- This Privacy Statement explains how we collect, process, and use data about you. This Privacy Statement applies to all users, including those users who use the Services via their employer or another company. This Privacy Statement also applies to all of the data that we collect through our Services, irrespective of the type of Services or the device you use to access the Services.
- This Privacy Statement addresses the data we process about individual authors of content (“Author”, ”User”, “you” or “your”) on, through or related to the services we offer to our customers.
- We are IN3 (“we”, “us”, “our” or “IN3”), a provider of “social listening” and market intelligence services, through our proprietary platform “Buzzdiggr” (together, the “Services”). Think of your preferred online search engine, only specializing in social interactions on the Internet, with the ability to analyze the results.
- To provide our Services, we crawl various sources on the Internet (e.g. websites, blogs, forums, social networks) and collect publicly available information, including personal data. Then, we analyze and index such information and save the results. We only use information published or made publicly available by Web Users on the Internet. Please note that IN3 does not collect nor process information which access is private or technically restricted, i.e. that is not generally publicly available on the Internet, regardless of the source.
- We crawl and index publicly available data from the Internet. We also contract directly with third party providers to gain access to their data. In each case, the data we have access to is published or made available by Authors. This data is then collated and stored in our database. We offer access to our database, as well as analytics of the data within that database, to third parties (our “Services”).
- Since all of the data that we access is publicly available, the raw data we have about you could be found by anybody with access to the Internet. Some of this data may be personal information about you (for example your name or username in connection with your Twitter or Facebook profile) and other data may not be (for example if you publish an anonymous review on a website).
- As you are the source of the raw data, you have control over that data within the platform you choose to publish it on (e.g. Twitter, Facebook or Instagram), 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 with respect to your personal information that we process, as set out in this Privacy Statement.
C. Data Collection
1) User Information
- There are three categories of information that we collect from you:
- Given Information: Information that you provide us explicitly, such as when filling out a registration form, registering for an event, or asking for information. For clarity, we refer to this as Given Information because you gave it to us by performing an action.
- Technical Information: Information that our servers automatically collect from you when you visit the Public Site, such as your IP address, browser type, operating system type, and the date/time of your visit. For clarity, we refer to this as Technical Information because we collect it automatically.
- User Information: Information that you provide us explicitly for purposes of identifying yourself as a Services user, such as for logging in, or other user interface activities with our Services as a User as defined in the Agreement. For clarity we refer this as User Information because you gave it to us in order to utilize the Service as a User.
- If you register as a user of any of our Services, we may ask you to provide your name, email address, contact telephone number (landline and/or mobile), the company you work for, your address, a username and password, and other data relevant to the Services we provide. If you are not an administrative user for your account, the same data about you may be provided by a colleague or other third party. We may also collect other data directly from you, from time to time.
- Depending on your account type, we may collect payment data from you in order to take payment for our Services.
- If you contact our support services, we will collect the data we need to categorize your question and respond to it. We also use this data to track potential issues with our Services and customize our support responses to better serve you.
- We collect data about you when you use any part of our Services. For example, if you are logged in to your Buzzdiggr account, we will collect data as to how often you use Buzzdiggr, what queries you created or amended, and other data about how you interact with Buzzdiggr. We may also collect data about how you interact with messages we send to you, for example whether you opened an email or read an in-app message.
- We indicate whether data we request is mandatory or optional and consequences of your refusal to provide such information. If you refuse to provide information that we indicated is mandatory, we may be unable to provide you certain Services.
- We collect data about the device you use to use our Services, including operating system details, web browser type, your mobile device identifier and mobile operating system, and the name of your ISP or mobile carrier. We may also collect your location data if your device permits this.
- More About Technical Information Technical information collected via the Public Site includes two types:
- Log file information: Our servers collect and save information to a log file each time you make a request to 2 access (visit) a web page or application, or download the content of a web page or application to your browser or device. More specifically, this information includes your web request, Internet Protocol (“IP”) address, browser type, referring/exit pages and URLs, the number of clicks you make, how you interact with links on the Public Site, domain names, landing pages, pages viewed, and other such information. This information allows for more accurate reporting and helps us to improve the Public Site.
