Creator Privacy Policy
Last updated 4/26/2023
This “Creator Privacy Policy” (or “Privacy Policy”) describes the privacy practices of Tagger Media Inc. and our subsidiaries and affiliates (collectively, “Tagger”, “we”, “us”, or “our”) with respect to our processing of personal information pertaining to individual authors of content, or creators (as explained below), in connection with our creator platform (the “Platform”). We make our Platform and creator personal information available to our business customers to enable them to plan campaigns, understand their audiences, discover and connect with creators, and to track, manage, and report results. Where we refer to “creators” in this Privacy Policy, we are referring to individuals who may have the ability to influence the behavior and opinions of others, including social media influencers (including on Instagram, Facebook, YouTube, TikTok, Twitch, Pinterest and Twitter), journalists, public figures, individuals acting on behalf of brands, individuals acting on behalf of retailers, and similar individuals.
This Creator Privacy Policy provides information about the types of personal information we hold about creators in connection with the Platform and how we collect, use and share it. It also tells you about rights some creators may have and how they can exercise those rights.
We provide important information for creators located in the European Union, European Economic Area, and United Kingdom (collectively, “Europe” or “European”) in the Notice to European Creators section of this policy. We provide important information for creators who are residents of California in the Your California Privacy Rights section of this policy.
Please note that this Creator Privacy Policy does not apply to Tagger’s processing of personal information pertaining to (i) our customers’ personnel; or (ii) individuals who visit or submit information to any of our websites. Our Website Privacy Policy applies to our processing in that regard. This Creator Privacy Policy also does not apply to any personal information in connection with which Tagger acts as a processor or service provider on behalf of our customers or others. For example, once you enter a contract or otherwise engage with one of our customers, the processing of your personal information by our customer is outside of our control and subject to our customer’s privacy policies, practices and any contract or other arrangement you or we may have with the customer. Should you have any questions or concerns concerning the processing of your personal information by one of our customers, please direct your inquiries to that customer.
Table of Contents
- Personal Information We Collect
- How We Use Your Personal Information
- How We Share Your Personal Information
- Use of Third-Party API Services
- Your Choices
- Security Practices
- International Data Transfers
- Children
- Changes to this Creator Privacy Policy
- How to Contact Us
- Your California Privacy Rights
- Notice to European Creators
Personal Information We Collect
We may collect the following types of personal information about you in the following ways:
Information we obtain from third party sources, including social media platforms and publicly available online sources. We collect this data from a variety of third-party sources, including social media platforms (including via social media APIs), third party data collection partners and other publicly available online sources. Examples of the categories of personal information collected in this manner include the following:
- Identification data, such as your first and last name, email address, and the city, state and country in which you reside.
- Professional contact data, such as your business email address, job title and business sector.
- Social media profile information, such as your social media handles, username, profile pictures, interests, number of social media followers and other publicly-available personal information forming part of your social media account profiles.
- Social media content, such as the content of posts you make on social media as well as engagements with that content (e.g., likes, retweets and comments).
- Brand affiliations, such as brands and/or products endorsed or otherwise promoted by you.
Information we obtain from you. Our customers may request or recommend that you authenticate through the Platform or you may otherwise directly contact or engage with us, in which case we may obtain personal information about you directly from you. Such data may include additional (but non-public) information within the categories of data identified in the “Information we obtain from third party sources, including social media platforms and publicly available online sources” section above, including (without limitation) your impressions, Instagram stories, and demographic data. Such data may also include the following categories of personal information:
- Contractual relationship data, such as your rate card and the terms of your engagements.
- Campaign performance data, including data regarding your reach, likes, and engagement with your audiences.
- Application data, such as data submitted in connection with an application to one of our clients to be a brand ambassador or other representative.
- Chat data and other correspondence, such as discussions between you and our customers and information you provide when you contact us with requests, questions, feedback, or otherwise correspond with us.
- Any other data you choose to make available to us.
Customer Data We Collect as a Service Provider/Processor. Our customers may supplement the personal information we make available to them via the Platform with personal information about you that they have procured independently (“Customer-Procured Data”). Our customers input such Customer-Procured Data into our Platform, and we only use Customer-Procured Data to provide our Platform and services to that customer. However, this data is provided in the discretion of our customers and Tagger has no control over the input of such data. Such data may include additional (but non-public) information within the categories of data identified above.
In respect of this Customer-Procured Data, to the extent received solely from our customers and not otherwise, we act as a processor or service provider on behalf of our customers for their respective Customer-Procured Data. Our processing of any such personal information is outside the scope of this Creator Privacy Policy and is subject to our customers’ own privacy policies and practices and any contract or other arrangement you or we may have with such customer.
