law are met; (e) The right to restrict processing of your personal data, to the extent that the conditions laid down by law are met; (f) The right to data portability, respectively (i) the right to receive Influencer Data in a structured, commonly used and machine-readable format, and (ii) the right to have oyur personal data transmitted by UNIFY SOCIAL to another controller, provided that the requirements laid down by the law are met; (g) The right to opposition, namely the right to oppose, for good reasons, future processing of your personal data; (h) The right not to be subject to an automatic individual decision, namely the right not to be the subject of a decision taken solely on the basis of automatic processing activities; and (i) The right to address to a national supervisory authority for personal data processing or to the competent courts, to the extent he/she deems necessary.
DATA RETENTION AND DELETION We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. We may retain aggregated data, which cannot identify an individual or device and is used for reporting and analysis purposes, for as long as commercially necessary. We retain identifiable data, which is directly collected for purposes of providing our service to you or serving content to end-users, for no longer than twenty-four (24) months from the INFLUENCER’s last interaction with our App and/or services, after which time we will either de-identify the data by removing unique identifiers or aggregating the data, or simply delete it.
CHILDREN’S PRIVACY The App is not directed to children under 16. We do not knowingly collect Personal Information from anyone under 16 years of age. If you accept this Privacy Policy you represent and warrant that either you are 16 years of age or older or the consent or the authorisation to the consent was made by the holder of parental responsibility over you.
SECURITY OF YOUR INFORMATION We maintain tight controls over all the data we collect, retaining it in secured databases with limited and controlled access rights, to ensure it is secure. Where we have given you (or where you have chosen) a password that enables you to access certain features of the Service, you are responsible for keeping this password confidential. Please remember that unfortunately, the transmission of information via the internet is not completely secure, so although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access..
CHANGES Should the scope of data, or the circumstances of data management be subject to change, this policy shall be amended and published on the App within 30 days. Please pay attention to the amendments of this policy, as they contain important information regarding the management of your personal data.
CONTACT US We regularly review our compliance with this Privacy Policy. Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to [email protected]
This privacy policy (“Privacy Policy”) applies to information collected through App, whether accessed via the Approved Devices or other technology. This Privacy Policy explains what information we may collect through the App, how such information may be used and/or shared with others, how we safeguard it and how you may access and control its use in connection with our marketing communications and activities. Please read this Privacy Policy carefully, prior to using and/or accessing the App. By using and/or accessing the App or any other of our services, you are acknowledging that you understand and agree to the terms hereof as well as the Terms set forth on the App. We pledge to meet fully, and where possible exceed, internationally recognized standards of personal data privacy protection, with special regard to the General Data Protection Regulation. In doing so, we will ensure compliance by our staff with the strictest standards of security and confidentiality. The most important data protection principles we follow are as follows:
- All data are processed lawfully, fairly and in a transparent manner;
- All data are collected for specified, explicit and legitimate purposes as described in this Privacy Policy and not further processed in a manner that is incompatible with those purposes;
- The processing of data is adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- All data shall be accurate and, where necessary, kept up to date; we take every reasonable step to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- All data are kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
- All data are processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
- We accept that your personal data may only be used or disclosed for the purpose for which it was originally collected; for a directly related purpose; or for a purpose to which you have consented.
INFORMATION TO DATA SUBJECTS
THE LEGAL BASIS FOR OUR DATA PROCESSING
- GDPR Article 6 (1) a) where the processing is based on the consent of the data subject (hereafter referred to as Consent) – e.g.: use of cookies on our App.
- GDPR Article 6 (1) b), on where processing is necessary for the performance of a contract to which the data subject is party (hereafter referred to as Conclusion of Contract) – e.g.: execution of the Terms and/or of the Copyright Assignment Agreement.
- GDPR Article 6 (1) c) where data processing is necessary for the fulfillment of or compliance with a legal obligation of the data controller (e.g. obligations with tax statues).
