- Information Collection
- Use of Information
- Legal Basis for Processing Your Information
- Disclosure of Your Information
- Data Security and International Transfer
- Cookies, Third Party Services and Features and Analytics
- Data Retention
- Your Rights
Last updated: 24th October 2019
Please read carefully to understand our views and practices regarding your personal data and how we will treat it. “Processing” means using your information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information.
For the purpose of the EU General Data Protection Regulation 2016/679 (“GDPR”), the controller of your data is IMCompanion Limited, a company registered in England and Wales under company number 11848139 whose registered office is 6 Bevis Marks, 15th Floor, London, England, EC3A 7BA.
All your data will be held and used in accordance with the GDPR and any relevant national laws which implement the GDPR and any legislation that replaces it in whole or in part.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes so that we can update our records accordingly.
We may collect, store and use the following kinds of information:
Information You Provide.
You may give us information about you by:
- completing the contact form on our website (including your name, email address, phone number, location, company, social media accounts and/or website and any information you enter into the “How can we help you” field);
- enquiring about and/or registering to become a subscribed user of the Online Tools (including your username, password, company title, email address, physical address, telephone number, and, where applicable, your credit card number or other billing information);
- subscribing to our email notifications and/or newsletters (including your name and email address);
- corresponding with us via email, phone or otherwise; and
- entering into or negotiating to enter into a business relationship with us (including your name, address, email address, phone number, social media accounts and/or website, account name, nickname, information about preferences, information from your agent or manager if applicable, start and end date of agreements made, bank details, and impressions on your social media accounts relating to marketing posts (including the amount of views, engagements, etc.) you have agreed to provide us with).
Information We Collect.
We may collect, store and use the following kinds of information:
- your IP address and non-personal identification information about you whenever you interact with our Site, including your operating system, browser type and download errors; and
- if you are a social media influencer (“Influencer”), publicly available information from social media sites or your public website (including your name, email address, location, social media posts (including photos, videos and stories), and followers).
Information We Receive from Other Sources.
We also work closely with third parties (including, for example, business partners, clients, vendors, consultants, and other service providers) and may receive information about you from them.
Use of Information
We will use this information:
- to provide you with the products and services made available through the Site and the Online Tools, to communicate with you, and to manage your registered user account, if you have one;
- to send periodic emails, which may include company news, updates, related product or service information, etc., that you have subscribed to;
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased;
- if you are an Influencer, to approach you for new collaborations and connect you with brands;
- if you are an Influencer, to audit the performance of a marketing campaign;
- to notify you about changes to our service and send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages;
- to administer and improve our Site and Online Tools; and
- as part of our efforts to keep our Site and Online Tools safe and secure.
Legal Basis for Processing Your Information
In accordance with GDPR, the main grounds that we rely upon in order to process your information are as follows:
- The processing of your information is necessary for entering into or performing a contract. In order to perform obligations which arise under any contract we have entered into with you, it will be necessary for us to process your information.
- Legal Obligation. The processing of your information is necessary for compliance with a legal obligation. We are subject to certain legal requirements which may require us to process your information. We may also be obliged by law to disclose your information to a regulatory body or law enforcement agency.
- Legitimate Interests. The processing of your information is necessary under legitimate interests. Either we or a third party will need to process your information for the purposes of our (or a third party’s) legitimate interests, provided that those interests are not overridden by your rights and freedoms (including your right to have your information protected) and you have a reasonable expectation that your information will be processed. “Legitimate Interests” means the interests of our company (or a third party such as a brand) in conducting and managing a business. The main objective of our company is to facilitate collaborations between Influencers and brands. The personal information about influencers that we collect in connection with our Online Tools is information which is publicly available and, in many cases, has been published by the Influencer specifically for marketing and publicity purposes. We process this information for our legitimate interest in providing the Online Tools and related services to our brand clients in connection with their legitimate interest in marketing their products. We (and registered users to our Online Tools and our brand clients) use an Influencer’s publicly available information (which clearly indicates a desire on the part of that Influencer to be discovered by brands and followers) to facilitate a relationship between such Influencer and a brand. This benefits our client brands by introducing them to Influencers with whom they can collaborate with on marketing campaigns and the Influencers by helping them grow their careers through such relationships with our brand clients. Our other legitimate interests include: (i) optimising future marketing campaigns; (ii) responding to requests and enquiries from you or a third party; (iii) optimising our website and user experience; and (iv) informing you about our services and ensuring that our operations are conducted in an appropriate and efficient manner.
- Consent. In some circumstances, we may ask for your consent to process your information in a particular way.
