Effective Date: July 3, 2018
OUR PRIVACY COMMITMENT
WHAT THIS POLICY COVERS
WHO THIS POLICY COVERS
|Content Creators||Individuals who create social media content in the StyleHaul network and Potential Content Creators|
|Business contacts at Brands||Individuals who use StyleHaul services to connect with Content Creators|
|End-users||End-users who engage with the Sites or Content created by StyleHaul or StyleHaul Creators.|
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
TYPES OF INFORMATION WE COLLECT
Personal information means information that can be used to identify you. This includes:
From Content Creators:
- email address;
- date of birth;
- content types;
- social media username and handle;
- social profile name, url, follower count and other metrics related to the engagement rate;
- profile pictures;
- caption data;
- demographics of creator;
- video engagement; and
- social media friend count.
Content Creators using the StyleHaul Society service may also disclose a whole range of personal information to us such as what colour hair they have, what brands they use, whether they own pets, and so on. Such information is collected from Content Creators using surveys.
- post comment content and metadata of comments (for example, Instagram username, profile picture, full name, created time);
- engagement rates;
- image post like count and other engagement metrics; and
- Facebook link, profile picture and fan count.
From Business Contacts at Brands:
- business contact details, including: name, telephone number and email address;
- marketing preferences, including any marketing consents given; and
- billing details.
Some personal information is needed in order to access certain areas of the Sites and the StyleHaul Features. Providing additional information beyond what is required is entirely optional, but enables you to more easily utilize and benefit from the StyleHaul Features.
INFORMATION WE RECEIVE FROM THIRD PARTIES
If you are a Content Creator, we may receive information about your content, such as the number of views, the number of followers and the subject matter of your content from third parties such as Tubular Labs and Social Blade. We will also gather such information from social networking sites and the Internet.
We are also working closely with third parties (including, for example, business partners, advertising networks, analytics providers, search information providers,) and may receive information about you from them. From these third parties we receive:
Information about your content and information about how you engage with content
When you are purchasing products through our third party clients, such as Sephora, with your consent, those vendors may provide us information regarding your transactions in accordance with their privacy policies, but such vendors will not provide StyleHaul your payment information under any circumstances.
When you engage with our Sites through social media such as Facebook and YouTube, or other non-StyleHaul sites or applications, those sites will share personal data with us: about the content you have viewed or interacted with and about adverts within the content which you have been shown or clicked on; and other information you have given those sites permission to share.
The privacy policies for these sites and applications will contain more detail about this and how to change your privacy settings on those sites and applications.
HOW WE USE YOUR PERSONAL INFORMATION AND WHAT THE LEGAL BASIS FOR THIS USE IS
We process your personal information for the following purposes:
- To fulfil a contract, or to take steps linked to a contract: this is relevant where you for example join the StyleHaul Society or are a Brand using our Services: This includes:
- verifying your identity;
- communicating with you;
- handling your requests, customer service questions or issues;
- delivering services you request;
- facilitating payment where applicable;
- sending you messages in response to your requests to perform an activity in connection with your use of the StyleHaul Features; and
- connecting Creators with Brands so that content can be distributed across social media channels using social media platforms and other media. StyleHaul may use automated processing to help match Creators to Brands (see below for more)
- As required by us to conduct our business and pursue our legitimate interest, in particular to:
- request feedback;
- administer contests, promotions and surveys;
- send invitations to events;
- administer our StyleHaul Features and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- grow our business and improve the StyleHaul Features to ensure that content is presented in the most effective manner for you;
- engage in direct marketing activities and to understand you better by analysing your interactions with us, our Site, the StyleHaul Functions and the Creator Content;
- keep our StyleHaul Features safe and secure; and
- measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- Where you give us consent (where required by local law) to:
- send communications to you about promotions, updates, or special offers that may be of interest to you;
- alert you of new products or services, features, or enhancements;
- send you direct marketing in relation to our relevant products and services, or other products and services provided by us, our affiliates and carefully selected partners.
- For purposes which are required by law, in particular:
- in response to requests by government or law enforcement authorities conducting an investigation;
- when we place cookies and use similar technologies in accordance with our Cookies Section below; and
- where we are required by law to collect information from parents for the purposes of obtaining parental consent for children over 13 who use StyleHaul Services.
We keep track of your interactions with us in accordance with our data retention policies, including but not limited to your activity within the StyleHaul Features. We may make your personal information non-personally identifiable by removing characteristics (such as your name or email address) that make the information personally identifiable. This process is known as de-personalizing or anonymizing your information resulting in “Analytical Data”.
If you are a Content Creator:
- you grant us a royalty-free, worldwide, perpetual, irrevocable and fully transferable right and license to use your personal information in this way. We are expressly authorized to make any commercial use of the Analytical Data, including without limitation, sharing the Analytical Data with third parties.
- StyleHaul may use automated processing to match you with Brands. For example, this automated processing can be used to help StyleHaul create a shortlist of the most suitable Creators for a particular. The automated decision will analyse data such as your interests, experience, engagement rates, and demographics to best match the Brands requirements. As a Content Creator these automated decisions will impact the campaigns that you may be selected to work for. You can opt out of these automated decisions by contacting email@example.com.
