Privacy policy
IROIN® Influencer Marketing Suite
IROIN® Influencer Marketing Suite
Last updated 12.05.2020
The following privacy policy applies to the cooperation of potential and existing contractual partners (hereinafter "Influencer") and CrowdArchitects GmbH (hereinafter "CrowdArchitects"). We attach great importance to data protection. The collection and processing of your personal data is carried out in compliance with the applicable data protection regulations, in particular the General Data Protection Regulation (DSGVO).
1 Responsible
The person responsible for the collection, processing and use of your personal data within the meaning of Art. 4 No. 7 DSGVO is
CrowdArchitects GmbH
Erich-Kästner Str. 1
99094 Erfurt
Fon: +49 (0)361 3494945-0
E-Mail: hello@iroin.io
If you wish to object to the collection, processing or use of your data by us in accordance with these data protection provisions as a whole or for individual measures, you can address your objection to the person responsible. You can save and print this privacy policy at any time.
2 General purposes of the processing
We use personal data for the purpose of contacting you, researching for and conducting marketing campaigns, and reporting on them.
3 What data we use and why
3.1 Contacting
If you contact us (e.g. by e-mail), we process your information to process the request and in the event that follow-up questions arise. If the data processing is carried out for the implementation of pre-contractual measures, which are carried out on your or our request, or, if you are already in contact with us, for the implementation of the contract, the legal basis for this data processing is Art. 6 para. 1 p. 1 b) DSGVO. We only process other personal data if you consent to this (Art. 6 para. 1 p. 1 a) DSGVO) or we have a legitimate interest in processing your data (Art. 6 para. 1 p. 1 f) DSGVO). A legitimate interest is, for example, to respond to your email.
3.2 Data for the fulfillment of our contractual obligations
We process personal data that we need to fulfill our contractual obligations, such as name, address, telephone number and e-mail address. The collection of this data is necessary for the conclusion of the contract. The deletion of the data takes place after the expiration of warranty periods and legal retention periods.
The legal basis for the processing of this data is Art. 6 para. 1 p. 1 b) DSGVO, because this data is needed so that we can fulfill our contractual obligations to you and our customers.
3.3 Data to simplify the implementation of influencer marketing campaigns
We process personal data that facilitates the fulfillment of our contractual obligations on the basis of Art. 6 (1) (b) DSGVO and compile this data into a database. The collection of this data helps CrowdArchitects and its customers to plan and execute influencer marketing campaigns more efficiently. The deletion of the data takes place after the expiration of warranty periods and legal retention periods. This data includes:
First and last name
E-mail address
Phone number
Residential address
Sending address
Gender
Relationship status
Date of birth
Price information
Information from past campaigns in which the Influencer has participated
If applicable, information on the agency representing the influencer (first and last name, e-mail address, phone number, address)
Social media account information from blogs, Facebook pages, Instagram accounts, Pinterest pages, podcasts, Snapchat accounts, TikTok accounts, Twitch channels, Twitter accounts, WeChat accounts, YouTube channels.
Profile picture (from public feed)
Account name (@...)
IDs
Deposited names
Texts and links
Account and Posting Insights (including impressions, reach, comments, follower demographics).
Anonymized market research data (follower demographics, social media usage behaviors).
The data is public data, personally obtained data by the Influencer or the agency/management representing the Influencer, or it has come into our possession through personally obtained business cards, flyers, media kits or the like, or a direct survey.
3.4 Data for own marketing purposes
CrowdArchitects reserves the right to use the campaign content for its own marketing purposes (reposting of the contributions on the social media accounts of CrowdArchitects, campaign-related use of the contributions on the website iroin.io and in online press releases and print media). The granting of the right of use is contractually agreed between the Influencer and CrowdArchitects.
4 Login and authentication
By logging in or authenticating, users authorize this application to identify them and grant them access to specific services.
Depending on what is specified below, third-party providers may provide login and authentication services. In this case, this application may access some data stored by these third-party providers for login or identification purposes.
Insofar as you consent to this processing, Art. 6 para. 1 lit. a) DSGVO is the legal basis for the processing.
4.1 Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a login and authentication service provided by Facebook, Inc. that is associated with the Facebook social network.
Personal data collected: Profile picture (from public feed), account names (@...), IDs, deposited names, texts and links, account and posting insights (including impressions, reach, comments, demographics of followers).
We will use the information received only for the purposes described in this privacy policy (§5 Use of data).
Processing Location: USA - Privacy Policy: https://www.facebook.com/privacy/explanation.
