Privacy Policy

6.1. Background

This privacy notice sets out the basis on which any Personal Data we collect from or about you, or that you provide to us, including through www.clickanalytic.com and any sub-domain thereof (“ our website”), will be processed by us in accordance with applicable Data Protection Laws, provided that this privacy notice does not apply to information processed under Click Analytic’s Influencer Privacy Notice in Section 16 . Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.

Our website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

6.1. Google User Data

In our commitment to transparency and protecting user privacy, this section outlines our practices regarding the access, use, storage, and sharing of Google user data.

6.11.1 Access and Use of Google User Data Our website allows users to create an account using Google login for ease of access and to enhance user experience. When you choose to create an account using your Google login, we access and store specific pieces of your Google user data, specifically your email address, name, given name, and family name. This access only occurs with your explicit consent during the account creation process.

6.11.2 Storage of Google User Data

The Google user data we access is stored securely within our systems. We employ industry-standard security measures to ensure the protection and integrity of the data we collect and store. This data is used solely to facilitate the account creation process and to personalize your experience on our website.

6.11.3 Non-Disclosure of Google User Data We firmly adhere to the principle of not sharing any Google user data with third parties. Your privacy is paramount to us, and as such, the access and use of your Google user data are confined strictly to the purposes mentioned above. We do not sell, trade, or otherwise transfer your Google user data to outside parties.

6.11.4 Consent and Control Your use of Google login and provision of consent at the time of account creation represents your acknowledgment and agreement to our access, use, and storage of the specified Google user data. You retain the right to revoke consent and request deletion of your data from our systems at any time, in accordance with our data protection and privacy policies outlined in previous sections.

This policy is designed to ensure that you are fully informed about our data practices and your privacy rights when using our services. For any questions or concerns regarding this section or any other aspect of our privacy practices, please contact us directly.

6.2. Platform Users

If an organization with which you are associated (an “Organization”) signs up to use our Platform, we may receive Personal Data about you in connection with our provision of the Platform to your Organization. To the extent we process that Personal Data solely in order to provide the Platform to your Organization, under the GDPR, to the extent applicable, we will act as a processor (as defined in the GDPR) on behalf of your Organization in respect of that Personal Data; this privacy notice will not apply to the processing of that Personal Data and your Organization will act as a controller (as defined in the GDPR) in respect of that Personal Data and is responsible for obtaining all necessary consents and providing you with all requisite information as required by Applicable Law. To the extent we process your Personal Data for any other lawful business purpose of ours, under the GDPR, to the extent applicable, we will act as a controller of such Personal Data and this privacy notice will apply to the processing of such Personal Data. For clarification but not limitation, information we process for our legitimate business purposes, such as product development, sales and marketing, is not processed solely on behalf of your Organization. Notwithstanding the foregoing, and for the avoidance of doubt, with respect to transfer data processed by Click Analytic solely on behalf of a third-party controller (“Processed Transfer Data”), the provisions of this privacy notice specific to transfer data continue to apply in accordance with the General Data Protection Regulation EU 2016/679 (GDPR) but may be limited to working with the respective controller, given our role as a processor.

6.3. Legal Basis For Processing

We will only use your Personal Data to the extent that the law allows us to do so. Most commonly, we will use your Personal Data in the following circumstances:

where processing is necessary for the performance of a contract to which you are subject or in order to take steps at your request prior to entering into a contract;
where it is necessary for the purposes of our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests are to provide our website to you as a part of the service provided to your organization;
where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal; and/or
where we need to comply with a legal or regulatory obligation.

6.4. Definitions

In this privacy notice the following words and phrases shall have the following meanings:

“ Applicable Law” means (a) any law, statute, regulation, bylaw or subordinate legislation in force from time to time to which we are subject; (b) the common law and laws of equity as applicable to us from time to time; (c) any court order, judgment or decree which is binding on us; (d) any industry code, policy or standard which is applicable to us; (e) any applicable direction, policy, rule or order that is binding on us and that is made or given by any regulatory body having jurisdiction over us;

“ Data Protection Laws” means any Applicable Law relating to the processing, privacy, and use of Personal Data, including but not restricted to (a) the General Data Protection Regulation (EU) 2016/679 (“ GDPR“) and (b) any judicial or administrative interpretation of any such Applicable Law, and any guidance, guidelines, codes of practice, approved codes of conduct or approved certification mechanisms issued by any relevant regulatory or supervisory authority;

“ Data” means information which is stored electronically, on a computer, or in certain paper-based filing systems;

“ Personal Data” means any information relating to an identified or identifiable natural person (a “ Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and where referred to in this notice includes special categories of Personal Data; and

“ Platform” **** means our Influencer Tool including its features.

