Privacy Policy

Note: This Privacy Policy has been translated from a Swedish original version that you can find here. If any matter arises concerning this Privacy Policy, the original Swedish version shall be considered the only valid document.

Influeri AB ("Influeri" or "we" in any form) is committed to protecting your privacy.

Influeri provides the Influeri platform (the "Platform"), which is an automated marketing system for companies that want to use influencer profiles ("Profiles") in their marketing campaigns ("Campaigns"). The Profiles create posts in the Platform, which are used in the Campaign in question ("Posts") after approval from the relevant customer.

This personal data policy ("Privacy Policy") informs you about how we, as a data controller, process Profiles personal data and personal data concerning contact persons/representatives and users linked to our customers and other partners.

The policy also describes the rights of individuals under applicable data protection legislation and how they can be exercised.

Terms defined by law, such as "personal data", "processing" and "controller" shall have the same meaning in this Privacy Policy as in the relevant law, unless otherwise specified.

Processing refers to any action involving your personal data including collection, management, storage, sharing, access, use, transfer and erasure or destruction.

'Personal data' means any information that can be linked directly or indirectly (e.g. in combination with other information) to an identifiable or identified natural person.

A controller is a natural or legal person who, alone or jointly with others, determines the purposes and means of the processing of personal data.

"Applicable data protection law" means the legislation, regulations and rules, including those issued by the relevant supervisory authorities, in force from time to time relating to the protection of the fundamental rights and freedoms of natural persons and, in particular, the right to the protection of their personal data applicable to the processing in question, including Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the "GDPR") and legislation, regulations and orders supplementing the GDPR.

If you have any questions about our processing of your personal data, please contact us using the contact details at the end of this Privacy Policy.

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1. Where we collect personal data from

We collect personal data from:

• You, e.g. when you contact us in the normal course of business.
  

• Third-party databases. We collect Profiles personal data from social media via partner databases.
  

• Other contact person of the company or organization you represent, e.g. if your employer or co-worker provides certain information about you such as name, position and contact details.

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2. When and why we process personal data

2.1 Contacts for customers and other partners

2.1.1 Managing business relationships

In order to manage normal business relationships, we process your personal data as a contact person and/or representative of our customers or other companies with which we cooperate (partners). This includes, for example, managing an existing or potential contractual relationship and normal business correspondence, including communication with you as a contact person and/or representative.

Categories of personal data: Identity data (including social security number if a sole proprietorship), Contact data, Organizational data, Communication data.

Legal basis: The processing is necessary to meet our legitimate interest in managing, entering into and maintaining business relationships with the company or organization you represent.  

If you are the owner of a sole proprietorship, with whom we have or plan to enter into a contract, the processing is necessary to perform the contract with you and/or to take steps at your request prior to the conclusion of the contract.

The processing of social security number is necessary for the purpose of the processing.

Retention period: In order to manage the relationship with the company you represent, personal data is processed for the duration of the relationship, or for the shorter period that you act as a representative or contact person for the company in question. Thereafter, personal data may be processed for the time necessary to establish, exercise or defend legal claims. This may be up to the general limitation period, which in Sweden is ten (10) years.

2.1.2 Create and manage user accounts for customers in the Platform.

We process personal data for our clients' employees who have user accounts in the Platform.

Categories of personal data: Identity data, Contact data, Organizational data, Account data in the Platform, Activity information in the Platform.

Legal basis: The processing is necessary to meet our legitimate interest in providing the Platform to our customers.

Retention period: Personal data is retained until the account is closed.

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2.2 Profiles

2.2.1 Find Profiles for Campaigns

We process Profiles' personal data to find suitable Profiles for our customers' Campaigns. This is done by searching third party databases. In case the Profiles have user accounts in the Platform, we may also search for suitable Profiles among them.

By matching Profiles' social media with our client's mission statement and desired target group for a Campaign, the Platform selects the Profiles that match our client's requirements. Selected Profiles are then presented to our customer, who selects the Profiles desired for the current Campaign.

Categories of personal data: Account information and social media account content, Information on interactions on social media accounts, Information on followers and, where applicable, Statistics on published Posts.

Legal basis: The processing is necessary to meet our legitimate interest in finding suitable Profiles for specific Campaigns in order to fulfill contracts with our customers, and the processing is necessary to meet our legitimate interest in providing Profiles with opportunities to enter into contracts with our customers.