How We Use Your Personal Information
We may use your personal information for the following purposes and as otherwise described in this Privacy Policy:
To operate the Platform and our business and to serve our customers. We use your personal information to operate the Platform and our business and to provide our services to our customers, including to:
- provide, operate and improve our Platform and our business, including by empowering our customers to learn more about their brand, their customers, and their competitors and to facilitate communications and connections between you and our customers, including to facilitate influencer marketing campaign management;
- establish and maintain your profile(s) on our Platform;
- allow our customers to access, assess and monitor your profiles, including to make determinations as to whether to engage with you, to add their own information about you, and to monitor your profiles and performance within the Platform;
- generate and provide information to you and to our customers regarding campaigns and other social media performance;
- communicate with you about our Platform and services, including by sending announcements, updates, security alerts and support and administrative messages;
- understand your needs and interests, and personalize your experience with the Platform and our communications; and
- provide support for the Platform and our business, including to respond to your requests, questions and feedback, and to otherwise correspond with you.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and the personal information of other individuals. We may use this anonymous, aggregated or de-identified data and share it with our customers and other third parties for our lawful business purposes, including to analyze and improve the Platform and our services and to promote our business.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, court orders and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your, our customers’ or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern our Platform; and
- prevent, identify, investigate and deter security threats and fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
How We Share your Personal Information
To the extent permitted by applicable law and our contractual obligations, we may share your personal information with the following parties or as otherwise described in this Creator Privacy Policy or at the time of collection:
Customers. We disclose your personal information to our customers who access the Platform, as described above. We do not control, and are not responsible for, how our customers use the personal information that we make available to them. Their processing of your personal information is subject to their own privacy policies and practices.
Service providers. We may share your personal information with third party companies and individuals that provide services on our behalf or help us operate the Platform or our services (such as analytics and information technology services).
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. We may share your personal information with any third parties, including law enforcement, government authorities, and private parties, as we believe in good faith to be reasonably necessary or appropriate for the compliance and protection purposes described above.
Business transferees. We may sell, transfer or otherwise share personal information with acquirers and other relevant participants in business transactions (or negotiations of, or due diligence with respect to, such transactions), including a corporate divestiture, merger, consolidation, acquisition, reorganization or sale or transfer of some or all of our assets or equity securities, or in the event of bankruptcy, liquidation, dissolution or similar event.
With your consent or at your direction. We may share your personal information with any third party if you have provided your consent to such sharing or if you have otherwise instructed us to do so.
Use of Third-Party API Services
At Tagger, we utilize various third-party API services such as YouTube, Facebook, Instagram, TikTok, etc., to enhance the functionality of our platform. This privacy policy outlines how we collect, use, and protect user information, including API data, as a result of using these services. By accessing or using our platform, you acknowledge and agree to the terms set forth in this privacy policy.
Notification of Third-Party API Services
Tagger uses YouTube API Services to provide users with video content on our platform. By using our platform, you acknowledge and agree to YouTube’s Terms of Service and Google’s Privacy Policy (http://www.google.com/policies/privacy)
In addition to Tagger’s normal procedure for deleting stored data, users can revoke that Tagger’s access to their data via the Google security settings page at https://security.google.com/settings/security/permissions .
Tagger also uses Meta API Services and TikTok API Services. By using our platform, you acknowledge and agree to the following:
- Facebook’s Terms of Service and Meta’s Privacy Policy (https://www.facebook.com/privacy/policy)
- TikTok’s Terms of Service and TikTok’s Privacy Policy (https://www.tiktok.com/legal/page/us/privacy-policy/en)
User Information Collected
The API Client collects user information and API data when users interact with our platform, including but not limited to:
- User’s name, email, and other contact information
- Social media profile information
- User’s IP address, browser type, and device information
- Location data
- User’s interaction with our platform and third-party API services
Use of User Information
The API Client uses the collected user information for the following purposes:
- To enhance user experience by providing personalized content and advertising
- To optimize our platform and improve our services
- To provide customer support and respond to user inquiries
- To comply with legal obligations
Sharing of User Information
The API Client may share user information with third-party service providers who assist us in providing our services. We may also share user information with government authorities, legal counsel, or law enforcement agencies if required by law.
Third-Party Content and Advertising
The API Client allows third-party advertisers to serve content, including advertisements, on our platform. These advertisers may collect user information, and we encourage users to review their respective privacy policies.
Device Information Collection
The API Client may collect device information, including placing, accessing, or recognizing cookies or similar technologies on users’ devices or browsers, to improve our platform’s functionality and user experience.
We take user privacy seriously and strive to protect user information from unauthorized access, use, or disclosure. By using our platform, you acknowledge and agree to the terms set forth in this privacy policy. If you have any questions or concerns regarding our privacy practices, please email us at [email protected].