4.2 Google OAuth (Google Inc.)
Google OAuth is a login and authentication service provided by Google Inc. that is connected to the Google network.
Personal data collected: Profile picture (from public feed), account names (@...), IDs, deposited names, texts and links, account and posting insights (including impressions, reach, comments, demographics of followers).
We will use the information received only for the purposes described in this privacy policy (§5 Use of data).
Processing Location: USA - Privacy Policy: https://developers.google.com/terms/api-services-user-data-policy.
5 Use of the data
The data collected or received serve:
a) the decision-making process for an advertising cooperation with us or our customers. For this purpose, the data is prepared in tabular and graphical form and displayed on the platform and in presentations (sedcards). The basis of the decision-making process is the actual reach and performance of the respective account and the age, gender and country distribution of the followers matching the advertising campaign.
b) the evaluation of the advertising campaign carried out with regard to the target group reached and the quality of the content created (image or video). Based on reach and agreed budgets, KPI's such as CPM (cost per mille), CPE (cost per engagement) and CTE (click through rate) are calculated in order to make a statement about the success of the advertising cooperation. The results (number of impressions, comments, likes, average playback time) are prepared in tabular and graphical form and displayed on the platform and in presentations (reports).
6 Recipients of the data
The collected or received data is mainly received by the employees of CrowdArchitects, the IROIN Influencer Marketing Suite (http://iroin.ims.iroin.io) and further on by customers and, if applicable, potential customers of CrowdArchitects. The transfer of data to customers takes place in a commercial context for the planning and implementation of influencer marketing campaigns.
7 Storage duration
Unless specifically stated, we store personal data only for as long as necessary to fulfill the purposes pursued. In some cases, the legislator provides for the retention of personal data, such as in tax or commercial law. In these cases, we only continue to store the data for these statutory purposes, but do not process it elsewhere and delete it after the statutory retention period has expired.
8 Your rights as a data subject affected by data processing
According to the applicable laws, you have various rights regarding your personal data. If you wish to exercise these rights, please send your request by e-mail or by post, clearly identifying yourself, to the address mentioned in point 1. Below you will find an overview of your rights.
8.1 Right to confirmation and information
You have the right to receive clear information about the processing of your personal data. In detail: You have the right to receive confirmation from us at any time as to whether personal data relating to you is being processed. If this is the case, you have the right to request from us free information about the personal data stored about you, together with a copy of this data. Furthermore, you have the right to the following information:
a) the purposes of processing;
b) the categories of personal data processed;
c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular in the case of recipients in third countries or international organizations;
d) if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration;
(e) the existence of a right to obtain the rectification or erasure of personal data concerning you, or the restriction of processing by the controller, or a right to object to such processing;
f) the existence of a right of appeal to a supervisory authority;
g) if the personal data is not collected from you, all available information about the origin of the data;
h) the existence of automated decision-making including profiling pursuant to Article 22(1) and (4) of the GDPR and - at least in these cases - meaningful information about the logic involved and the scope and intended effects of such processing for you.
If personal data is transferred to a third country or to an international organization, you have the right to be informed about the appropriate safeguards pursuant to Art. 46 GDPR in connection with the transfer.
8.2 Right to rectification
You have the right to request us to correct and, if necessary, complete personal data concerning you. In detail: You have the right to demand that we correct any inaccurate personal data concerning you without undue delay. Taking into account the purposes of the processing, you have the right to request the completion of incomplete personal data - also by means of a supplementary declaration.
8.3 Right to erasure ("right to be forgotten")
In a number of cases, we are required to delete personal data relating to you. In detail: Pursuant to Article 17(1) of the GDPR, you have the right to request that we delete personal data concerning you without undue delay, and we are obliged to delete personal data without undue delay if one of the following reasons applies:
a) The personal data are no longer necessary for the purposes for which they were collected or otherwise processed.
b) you revoke your consent on which the processing was based pursuant to Art. 6 (1) p. 1 a) DSGVO or Art. 9 (2) a) DSGVO and there is no other legal basis for the processing.
c) you object to the processing pursuant to Art. 21 (1) DSGVO and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Art. 21 (2) DSGVO.
d) the personal data have been processed unlawfully.
e) The deletion of the personal data is necessary for compliance with a legal obligation under Union or Member State law to which we are subject.
f) The personal data was collected in relation to information society services offered pursuant to Art. 8 (1) DSGVO.