2) Author Information
- Depending on the source and restrictions which may apply (e.g. what you choose to make available or what the Internet source makes available), the data we collect about Web Users encompasses the following information. Please keep in mind that such information is only information you disclosed on the Internet and which is publicly available therefrom:
- Your name, username, pseudonym or other identifier;
- Your profile picture;
- Content you published using that name, username, pseudonym or other identifier, including e.g. posts, comments, expressions, opinions;
- Other images or videos that you post or interact with;
- Your location, as provided to us by any third-party website, page, forum, social network that shares such data with us, subject to your choices and preferences on such third-party website, page, forum, social network;
- Any other information you made generally available on a website, page, forum, social network we are authorized to crawl or that shares data with us.
- In addition to the data you disclosed or made publicly available on the Internet (or the third-party site or service made available), we may also use that information to infer other information about you. For example, we infer your centers of interest, your profession, your influence on a certain topic based on the information you published and your interactions on the Internet.
- Please note that we do not collect or try to infer from information we collect, any information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership and sexual orientation.
3) How do we use Data
uses Given Information to communicate with you about business matters, such as:
- Responding to inquiries
- Processing requests
- Placing orders
- Contacting you about Buzzdiggr Services
uses Technical Information to:
- Collect anonymous statistics on how the Public Site is used
- Measure site errors
- Enhance the Public Site
- Improve products and services
- Market Buzzdiggr services to you
- Buzzdiggr may also use Technical Information collected via cookies to improve your individual experience with the Public Site.
- Other Uses: IN3 uses third-party analytics tools to measure traffic and usage trends on the Public Site. These tools collect information, such as the web pages you visit or add-ons you use, sent by your device or the Public Site. We use this information to improve the Public Site. Because Buzzdiggr collects your information along with information from other users, we cannot reasonably use it to identify you specifically.
Buzzdiggr Uses Your Information entered into the Buzzdiggr Services Buzzdiggr
uses User Information to:
- Register you as a User with the Buzzdiggr Service
- Activate you as a User with the Buzzdiggr Service
- Provide you with support as a User of the Buzzdiggr Service
- We process
data about Web Users and Customers on the basis of our legitimate interest for
purposes of providing our Services and improving our Services and the way we
provide them, including the accuracy of our market intelligence as well as our
Of course, we also process personal data in order to comply with the legal and regulatory requirements bearing on us, for instance to comply with our accounting obligations or answer requests we may receive from judicial or administrative authorities.
- We send service communications to our Customers via email, or directly via the Services, e.g. to confirm the implementation of a feature you requested or informing you of a scheduled maintenance on the Services. We may also send you commercial communications pertaining to our Services. Furthermore, we may send commercial communications on your corporate email address even if you or your employer is not one of our customers. In any event, you can opt out of receiving commercial communications on your corporate email address using the link provided in any such commercial communication we send.
- We collect data Web Users publish or otherwise make publicly available on the Internet, analyze such data and provide our analysis to our customers only, as part of our Services, like a marketing research agency which would collect information in order to understand consumers’ needs and expectations for the purposes of improving existing services or developing new ones. For instance, we may collect that written post and photograph you posted on a social network, stating that you love this new bag you just bought and that you recommend it. As part of the Services we provide to the manufacturer of that bag or its representative, we will mark that post as positive toward that bag’s manufacturer reputation on the Internet.
- We do not use your personal data to engage in automated decision making about you.
- When we infer data about you, we do so automatically. The inferences are based on algorithms that analyze 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.
- 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.
D. Sharing Information
- We share data with our affiliates (meaning legal entities controlled by, controlling, or under common control with us) as reasonably necessary to provide the Services.
- 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.
- 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.
- If any third-party processes any of your data, we ensure there are sufficient contractual and operational safeguards protecting your data. We may also share your data with any member of our company group (i.e. our subsidiaries, parent companies, and affiliates).
- In Response to Legal Process: We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others: We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of the Agreement or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and Anonymous Information: We may share aggregate or anonymous information about users with third parties for research or similar purposes.
1) Cookies Introduction
- Cookies are small pieces of information that include a unique reference code that a website places on a computer used to access the Internet that can be used to recognize a return visitor and enable the collection and storage information about your activity on our website. Many cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the website and will last for a longer period.
2) Cookies We Use
We use the following cookies:
- Strictly Necessary Cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. It also includes details of your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, search activities as well as the page, content, software or resources that you access, your IP address, web addresses of the sites you arrive from and go to next and information about your connection, including your device’s browser, operating system, platform type and Internet connection speed.
- Analytical/Performance Cookies: They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality Cookies: These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
3) Third-Party Cookies
- Some of the cookies used on our website are set by us, and some are set by third parties who are delivering services on our behalf.
