Privacy Policy

Company Influee Inc. registered under its business address 228 Park Ave S, New York, NY 10003 and tax number: 36-4890293 (“Company”), is aware of the importance of your privacy, which is why we are committed to protect the confidentiality of Personal Data of our customers. This Privacy policy is intended to help you better understand how we collect, use, process and store your Personal Data and describes your choices regarding certain types of processing. We are aware of the importance of how Personal Data are handled and we assure you that we observe all applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (hereinafter: “GDPR”).

Unless otherwise indicated, terms used in this Regulation shall have the same meaning as under GDPR.

We assure you that your Personal Data, captured on our webpages or through doing business with you, will be collected, processed, protected and stored in compliance with the applicable legislation.

Personal Data and contact information shall be used solely for the purposes for which they have been submitted in compliance with your consent. On each separate occasion we will inform you beforehand of Personal Data collection and of the purpose thereof. Should we collect and use your Personal Data for any other purposes than those for which you have submitted them to us we will contact you in order to obtain your consent.

General Provisions

Together with our Terms of use (also referred as: “Terms”) this Privacy Policy governs Company's collection, processing and use of your Personal Data by using Company’s:

• Website at https://influee.co also referred as: “Website”),
• Mobile App (available at Google Play Store and Apple App Store), which provides the Services for Influencers with registered Accounts in accordance with Terms,
• Web application (also referred as: “Platform” or “Dashboard”), which provides Company’s Clients with the possibility to collaborate with an individual Influencer and submit their offer regarding marketing campaigns (financial framework, product description, etc.) to the Company,
• Any other Services accessible through the App and / or Website, provided by Company. This policy sets out the basis on which any Personal Data we collect from You, or that You provide to Company, will be processed and used by Company.

Personal information / Personal Data refers to any information that can be associated with a specific person (also referred as: “You” or “Influencer”) and can be used to identify that person, directly or indirectly, in particular by reference to an identifier such as a photograph, video, name, Instagram username, address, e-mail address, bank account number and payment transactions connected to Company Services, shipping location, an online identifier or similar information of that natural person and other required information Influencer provides to gain and operate a registered Influee Account (in this policy collectively referred as: “Personal Data” or “Personal information”).

User shall mean any Influencer who has already and willingly downloaded the Mobile App and any potential Client or other entity or person who visits our Website.

Company is the data controller responsible for your Personal Data. This privacy policy is issued on behalf of the Company so when we mention Influee, “we”, “us” or “our” in this privacy policy, we are referring to the company Influee Inc.

Company will:

• Always keep your data safe and private.
• Never sell your data.
• Allow you to manage and review your marketing communication preferences at any time.

Company does not collect or process your genetic, physiological, mental, racial or ethnic origin, cultural or social identity Personal Data, political opinions, religious or philosophical beliefs, trade union memberships, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Company merely collects or process Personal information / Personal Data from Instagram business accounts, used by Influencers, who have accepted this Privacy policy and install the Influee app. Any collection and processing is performed for brokering the Influencer’s Services to the Client, based upon the terms and conditions agreed in the marketing Campaign.

If you have any questions about this privacy policy, including any requests or complaints, please contact us by written notice at our postal address Influee Inc., 228 Park Ave S, New York, NY 10003; or send us an email to legal@influee.co or hello@influee.co.

Data Protection Officer

Company has appointed a data protection officer (also referred as: “DPO”), who has several responsibilities, under GDPR, including but not limited to:

• monitoring Company’s compliance with the GDPR and other data protection laws
• raising awareness of data protection issues, training Company staff and conducting internal audits and
• cooperating with supervisory authorities on our behalf.

Complaints

You have the right to make a complaint at any time to the authorized Data Protection Office. We would, however, appreciate the chance to deal with your concerns before you approach the data protection office, so please contact us in the first instance.

Cookie Policy

When Influencers or companies, which may become our potential Clients, access the Website, Platform and App or use Services, Company may place small data files called cookies on computers or other devices. This helps us to provide you with a good experience when you use the Apps, Platform or browse our Website and allows us to improve the App and our Website. Company uses these technologies to recognize you as Influencer of the Website, Platform and / or other Services in order to customize the Website and advertising content, measure communication and marketing effectiveness and collect information about Influencer’s devices to mitigate risk, help prevent fraud and promote trust and safety.