If we have made the personal data public and we are obliged to erase it pursuant to Article 17(1) of the GDPR, we shall take reasonable measures, including technical measures, having regard to the available technology and the cost of implementation, to inform data controllers that process the personal data that you have requested erasure of all links to or copies or replications of such personal data.
8.4 Right to restriction of processing
In a number of cases, you are entitled to request that we restrict the processing of your personal data. In detail: You have the right to require us to restrict processing if one of the following conditions is met:
a) the accuracy of the personal data is disputed by you for a period of time that allows us to verify the accuracy of the personal data,
b) the processing is unlawful and you have refused to erase the personal data and have instead requested the restriction of the use of the personal data;
c) we no longer need the personal data for the purposes of processing, but you need the data for the assertion, exercise or defense of legal claims, or
d) you have objected to the processing pursuant to Art. 21 (1) DSGVO, as long as it has not yet been determined whether the legitimate reasons of our company outweigh yours.
8.5 Right to data portability
You have the right to receive, transmit, or have us transmit personal data concerning you in machine-readable form. In detail:
You have the right to receive the personal data concerning you that you have provided to us in a structured, common and machine-readable format, and you have the right to transfer this data to another controller without hindrance from us provided that
a) the processing is based on consent pursuant to Art. 6 (1) p. 1 a) DSGVO or Art. 9 (2) a) DSGVO or on a contract pursuant to Art. 6 (1) p. 1 b) DSGVO and
b) the processing is carried out with the help of automated procedures.
When exercising your right to data portability pursuant to paragraph 1, you have the right to obtain that the personal data be transferred directly from us to another controller, to the extent that this is technically feasible.
8.6 Right of objection
You have the right to object from a lawful processing of your personal data by us, if this is based on your particular situation and our interests in the processing do not outweigh. In detail: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data relating to you which is carried out on the basis of Article 6 (1) sentence 1 e) or f) DSGVO; this also applies to profiling based on these provisions. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the purpose of asserting, exercising or defending legal claims.
If we process personal data for the purpose of direct marketing, you have the right to object at any time to the processing of personal data concerning you for the purpose of such marketing; this also applies to profiling insofar as it is associated with such direct marketing.
You have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you which is carried out for scientific or historical research purposes or for statistical purposes pursuant to Article 89(1) DSGVO, unless the processing is necessary for the performance of a task carried out in the public interest.
8.7 Automated decisions including profiling
You have the right not to be subject to a decision based solely on automated processing - including profiling - which produces legal effects concerning you or similarly significantly affects you. Automated decision-making based on the personal data collected will not take place.
7.8 Right to revoke consent under data protection law
You have the right to revoke consent to the processing of personal data at any time.
8.9 Right to complain to a supervisory authority
You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, workplace or the place of the alleged infringement, if you consider that the processing of personal data concerning you is unlawful.
9 Data security
We make maximum efforts to ensure the security of your data within the framework of the applicable data protection laws and technical possibilities. Your personal data is transmitted encrypted with us. We use the SSL (Secure Socket Layer) coding system, but we would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible. To protect your data, we maintain technical and organizational security measures in accordance with Art. 32 DSGVO, which we constantly adapt to the state of the art.
We also do not guarantee that our offer will be available at certain times; disruptions, interruptions or failures cannot be ruled out. The servers we use are carefully backed up on a regular basis.
10 Disclosure of data to third parties, no data transfer to non-EU countries
In principle, we only use your personal data within our company. If and insofar as we involve third parties within the framework of the fulfillment of contracts (such as customers for whom we conduct an influencer campaign), they receive personal data only to the extent that the transfer is necessary for the corresponding service. The transfer of data to customers takes place in a commercial context for the planning and implementation of influencer marketing campaigns.
In the event that we outsource certain parts of data processing ("commissioned processing"), we contractually oblige commissioned processors to use personal data only in accordance with the requirements of data protection laws and to ensure the protection of the rights of the data subject.
A data transfer to entities or persons outside the EU outside the case mentioned in this declaration in clause 4 does not take place and is not planned, with the exception of the transfer of data to customers of CrowdArchitects GmbH located in other EU countries for the purpose of conducting influencer marketing campaigns.
11 Data protection officer
If you still have questions or concerns about data protection, please contact our data protection officer:
E-mail: akilz@crowd-architects.com
12 Changes to this privacy policy
If new services or providers are used for data processing, we reserve the right to adapt this privacy policy in order to comply with the legal circumstances. We will inform the Influencers about the changes to the adapted data protection declaration via the contact data provided to us.