- GDPR Article 6 (1) f) where data processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, (hereinafter referred to as: Lawful Interest)
INFORMATION WE COLLECT Our Privacy Policy applies to any INFLUENCER. We collect certain data, information when you use our App. If you have any concern about providing information to us or otherwise used in any manner permitted in this Privacy Policy and the Terms, you should not become a user of our App. If you have already registered, you can request Us to close your profile. We collect the following types of your personal information and in the following ways. Information you provide us directly When you register with us, you provide us your full name, username, password, postal address, e-mail address, age, interests, phone number, bank details, revenues, and applicable taxes and contributions. You may provide additional information on a voluntary basis (for example gender, website, biography, images, pictures) to help you build your profile and to provide you more customized Campaigns. Communications between you and UNIFY SOCIAL qualify as personal information you provide us with. For example, we may send you service-related emails (e.g., account verification, confirmation, settlement, changes/updates to features of the App, technical and security notices, invitations to participate in a Campaign etc.). Note that you may not opt out of service-related e-mails. Service-related emails are vital part of the App we provide and are also essential tools of confirmation and settlement. Supplementary upon the registration in the App we may collect, in part, browser type, operating system, device type, an estimation of your geographic location associated with your IP address, the page served, the time, referring URLs and other information normally transmitted in HTTP requests. This statistical data provides us with information about the use of the App, such as how many visitors visit a specific web-page on which the App is used, how long they stay on that page, the type of content on that page. We may also automatically collect the internet protocol (“IP“) address or other identifier (“Device Identifier“) for each computer, mobile device, technology or other device (collectively, “Device“) you use to access the App. Our App uses several different technologies to collect Usage Information, including Device Identifiers. These may include, without limitation:
Cookies - Cookies are small text files placed on a Device when the Device is used to visit the App. We may place cookies or similar files on your Device for security purposes, to facilitate site navigation and to personalize your experience while using the App, such as showing you specific offer(s) that we think will be of interest to you. We also use cookies in order to keep you logged in to the App if you register with us. Cookies allow us to collect technical and navigational information, such as browser type, time spent on the App and pages visited. Cookies may include a Device Identifier along with information about the particular type of content in which you have shown interest. Cookies also allow us to select which content is most likely to appeal to you and display that content while you are using the Service. When interacting with the App, if you click on a link to one of our promoted offer(s), the customer sponsoring the promoted link may place a cookie on your Device as well, in which case you will be subject to their privacy policy..
Log Files - As is true of most web sites, we may gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and clickstream data. We use this information, which does not identify individual users, to detect fraud, administer the site, to track users’ actions around the App and to gather demographic information about our user base as a whole.
Pixels - A pixel tag is a transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or e-mail has been viewed. In addition, a pixel tag may tell your browser to get content from another server.
HOW WE USE THE INFORMATION WE COLLECT We use the information we collect about and from you for a variety of business purposes, including for example: to respond to your questions and requests; to provide you with access to the App or to certain functions and features of the App; to provide and maintain your platform account(s); to verify your identity; to communicate with you about your account and activities using the App and, in our sole discretion for marketing or solicitation purposes, to communicate changes to one of our policies; to tailor content or offer(s)/invitation Campaign we serve you; to improve the App for internal business purposes; to process applications and transactions; and for other lawful purposes we may disclose at the time you provide your Personal Information or to which you otherwise consent.
SHARING OF INFORMATION We may disclose Personal Information as follows:
- To any current or future affiliates, parent companies, or subsidiaries.
- To vendors, service providers, agents, contractors, or others who perform functions (e.g., maintenance, data analysis, customer relationship management, email marketing, surveys, credit card processing, data hosting, or fraud detection) on our behalf.
- To Customers. For example, we may provide Brands with information to inform them about you as a potential and registered INFLUENCER.
- We may also disclose Personal Information when legally required to do so, to cooperate with law enforcement investigations or other legal proceedings, to protect against misuse or unauthorized use of the App, to limit our legal liability and protect our rights or to protect the rights, property or safety of users of this Site, the Service or the public.