Retention period: Personal data is retained until the end of the relevant Campaign.

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2.2.2 Creating and managing user accounts for Profiles in the Platform

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2.2.3 In order to upload material to the Platform within the framework of an assignment, the Profile in question must first create an account in the Platform. We therefore process the Profiles personal data in order to enable the Profiles to use the Platform.

Categories of personal data: Identity data, Contact data, Account data in the Platform, Activity information in the Platform.

Legal basis: The processing is necessary to meet our legitimate interest in offering Profiles the opportunity to create an account in the Platform, to enable Profiles to enter into contracts with our customers. The processing is also typically in the interest of the Profiles, as they may be considered for business opportunities.

Retention period: Personal data is retained until the Profile chooses to close the account. Profiles can always choose to close their account via the settings in the Platform.

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2.2.4 Future campaigns

We use personal data stored in the Platform from previously completed Campaigns to create a basis for finding suitable Profiles for future Campaigns.

Categories of personal data: Identity data, Contact data, Statistics on published Posts, Information on activity in the Platform.

Legal basis: The processing is necessary to meet our legitimate interest in finding suitable Profiles for specific Campaigns in order to fulfill contracts with our customers, and the processing is necessary to meet our legitimate interest in providing Profiles with opportunities to enter into contracts with our customers.

Retention period: Personal data is retained until the Profile chooses to close the account or five (5) years from the Profile's last activity in the Platform. Profiles can always choose to terminate their account via the settings in the Platform.

2.2.5 Profiles that do not want to be contacted

We process personal data to ensure that we do not contact Profiles who have asked not to be contacted by us.

Categories of personal data: Identity data, Contact data.

Legal basis: The processing is necessary to meet our legitimate interest in not contacting Profiles who have asked not to be contacted by us.

Retention period: Personal data is retained for this purpose for five (5) years.  

2.3 Other processing operations concerning both customers and Profiles

Managing and responding to feedback and questions

If a representative of one of our customers or Profiles contacts us, e.g. via email, we will process personal data provided to us to communicate with the individual and to investigate and respond to any questions and/or feedback.

Categories of personal data: Identity data, Contact data, Organizational data, Communication data.

Legal basis: The processing is necessary to meet our legitimate interest in managing and responding to feedback and questions.

Retention period: Personal data is retained until the customer service case has been closed and thereafter for the time necessary to establish, exercise and defend legal claims.

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2.3.1 Developing the Platform‍

We process personal data for the purpose of developing the Platform. This is done by compiling feedback and results from our customers, Profiles and other company stakeholders, and by analyzing the use of the Platform and other information related to the Platform.

Categories of personal data: Identity data, Contact data, Organizational data, Communication data, Statistics for published Posts.

Legal basis: The processing is necessary to meet our legitimate interest in improving and further developing the Platform.

Retention period: Personal data is retained for a period of five (5) years.

Fulfilling legal obligations

We process your personal data to comply with legal obligations that apply to us, such as bookkeeping and accounting requirements.

Categories of personal data: All data necessary to fulfill the respective legal obligation.

Legal basis: The processing is necessary to comply with legal obligations to which we are subject.

Retention period: Personal data is retained for the time necessary for us to fulfill our legal obligations.

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2.3.2 Establishing, enforcing or defending legal claims

For the purpose of establishing, exercising or defending legal claims, e.g. in the context of a dispute or legal proceedings, we may process your personal data.

Categories of personal data: All data necessary for the establishment, exercise or defense of legal claims.

Legal basis: The processing is necessary for our legitimate interest in establishing, exercising or defending legal claims, e.g. in a dispute and legal proceedings.

Any sensitive personal data is processed only if it is necessary for the establishment, exercise or defense of legal claims.

Retention period: Personal data is retained during the statutory limitation period for the purpose of establishing, exercising and defending legal claims. The general statutory limitation period in Sweden is ten (10) years.

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3. Recipients with whom personal data is shared

When necessary, we share personal data with the following recipients. Unless otherwise specified, named recipients are independent data controllers for the processing of personal data.

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4. Data processors

To fulfill the purposes of the processing of personal data, we share your personal data with service providers we have engaged, such as system providers. The service providers we have engaged may only process your personal data according to our explicit instructions and may not use your data for their own purposes. They are also required by law and contract to take appropriate technical and organizational security measures to protect your data.

