This privacy policy applies to Our Site and platform and the content management services. This privacy policy describes how Our Site collects and uses the Personal Information (described below) you or social media users provide through the Services, including through our mobile application. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information.
If you have an unresolved privacy or personal information use concern that we have not addressed satisfactorily, please contact Our Site’s Data Protection Representative.
CHANGES TO THIS POLICY
We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by means of a prominent notice on the Services prior to the change becoming effective. If you are an Our Site Customer, we may notify you of such changes by email (sent to the email address specified in a Customer’s account). Any access or use of the Services by you after such notice shall be deemed to constitute acceptance by you of such changes, modifications or additions. We encourage you to periodically review this page for the latest information on our privacy practices. If you do not agree to abide by these practices or any future privacy policy, please do not use or access the Services.
PERSONAL INFORMATION WE COLLECT
We collect information that may allow the identification of a natural person ("Personal Information") (i) from individuals who upload user-generated content to Customer or other digital properties (such as a Customer’s website, Instagram or Facebook) on behalf of our Customers ("Social Media Users"), and (ii) from users which interact with the Customer galleries.
With regard to each of these groups we collect the following Personal Information:
Social Media Users: We collect information from Social Media Users such as public uploads and posts, including publicly posted photographs. With such assets, we process name, social media username, physical address (if available), email-address (if available), IP address, and geo location (if available).
End Users: When End Users interact with our web sites or the user galleries we collect IP address and date/timestamp. If an end-user buys products directly from a Customer digital property, Our Site additionally collects purchase information (including purchased product ID, transaction ID, transaction price, date of purchase, unique ID that our Customer may have assigned to such End User), email-address and username (if provided by End Users to Customers).
USE OF PERSONAL INFORMATION
Social Media Users: We only process Personal Information we collect from you to provide the services for which our Customers have engaged us. Our Customers to whom you have submitted content through Our Site Services or whose brand hashtags, @brand mentions or branded location tags you have included in your social media posts, may use your username or email address to communicate with you, in addition to using your photo. IP and geo-location are used to filter content by region, country or other local area. Such data is used with your consent only.
End Users: We process the Personal Information described above to allow our Customers to analyze with which digital assets you interacted prior to purchasing a product from a Customer digital property after interacting with the user galleries on those digital properties. Furthermore, we collect the information to improve the Services, and to improve marketing, analytics and the functionality of the Services. Finally, we log IP and date/timestamp to investigate and/or prevent security breaches.
ACCESS TO AND DELETION OF YOUR PERSONAL INFORMATION
Upon request, Our Site will provide you with information about whether we hold any of your Personal Information and, if that is the case, what Personal Information we hold. If your Personal Information changes, or if you wish to exercise your right to be forgotten, you may correct, update, delete or deactivate your information from our records by (for Customers) logging into your account and making the appropriate changes or emailing your Account Manager directly, or (for Social Media and End Users) contacting us. We will respond to requests to access Personal Information under this paragraph within 10 business days of receipt of such request.
If the Personal Information is controlled by Our Site Customer, we will inform you how to exercise your rights mentioned above.
COOKIES AND TRACKING TECHNOLOGIES
Technologies such as cookies, beacons, tags, scripts or similar technologies are used by Our Site and our third-party marketing partners, affiliates, and analytics providers. These technologies are used in analyzing trends, administering the Services, tracking users’ movements around the Services, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by the third parties mentioned above on an individual as well as aggregated basis.
With respect to cookies in particular, we use cookies to analyze End User interactions with our Services such as purchases on the digital properties of those Customers who have chosen to implement them. End Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Services, but your ability to use some features or areas of our Services may be limited.
We partner with third parties to manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on our web sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads. Please note this does not opt you out of being served ads. You will continue to receive generic ads.
RETENTION OF PERSONAL INFORMATION
Our Site will retain Personal Information for as long as needed to provide the Services or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
MOBILE APPLICATION
When you download our mobile application and use our Services, we automatically collect information on the type of device you use, operating system version, and system and performance information.
We do not ask for, access or track any location-based information from your mobile device at any time while downloading or using our mobile application and the Services.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personally identifiable information you submit within the mobile application.
SECURING YOUR PERSONAL INFORMATION
We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. Nonetheless, due to the inherent nature of the Internet as an open global communications vehicle, we make no guarantee as to the security of your information or that your information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. When you enter sensitive information (such as Customer log in credentials entered onto Our Site), we encrypt the transmission and storage of that information using industry standard encryption technologies. If you contact us by email or a "contact us" or similar feature on the Site, you should be aware that your transmission might not be secure. A third party could view information you send by these methods in transit. If you have any questions regarding security you can contact us.
We will make any legally or contractually required disclosures of any breach of confidentiality, privacy, or integrity of your personal data to you via email or conspicuous posting on this Site in the most expedient time possible and without unreasonable delay, consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
BUSINESS TRANSFER
In the event that Our Site is or substantially all of its assets are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, such databases containing Personal Information may be one of the transferred assets. In the event of such a transfer, Our Site will place a prominent notice on our Services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information.
CHILDREN’S POLICY
The Our Site Services are in no way directed to persons under the age of 18. Our Site collects Personal Information through third party social media services that are not directed at children under the age of 13. If you have reason to believe that Our Site collected the information of an individual under 18, please contact us, and we will endeavor to delete that information and terminate the child’s information from our databases.
CALIFORNIA CONSUMERS
In addition to the rights set out in this privacy policy, California law, including the California Consumer Privacy Act of 2018 (the "CCPA"), provides for additional rights to California consumers. Your rights as a California consumer are summarized below.
You have the right to request additional information about your personal information, including the categories and specific pieces of personal information we have collected about you, the source of such personal information, the purpose for such collection, and information about how your personal information is shared with third parties.
We will not discriminate against you in the event that you exercise any of your rights as a consumer under the CCPA.
CONTACT US
If you have any questions or comments about this privacy policy or about our use of your Personal Information, please contact us.