Your Choices
All creators, regardless of where they live, have the following rights:
- Access or Update Your Information. Note that most of the personal information we have about you comes from third-party platforms, websites and other online forums where you have provided that information and made it publicly available. If such information is inaccurate, we encourage you to correct it on the original platform on which you published it. If you would like to see or amend your profiles within our Platform, please email us at [email protected].
- Opt-out of the Platform. If you would like us to remove your profile from the Platform altogether, please email us at [email protected].
If you are a resident of a jurisdiction that affords you additional rights by law with respect to your personal information, you may also have some or all of the following rights:
- Information
- Access
- Correction / Rectification
- Deletion / Erasure / To be forgotten
- Transfer
- Restriction of processing
- Objection to processing
- Non-discrimination
- Opt-out of certain sharing
- Opt-in to certain sharing (if we know that you are under 16 years of age)
Certain of these rights, as applicable, are described in the Your California Privacy Rights and Notice to European Creators sections, below. You can exercise any of the above rights by emailing [email protected] or as otherwise provided in the Your California Privacy Rights and Notice to European Creators sections, below, to the extent applicable.
Security practices
The security of your personal information is important to us. We employ a number of technical, organizational, physical and contractual safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfers
We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.
Creators in Europe should read the important information provided below about transfers of personal information outside of Europe.
Children
We do not knowingly collect personal information from children. We define “children” as follows: anyone under 16 years old, or the age needed to consent to the processing of personal information in your country of residence.
If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it. If you are a parent or guardian of a child and believe we have collected the personal information of your child without your consent, please contact us to have this information deleted.
Changes to this Creator Privacy Policy
We reserve the right to modify this Creator Privacy Policy at any time. If we make material changes to this Creator Privacy Policy, we will notify you by updating the date of the policy and posting it on our website at https://www.taggermedia.com/. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if we have your contact information). Any modifications to this Creator Privacy Policy will be effective upon our posting or as otherwise indicated at the time of posting. In all cases, your use of the Platform after the effective date of any modified Creator Privacy Policy indicates your acceptance of the modified terms of the policy.
How to Contact Us
Please direct any questions or comments about this Creator Privacy Policy or privacy practices to [email protected]. You may also write to us via postal mail at: 2001 Wilshire Blvd. Suite 301Santa Monica, CA 90403
Your California Privacy Rights
This section describes how we collect, use, and share Personal Information of users that are California residents in connection with our services in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) / The California Privacy Rights Act (“CPRA”) and their rights with respect to that Personal Information. For purposes of this section, the term “Personal Information” has the meaning given in the CCPA/CPRA but does not include information exempted from the scope of the CCPA/CPRA.
Your California privacy rights. California residents have the rights listed below under the CCPA/CPRA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with which we share Personal Information.
- The categories of Personal Information that we sold or disclosed for a business purpose.
- The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.
- Access / Know. You can request a copy of the Personal Information that we have collected about you.
- Deletion. You can ask us to delete the Personal Information that we have collected from you, unless the CCPA/CPRA recognizes an exception.
- Opt-out. You can opt-out of certain sharing of your Personal Information, specifically for behavioral advertisement and “sale” under the CCPA/CPRA’s broad definition of that term. We do not knowingly share the Personal Information of consumers under 16 years of age.
- Right to correction. You can request to have your Personal Information and Sensitive personal information corrected if you find them to be inaccurate.
- Right to limit use of sensitive personal information. You can restrict use of this separate category of personal information, particularly around third-party sharing.
- Nondiscrimination. You are entitled to exercise the rights described above free from discriminatory treatment as prohibited by the CCPA/CPRA. Specifically, if you exercise your rights under the CCPA/CPRA, we will not deny you goods or services, charge you different prices or rates, provide you with a different level of service or quality of goods or services, or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services, except as permitted by the CCPA/CPRA.
Exercising your right to information, access and deletion. You may submit requests to exercise your right to information, access or deletion by calling us toll free at 1-(888) 201-4517, or via email to [email protected].
Exercising your right to opt-out of certain sharing of your Personal Information. We share Personal Information with our customers as described in this User Privacy Policy. Because the CCPA/CPRA defines the term “sale” very broadly, such sharing could be considered a “sale” under the CCPA/CPRA. You can request to opt-out of behavioral advertisement and this sharing of your Personal Information here: Do Not Sell Or Share My Personal Information. For the avoidance of doubt, this right to opt-out of certain sharing of your Personal Information does not apply in (among other circumstances) any situations where we are processing your Personal Information on behalf of our customers rather than for our own purposes. Any requests with respect to the processing of Personal Information in the possession or control of our customers should be directed to the relevant customer.
