Privacy Policy for Influencers
1. Introduction and Definitions
INFY LTD (hereinafter Infy) recognizes the importance of the protection of personal data that Infy processes about Influencers from social networks. The Infy platform contains public information about people who have profiles on social networks, and the treatment of such is explained in this document.
In this Policy, we inform Influencers about data processing according to that which is set out in the current regulation of data protection, which establishes that when it’s impossible or requires a disproportionate effort to inform the interested parties about the processing of their data, the appropriate measures must be adopted to protect their data, freedoms and legitimate interests, including making the information public, which is achieved through this Privacy Policy.
In order to correctly understand this Privacy Policy, the following terms are defined:
• The Influencer is a physical or legal person who possesses a public profile on a social network, especially Instagram, Youtube, Tik Tok, and whose number of followers exceeds 1,000 followers.
• The Infy Platform is the service that Infy carries out to analyze the profiles of the Influencers in order to allow clients of Infy to conduct commercial actions and collaborations with the Influencers.
2. Entity responsible for processing data
The Infy platform, as well as the data processing, are the responsibility of INFY LTD with registered office at International House, 12 Constance Street, London, E16 2DQ, The United Kingdom of Great Britain and Northern Ireland.
The Influencer can contact Infy at the following email address: [email protected].
3. How and why influencers' personal data is processed
3.1 What data is processed?
The personal data that Infy processes about Influencers is the data that the same Influencers have made public on social media, including but not limited to:
• Profile information: names and surnames, commercial names, profile names, images, videos, languages, profile descriptions, publications, etc.
• Professional contact information: emails, online and/or street addresses.
• Statistical data about followers: Infy only processes non-personal information about the audience of an Influencer.
In addition, Infy may process special categories of data, such as political opinions, racial or ethnic origin, religion or philosophical convictions, etc., only in the case that an Influencer has included the information on his or her public profile. Therefore, Infy does not have the technological capacity to know if this data is being processed, unless it is made expressly public by the Influencer.
3.2 What is the data used for?
This data is used in order to perform an analysis of social media profiles so that Infy and its clients can connect and collaborate with Influencers and thus carry out commercial intents and actions. Likewise, the data is processed in order to contact Influencers by means of the contact information they’ve made public, and in order to offer them collaborations.
3.3 Lawful processing
The legal basis that legitimizes the data processing of Influencers, for the purposes indicated in this Policy, is the legitimate interest of Infy, of its clients, and in this case of the Influencers, to carry out commercial activities between the parties.
Additionally, Infy informs the Influencers that, as it only processes personal data made public by them on social networks, the impact on their privacy is minor.
In the case of the special categories of data, the legal basis that legitimizes data processing is that the data has been openly made public by the Influencers.
3.4 Time periods of processing and updates
The Influencer’s data will be processed for an indefinite period of time unless the Influencer requests the erasure of data or opposes its processing. Subsequently, the data will be stored as blocked, during the time necessary to attend to any possible responsibilities arising from its processing.
In addition, the Influencer’s information will be updated periodically based on the changes made by the Influencer to his or her public profile.
4. Minors
Infy does not have the capacity to control the age of the Influencer, given that it is not personal data that the Infy platform captures consciously. Nevertheless, in the case that Infy may suspect for whatever reasons that there are minors on the platform, Infy will undertake the appropriate steps to request consent to data processing from the minor and/or legal guardians, or, if applicable, cancel the data.
5. The Influencer's rights and how to exercise them
Data protection regulations guarantee the Influencer the following rights:
• Access: The Influencer has the right to know what information is processed, from where it has been obtained, to whom it has been provided, and how it has been processed.
• Rectification: The Influencer has the right to correct any inaccurate or out-of-date information.
• Erasure: The Influencer has the right to request the erasure of his/her personal data.
• Objection: The Influencer has the right to object to the processing of his/her personal data for some specific purpose.
• Restriction: The Influencer has the right to request the restriction of his/her personal data, but in a way that it is retained for some later purpose.
• Portability: The Influencer has the right to obtain a copy of his/her personal data in an electronic format and, in certain circumstances, request that it is supplied to another service provider. This only applies to computerized processing carried out with the Influencer’s consent or in order to fulfill a contract.
• Withdrawal of consent: The Influencer has the right to withdraw his/her consent that, in this case, is given for the processing of data.
These rights require the possibility of identifying the Influencer who exercises them and of linking his/her identity with data processed by Infy, so the Influencer shall provide information in order to be identified.
The Influencers can exercise the aforementioned rights before Infy, by mail to the above-mentioned address, or by email to [email protected].