Influencer Privacy Policy

Influencer Privacy Notice

December 2021

This Privacy Notice applies to any influencer who appears in our influencer database, along with publicly available information we collect about you.  This may be provided to us by third parties when using our service.  In this notice we will explain how we use this information and how you can manage your privacy choices and exercise your rights in relation to certain data about you collected and used by INCA.

Who are we?

Inca is an influencer marketing platform which operates globally as part of the GroupM group of companies. In the European Economic Area (EEA) and Switzerland the Inca legal entity responsible for the data that collects is GroupM UK Ltd. 

If you have any questions or comments regarding this Privacy Notice, including any request to exercise your legal rights, please contact us at privacy@groupm.com.

INCA is a data controller responsible for your personal data (as this term or similar term is defined by applicable law) when you visit our Website or provide us with contact information.

INCA uses the services of Captive8 in the provision of its own services, who act as a separate controller.  By creating a user account on INCA’s platform you are also signing up for the Captiv8 Platform whose privacy policy can be found at https://captiv8.io/policy/.

What information we collect

We collect Personal Data (which may include sensitive data) from you when you sign up to use our platform.   This may include but not be limited to your name, electronic mail address, location and postal address, social media name, age, gender, education and IP address.

We may also receive information from third parties. When you connect your user account to a third-party platform, for example Facebook or Instagram, they may pass us information about how you interact with their service.  We will add this information into our influencer database and may pass this to our clients so they may choose you to advertise their products.

The type of information this could include would be your social media handle, any information that you have permitted the third party to share with us, and any information you have made public.  You should be able to review and change these settings in the third-party platform and unlink the accounts.  If you unlink your third-party account, we will remove the information collected about you in connection with that service. If you are an influencer included in our database and you wish to be removed from the database, please contact us at privacy@groupm.com.

Sensitive data

We may also collect sensitive data (also known as special category data). We will not collect this type of information without your consent and we will never use such information in online advertising placement.

The types of sensitive data we may collect from you includes data relating to your:

  • Racial or ethnic origin
  • Political opinion
  • Religious or philosophical beliefs
  • Health
  • Sex life
  • Sexual orientation

What we do with your sensitive data

We will use this information to conduct surveys in order to better understand how diverse the INCA influencer community is, to take actions to support under-represented groups and to make sure our creator selection is inclusive and fair.

Legal basis

We process this data based on your consent, by signing up to our platform and agreeing to the terms of service and consent to the use of your data as described in this policy.  You may withdraw your consent at any time and require us to stop processing your data, to do so please contact privacy@groupm.com.

Transfer of data

We may transfer that personal data to our affiliates and subsidiaries or to other third parties, across borders, and from your country or jurisdiction to other countries or jurisdictions around the world to enable us to use that personal data as described above. Our standard practice is to use European Union model clauses for the transfer of data from the EEA & Switzerland to other non-EEA countries.

In the event that another company acquires us, or all or substantially all of the assets of our business, through a consolidation, merger, asset purchase, or other transaction, we reserve the right to transfer all information (including any information you may have provided through the “contact us” page) that is in our possession or under our control to the acquiring party, and that information may be used by the acquiring party in its business.

How we use the personal data

We process the personal information described above to enable us to provide our services to you, including setting up accounts; customer service and communicating with you about updates or services which you have signed up for.  We may provide our influencer database to our subscribers including the information provided by third parties detailed above.

Who do we share your data with?

We may provide access to information we collect to our vendors and contractors (also known as third parties) who are performing services on our behalf to enable the uses of your information that we have described above. These vendors are not permitted to use this information for any other purpose. Additionally, we must disclose information when we believe we’re legally obliged to, or in order to investigate, prevent, or take action regarding prohibited activities, such as incidents of hacking, misuse, or other prohibited activities.

How long will we keep your data?

We will keep your information for a reasonable period for the purposes set out above. We follow generally accepted online advertising industry standards to ensure that your personal data disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used. These standards include undertaking necessary physical, electronic, and management activities required to protect data integrity, access, and use.

Your rights

You have the right to access, update, change, delete, restrict the use of, or obtain a copy of your Personal Data in an easily readable format. In certain circumstances, you may also request that GroupM transfer your Personal Data to a third party, and the right to object to its use for marketing purposes. If you wish to exercise any of these rights please contact our DPO at DPO@GroupM.com.

Where our processing of your personal data is based on your consent, you also have the right to withdraw this consent at any time by contacting our DPO at DPO@GroupM.com. Please note that your withdrawal of consent will not affect the lawfulness of our processing of your personal data prior to withdrawal of consent.

Information security

Maintaining the privacy of our users’ information is very important to us which means we take care and pay special attention to our security measures to protect this information from data breaches. We follow industry standards to protect against the unauthorized access to, retention of, and disclosure of information. This includes physical, electronic, and management activities to protect information integrity, access, and use.

Changes to this Privacy Notice

Please note that because of the changing nature of privacy laws and regulations, digital technologies, and our business, we may modify this Privacy Notice from time to time. Please review this Privacy Notice periodically to become aware of any changes that may have occurred (we will update the effective date at the top of the page to help you know when changes have been made).

If you have any complaints or wish to contact us: Please use the details set out below depending on where you are located and we will do our best to address any complaints or worries you may have about how we collect and handle your Personal Data.

If for whatever reason you don’t feel like we have adequately addressed your concerns you can contact the Data Protection Authority in your jurisdiction and make a formal complaint.

Europe:

Sea Containers
18 Upper Ground
London
SE1 9ET

DPO@groupm.com

Outside Europe:

GroupM Worldwide LLC

Privacy@groupm.com
GroupM, 498, 7th Avenue, New York, NY, 10018, USA – Attn: Director of Privacy