Cookies are small pieces of information sent by a web server to a web browser which allows the server to uniquely identify the browser on each page.
We do not knowingly collect personal information from children under 13. We take the privacy of children seriously, and encourage parents to play an active role in their children online experience at all times.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH
Personal data may be shared with government authorities and/or law enforcement officials if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
We may use your personal information to send communications to you about promotions, updates, product sampling, or special offers that may be of interest to you.
We may share your personal information with carefully selected vendors and business partners, including companies that perform marketing services, product merchandising services and other business operations for us in the following categories: contract performance and payment, analytics and sentiment analysis to measure performance of a campaign, and shipping or fulfilment services for sending product .
We may also provide Analytical Data to prospective partners and other third parties.
In addition, we will share the personal information we collect from you under the following circumstances:
- Advertisers and advertising networks. We may share your personal information with our client networks that require the data to select and serve relevant adverts to you and others. We may provide our clients with aggregate information about our users (for example, we may inform them that 500 men aged under 20 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in New York). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
We share personal information relating to Content Creators using the StyleHaul Society service with brands, so that connections can be made and content can be distributed across social media channels using social media platforms and other media and in connection with the development of paid campaigns
ADDITIONAL INFORMATION YOU SHOULD KNOW ABOUT THIRD PARTIES
If you link you Google and/or YouTube accounts to our Sites, and wish to revoke our access to your data at any time, you may do so here: https://security.google.com/settings/security/permissions.
Although we encourage such third parties to adopt and follow their own privacy policies, we are not responsible for their collection and use of your personal information.
You should refer to the privacy policies and statements of other websites or contact the respective websites to obtain information regarding their information collection, use and disclosure policies.
WHAT CHOICES DO YOU HAVE ABOUT THE COLLECTION AND USE OF YOUR PERSONAL INFORMATION?
CONTROL OF YOUR INFORMATION
You may access information held about you (which may, subject to applicable law, be subject to a fee), update or delete your personal information by emailing us at firstname.lastname@example.org. Please note that we may retain your information for a reasonable period of time afterward to comply with our legal and regulatory obligations.
OPTING OUT OF RECEIVING COMMUNICATIONS FROM US
If you no longer want to receive our newsletter, emails or other announcements or marketing communications from us, you may unsubscribe by writing to us at email@example.com or replying to the unsubscribe link at the bottom of our communication or otherwise following instructions in the communication.
WHAT SECURITY MEASURES DO WE TAKE TO SAFEGUARD YOUR PERSONAL INFORMATION?
We use reasonable technical, administrative and physical measures to protect information contained in our system against misuse, loss or alteration. The personal information that you provide to us is stored on servers, which are located in secured facilities with restricted access, and protected by protocols and procedures designed to safeguard such information. However, no server, computer or communications network or system, or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect user information, we cannot ensure or warrant the security of any information you transmit to us or through the use of any of the StyleHaul Features and you acknowledge and agree that you provide such information and engage in such transmissions at your own risk. Once we receive a transmission from you, we will endeavor to maintain its security on our systems.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. If we receive instructions using your log-in information we will consider that you have authorized the instructions.
NOTIFICATION OF CHANGES
QUESTIONS? CONTACT US
MORE INFORMATION FOR INDIVIDUALS FROM THE EEA AND SWITZERLAND
a. Your data controller entity
The data controller for your information is StyleHaul, Inc.
b. Transfers of personal information outside the EEA
We operate globally, so we do need to transfer your personal information internationally. In particular, your personal information will be transferred to and processed in the United States where many of our central databases operate and may also be transferred to Singapore and Indonesia, where we have offices. Where information is transferred from StyleHaul Europe to StyleHaul Inc in the United States, StyleHaul has an intra-company agreement incorporating the EU Commission approved standard contractual clauses.
Where information is transferred outside the EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request to firstname.lastname@example.org.
c. Legitimate Interests
We carry out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details below.
d. How long will you retain my personal information?
Where we process registration information, we do this for as long as you are an active user of the StyleHaul Features.
Where we process personal information for marketing purposes or with your consent, we process the information until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your information indefinitely so that we can respect your request in future.
Where we process personal information for Site security purposes, we retain it for only as long as necessary.
Where we process personal information in connection with performing a contract, we keep the personal information in line with the contractual limitation period and applicable laws on contract and payment information retention.
Where we offer online services to children over 13 in Europe or the United States we obtain parental consent where required by applicable law. Therefore if you are a parent we may ask you for certain information to verify parental consent.
f. Your rights
You have the right to ask us for a copy of your personal information; to correct, delete or restrict (stop any active) processing of your personal information; and to obtain the personal information you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this information to another controller.
In addition, you can object to the processing of your personal information in some circumstances (in particular, where we don’t have to process the information to meet a contractual or other legal requirement, or where we are using the personal information for direct marketing).
If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
These rights may be limited, for example if fulfilling your request would reveal personal information about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We will inform you of relevant exemptions we rely upon when responding to any request you make.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your personal information for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time.