TRANSFER PERSONAL DATA TO THIRD COUNTRIES Your personal data which we collect is stored within the European Union (“EU”) and the European Economic Area (“EEA”). In addition, your personal data may be transferred to, and stored at, a destination outside the EU and EEA. When your personal data is transferred from your own country to another country, the laws and rules that protect your personal data in the country to which your information is transferred to may be different (or less protective) from those in the country in which you work. It is our intention not to transfer your personal data outside the EEA unless adequate protections are in place, including: (i) an adequacy decision by the European Commission in respect of the recipient country or countries; (ii) appropriate binding corporate rules; (iii) an approved code of conduct together with binding and enforceable commitments of the controller or processor in the country outside the EU and EEA; (iv) an approved certification mechanism together with binding and enforceable commitment of the controller or processor in a country outside the EU and EEA to apply the appropriate safeguards; or (v) EU standard contractual clauses approved by the European Commission. We may transfer personal data to a third country based on our services and the seat or address of Brands and / or INFLUENCERS. The basis of such transfers is nor an adequacy decision (Article 45 of GDPR) or an appropriate safeguards (Article 46 of GDPR), nor binding corporate rules (Article 47 of GDPR).The basis of such transfer is Article 49 of GDPR:
- In the absence of an adequacy decision pursuant to Article 45(3), or of appropriate safeguards pursuant to Article 46, including binding corporate rules, a transfer or a set of transfers of personal data to a third country or an international organisation shall take place only on one of the following conditions:
YOUR PRIVACY RIGHTS AND CHOICES (a) The right to information, namely the right to receive details of the data processing activities performed by UNIFY SOCIAL; (b) The right of access to your personal data, namely the right to obtain confirmation from UNIFY SOCIAL regarding the processing of your personal data, as well as details of the processing activities; (c) The right to rectification, namely the right to obtain data rectification of inaccurate your personal data by UNIFY SOCIAL, as well as the completion of incomplete data; (d) The right to delete your personal data ("the right to be forgotten"), to the extent that the conditions provided by the law are met; (e) The right to restrict processing of your personal data, to the extent that the conditions laid down by law are met; (f) The right to data portability, respectively (i) the right to receive Influencer Data in a structured, commonly used and machine-readable format, and (ii) the right to have oyur personal data transmitted by UNIFY SOCIAL to another controller, provided that the requirements laid down by the law are met; (g) The right to opposition, namely the right to oppose, for good reasons, future processing of your personal data; (h) The right not to be subject to an automatic individual decision, namely the right not to be the subject of a decision taken solely on the basis of automatic processing activities; and (i) The right to address to a national supervisory authority for personal data processing or to the competent courts, to the extent he/she deems necessary.
DATA RETENTION AND DELETION We will not retain data longer than is necessary to fulfill the purposes for which it was collected or as required by applicable laws or regulations. We may retain aggregated data, which cannot identify an individual or device and is used for reporting and analysis purposes, for as long as commercially necessary. We retain identifiable data, which is directly collected for purposes of providing our service to you or serving content to end-users, for no longer than twenty-four (24) months from the INFLUENCER’s last interaction with our App and/or services, after which time we will either de-identify the data by removing unique identifiers or aggregating the data, or simply delete it.
CHILDREN’S PRIVACY The App is not directed to children under 16. We do not knowingly collect Personal Information from anyone under 16 years of age. If you accept this Privacy Policy you represent and warrant that either you are 16 years of age or older or the consent or the authorisation to the consent was made by the holder of parental responsibility over you.
SECURITY OF YOUR INFORMATION We maintain tight controls over all the data we collect, retaining it in secured databases with limited and controlled access rights, to ensure it is secure. Where we have given you (or where you have chosen) a password that enables you to access certain features of the Service, you are responsible for keeping this password confidential. Please remember that unfortunately, the transmission of information via the internet is not completely secure, so although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the App; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access..
CHANGES Should the scope of data, or the circumstances of data management be subject to change, this policy shall be amended and published on the App within 30 days. Please pay attention to the amendments of this policy, as they contain important information regarding the management of your personal data.
CONTACT US We regularly review our compliance with this Privacy Policy. Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to [email protected]
