If you’d like to access, amend or delete any information, please contact firstname.lastname@example.org. If at any time, you are concerned or have questions about how we might be handling your data, please contact our Data Protection Officer at Aphaia Ltd, Eagle House, 163 City Road, London, EC1V 1NR, or via email (email@example.com), or telephone (02032904231).
- Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.
- We will collect and use personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
- We will collect, store, use and disclose Personal Data in accordance with all applicable laws relating to the protection of Personal Data, including the EU Data Protection Directive 95/46/EC, the EU General Data Protection Regulation 2016/679 and, the EU ePrivacy Directive 2002/58/EC as amended by Directive 2009/136/EC, as amended or superseded from time to time, and any national implementing legislation (“Data Protection Laws”).
- We will only retain personal information as long as necessary for the fulfillment of those purposes.
- We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.
- We will delete the data of any users (including influencers) that we have unknowingly collected if we are informed that they are under the age of 13.
- Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.
- We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
- We will make readily available to customers information about our policies and practices relating to the management of personal information.
Personal data we may process about you
“Personal Data” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, 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.
We may obtain and use the following Personal Data about you and anyone you chose to invite to collaborate with on our platform.
- Any correspondence we have with you and other users you invite to collaborate with on Peg;
- Any correspondence you have over the platform with other users on Peg;
- Data you provide when you fill out forms on Peg, including but not limited to data you provide when you register to become a user (which may include name, email, website, phone number and job title);
- Data and information you submit or upload to Peg;
- Details of financial transactions made by you through Peg; and
- Details of your visits to Peg, which includes without limitation, location and traffic data, resources you access and other communication data. Influencer profile viewing statistics may be shared with influencers or their talent representation from time to time.
- Campaign-related user tracking information based on UTM parameters where we provide the link from an influencer to our customer. Such tracking information may be jointly controlled with our customers and influencers.
We additionally collect the following data from these specific user groups on Peg.
- User and channel statistics that are publicly available from YouTube, Facebook, Twitter and Instagram APIs and website, including but not limited to username, name, number of and growth of subscribers / followers, location, talent representation, email, channel description and keywords, individual video data and video commenters’ names and sentiment of comments;
- User and channel statistics that are available from YouTube only upon authorisation from the influencer or their talent manager / multi-channel network (MCN), including but not limited to audience demographics and video-specific data like watch time and click through rates;
- Other publicly available information including press mentions, brands collaborated with and Wikipedia descriptions;
- Information on influencers is shared with other users of the Peg platform.
- YouTube video commenters
- Name associated with the YouTube account of the commenter
- Paying customers
- Payment method details (card or bank transfer).
- Peg employees
- Data required to comply with government regulations and requirements, including but not limited to legal name, address, passport ID, right to work data, P45 forms, pension scheme participation data and attendance logging;
- Data required to fulfil our contract with employees, including but not limited to PAYE and bank details;
- Data required for participation in Peg’s share options scheme.
We may collect information regarding your login and browsing activity through the use of a cookie file. This cookie file is stored on the hard drive of your computer, and contains information that is transferred to your hard drive. We use this data to help us improve the experience of users on Peg.
The collection of this data allows us to:
- Identify you upon your return to our website; and/or
- Identify the last project you were working on and the relevant search criteria.
We use the following cookies:
- Functionality cookies: used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences.
- Analytical/performance cookies: allow us to recognise 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.
- Targeting cookies: records your visits to our website, the pages you have visited and the actions you have taken. We will use this information to make our website more relevant to your interests. We may also share this information with third parties for this purpose.
Our grounds for data processing
Peg processes data based on the following:
- Contract: where this is necessary to enter into and fulfil contracts with influencers, MCNs, talent managers / agents and customers, where these are individuals, or employment / consultancy and related contracts;
- Consent: where it is necessary to access influencers’ accounts via social media platform APIs (including YouTube, Facebook, Instagram, Twitter and Twitch);
- Legitimate interest: to list and assess influencers and brands from the open internet in order to offer such listings to Peg customers for possible influencer campaigns. This may include analysing publicly available (open) commenters’ data in order to assess influencers’ interactions with the audience, and browsing non-influencer profiles in search for influencers;
- Legitimate interest: Peg monitors website users’ analytics for fraud and dishonest behaviour prevention, safety and security, error detection and rectification, keeping track of transactions, pursuing and defending against claims, in addition to improving the service and helping assess the influencers on Peg based on user interactions.
Where we store your Personal Data
The Personal Data we obtain from you may be moved to and stored at a destination within the European Economic Area ("EEA"). Staff members operating within the EEA who work for or on behalf of us may process this information. Such staff members may, among other things, be involved in the processing of payment details, the provision of support services and the delivery of your request(s) for us to provide services to you.
Without limiting the foregoing, Personal Data we obtain from you may be processed by our service providers based in countries outside of the EEA for the purposes of providing services to you. Such exports will be based on adequacy decisions, notably on the EU-US Privacy Shield for US transfers.
How long we keep your Personal Data
Peg will retain Personal Data with the following limits:
- Registered users: for the duration of your registration with Peg, subject to you closing your account or requesting erasure of your data, except for the data that may continue to be processed based on our legitimate interest. the services we provide and in accordance with the registered user’s instructions or for such periods as may be required by law. For any analytics or tracking data, Peg may choose to anonymise the data if deletion is not feasible. If not specifically requested, Peg may retain email addresses for direct marketing purposes, subject to provision of opt-out under ePrivacy Regulations. Peg may also retain any data that is required for proof of transactions.
- Non-registered users: IP addresses, browsing information and UTM parameters enabling user identification for campaign purposes as long as it is necessary and reasonable for campaign and general analytics purposes.
- Influencers: indefinitely unless deletion is requested by the influencer or their talent manager / MCN (in accordance with any agreement we will have signed into).
- You have the right to obtain confirmation under Article 15 of the EU General Data Protection Regulation (GDPR) that your data is being processed and what the circumstances of the processing are, in addition to the data itself, without adversely affecting rights and freedoms of third-party individuals.
- You have the right to request us to refrain from processing your data for the purposes of marketing. To exercise such right, you may reply to any information we send you, detailing your request that we refrain from sending any marketing correspondence, or you can exercise this same right by contacting us electronically via email at firstname.lastname@example.org. If at any time we intend to use your data for such marketing purposes however, it is standard practice for us to make you aware in advance of collecting such data. Registered users will automatically receive updates about the platform unless they object via email as described above.
- You have at all times the right to access / amend / delete any Personal Data we hold about you or to exercise your right of data portability or to object to, or restrict, the purposes for which your Personal Data is processed on certain grounds. You may exercise this right by making a request in accordance with Data Protection Laws, by emailing email@example.com. Data you request will be provided in a structured, commonly used and machine-readable format that can be transferred to other providers.
- Influencers and other data subjects we have profiled on Peg retain the right to object at any time to the processing of personal data.
- Based on the name associated with a YouTube channel, Peg’s algorithms predicts the likely gender and age of a sample of commenters on certain YouTube videos uploaded by influencers. If you wish to find out whether we have profiled you in such a way or wish to object to such profiling of you in the future, please email us at firstname.lastname@example.org.
- You may opt-out of direct marketing communications by emailing us at email@example.com or by following the opt-out link in each email.
- You may also lodge a complaint with the UK data protection regulator, the Information Commissioner (ico.org.uk) should you be dissatisfied with the way that we handle your Personal Data.
If at any time we make a change to this policy, we will update this page to reflect such change. Where we feel it appropriate, we will notify you by email, however we recommend you review this page periodically to ensure you remain happy with the latest version.