We may use cookies, pixel tags, web beacons, and other tracking technologies to collect information about you when you interact with our Services, including information about your browsing behaviour on the Platform.

Most web browsers are set to accept cookies by default. You are free to decline most of our cookies if your browser or browser add-on permits but choosing to remove or disable our cookies may interfere with your use and functionality of the Services. Additionally, we may use certain persistent cookies that are not affected by your browser settings but will use such cookies solely for identity verification and fraud prevention purposes. For more information about cookies and how to block, delete or disable them, please refer to your browser instructions, or contact us at hello@influee.co.

Information we collect about you

By accepting this privacy policy, you explicitly provide your consent that Company may collect, use, store and transfer different kinds of Personal Data from collaboration with you, which we have grouped together as follows:

Submitted Personal information

This is Personal information you may give us about you by filling in forms on Website, Platform and / or Apps and / or corresponding with us by regular mail, phone, email or otherwise. This includes Personal information (collectively also referred as: “Submitted Personal information”) You provide by:

• filling in forms on the App, Website and / or Platform and/or subscribing to our Newsletter (such as Company news and updates that provide information regarding the latest developments of the platform and the company, promotions, and industry news), download a document from Website, register for a webinar or enter a Company’s contest, survey or other marketing activity. The latter shall be further described in terms and conditions of the relevant activity; and / or
• (actively) corresponding with us (for example, by email, via the chat functions on the App and / or the Website and / or through our customer service or otherwise actively correspond with Company) and / or participating in discussion boards or other social media functions on the App or the Website;
• providing required Personal information and requested documents in the context of verifying Influencer’s identification and detection of money laundering, terrorist financing, fraud, or any other financial crime.
• when using Google Login we store your first name, last name and your email. We only this data for authentication purposes.

Submitted Personal information is used to verify your identity to protect against fraud, comply with Anti-money laundering and counter terrorist financing legislation and other financial crime laws and to confirm your eligibility to use our products and Services; and consists of, as follows:

• Data of the Influencer for logging in the App: first name, last name, Instagram username, e-mail address - to verify your identity and provide you Company Services, notifications of the Platform and forgotten password, and any changes to our Service or Terms or Privacy Policy;
• Shipping data of the Influencer: address, phone number – for the purpose of delivering the Client’s products which shall be used in creation of Influencer’s Content;
• Bank account data of the Influencer: bank account data, i.e. the bank account number, bank sort code, IBAN - to carry out our payment obligations form the escrow account, after your duly performance of Services, i.e. distribution of any transactions;
• Identity data of the Client: e-mail address from the appointed employee / representative of the Client or e-mail address of the Influencer – for transaction emails and receiving marketing material from us and our third parties based on your communication preferences.

Personal information collected by using Automated Personal Data

Automated Personal Data shall mean data collected by using Cookies and other automated technologies or interactions.

Automated Personal Data is Personal information you agree to give us about you as you interact with our Websites. We may automatically collect Technical Data about your equipment, browsing actions, including your IP address, patterns and other activity when using Website, Apps and / or Platform. Company collects this Personal Data by using cookies, server logs and other similar technologies. This allows us to recognize our Users and avoid repetitive requests for the same information. With automated technology we track, collect and store the User’s behaviour on the Website / Platform. However, Company does not allow other websites to read cookies from our Website.

Automated Personal Data is used to improve ‘User experience’ and certify the App’s / Website’s safety and security, and to ensure that content from our Website is presented in the most effective manner for its visitors and to administer our Website and Apps for internal operations, including troubleshooting, data analysis (e.g. to measure or understand the effectiveness of advertising); testing, research, statistical and survey purposes, when you choose to do so.

Automated Personal Data is also used to verify your identity, protect against fraud, comply with Anti-money laundering and counter terrorist financing legislation and other anti-financial crime laws and to confirm your eligibility to use our Services; and to comply with our regulatory obligations.

For the purpose of evidencing our business collaboration, we collect certain information about your use of the Services on the Platform, such as use of the Apps and Platform, including but not limited to i) keeping track of performed transactions and / or transfer of Influencer’s Assets on App balance and further on Influencer’s bank account and vice-versa; and ii) keeping track of placed, filled or cancelled Company payments due to failure of Services or similar.