Exercising your right to limit the use of your Personal Information. You can request to limit the use of your Personal Information here: Limit The Use Of My Sensitive Personal Information. For the avoidance of doubt, this right to limit the use of your of your Personal Information does not apply in (among other circumstances) any situations where we are processing your Personal Information on behalf of our customers rather than for our own purposes. Any requests with respect to the processing of Personal Information in the possession or control of our customers should be directed to the relevant customer.
Verification of your Requests; Authorized Agents. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. We will need to verify your identity to process your information, access and deletion requests and reserve the right to confirm your California residency. To verify your identity, you will need to provide us with the following information about you: Full name, e-mail and links to social media handles. Depending on the nature and scope of your request, we may also need to request additional information from you, which we will use only for the purposes of verification. Upon receipt of your request, we will notify you if we need additional information from you to verify your request. We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide the information we request to verify your identity and provide us with confirmation that you have given the authorized agent permission to submit the request.
Personal information that we collect, use and disclose. The chart below summarizes the Personal Information we collect by reference to the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140) and describes our practices currently and during the 12 months preceding the effective date of this Creator Privacy Policy. The terms in the chart refer to the categories of information, sources, purposes and third parties described above in this Creator Privacy Policy in more detail. Information you voluntarily provide to us, such as in the content of your posts, content from chats you engage in with our customers or others, or data input into free-form webforms, may contain other categories of personal information not described below. In addition to the disclosures described in the chart below, we disclose Personal Information as described in the How we share your personal information section, above.
| Statutory category / Personal information we collect in this category | Source of PI | Business/commercial purpose for collection | Categories of third parties to whom we “disclose” PI for a business purpose | Categories of third parties to whom we “sell” PI |
|---|---|---|---|---|
Identifiers
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California Customer Records (as defined in California Civil Code §1798.80)
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| Inferences
May be derived from:
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N/A |
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Sensory Information
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Physical Description
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Professional or Employment Information
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Your California privacy rights. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to [email protected]. In your request, you must include the statement “Shine the Light Request,” and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
Notice to European Creators
The information provided in this “Notice to European Creators” section applies only to individuals in Europe.
Personal information. References to “personal information” in this Creator Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller and representatives. Tagger Media Inc. is the controller of your personal information covered by this Creator Privacy Policy for purposes of European data protection legislation. Our representative in the European Union is European Data Protection Office (EDPO). You can contact EDPO regarding matters pertaining to the GDPR:
- by using EDPO’s online request form: https://edpo.com/gdpr-data-request
- by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium
Our representative in the UK is EDPO UK Ltd. You can contact EDPO UK regarding matters pertaining to the UK GDPR:
- by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request
- by writing to EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom
Data Protection Officer (“DPO”). We have appointed a DPO. Our DPO can be contacted at [email protected].
Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Creator Privacy Policy are described in the table below.
| Purpose | Category(ies) of personal information involved | Why do we do this | Our legal basis for this use of data |
|---|---|---|---|
| To operate the Platform and our business and to serve our customers. |
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We have a legitimate interest in providing and improving the Platform. We consider and balance any potential negative impact on you and your rights before we process your information. We do not use your personal information for these activities where our interests are overridden by the impact on you. |
| To create anonymous, aggregated or de-identified data. |
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We have a legitimate interest in analyzing how the Platform is used. We consider and balance any potential negative impact on you and your rights before we process your information. We do not use your personal information for these activities where our interests are overridden by the impact on you. |
| Compliance and protection. |
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We have a legitimate interest in ensuring the ongoing security and proper operation of our Platform and associated systems. |
Use for new purposes
We may use your personal information for reasons not described in this Creator Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Sensitive personal information
We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Platform, or otherwise to us. If you provide us with any sensitive personal information when you use the Platform, you must consent to our processing and use of such sensitive personal information in accordance with this Creator Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through the Platform.
Profiling and automated decision making
Profiling is the automated processing of personal information to evaluate certain things about an individual. Automated decision-making means decisions made solely by automated means without any human involvement. We do not currently use profiling or automated decision-making mechanisms when processing your personal information.
Retention
We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. When we no longer require the personal information we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.
Your rights
European data protection laws give you certain rights regarding your personal information. If you are located within Europe, you may ask us to take the following actions in relation to your personal information that we hold:
- Inform. Right to know about processing your personal information.
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct / Rectification. Update or correct inaccuracies in your personal information.
- Delete / Erasure / To be forgotten. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
- Data portability. Obtain and reuse their personal information for their own purposes across different services.
You may submit these requests by email to [email protected]. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction.
You will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Cross-Border Data Transfer
If we transfer your personal information out of Europe to a country not deemed by the European Commission and/or UK Government, as applicable, to provide an adequate level of personal information protection, the transfer will be performed subject to appropriate safeguards and otherwise in accordance with European data protection laws. You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe.