Advertisers Privacy Policy

Last Updated: May 22, 2018

This user privacy policy (“User Policy”) describes the policies and procedures of Influencers by Launchmetrics on the collection, use and disclosure of your information, and what choices you have with respect to the information on https://www.stylecoalition.com (the “Site”) and the services, features, content or applications we offer (collectively with the Site, the “Services”).

When we refer to Launchmetrics (collectively referred as Launchmetrics, “we”, “us”, “our” in this Privacy Policy) we mean the Launchmetrics entity and its subsidiaries (including Style Coalition) that act as the Controller of your Personal Data as a User of the Services.

When we refer to advertisers (“Advertisers”) we mean brands that have submitted an online application for evaluation by Launchmetrics and be registered on the Advertisers platform after validation by Launchmetrics. Once registered as an approved brand, an Advertiser can search Registered Influencers profiles via a search engine, submit proposals through the platform for marketing campaigns utilizing Influencer’s services (“Campaign”) for consideration; review Campaign pricing information; review the status of pending Campaign requests; and review active Campaign statuses.

When we refer to users (collectively referred to as “Users”, "you", or "your" in this Privacy Policy) we mean all individuals who are holders of an Influencers by Launchmetrics account as Advertisers including those users granted access to the Services via their employer or another company.

When we refer to influencers (“Influencers”) we mean Influencers that have submitted an online application for evaluation by Style Coalition and Launchmetrics to be contacted by brands on future projects and are now registered on the Influencers by Style Coalition platform after validation by Style Coalition and Launchmetrics (“Registered Influencers”) and Influencers that were identified on Social Media APIs by Style Coalition and Launchmetrics as potentially interesting for brands because of their level of influence on the topics of fashion, luxury and beauty but did not make the process of registering on the platform (“Crawled Influencers”). The selected profiles are made accessible to brands via a search engine, which can then "invite" them to join our network by registering (they join then the subset of Registered Influencers).

We receive information about you from various sources, including: (i) if you register for the Site and the Services, through your User account on the Services (your “Account”), and (ii) your use of the Services generally; and (iii) from third party websites and services. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

Updates in this version of the User Policy reflect changes in data protection law. In addition, we have worked to make the User Policy clearer and more understandable. To find more quickly the information you are looking for, please look at our table of contents

Please read this statement carefully to understand our policies and practices regarding your information and how we will treat it.

What Does This Privacy Policy Cover?

This User Policy covers the treatment of personal data (“Personal Information”) gathered when you are using or accessing the Services. This User Policy also covers our treatment of any Personal Information that our business partner share with us or that we share with our business partners.

This User Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (“Third Party Services”) that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

In addition, a separate agreement governs delivery, access and use of the Services (the “Terms of Service”) and the processing of your Data. If you choose to create a Campaign with Influencers, we will provide an agreement (“Campaign Agreement”) with the outlined Campaign Terms to the chosen Influencers.

What Information Do We Collect and Receive?

The information we gather enables us to personalize, improve and continue to operate the Site. In connection with certain aspects of the Site, we may request, collect and/or display some of your Personal Information. We collect and receive Data and other information in different ways:

  • User Data or Account Information.

    When you create an Account, you will provide information that could be Personal Information, such as your first name, last name, username, password, email address, phone number, representation information, profile picture, address, date of birth, expertise and non mandatory personal information and social media accounts if provided. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services. Although we reserve the right to contact you but only when we believe it is necessary, such as for account recovery or security purposes.

  • Other Information.

    Style Coalition and Launchmetrics also collect, generate and/or receive other information:

    1. Usage Information:
      • IP Address Information and Other Information Collected Automatically

        We automatically receive and record information from your web browser when you interact with the Site, including your IP address and cookie information but also your browser type, domain names, access times and referring website addresses. Generally, the Site automatically collects usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Site so that we can analyze and improve them.

      • Log Data

        As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Site or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Site or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.

        We collect log information for different reasons like:

        - Detecting or preventing fraud, and unauthorised access;

        - Help users and address their needs while using the platform;

        - Keep improving our product in terms of features scope and security needs.

      • Aggregate Information

        We collect statistical information about how registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser, unless you give us the explicit agreement to do so.