Automated Personal Data consists of and is used for, as follows:

• Transaction data: storage of Company’s performed transactions and / or transfer of payment for Services from our Clients to Influencer or vice-versa. Collected transaction data includes date, time, amount, currencies used, beneficiary bank account details (the storage of such data shall last 10 years or more in case applicable legislation governing prevention of money laundering and terrorist financing legislation determines otherwise);
• Profile Data: interests, preferences, feedback, survey responses;
• Usage Data: includes information about how you use Website, Platform and / or Services;
• Technical Data: includes IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Websites, Apps and / or Platform.

Combinations and associations of Personal Data categories

We may associate any category of to any other category of Personal Data. We will treat the combined information as Personal Data in accordance with this policy for as long as it is combined.

For advertising networks, we utilize anonymized Personal Data in order to serve relevant adverts to target segments. However, Company will never disclose identifiable information to advertisers.

Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your Personal Data. Please contact us via the Company email if any details about the specific purpose or legal ground we are relying on to process your Personal Data could be seen as unclear, from your perspective.

Marketing

Company is striving to provide clear information of Personal Data usage for our marketing purposes and simple access to individual's communication preferences management or opt-out from receiving any marketing communications from us whenever you want.

Promotional offers from us

We may use your Personal Data (such as your Submitted Information and Automated Personal Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have signed up to and / or utilize the Influee App or our Website and, in each case, you have not opted out of receiving marketing notifications.

Third party marketing

We will not share your Personal Data with any company outside the Influee group that is not our contracted data processor, who is obliged to process Personal Data on behalf of Company at least in such a manner that processing will meet the requirements under the applicable law.

Opting out

You can stop receiving marketing messages at any time by sending your choice to hello@influee.co.

Disclosure of your Personal Data

Data Processing Partners

We will disclose the Personal Data we collect from you to certain processors who need to use Personal Data in delivering their services to us. Such partners shall use Personal Data securely and confidentially and under strict contractual controls in accordance with data protection laws and enforced by Company.

To the extent that we shall be obliged to provide your Personal Data to the following sets of data processors in order to perform the Company Services and / or to provide you customized marketing communication with your consent, we reserve the right to send your data to:

• Banking and financial services partners: Financial services providers that help us provide the Company Services including banking partners, banking intermediaries and international payments services providers (e.g. for payment or pay out services: Stripe, Inc. and TransferWise Ltd.
• Fraud prevention agencies: This is in order to verify your identity, protect against fraud, comply with anti-money laundering laws and to confirm your eligibility to use our products and Services;
• Cloud storage providers: This is in order to safely and securely store your data;
• Advertisers and analytics providers: For advertising networks, we utilize anonymized Personal Data in order to serve relevant adverts to target segments. However, Company will never disclose identifiable information to advertisers.
• Marketing automation and CRM provider: This data processor enables us to collect and manage your Personal Data at one place ) and to ensure you the rights to access, manage, export or delete your Personal Data (for EU - at least in such a manner that meets the requirements under GDPR).
• Companies that are Influee license holders: In order to provide a unified service across all of our Services, we may disclose your Personal information to Influee license holders. Such entities will have agreed to be acting as joint controllers or processors in order to provide the Company Services.

Other circumstances

We may also disclose your personal information in the following circumstances:

• If Company or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request.
• In order to enforce or apply the Terms of Service and / or any other agreements between you and Company or to investigate potential breaches or protect the rights, property or safety of Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of protection from fraud or tax evasion.

Data Processing Clients

We shall ensure that our Clients as well as other users of our App or Platform or any other person authorised to process the Personal Data of the Influencer either have committed themselves to confidentiality of Personal Data or are under an appropriate statutory obligation of confidentiality (e.g. attorneys at law). The obligation to protect Personal Data secrecy shall be binding even after the termination of contract or after the performance of the services, work and tasks.

Storage security and International transfers

Company’s servers are based in EU, hence your Personal Data shall be processed within EEA in order for us to enable the execution of Company Services.

We will need to process your Personal Data in order to deliver our Client’s product or to execute an international payment on your behalf, etc. We will take all steps to ensure that your data is treated securely and in accordance with this privacy policy.