6.5. Information You Give Us

This is information about you that you give us through the use of the website and/or Platform (e.g. when you correspond with us by telephone, e-mail or otherwise, including when you report a problem with our website). The information you give us may include your name, address, e-mail address, phone number and social media username (or ‘handle’). ****

When you register your interest, download a free report, call us, or complete an online query in any way on this website we will retain this information in order to respond to your query and communicate with you. You can update this information at any time or opt out of receiving any further marketing communications. If you become a customer of Click Analytic we will need to continue to contact you for development, progress or performance related matters.

6.6. Information We Collect About You.

With regard to each of your visits to our website and/or Platform we will automatically collect, or will collect through a third party acting on our behalf, the following information:

6.6.1 technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and your platform.
6.6.2 information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and any phone number used to call our customer service number.

We are working closely with, and receive Personal Data from third parties (such as business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers and credit reference agencies). For further details about these other sources please contact us using the details provided below.

6.7. Disclosure Of Your Information

You agree that we have the right to share your Personal Data with selected third parties including business partners, suppliers and sub-contractors in connection with our business, including without limitation to allow us to provide access to our website. Without limitation of the foregoing, we may share your Personal Data with professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

We will maintain certain data that you transmit to the Site for the purpose of managing the performance of the Site, as well as data relating to your use of the Site. Although we perform regular routine backups of data, you are solely responsible for all data that you transmit or that relates to any activity you have undertaken using the Site. You agree that we shall have no liability to you for any loss or corruption of any such data, and you hereby waive any right of action against us arising from any such loss or corruption of such data.

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

6.8. Information For Data Controllers

Important information for data controllers: you acknowledge that when processing personal data of individuals, you may become a data controller, and you must comply with GDPR.

If you are an individual and process personal data in the course of a purely personal or “household” activity, you may be exempt from the application of GDPR. If you are unsure whether this exemption applies, please, obtain legal advice.

If you are a legal person, you may become a data controller for the purposes of GDPR when you process personal data about natural persons. This is the case whether you obtain personal data through Us or through any other third party (for instance, if you manually compile your own database from Instagram). If GDPR applies to you, you hereby confirm that you and Us (the “Parties”): 1) each independently determines the purposes and means of the processing of personal data and acts as an independent controller; 2) the Parties do not jointly determine the purposes and means of the processing and do not act as joint controllers; 3) neither of the Parties processes personal data on behalf of the other Party and does not act as a processor; 4) each of the Parties shall independently take all necessary measures to comply with applicable data protection laws.

6.9. Collect Of Information

We collect Device Information using the following technologies:

“Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
“Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
“Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.
“SalesIQ” track amount of time spent by a user in the site and pages visited.

6.10. Links to Third Party Sites

This website may offer links to other third party websites. You should be aware that operators of linked websites may also collect your personal information (including information generated through the use of cookies) when you link to their websites. Click Analytic is not responsible for how such third parties collect, use or disclose your personal information, so it is important to familiarize yourself with their privacy policies before providing them with your personal information.

As of the date this policy went into effect, Click Analytic uses third party services such as Google. To learn more about the privacy policy of Google, please go here: https://policies.google.com/ As of the date this policy went into effect, Click Analytic uses third party services such as Facebook. To learn more about the privacy policy of Facebook, please go here: https://www.facebook.com/policy.php

As of the date this policy went into effect, Click Analytic uses third party services such as Zoho Sales IQ. To learn more about the privacy policy of Zoho Sales IQ, please go here: https://www.zoho.com/privacy.html

Influencer Privacy Notice

16. Influencer Privacy Notice

16.1. Background

We collate publicly available information about influential individuals (“ you” or “ your” in this privacy notice if we have obtained information about you). This pooled information, or ‘personal data’, is made available on Click Analytic’s Influencer Tool (the “ platform”) for its users to discover, evaluate and manage their engagement with influential people.

Click Analytic respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when it is used on our market-research database, your privacy rights and how the law protects you.

In essence, We only process information that are publicly available. We ensure we have a legal basis for processing your personal data. We treat it in accordance with relevant legislation and respect Your Rights (see section below).

16.2. The Data We Process And How It Is Obtained

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collate, use, and transfer different kinds of publicly available personal data about you which is obtained directly or indirectly via secondary sources such as social media networks and other Internet sources. This personal data may include the following:

1. your name, age and affiliated organization (if applicable);

2. your social media handle;

3. messages which you have shared publicly on social media; and

4. any other information you manifestly make public.

