PRIVACY POLICY
Processing personal data of (potential) influencers
GLAMO Agency LLP (GLAMO or we/us/our) maintains a large network of leading and authentic digital influencers that we may connect to our customers who have brand portfolios in the beauty, fashion, lifestyle and hospitality industry.
In order to connect you to the marketing portfolios of our customers, we need to process certain personal data of you. You may be an influencer with whom we now work with, or have worked with some time ago, or with whom we would like to work with in the future. In any case, your privacy is highly important to us. In this Privacy Policy we will inform you about the way we process your personal data when you are an influencer, former influencer or potential influencer in our network. When processing your personal data, we make use of our internal GLAMO Platform, where we store information that we may receive from you, obtain from public sources or receive from third parties upon your consent. It is important that you read and understand this Privacy Policy, so you are able to make informed decisions and genuine choices about the data that we process.
1. To whom does this Privacy Policy apply?
This Privacy Policy is applicable to you when you are an influencer in our network. This is the case if you are or have been involved in digital influencer marketing campaigns with us. Another possibility is that you are in our network because you are an active professional digital influencer with whom we do not yet have a contractual relationship, but we may like to work together with you in the future. In that case you are a potential influencer.
2. Who is the data controller?
GLAMO is the data controller for the processing of your personal data under the applicable data protection laws of the United Kingdom.
3. What types of personal data do we process?
We may process the following types of personal data from you:
(a) Personal data of (former) influencers. The personal data we process of our influencers includes your name and address data, gender, date of birth, your public profile photo from social networks, e-mail address, phone number, social media accounts and/or website, account name, nickname, information about preferences, information from your agent or manager if applicable, amount of followers, estimated engagement on social media accounts and assumed target groups. Next to that, the personal data we process includes the details of arrangements made between you and GLAMO including start and end date of agreements made, bank details, social security number, Chamber of Commerce number, information that you (or your agent/manager) provide us in the course of our relation and impressions on your social media accounts relating to marketing posts (including the amount of views, types of followers, age groups etc.).
(b) Personal data of potential influencers. The personal data we process of the potential influencers in our network includes your name and address data, gender, date of birth, your public profile photo from social networks, e-mail address, phone number, social media accounts and/or website, account name, nickname, information about preferences, information from your agent or manager if applicable, amount of followers, estimated engagement on social media accounts and assumed target groups. If you or your agent/manager has been in contact with us, we may process the data that has been provided to us in this respect.
The aforementioned types of personal data may originate from various sources. We may process personal data that we have found on your public profile on social media or your public website to the extend you have made this information public intentionally and not solely for private purposes. When you are an influencer or former influencer we will process personal data that we have obtained in connection with our cooperation. This data may originate from your agreement with us, from your social media profile(s) or website(s) and from information you (or your agent/manager) provided to us.
4. What are the purposes for the processing of your personal data?
When you are a (former) influencer, we may process your personal data for the following purposes:
1. Maintaining the administration of our network of (potential) influencers;
2. Approaching you for new collaborations;
3. Making propositions for our customers;
4. Improving our services towards our customers by market analysis, identification of reach and target groups;
5. Maintaining contact, handling enquiries, complaints and disputes;
6. Compliance with applicable laws and regulations;
7. Contract management;
8. Rolling out marketing campaigns in collaboration with the influencer;
9. Performance of contracts with influencers;
10. Auditing the effect of a marketing campaign, measuring impressions.
When you are a potential influencer, we may process your personal data purpose 1 to 6 of the above.
We will not further process your personal data for other purposes than mentioned in this Privacy Policy.
5. What are the applicable legal grounds for the processing of your personal data?
We may only process your personal data when there is a legal ground. When you are an influencer, we will need to process your personal data for the execution of the agreement that we will have with you. Also, we may ask your consent for certain data processing activities such as auditing the effect of a marketing campaign. We may furthermore process personal data of our influencers and of potential influencers based on our legitimate business interest to the extent such interest is not overridden by your privacy interests or fundamental rights and freedoms. Where required, we may process your personal data to meet with our statutory obligations.
6. Consent for sharing additional social media data
If you are an influencer, we will ask your consent for sharing specific information in relation to (the reach of) your posts, weblogs and vlogs with us. When you give your consent, you allow social media channels such as Facebook and other parties, like Google Analytics, to provide data relating to the amount of views or clicks and other aggregated information about your followers or website visitors (e.g. age, location, interests, language) in relation to your posts or website content. The information we receive is not attributable to individual followers or website visitors yet may contain your personal data (in any case your account name or website URL). The parties providing such information will remain data controllers in relation to the personal data they will process in this respect. GLAMO will only be the data controller for the further processing of your personal data and we will only process such in accordance with this Privacy Policy.
7. How long will your personal data be retained?
We will not retain your personal data longer than necessary for the purposes for which we have obtained your personal data. In principle w e may retain your personal data up to a maximum of two years upon the ending of our business relationship, unless we are required to retain your personal data to live up with a statutory obligation.
8. Who has access to your personal data?
Persons working at or on behalf of GLAMO may have access to your personal data on a need-to-know basis. Next to that, GLAMO may involve third party service providers who will act as a data processor on our behalf. GLAMO selects its service provides with due care and makes all necessary arrangements with these third parties. In any case, GLAMO will enter into a data processing agreement which includes arrangements on data security to protect your personal data against data breaches.
GLAMO may provide certain personal data to its customers in order to provide them with business propositions or in relation to a marketing campaign of a customer that you participate in. When our customers would further process your personal data, they would do so for their own purposes acting as a data controller. The terms and policies of our customers may apply to such data processing activities.
GLAMO may provide your personal data to competent authorities upon their request to the extent legally required or to the extent this would be necessary to defend GLAMO's rights in legal proceedings or investigations.
9. How is your personal data secured?
We will exercise due care when dealing with your personal data. Amongst other things, this means that we will adopt appropriate technical and organizational measures to secure and protect your personal details against loss and unlawful processing. We protect our systems and applications according to the applicable standards for information security and we also make data processing agreements with our service providers which include obligations to implement adequate security measures.
10. Your rights
You have certain rights relating to the processing of your personal data. You may at any time, with reasonable intervals, exercise your right of inspection of your personal data. Upon your inspection, you may request us to correct or delete your personal data when the data is incorrect or excessive.
11. Contact
If you have any questions concerning the manner in which we process your personal data, about this Privacy Policy, or you wish to invoke your rights, you may contact us at privacy@glamo.agency
This Privacy Policy may be modified from time to time. We encourage you to check this Privacy Policy regularly so that you are aware of any changes.
This Privacy Policy was last updated on Jan 3rd 2020.