All information you provide to us is stored on our secure servers, encrypted at rest. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted in transit. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our App and / or our Website, you are solely responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our App or our Website; 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.

Notwithstanding the above, Company cannot be held accountable for any disclosure of your Personal information that you have shared with social networking or using chat room “Influee Messages” available within the App and Platform. Please ensure that when you are using these features, you do not submit any Personal Data that you do not want to be seen, collected or used by other users.

Retaining your Information

Company undertakes to hold, store and use the collected data only until the purpose, for which individual data were obtained and used further, has been achieved. After the retention of data period has expired, your Personal Data will be either efficiently and permanently erased or anonymised.

The data that are processed on the basis of law are kept for the period laid down by law. The data that are processed so that our contractual relationship with you can be carried out are kept for the period necessary to implement the contract and for the legal statute of limitations concerning any claims resulting from the so concluded contract, with the exception of a dispute in relation to the contractual relationship.

The Personal Data that are processed on the basis of your consent or legitimate interest, e.g. sending electronic news, are kept until you withdraw your consent in which case we undertake to review the existence of the data processing purpose at regular intervals. The Personal Data will only be erased prior to the withdrawal if the purpose they are processed for has been achieved (e.g. if electronic ads are no longer sent) or if it is so provided by law.

The data retention period for Personal Data obtained from your collaboration in any Campaign is 5 years following the completion of the Services (pursuant to general legal statute of limitations for claims of damages). If for certain data processed for the purpose of carrying out our contractual relationship there is a different data retention period (for example if the retention period for accountancy and tax data is 10 years), such period shall apply. During this period, the processing of data is restricted.

Your Legal Rights

You have rights under data protection laws in relation to your Personal Data. Please see below to find out more about these rights:

Request access - enables you to receive a copy of the Personal Data we hold about you. If you require this, then please reach out to our support team at hello@influee.co.

Request correction - enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. If you require this, then please reach out to our support team via the in-App chat function or e-mail hello@influee.co.

Object to processing - situations 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 supersede your rights. In other cases Company could be under certain compliance obligations to process and retain certain data according to the applicable law. Please note that such requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain data, then we may not be able to provide the Company services and it is likely we will have to terminate your account.

Request restriction of processing - enables you to ask us to suspend the processing of your Personal Data i) if you want us to establish the data's accuracy; ii) where our use of the data is unlawful, but you do not want us to erase it; iii) where you need us to hold the data even if we no longer require it, but you need the data to establish, exercise or defend legal claims; or iv) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it. Please note that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the Company Services. In this case, we may have to disallow your use of the Company Services (please note that we will notify you if this is the case at the time).

Request erasure - enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it (you may also have waived your right to any claim for damages against Company for such purpose). 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, where we may have processed your information 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 of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Statutory retention requirements supersede any contractual right to erasure requests under applicable data protection laws.

Request the transfer of your Personal Data to you or to a third party - We will provide to you or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. If you require this then please reach out to our support team via hello@influee.co.

Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Company’s services to you. In the event that Company shall be obligated to process and store relevant Personal Data for certain period of time, in order to comply with regulator’s order or legislation (e.g. prevention of money laundering, terrorist financing, fraud, tax evasion), we may still process and store your data, regardless of User’s withdrawal of consent.

You can withdraw your consent of our processing your information at any time by contacting us via Company email. However, please be aware that this may affect your ability to use such services going forward. Please remember that if we share your data with our partners in such events you will also be subject to our partner's privacy policy as well.

Miscellaneous

No fee usually required

You will not have to pay anything 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 questions and requests within 15 working days. Occasionally it may take us longer if your questions and requests are particularly complex or many questions or requests have been made. In this case, we will notify you and keep you updated.

If you fail to provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (including the Company Services). In this case, we may have to cancel your use of the Company Services but we will notify you if this is the case at the time.

Changes to privacy policy

Any changes we may make to our privacy policy in the future will be posted online and, where appropriate, notified to you by e-mail and / or when you next start the App or log onto the Website. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App, Platform and / or the Services.

Contact

All questions relating to data and your privacy are welcomed and should be addressed to our support team or to our appointed data protection officer. If you have any questions, comments or requests regarding this privacy policy then please: contact us via our support team: hello@influee.co or contact our appointed data protection officer or our legal department: legal@influee.co.