We may combine the above referenced personal data with information we receive from third parties relating to your social media audience. Such combined personal data, while anonymous with respect to your social media followers, is identifiable of you.

We analyze a vast amount of information in order to provide Customers with statistics. In relation to Influencer audience (the “Audience”), this includes, in particular: gender, age group and ethnicity. While these items may represent a somewhat sensitive issue, We have undertaken a review of our legitimate interests and the risks to the rights and freedoms of individuals. We concluded that our processing for statistical purposes is in line with legislation and does not affect the rights and freedoms of individuals.

In order to legally process data on the ethnic origin of the Audience, We require relevant legal basis. One of the bases is processing for statistical purposes (while safeguarding fundamental rights and interests of the Audience). Such processing does not have discriminatory effects on natural persons involved nor results in measures having such effect. Finally, there is no automated decision-making and profiling based on ethnic origin of the Audience.

16.3. How We Use Your Personal Data

We will only use your personal data to the extent that the law allows us to do so. We will use your personal data where it is necessary to pursue our legitimate interests and your interests and fundamental rights do not override those interests.

As part of these legitimate interests, the platform may benefit you as an influencer by facilitating your connection with companies (and their brands) to enable those companies to expand your presence in the influencer marketing ecosystem and to enhance your subject-matter expertise. Influencers often reach out to us and request to be included on the platform. The platform also affords a mutual benefit to both brands and influencers by empowering brands and influencers to build meaningful relationships for their shared gain. Additionally, the platform affords a greater public benefit by facilitating the growth and development of, and insight into, the wider influencer marketing ecosystem.

We process your personal data for the purposes of allowing users of our platform and associated market-research database to discover, evaluate and manage their engagement with influential people. In addition to allowing users to conduct market research, as noted above, we will use your personal data to connect you through our platform with companies (and their brands).

In particular, we would like you to be aware that the Click Analytic platform uses algorithms to construct profiles about individual influencers, and therefore we may use the personal data described in the section above so that an evaluation can be made about your behavior, preferences and interests (among other things). Under the GDPR (to the extent applicable), this usage may be considered profiling. In particular, these algorithms assess your reach (e.g. size of your social media audience), relevance (e.g. the contextual affinity of your content to Click Analytic’s customers’ areas of interest) and authenticity (e.g. audience engagement with your social media content) in various areas. The GDPR defines “profiling” as “any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements”. To the extent Click Analytic’s processing constitutes profiling under the GDPR (to the extent applicable), you have the right to specifically object to the processing of your personal data for the purpose of profiling. To learn more, please reach out to contact@clickanalytic.com.

16.4. Disclosures Of Your Personal Data

We may share your personal data with the persons and in the contexts set out below:

1. users of our platform and associated market-research database;

2. service providers who provide us with IT, system administration, and other services;

3. professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;

4. persons to whom we are under a duty to disclose or share your personal data in order to comply with any legal obligation, including without limitation public authorities who may need to see your personal data to meet national security or law enforcement requirements, and regulators and other authorities who require reporting of processing activities in certain circumstances;

5. third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice;

6. third parties with whom we may be required to communicate if we discontinue our business, or file a petition or have filed against us a petition in bankruptcy, reorganization or similar insolvency petition, application or proceeding;

7. our Corporate Affiliates; for the purposes of this privacy notice: “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with Click Analytic, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise; and

8. third parties with whom we may be required to communicate in order to enforce or apply the terms of our agreements; or to protect the rights, property, or safety of Click Analytic, our customers, or others.

We use reasonable efforts to ensure that all third parties respect the security of your personal data and to treat it in accordance with the law. Apart from users of our market-research database, who will separately be required to adhere to privacy laws when dealing with your personal data, we do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our documented instructions.

16.5. Data Security

We have put in place appropriate security measures intended to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Processors of your personal data acting on our documented instructions will only process your personal data in accordance with our instructions and are subject to a duty of confidentiality.

16.5. Data Retention

We will only retain your personal data for as long as necessary to fulfil the purposes for which it was obtained. 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

16.6. Your Legal Rights

Under certain circumstances, you may have certain rights under data protection laws in relation to your personal data, including to:

Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of any new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. _In particular, to the extent Click Analytic’s processing constitutes profiling under the GDPR, you have the right to specifically object to the processing of your personal data for the purpose of profiling._ In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

You generally will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you wish to exercise any of the rights set out above, please contact us at contact@clickanalytic.com. Please note that Click Analytic reserves the right to refuse any request to exercise such rights to the extent permitted by applicable law.

#### 16.7. Opting Out

You can ask us or third parties to stop processing your personal data. To do this email us at contact@clickanalytic.com