Disclosure of Your Information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 1159 of the UK Companies Act 2006.
We may share your information with selected third parties in the following manner:
- We may share your information with subcontractors in connection with their performance of certain business-related functions on our behalf such as maintaining mailing information and processing payments. We will share your information with these subcontractors only to the extent that they need to perform their specific function and only pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your data.
- In the event we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Companion or substantially all of its assets are acquired by a third party, in which case personal data held by Companion about its clients, suppliers, subcontractors and the influencers it works with 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 obligation, or in order to enforce or apply our Terms & Conditions terms and conditions of service and other agreements; or to protect the rights, property, or safety of Companion, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Data Security and International Transfer
We will take all steps reasonably necessary to protect your information and prevent unauthorized access. Nevertheless, 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.
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may be shared with international entities within the Billion Dollar Boy Group or one of the many external third parties we use that are based outside the EEA. It may also be processed by staff operating outside the EEA who work for us. Such staff maybe engaged in, among other things, the processing of your payment details and the provision of support services.
To the extent that any of your data is provided to third parties outside the EEA, or accessed by third parties from outside the EEA, we will use reasonable efforts to ensure that appropriate safeguards are in place in accordance with the GDPR. The safeguards we may implement include:
- Only transferring your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Using specific contracts approved by the European Commission which give personal data the same protection it has in the EEA; or
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the EEA and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Cookies, Third Party Services and Features and Analytics
Third Party Services and Features. Our Site contains hyperlinks to websites, locations, platforms and services operated and owned by third parties (“Third Party Services”). In addition, we maintain social media profiles with features that allow you interact with, connect to, or access these social media profiles through certain Third Party Services and third-party devices (“Third Party Features”). For example, you interact with a Third Party Services when you “like” or “share” content over social media. The fact that we link to Third Party Services does not constitute an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over any Third Party Services and accept no responsibility or liability for any Third Party Services. Remember that third parties may use tracking technologies independently to collect information about you and use such information. We encourage you to read the privacy policies or statements of the other websites you visit.
We will only retain your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
The criteria we use to determine retention periods will be determined by the nature of the data and the purposes for which it is kept, the sensitivity of the data, the potential risk of harm from unauthorized use or disclosure and the applicable legal, regulatory, tax, accounting or other requirements.
Right of Access. You have the right at any time to ask us for a copy of the personal information that we hold about you.
Right of Correction or Completion. If personal information we hold about you is not accurate or is out of date or incomplete and requires amendment or correction you have a right to have the data corrected or completed.
Right of Erasure. In certain circumstances, you have the right to request that personal information we hold about you is erased.
Right to Object to Processing. In certain circumstances, you have the right to object to our processing of your information. For example, you have a right to object if the processing of your data is for direct marketing purposes or our using your information on the basis of our legitimate interests or those of a third party.
Right to Restrict Processing. In certain circumstances, you have the right to ask that we restrict our processing of your personal information. For example, you may contest the accuracy of the personal data we hold and ask us to restrict the processing of such data while we are in the process of verifying its accuracy.
Right of Data Portability. In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format. You also have a right to ask us to transmit that information directly to a third-party entity. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third party organisation’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
Right to Withdraw Consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your information for a specific purpose, you have the right to withdraw your consent for that specific purpose at any time. Upon receipt of such a withdrawal, we will cease to process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Right to Lodge a Complaint. You can lodge a complaint with the UK Information Commissioner’s Officer or with the relevant authority in your country of work or residence if you are unhappy with Companion’s use of your information. Please see below for the relevant contact details.
You can exercise any of the above rights at any time by contacting us at [email protected] Please note we will require evidence of your identity before we are able to respond to your request.
Contact details for the UK Information Commissioner’s Office are as follows:
Telephone: 0303 123 11113
Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
A list of relevant authorities in the EEA can be accessed here.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The Site and Online Tools are not directed to persons under 18. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at [email protected] If we become aware that a child under 13 has provided us with personally identifiable information, we will remove such information from our files immediately.
Post: 78 Whitfield Street, London, W1T 4EZ
Phone: +44 20 3637 0447
You can opt out of receiving certain promotional emails from us at any time by following the instructions as provided in the emails to click on the unsubscribe link or by sending an email to us at [email protected] with the word UNSUBSCRIBE in the subject field of the email.
If you are a registered user of our Online Tools, you may update or correct the information you provided to us by requesting us to make such changes at [email protected] If you are an Influencer, you may request to access, correct, or delete the information we have collected about you from social media channels or other websites by requesting us to make such changes at [email protected]