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5. Transfer of personal data to non-EU/EEA countries

If Influeri transfers or discloses your personal data to a recipient in a country outside the EU/EEA area (third country), Influeri will ensure that appropriate safeguards are in place (such as the European Commission's standard contractual clauses and other necessary measures) to protect the personal data.

Under the GDPR, you have the right to obtain, upon request, a copy of the documentation demonstrating that appropriate safeguards have been put in place to protect your personal data when transferred to a third country.

If you want to know more about the processing of your personal data and whether your personal data is transferred to a third country, please contact us at the contact details provided at the end of this Privacy Policy.

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6. Your rights

In connection with our processing of your personal data, you have the right to exercise the following rights under the General Data Protection Regulation. If you wish to exercise any of your rights, you can contact us via the contact details set out in section 7 of this Privacy Policy.

Access‍

You can request confirmation of whether or not we are processing your personal data. If we are processing your personal data, you also have the right to request access to your personal data and further information such as the purpose of the processing. You also have the right to receive a copy of the personal data being processed. If the request is made electronically, the information will also be provided in a commonly used electronic format unless you request otherwise.

Rectification

If you indicate that personal data concerning you is inaccurate or incomplete, you have the right to have your personal data rectified or completed.

Objecting to special treatment

You may object to the processing of your personal data if the processing is for direct marketing purposes or, if the processing is based on a legitimate interest, for reasons relating to your particular situation. In case of such an objection, we are obliged to cease processing, unless we can demonstrate compelling legitimate grounds to continue processing and these grounds override your interests. We may also continue processing that is necessary for the establishment, exercise and defense of legal claims. However, processing for direct marketing purposes will always cease if you object to such processing.

Erasing

You can have your personal data deleted in the following circumstances:

• If the personal data is no longer necessary for the purposes for which it was collected or otherwise processed.
• If our processing of personal data is based solely on your consent and you withdraw your consent.
• If you object to the processing and our processing (i) is based on legitimate interest and does not constitute an overriding compelling legitimate ground for processing, or (ii) is for direct marketing purposes.
• If your personal data has been processed unlawfully.
• If your personal data must be erased to comply with a legal obligation under Union law or the national law of a Member State to which we are subject.
  

However, the right to erasure does not apply to the extent that processing is necessary to exercise the right to freedom of expression and information, to comply with a legal obligation or to establish, exercise or defend legal claims.

If you have the right to erasure of your personal data and we have made the personal data public, we may also be obliged, in certain circumstances, to notify the controllers processing the personal data that you have requested them to erase any links to, or copies or reproductions of that personal data.

Limitation of treatment

In the following circumstances, you can request that we restrict the processing of your personal data to the storage of your personal data only:

• If you contest the accuracy of the personal data, we will restrict the processing for a period of time that allows us to verify the accuracy of the personal data.
• If the processing is unlawful and you oppose the erasure of the personal data and instead request a restriction of their use.
• If we no longer need the personal data for the purposes of the processing but you need them to establish, exercise or defend legal claims.
• If you have objected to processing, pending verification of whether our legitimate grounds outweigh your legitimate grounds.
  

However, we may continue to process your personal data if you consent to it, or to establish, exercise or defend legal claims or to protect the rights of another natural or legal person.

Withdrawing consent

You always have the right to withdraw your consent to the processing of personal data to the extent that the processing is based on your consent.

Data portability

You have the right to request a machine-readable copy of the personal data processed on the basis of your consent or where the processing is necessary for the performance of a contract with you, and where personal data has been obtained from you (data portability), and to request the transfer of the information to another controller (where possible).

Complaints to the supervisory authority

You are welcome to contact us with questions or complaints regarding the processing of your personal data. However, you also always have the right to lodge a complaint regarding the processing of your personal data with the Swedish Authority for Privacy Protection. For more information on how to contact the Authority, please visit www.imy.se.

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7. Contact details

If you have any questions regarding the processing of your personal data or if you wish to exercise any of your rights under applicable data protection legislation, please contact Influeri at the contact details below.

Data controller:

Influeri AB 559333-4740

Emmy Rappes Gata 1 113 68

Stockholm

E-mail address: info@influeri.com

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8. Categories of personal data

Below you will find an explanation of the categories of personal data that we may collect and store.