4) Managing, Blocking and Deleting Cookies
- Some Internet browsers contain controls for managing cookies. Those controls may enable you to delete cookies or to accept or reject certain categories of cookies. You may be able to manage other (non-cookie) tracking technologies through the websites of the firms that provide such technologies or through the operating system of your mobile device. You should consult the “Help” section of your browser or the website of your hardware, software, or operating system providers for further information or opting-out directly with the third-party that operates and controls the cookie. In addition, you can opt-out of third-party personalized advertising cookies.
- Please note that if you reject or delete cookies the related features and functions of our website may be unavailable to you and the performance of our website as experienced by you may be impaired.
F. Security, Accuracy and Retention
Buzzdiggr takes all reasonable and necessary technical and organizational security measures against the unauthorized or unlawful use of your information, and have implemented and will continue to monitor and update appropriate technical and organizational measures to ensure a level of security appropriate to the risk. In assessing the appropriate level of security, Buzzdiggr shall take into account the state of the art, the cost of implementation and nature, scope, context and purposes as well as the risk or varying likelihood and severity of such risk.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Accuracy: We do our best to collect and process data that is accurate and keep it up-to-date. However, since data we collect is publicly available information on the Internet, we advise that you first rectify that data on the original service or site on which you first published it.
If you are a Web User and wish to notify us about inaccurate or outdated data, please contact us on firstname.lastname@example.org. If you are a Customer, please contact your employer or Service administrator, who will be able to update or rectify inaccurate or outdated personal data concerning you.
Retention: We will retain data about you for as long as it is necessary for us to provide the Services, or to comply with our legal obligations. We retain the information necessary to provide our Services during seven years from the date we collected it. In addition, we will delete data concerning you prior to the expiry of this seven years period if you request us to do so, or if you deleted it from the third-party site or service on which you first published it (where such deletion is possible or allowed) and you notified that removal to us. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Security: We have implemented and maintain appropriate administrative, technical and physical controls that are designed to safeguard ay information we process, including industry-standard encryption technology. We also ensure that our providers which may access or process your data under our instructions are bound by contractual requirements to implement and maintain similar controls.
Children’s Privacy Buzzdiggr does not knowingly collect or solicit any information from anyone under the age of 13 nor knowingly allow such persons to use the Public Site. The content of this site is not directed at children under the age of 13. If we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us as set forth below.
G. Your Rights
- You as a
data subject have many possibilities to impact how your personal information is
being processed. Under GDPR you have the following rights:
- Request access to your information we process.
- Request for your information to be deleted or for you to be forgotten (right to erasure)
- Request us to correct or change your information. As a customer you may also do this by logging in to your account.
- Limit, restrict or object to our use of your information.
- Access your information and/or receive it in a machine-readable form.
- The right to request that we refrain from further use of your personal data.
- In respect of the above rights, in order to comply with legal requirements pertaining to privacy, we will verify your identity and may require that you provide additional information before we enforce your rights.
- To exercise any rights listed above, please email us at email@example.com.
- Please note that if you request us to remove your information, we may retain some of the information for specific reasons, such as to resolve disputes, troubleshoot problems, and as required by law. Furthermore, some information is never completely removed from our databases because of technical constraints and the fact that we regularly back up our systems. Therefore, not all of your personal information will ever be completely removed from our databases.
- 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. 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.
- We will retain data about you for as long as it is reasonably necessary for us to provide the Services. We anonymize any data about you as soon as it is reasonably practical, once you no longer use our Services.
- 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.
H. Privacy and Third Parties
- This Privacy Statement only addresses our collection, processing and use (including disclosure) of your personal data. Our affiliates and other third parties may have access to your personal data and use it in other ways in accordance with their own privacy practices. We encourage you to familiarize yourself with the privacy statements provided by any platform you use to publish any data.
- Buzzdiggr Services are delivered to User via application specific sites associated with the Services (app.buzzdiggr.com) and such Buzzdiggr application sites do receive information from third-parties, such as Facebook, Twitter, and Instagram and other social media data sources, and we are required to comply with our contract(s) with them or their public terms and conditions. If you believe we have information from you that you do not want us to have, please contact us as described below and contact the social media provider to whom you initially gave that information. We will delete your content promptly upon your request.
I. Change of Policy, Governing Laws and Jurisdiction
- 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 related to it.