This privacy statement addresses the personally identifiable information (“data”) that we collect and process about individual authors of online content (“Author”, “you” or “your”) through the services that we offer to our customers. Basically, if you publish information on publicly available websites (Twitter, Instagram, etc.), you’re an Author for purposes of this privacy statement.
1.1. We are Audiense Limited (trading as Audiense) (“we”, “us” or “Audiense”). Our registered office address is at 10 Devonshire Square London, United Kingdom EC2M 4YD. Our company number is 07927254 and our VAT number GB142216647. We are a data processor of the data that we process about you.
1.2. We contract directly with third partiesto gain access to their information (including data) and sometimes we maye crawl and index publicly available information (including data) from the Internet. In each case, the information that we have access to is published or made available directly by Authors, giving their consent to third parties as data controllers (websites) to share it with Audiense and/or to make it publicly available. This information is then collated and stored in our database, acting Audiense as a data processor. We offer access to our database, as well as analytics of the data within that database, to third parties (our “Services”) as data subprocessors, always according to the data controller guidelines.
1.3. Since all of the information that we access is publicly available, the raw information we have about you could be found by anybody with access to the Internet. Some of this information is personal data. For example your name or username in connection with your Twitter profile would be personal data. Other information we process may not be personal data (for example if you publish an anonymous review on a website).
1.4. As an Author, you are the source of the data. You have control over that data within the platform you choose to publish it on (e.g. Twitter or Facebook), including through using the privacy settings made available to you by that platform. In addition to whatever rights you have via your relationship with any publishing platform, you also have certain rights relating to your data that we process, as set out in this Privacy Statement.
2.1. The data we collect varies depending on the source of the data, what the source or platform chooses to make available to us, plus what you choose to make available. It could include the following:
2.2. In addition to the data you make available about yourself, we may also use that information to infer other data about you. For example, based on your name, we may infer your gender. Equally, based on the content of one of your posts, we may infer some of your interests, your profession, your location, etc.
2.3. We may also analyse the content of the data you publish and provide our analysis to our customers. For example, if you publish a Tweet stating that you like a certain brand’s ice cream, we may mark that Tweet as having a positive sentiment toward that brand.
3.1. The legal basis for the data that we process is pursuant to the consent Authors give to third parties (data controllers), acting Audiense as data processor, sometimes it may be baased on our legitimate interests and sometimes on a third party legitimate interests. Our legitimate interests are in providing our Services to our customers, which includes providing technology that empowers our customers to enrich 3rd party data in real time and act with more certainty in a way that is easy-to-access and use. In turn, this allows our customers to learn more about their brand, their customers, their competitors, and other information available on the social web that is relevant to our customers.
3.2. We also use the data in ways related to, but ancillary, to the Services that we offer. For example, we may use the data to comply with our legal obligations or enforce our rights, including the legal obligations or enforcement of rights of third parties. We may also use the data to improve our Services.
3.3. Although it is the responsibility of our customers to use our Services properly, we do put in place safeguards to protect your data. We require our customers to comply with applicable law, including data privacy law, when using our Services. We also prohibit our customers from using our Services, including your data, in a way that is outside of your reasonable expectations.
3.4. When we infer data about you, we do so automatically. The inferences are based on algorithms that analyse the data that you have posted. We do not make any decisions about you based on the data that we process about you (inferred or not). In other words, we only make the data available to our customers. It is up to our customers what (if anything) to do with the data and any inferences about the data.
4.1. In addition to sharing your data with our customers, we may share your data with any member of our company group (i.e. our subsidiaries, parent companies, and affiliates).
4.2. We may share your data with selected third parties, including our business partners, suppliers, and sub-contractors, for the performance of any contract we enter into with them. We may also share your data with analytics and search engine providers that assist us in the improvement of our website.
4.3. We may also disclose your data to other third parties. For example, if we sell or buy any business or assets, we may disclose your data to the prospective seller or buyer of such business or assets. Alternatively, if we or substantially all of our assets are acquired by a third party, your data may be part of the transferred assets.
4.4. If any third party processes any of your data, we ensure there are sufficient contractual and operational safeguards protecting your data.
4.5. We may share your data with customers o third parties that are outside the territory of the European Economic Area. In case any of these countries isn’t covered by a decision of adequacy of the European Commission, we will ensure there are sufficient contractual and operational safeguards protecting your data.
5.1. Most of the data we have about you comes directly from you. If it is inaccurate, we advise you to fix it on the original platform in which you published that data. Where we infer data about you, it is our aim to ensure that any of this additional data is accurate and kept up to date.
5.2. We will retain any data about you for as long as the data controllers decide or as long as it is reasonably necessary for us to provide the Services in real time. However, if you request that we delete your data, or if you delete your data from the platform in which it was originally published, we will also delete your data from our Services.
6.1. We may transfer your data to, and store it in, a country other than your own. That country may not provide the same level of data protection as your own country. Whenever we transfer your information outside of Europe, we will take steps which are reasonably necessary to ensure that adequate safeguards are in place to protect your personal information and to make sure it is treated securely. If you are located in Europe, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.
6.2. The servers in which we hold your data have appropriate administrative, technical, and physical controls that are designed to safeguard your data, including industry-standard encryption technology.
6.3. You have a number of legal rights in your data under applicable data privacy law. Under applicable law you may:
6.4. To exercise any rights listed above, please email us at firstname.lastname@example.org or write to us at the address listed at the top of this document.
6.5. If you do not agree with any decision regarding the processing of your personal data and the exercise of your rights, you can contact our Data Protection Officer:
6.6 If it is not resolved, you may lodge a complaint with the supervisory authority about our processing of your data under this Privacy Statement. The appropriate supervisory authority is the data privacy regulator in which you live. If you live in the United Kingdom it is the Information Commissioner’s Office and you can report a concern at ico.org.uk/concerns
7.1. This privacy statement only addresses our collection, processing, and use (including disclosure) of your data. Our customers and other third parties that may have access to your data can use it in other ways in accordance with their own privacy practices and applicable law. We encourage you to familiarize yourself with the privacy statements provided by any platform you use to publish any information.
8.1. English law governs this privacy statement and any dispute or claim related to it. Each party agrees that the English courts have exclusive jurisdiction over this privacy statement and any dispute or claim.
LAST UPDATED: 24TH MAY 2018