      • Third party data

        In the course of using our Service, for example by using the comments sections or other interactive features (“Interactive Areas”), you may post or upload information, comments, content or materials created or provided by you that may contain personal data. In this case, Launchmetrics is a Processor of this data and you, as a User, are the Controller as we store your Contact Information, but you decide and are responsible for what happens to this data.

    2. Cookies Information:

      We use cookies and similar technologies in our Sites and Services that help us collect other information. The Sites and Services may also include cookies and similar tracking technologies of third parties, which may collect information about you via the Sites and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookies Policy.

      Our cookies might, contain Personal Information (IP address), but we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Site.

      Our website uses Session Cookies. Session Cookies are temporary and deleted from your machine when your web browser closes. We use session Cookies to help us track internet usage as described above.

      If you do not want Cookies to be dropped on your device, you can adjust the setting of your Internet browser to reject the setting of all or some Cookies and to alert you when a Cookie is placed on your device. For further information about how to do so, please refer to your browser ‘help’ / ‘tool’ or ‘edit’ section or see www.allaboutcookies.org. Please note that if you use your browser settings to block all Cookies (including strictly necessary Cookies) you may not be able to access or use all or parts or functionalities of our Sites.

      If you want to remove previously-stored Cookies, you can manually delete the Cookies at any time. However, this will not prevent the Sites from placing further Cookies on your device unless and until you adjust your Internet browser setting as described above.

      Below are pages describing these settings in more detail for each browser.

      If you use multiple browsers (e.g. Internet Explorer, Google Chrome, Firefox, etc) you must repeat this procedure with each one, and if you connect to the web from multiple devices (e.g. from work and at home), then you will need to set your preferences on each browser on each device.

      We strongly recommend that you leave cookies active, because they enable you to take advantage the most attractive features of the Site but this remains your personal choice.

      For more information on the development of user-profiles and the use of targeting/advertising Cookies, please see www.youronlinechoices.eu if you are located in Europe or www.aboutads.info/choices if in the United States.

How Do We Use The Data Collected?

The Site is designed to help you find and share information about our influencer network. As a result, some of the information generated from your feedback is shared with the Influencer Network.

Customer or User Data will be used by Style Coalition and Launchmetrics in accordance with Customer or User instructions, including any applicable terms in the Terms of Service and User’s use of Services functionality, and as required by Applicable laws.

Different Launchmetrics entities provide the Services in different parts of the world. Data protection laws in certain jurisdictions differentiate between the “controller” and “processor” of information.

User Profile Information:

Your Profile and other Account details will not be visible to others, including Influencers and other Advertisers but may be visible to Launchmetrics admin and staff. Of course, certain general information may be disclosed to Influencers whose services you request in connection with a Campaign and/or engage for a Campaign.

IP Address Information:

While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Aggregate Information:

We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.

Information Shared with Third Parties:

Launchmetrics may share data with trusted partners to help perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Launchmetrics, and they are required to maintain the confidentiality of your information.

Information Shared with Our Agents:

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, User information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, User information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce these Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to User support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Information We Share With Your Consent:

Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to prevent the sharing of this information.

Is Information About Me Secured?

We work hard to secure your Personal Information from unauthorized access to or unauthorized processing, alteration, disclosure or destruction of Personal Data we hold by taking appropriate Technical and Organisational Security Measures, having regard to the state of the technological development and the cost of implementing any measures where appropriate, for example, pseudonymisation and encryption of Personal Data.

Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.

We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of User information at any time. We otherwise store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.

Where it is likely that a breach results in a risk to the rights and freedoms of individuals, we will notify the relevant supervisory authority within 72 hours of the becoming aware of it. This information can be provided in phases to facilitate a fast and efficient reporting. Where a breach is likely to result in a high risk to the rights and freedoms of individuals, we will notify those concerned directly with the following information:

  • The nature of the personal data breach including, where possible:
  • the categories and approximate number of individuals concerned; and
  • the categories and approximate number of personal data records concerned.
  • The name and contact details of the data protection officer or other contact point where more information can be obtained.
  • A description of the likely consequences of the personal data breach.
  • A description of the measures taken, or proposed to be taken, to deal with the personal data breach and, where appropriate, of the measures taken to mitigate any possible adverse effects.

The servers that store your data have appropriate administrative, technical, and physical controls that are designed to safeguard your data, including industry-standard encryption technology.

If you have any questions or concerns regarding security using the Site, please send us a detailed message to security@launchmetrics.com. We will make every effort to answer your concerns.

