Introduction
Symmetry collects and collates data of influencers globally. This includes the data of social media platforms like TikTok, YouTube and Instagram users with a sizeable number of followers (“Influencer” or “Influencers”). Our platform processes this data and provides information about Influencers and their online performance to Platform users, which includes representatives of companies and brands (“User” or “Users”). This helps our Users engage Influencers based on their business objectives.
Data collection and processing
Registration information
The legal basis under EU law for collecting and processing User’s Registration Information is our legitimate interest in operating and managing User access to the Platform.
To access and use the Platform, our Users have to provide basic contact information as part of the registration process. We collect and process the following:
- Name
- Email address
- Password
User data consumption data
The legal basis under EU law for collecting and processing User’s Consumption Data is our legitimate interest in determining business costs and profitability of the User.
To gauge data consumption by our Users, we collect and process:
- Information about each User’s data consumption on the Platform
- Metrics about the data that each User consumed on the Platform
Influencer information
The legal basis under EU law for collecting and processing Influencer Information is our legitimate interest in providing sophisticated influencer search capabilities that facilitate the needs of Users to find social media Influencers suitable for their needs.
We collect and process information about Influencers, including aggregated statistics about their social media activities and performance.
We collect and process the publicly available information about Influencers around the world, such as their name, social media nickname (if any), gender, location (country/state), social media profile image, personal characteristics, social media content posted by the Influencer (including hashtags and brands advertised by the Influencer), and social media performance data (such as number of followers, engagement rate, likes over time, assessed follower credibility and follower demographics). This information is generated by the Influencer’s online activities on Instagram, TikTok and YouTube.
Data sharing
Except for the events listed below, we will not share User’s Information with third parties without explicit and informed consent of the User:
Sharing with service providers
We will process Personal Information with assistance of our service providers in internal operations of the Service. These service providers, such as Google Cloud, are authorised to use Personal Information as necessary to provide these services to us and not for any other purpose.
Sharing with users
We will share Influencer Information with our Users to allow them to consider collaborating with different Influencers.
Sharing with competent authorities in case of abuse of rights
The legal basis under EU law for processing personal information for the purpose of handling instances of abusive use of the Service is our legitimate interests in defending and enforcing against violations and breaches that are harmful to our business.
If a User has abused their rights to use the Service, or has violated any applicable law, we will share Registration Information with competent authorities and with third parties (such as legal counsel and advisors), for the purpose of handling the violation or breach.
Sharing with competent authorities if legally required
We will share any information we are required to by a judicial, governmental or regulatory authority.
Sharing with third parties
The legal basis under EU law for us sharing personal information in the event of a change in our corporate structure is our legitimate interests in our business continuity.
If operation of our Service is managed through a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share information only as required to enable the structural change in the operation of the business.
Security and data retention
Security measures
We implement strict measures to reduce the risks of damage, loss of information and unauthorised access or use of information, such as secured HTTP. However, these measures do not provide absolute information security. Hence, security of personal information is not guaranteed.
Retention of information
Influencer Information is processed only instantaneously when data is presented to our Users through the Platform and is not retained by Symmetry. We will retain Registration Information for as long as the User is engaged under a service agreement with us. Thereafter, we will still retain it as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.
Additional information for individuals in the EU/EEA
Symmetry is the data controller of the personal information processed by the Service.
The following is the data controller for the purposes of the personal data we collect via the Platform:
Symmetry Group Limited
Email: [email protected]
Cross-border transfers
Information we collect will generally be processed within the EU/EEA and in UAE which is recognised by the European Commission as having adequate protection for personal data.
If we transfer personal information from the EU/EEA to other jurisdictions outside the EU/EEA, we will do so using adequate safeguards determined by the EU Commission, such as EU Standard Contractual Clauses. However, this does not apply to Influencer Information that we make available to Users that are located in jurisdictions outside the EU/EEA. In that case, the Influencer Information is based on content that the Influencer has already manifestly made public to a global audience.
Your rights
You have certain rights to access, update or delete your information, obtain a copy of your information, and object or restrict certain data processing activities.
If you are in the EU/EEA, you have the following rights under the GDPR:
- Right to Access your personal data that we process and receive a copy of it.
- Right to Rectify inaccurate personal data we have concerning you and to have incomplete personal data completed.
- Right to Data Portability, that is, to receive the personal data that you provided to us, in a structured, commonly used and machine-readable format. You have the right to transmit this data to another service provider. Where technically feasible, you have the right that your personal data be transmitted directly from us to the service provider you designate.
- Right to Object, based on your particular situation, to using your personal data on the basis of our legitimate interest. However, we may override the objection if we demonstrate compelling legitimate grounds, or for the establishment, exercise or defence of legal claims.
- Right to Restrict the processing of your personal data (except for storing it) if you contest the accuracy of your personal data, for a period enabling us to verify its accuracy; if you believe that the processing is unlawful and you oppose the erasure of the personal data and request instead to restrict its use; if we no longer need the personal data for the purposes outlined in this Policy, but you require them to establish, exercise or defend legal claims; or if you object to processing, pending verification whether our legitimate grounds for processing override yours.
- Right to be Forgotten. Under certain circumstances, such as when you object to us processing your data and we have no compelling legitimate grounds to override your objection, you have the right to ask us to erase your personal data. However, we may still process your personal data if it is necessary to comply with a legal obligation that we are subject to under laws in EU Member States or for the establishment, exercise or defence of legal claims.
If you wish to exercise any of these rights, contact us at [email protected].
We reserve the right to ask for reasonable evidence to verify your identity before we provide you with information. Where we are not able to provide you with information that you have asked for, we will explain the reason for this.
Subject to applicable law, you have the right to lodge a complaint with your local data protection authority. If you are in the EU, then according to Article 77 of the GDPR, you can lodge a complaint to the supervisory authority, in particular in the Member State of your residence, place of work or place of alleged infringement of the GDPR.