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hypetrain privacy policy

When you use our platform “Hypetrain” available at https://hypetrain.io (the “Platform”) we can collect information about you that can directly or indirectly identify you (the “Personal Data”).

Under “you” in this Privacy Policy means:

  • Advertisers (agency, brand and any other persons uses Influencers to promote goods/services, etc),

  • Influencers:

  • agency that represents the interests of influences,

  • influencer himself/herself, who acts on his/her own behalf.

Unless expressly provided otherwise, all of the following terms apply to all of the above categories of users.

This Privacy Policy describes:

  • What Personal Data we collect from you,

  • How we process your Personal Data,

  • The choices you have regarding your Personal Data.

If you do not agree with this privacy policy, please do not use the platform.

We may periodically update this Privacy Policy. Your continued use of the Platform after the effective date of the updated Privacy Policy will be subject to the new Privacy Policy. If we make any major changes to our Privacy Policy and will need your explicit consent for further processing of your Personal Data, we will request your consent or your renewed consent (in case it was obtained previously).

Data we collect

We would like to pay your attention that we collect very limited amount of Personal Data strictly required to provide you the Platform which includes:

  • In respect of the Advertisers we may collect:

  • Contact Data such as company name, employee full name and email,

  • Payment Data such as an amount of payment and your bank details (if you provide it to us) (please, note, that your credit card data is processed by our third-party partner (see the section “Who can have access to your Personal Data”)),

  • Technical Data such as IP address, browser type and language, general location data,

  • Usage Data, i.e. information about your use of the Platform,

  • Communication Data, i.e. all communications made through the Platform, including any attachments.

  • In respect of the Influencers we may collect:

  • Contact Data such as full name, name of the company and full name of the employee (if Influencer acts through the agency), email, identifying document details, residential address,

  • Payment Data such as an amount of payment and bank details,

  • Social Media Data such as link to the profile, full name specified in the profile, nickname of the profile, avatar, language, biography, country/city/state, brand and common interests, notable engaged users, sponsored posts, audience data, content or materials from profile,

  • Technical Data such as IP address, browser type and language, general location data,

  • Usage Data i.e. information about your use of the Platform,

  • Communication Data, i.e. all communications made through the Platform, including any attachments.

  • In order to provide you statistics in relation to the Influencer’s profile we may also analyse the Influencer’s audience (the “Audience Data”). Audience Data includes avatar, full name specified in the profile, nickname of the profile, gender, location, subscriptions, comments. Audience Data is only relevant to the Influencer and is kept in an aggregated form together with information about Influencer.

How do we collect your personal data

We collect Personal Data in the following cases:

  • Contact Data and Payment Data are collected only if you provide it to us,

  • Technical Data and Usage Data are collected automatically by electronic means, including with the help of cookies, when you use the Platform,

  • Social Media Data and Audience Data are collected automatically from the public sources subject that such data is made public by the data subject, indicating that the data subject wishes and expects such data to be further processed,

  • All Communication Data is stored by us to have access to the arrangements in case of disputes. Please note that we do not use your Communication Data for any other purposes and do not share Communication Data with third parties. We can only share it if we have reason to believe that we are legally obligated to do so (for example, in the event of a dispute).

Since we process a big amount of data, we are not able to notify every Influencer and its audience about such processing but we assume that notification about such processing follows from this Privacy Policy. Such processing is based on the legitimate interest as described in the section “How do we use your Personal Data” and does not affect the rights and freedoms of Influencer and its audience as natural persons.

How do we use your personal data

Your Personal Data is used as follows:

Purpose of the processing

Type of Personal Data

Legal ground for the processing

To establish a contractual relationship with you

Contact Data Payment Data

Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract

To generate best efforts statistics in relation to the Influencer’s profile to provide the Advertiser with an approximate understanding of a potential cooperation

Social Media Data Audience Data

The legitimate interest for statistical purposes based on the balance of interests:

  • Influencer's interest is to attract the Advertiser's attention for cooperation;

  • our interest is to provide the Advertiser with an approximate information about the potential cooperation with the Influencer

To have access to the arrangements

Communication Data

Our legitimate interest to be able to help ensure the rights of our users, based on the balance of interests

To keep the Platform safe and fair

Technical Data Usage Data

Our legitimate interest to ensure safe usage of Platform (including troubleshooting, testing, system maintenance, support, reporting and hosting of data) based on the balance of interests

To make the Platform more suitable for you

Technical Data Usage Data

Our legitimate interest to provide you better services (including by analysing your behaviour, studying your preferences and in line with that modifying and improving the Platform) based on the balance of interests

To show you personalized advertisements

Technical Data Usage Data

Your explicit consent

Cookies and similar technologies

Cookies are small text files sent to your computer or mobile device that enable the Platform and its features to function properly.

Some of our cookies are necessary for certain uses of the Platform. These cookies allow us to make Platform usable by enabling basic functions like page navigation and access to secure areas of the Platform. The Platform cannot function properly without these cookies.

We have also created and implemented our cookies and cookies from third parties for analytical and marketing purposes. Analytical and marketing cookies, among other things, collect information on how users use the Platform and the effectiveness of our third-party advertising.

You can generally activate or later deactivate the use of cookies through a functionality built into your browser. You can also contact us with the request to disable particular categories of cookies.

Who can have access to your personal data

Below is the list of our third-party partners and the purpose for which we engaged each third party:

Name of such third party

Its privacy policy

How such third party uses your Personal Data

Google Firebase

https://firebase.google.com/support/privacy

To better understand users of Platform, learn about their preferences

Facebook Analytics

https://www.facebook.com/about/privacy/previous

Yandex Metrika

https://yandex.ru/legal/confidential/

Facebook ads

https://www.facebook.com/about/privacy/previous

To provide you advertising that matches your interests

HubSpot

https://legal.hubspot.com/privacy-policy

CRM system

Stripe

https://stripe.com/privacy

To accept payments from Advertisers

Tipalti

https://tipalti.com/privacy/

To make payments to Influencers

International data transfers

We can have partners all over the word, thus your Personal Data can be transferred to anywhere in the world. Since different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission.

Your rights and Options

We process and answer your requests without undue delay and in any event within 1 month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to 3 months in total.

You have the following rights regarding your Personal Data we hold about you, unless provided otherwise by applicable law.

Your rights. You have the right to access Personal Data we hold about you, correct your Personal Data, have your Personal Data deleted, object how we process or share your Personal Data, and restrict how we process or share your Personal Data. You can at any time send us a relevant request to access, correct, delete, stop or restrict processing or sharing of your Personal Data via e-mail specified above.

Note that if you ask us to delete your Personal Data, we can retain your Personal Data as necessary to comply with our legal obligations or resolve disputes.

If your explicit consent serves the basis for Personal Data processing, you can withdraw the consent at any time sending a relevant request via e-mail specified above.

Rights of California residents

As required by California Consumer Privacy Act (CCPA) we endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by e-mail.

Right to opt out. Under the CCPA each California resident can request business stops selling Personal Data to third parties.

Do we actually “sell” Personal Data? We do not, and will not, provide your Personal Data in direct exchange for money. Therefore, in the literal sense, we do not sell your Personal Data.

Other rights. You also have a right to be informed about what categories of Personal Data we are collecting: you can request us to disclose what Personal Data we have collected in the past 12 months and right to get a free copy of your Personal Data disclosed in a readily usable and readable format. You can also request us to delete the Personal Data we have collected in the past 12 months. We will not discriminate against you for exercising any of your rights granted under CCPA.

Mandatory verification. As required by CCPA we will need to verify your identity before processing your request. In order to verify your identity, we will generally match sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline the request, mainly where we are unable to verify your identity, for example, if you have requested us to delete your Personal Data or your account within the Platform.

Data retention

We retain your Personal Data for as long as it is necessary to fulfill the purposes specified in the section “How do we use your Personal Data”. We regularly (at least once a year) review and de-identify unnecessary data to store it for research or statistical purposes only. Your Personal Data is automatically deleted after 1 month after your account within the Platform was deleted.

Age limits

We do not knowingly collect or solicit Personal Data about or direct or target personalized advertisements to anyone under the age of 13, except in European Economic Area, where the age is limited to users under 16, or knowingly allow such persons to use the Platform. If you are under the age of 13 (or 16 where applicable), please do not send any Personal Data to us. If we learn that we have collected Personal Data about a child under age 13 (or 16 where applicable), we will delete that Personal Data as quickly as possible. If you believe that we might have any Personal Data from or about a child under the age of 13 (or 16 where applicable), please contact us.