Effective Date: February 25, 2020
COLLECTION OF PERSONAL DATA
When you visit TOPINFLUER.COM, we automatically collect certain data and information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device.
We collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
HIGHWEB IRELAND OPERATIONS LTD collect Device Information using the following technologies:
“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org;
“Log files” track actions occurring on TOPINFLUER.COM, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps;
“Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse TOPINFLUER.COM;
“Personal Information” includes both “Device Information” and “Order Information”.
PERSONAL INFORMATION MODE OF USE
To communicate with you; and, when in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
We use the Device Information that we collect to help us improve and optimize our Site (for example, by generating analytics about how our users browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
We use anonymized heat-mapping software like Hotjar in order to better understand our users’ needs and to optimize this service and experience. These technology services help us better understand our users’ experiences (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.), and enable us to build and maintain our service with user feedback. They store this information in pseudonymized user profiles.
All data collected on our public-facing Site will never be used this information to identify individual users or to match it with further data on an individual user. This policy differs from our login-only application.
SHARING YOUR PERSONAL INFORMATION
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Google Analytics to help us understand how our users use the Site — you can read more about how Google uses your Personal Information here:
We may share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
PLATFORM DATA PROCESSING
The Data Controller of the personal data we process is: ADV Online Company OU. You may contact us using the details at the end of this Policy, and our representative in the EU is:
The purposes of our data processing are as follows:
Category of data subject
Categories of data
Legal basis for data processing
Visitors to TOPINFLUER.COM
Web pages visited or surfed to or from; data submitted on contact forms; cookie data
Managing and improving TOPINFLUER.COM and responding to your inquiries or requests
Directly from you
Our clients’ business and IT contacts and registered users
Name, title, business email, business phone numbers, business address, login details
Managing provision of our services, permitting and controlling access to our platform, providing customer service
From our clients or directly from the individuals
This processing is necessary for the fulfillment of our contracts with our clients
Potential clients, suppliers and service providers
Name, title, business email, business phone numbers, business address, business interests, professional experience and qualifications
Growing and managing our business
Directly from you; or from other public sources (e.g. trade shows, professional websites)
This processing is based on our legitimate interests in developing and obtaining goods and services for our business. All this data is business data and its processing should have no negative impact on your privacy
Influencers and creators listed on our platform, and their followers
Names and handles, bio and interests, public posting activity, public conversations, engagement, followers and follower counts
Providing our services and permitting clients to set up and manage campaigns on our platform
Social media platforms
Also from clients
This processing is based on our legitimate interests in providing and managing our platform and services. This is information that has been made available publicly by the users, and its processing should have no negative impact on your privacy; we apply industry-standard security measures and also provide an easy means of opting out of inclusion in our platform as indicated in section 5 below.
Influencers and creators listed on our platform
Communicating with you regarding business opportunities with HIGHWEB IRELAND OPERATIONS LTD clients/ advertisers
Influencers’ public profiles/Influencers’ websites
This processing is based on our and our clients’ legitimate interests in communicating with you for business purposes, including introducing opportunities for influencer marketing arrangements or campaigns with them. For this we use contact information that has been made available publicly by you, and its processing should have no negative impact on your privacy; we apply industry-standard security measures and you can opt out of receiving such communications at any time.
Please note that our clients may also enter certain personal data into our systems (e.g. in relation to particular influencers they work with, or because influencers have directly agreed to give them greater access). We are a data processor and not a controller of this data. We will normally need to pass any questions in relation to this data on to the relevant client for action or response.
Authentication of Data from Social Network Platforms:
Via the Links Accounts Page of your Account, you may choose to opt-in and allow ADV Online Company OU to connect to one (1) or more of your Social Network Accounts so that HIGHWEB IRELAND OPERATIONS LTD may access data from the applicable Social Network platforms on your behalf (such data collectively, the “Authenticated Data”).
HIGHWEB IRELAND OPERATIONS LTD may use Authenticated Data to improve the Services for you (e.g. by using such data to deliver more accurate statistical data) and to improve the Services overall. Authenticated Data used to improve HIGHWEB IRELAND OPERATIONS LTD Services will be aggregated and anonymized and used for purposes such as producing market estimations. If you have opted into an agreement with an ADV Online Company OU client, HIGHWEB IRELAND OPERATIONS LTD may grant access to some of your Authenticated Data, for the purpose of ensuring that all of your post or video activity is correctly attributed to you within ADV Online Company OU Services). You may revoke HIGHWEB IRELAND OPERATIONS LTD ability to collect your Authenticated Data at any time through the opt-out feature in the Links Accounts Page of your Account (see Your Choices below). If you opt into authenticating any of your Social Network Accounts with ADV Online Company OU, HIGHWEB IRELAND OPERATIONS LTD will:
Never post on your behalf to any of your authenticated Social Network Accounts (e.g. your Facebook Page or YouTube Channel).
Never manage any of your Social Network Account ad campaigns (e.g. Facebook ad campaigns or YouTube ad campaigns) and will never alter any of your Social Network ad settings.3. The recipients of the data are as follows:
6.3. We provide data to other companies in our corporate group and technical service providers inside and outside the EU (with Iceland, Liechtenstein and Norway, the “EEA”) that require access to data in order to assist us in providing our services. In particular, we work with reputable external data processors, to which we provide certain data which may include personal data, in order to provide our platform and services, including for the purposes of storage, analysis, development, testing etc.
6.4. In each case we have in place safeguards that enable transfers from the EEA to happen in a way that ensures that data is handled in accordance with similar standards to those applicable in the EEA. These include: a decision from the European Commission indicating that the place of receipt has adequate data protection laws; the EU-US Privacy Shield for transfers to business partners in the US; and European Commission approved standard contract clauses for other transfers outside the EEA. A copy of these documents can be provided upon request.
6.5.We present posts and data received from the social networking platforms to our clients via our platform, as well as email addresses where you have made them publicly available.
6.6. Where data (which may include personal data of users or influencers) is entered by our clients we enable clients’ authorized users to access, update and process the data provided by that client.
6.7. If any state body or regulator validly requested data from us, then we would normally comply with such request without having to notify you or other users.
6.9. EU data subjects have various legal rights in relation to their data including:
6.9.1. To ask for access to it;
6.9.2. To ask for errors in it to be corrected;
6.9.3. To ask for it to be erased (the “right to be forgotten”);
6.9.4. If not erased, then to ask us to restrict its processing;
6.9.5. To object to its processing for specific purposes;
6.9.6. To ask for a copy to take to another service provider.
6.10. Where we process any data based on consent that you have given in the past, then you are always allowed to withdraw your consent at any time (though the processing that took place before withdrawal will still be legal).
7.1. If you are a social media user or influencer who would like to opt-out of inclusion in TOPINFLUER.COM platform, please our form, posted at https://topinfluer.com.
7.2. For any other purposes, please use:
ADV Online Company address and contact information:
6-9 Trinity Street Dublin 2, Ireland, 675090.
E-mail: [email protected]
Correspondence between you and HIGHWEB IRELAND OPERATIONS LTD can be maintained via e-mail or postal and delivering services. E- mails or other correspondence, sent from the above addresses are official and are subject to obligatory execution. In case an e-mail was sent by ADV Online Company OU, the latter is not obliged to subsequently send the document on paper.