California Privacy Rights (for California residents)

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Data that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: STYLE COALITION, 180 Varick Street, Suite 1128, New York NY 10014 USA.

Your rights under GDPR (for EEA residents)

Under General Data Protection Regulation (GDPR), Users have the right to ensure:

  • we process your data fairly and lawfully within the consent you have provided us.
  • your data is accurate.
  • your data is secure.

Users can:

  • ask confirmation of whether, and where, a Controller is processing Personal Data;
  • ask us to provide details of the Personal Data we hold on you (information about the purposes of the processing, the categories of data being processed, the categories of recipients with whom the data may be shared,and obtain a copy of the personal data being processed (see the contact information below);
  • know how long we keep your data;
  • use your rights to erasure, to rectification, to restriction of processing and to object to processing, or to complaint to relevant authorities;
  • obtain information regarding the source of the data if the data were not collected directly from you ; and
  • obtain information about the existence of, and an explanation of the logic involved in, any automated processing that has a significant effect on you or other data subjects.

We will maintain complete and accurate records and information to demonstrate our compliance with our obligations under this Privacy Policy and also for audits conducted by you or on your behalf.

To exercise any of these rights, please contact us at security@launchmetrics.com or by mail to Launchmetrics, 180 Varick Street, Suite 1128, New York NY 10014, Attention: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

How Long Do We Conserve Your Data?

Launchmetrics shall retain the right to maintain your Account and Profile information for archival and recordkeeping purposes for a period of three (3) years after the cancellation of our Services, and for use in accordance with a User’s instructions, including any applicable terms in the Terms of Service and User’s use of Services functionality, and as required by applicable laws.

Such time period will not apply if you have requested that your data be deleted within three (3) years of deactivation.

If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account.

What Happens When There are International Data Transfers?

We are a global organisation, as such, we may share information about you within Launchmetrics offices and with affiliates and transfer it to countries in the world where we do business in connection with the uses identified above and in accordance with this Privacy Policy.

In some cases, we use suppliers located in various countries to collect, use, analyse, and otherwise process information on its behalf. It is our practice to require such suppliers to handle information in a manner consistent with our policies and applicable laws.

For transfers of personal data outside of the EEA, we are making sure that any of these transfers are supported by the strict legal compliance of our suppliers to the GDPR. When necessary, compliance can be achieved by the use of an approved certification mechanism such as the EU-US Privacy Shield. This framework was developed to establish a way for companies to comply with data protection requirements when transferring personal data from the European Union to the United States.

We also offer EU Standard Contractual Clauses (also called Model Clauses), to meet the GDPR requirements for our customers who operate in the E.U.

How do I Review or Change my Personal Data?

If you are an approved Advertiser, you can access information associated with your Account by logging into the Services and accessing your personal dashboard. If you would like to review or change your Personal Data, we will deal promptly and appropriately with any inquiries unless we have to keep that information for legitimate business or legal purposes. However, if your requests are deemed to be excessive or complex a small fee may be charged and a time-period extension may apply.

You can contact us at: security@launchmetrics.com.

How Can I Delete My Account?

You may request that Style Coalition and Launchmetrics deactivate your Account at any time by following the procedures on the Site or by emailing irm@stylecoalition.com. If you deactivate your Account, Style Coalition by Launchmetrics will endeavor to promptly cease displaying your Profile (to the public or to Advertisers), but the Account shall remain active so long as there are any pending transactions associated with your Account.

How do you Protect Children's Privacy?

STYLE COALITION does not knowingly collect Personal Data from children under the age of thirteen (13). If you believe we might have any information from or about a child under thirteen (13), please contact us at security@launchmetrics.com.

What Happens When There Are Changes to this Privacy Policy?

Although most changes are likely to be minor, STYLE COALITION will occasionally update this Privacy Policy to reflect company and customer feedback about the Site. Changes and clarifications will take effect immediately upon their posting on this Site. STYLE COALITION encourages you to periodically review this Privacy Policy to be informed of how we are protecting your information and check for any changes. We have the sole discretion to modify this Privacy Policy. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services.

Do you have a Data Protection Officer?

Yes, if you would like to communicate with our Data Protection Officer, please send a message to dpo@launchmetrics.com.

How to contact us?

If you have any questions or concerns regarding privacy using the Site, please send us a detailed message to info@stylecoalition.com. We will make every effort to resolve your concerns.