LAST UPDATED APRIL 28, 2019.
Influreply Inc. (Influreply or We/we or Our/our or Us/us) is committed to respecting the privacy of your personal information and data.
our online properties (here and after, each a “Website”), including:
the Influreply Platform (including the Influreply Influencer mobile application); and
our websites, including, but not limited to, https://www.influreply.coc/ and any of our related websites, social media pages, internal websites, and other mobile or tablet applications;
any other means through which an individual provides personal information to Influreply, including either physically or electronically; and
any other means through which we lawfully collect personal information about you.
PERSONAL INFORMATION IS IMPORTANT TO US
We are committed to safeguarding personal privacy. We recognize that you have a right to control how your personal information is collected and used. Providing personal information is an act of trust and it is taken seriously. Unless given consent to do otherwise, we will only collect and use personal information as set out below.
ON WHAT BASIS DO WE PROCESS YOUR DATA
Influreply also reserves the right to use, disclose or otherwise process any personal information to satisfy any law, regulation or legal request, or in relation to Influreply’ other legitimate interests such as and where that personal information is relevant to legal action relating to Influreply.
ANONYMITY AND PSEUDONYMITY
KINDS OF PERSONAL INFORMATION THAT INFLUREPLY COLLECTS AND HOLDS
Personal information that may be requested includes, but is not limited to:
contact information such as your full name, date of birth, telephone number, mobile telephone number, current and valid email address, residential address and postcode;
your Apple AppStore and/or Google Play Store ID and your unique device identifier (UDID);
your social media handles and login details including usernames and passwords;
more detailed contact preferences;
sensitive information about you;
photographs of you;
your occupation and information regarding your professional history and professional interests;
information regarding your education and qualifications;
information regarding your personal interests and interesting and relevant information about you;
financial details including your bank account details and PayPal details;
your online behavior and interests based on your online browsing activity;
information about your preferences, interests, and experiences with our products or services. This information is collected in order to tailor our communications to you and continuously improve our products and services;
information about your experience with our products or services or third party products or services listed on a Website;
your credit card details (where you purchase any products or services from us);
the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to Influreply and used for the purposes set out in this policy (which may include using their details for marketing purposes); and
When you use a Website, we may also collect personal information about you in the following general categories:
device information: we may collect information about your mobile devices such as the hardware model, operating system, preferred language, unique device identifier, and mobile network; and
other information: we may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a Website.
HOW INFLUREPLY COLLECTS AND HOLDS PERSONAL INFORMATION
ACTIVE INFORMATION COLLECTION
Information may be collected (and combined) via our Collection Channels if you:
sign-up and/or register to become a member of any Collection Channel;
submit any content to or participate in any way via a Collection Channel, including engaging with other users or taking part in campaigns;
subscribe to any newsletters, updates, alerts or news and media releases, or request launch or event information or information about our products or services or other information services as well as third party products or services;
complete and submit any forms or applications to us;
contact us directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
participate in any offers, promotions or marketing activities;
interact with a Website for a specific purpose;
interact with or browse a Website generally; or
if you are a business we trade with, complete a credit application.
Personal information is requested in order to allow you to participate in a Collection Channel, to facilitate or provide you with certain content, products or services, and information about such content, products or services (including the uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), marketing materials (including direct marketing materials), newsletters, electronic newsletters (e-newsletters), news and media releases / launch information, and also to advise you of other Influreply or third-party opportunities and products, services, offers, competitions or events which may be of interest. No one is obligated to provide personal information. However, failure to do so may result in you being unable to participate in a Collection Channel and Influreply being unable to facilitate or provide you with certain content, products or services, products or services information, upcoming opportunities and promotion, competition, offer or event information or accept competition entries or other content from you (where applicable).
We may collect your personal information from legitimate third party sources including social media channels, list brokers and other data providers or organizations that share data in circumstances where it is lawful and/or you have given permission for them to do so. If you are a representative of a business we trade with, we may also obtain your credit history information from a credit reporting body, and trade history information from references you provide us with.
The collection of personal information is neither intended for nor directed to, persons who are under the age of sixteen (16) years old. Personal information will not be collected by any person who is known by Influreply to be under the age of sixteen (16) without the consent of a parent or legal guardian. Persons under age sixteen (16) may only use our Websites with the involvement and consent of a parent or legal guardian.
PASSIVE INFORMATION COLLECTION
As with many commercial websites and mobile and tablet applications, we may also collect information which tells us about visitors to our Websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a Website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally including when you are logged into an account, you consent to the collection of such information where it is personal information.
Our Websites may use and combine such passively collected anonymous information or personal information and/or information from various third party sources, including as described above, and may combine this anonymous information or personal information with other personal information collected from you to provide better service to Website visitors and users, customise a Website based on your preferences, compile and analyse statistics and trends, provide you with relevant advertising when you visit a Website or a third party website, and otherwise administer and improve a Website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website, you consent to information about you being collected, compiled and used in this way.
PURPOSES FOR WHICH INFLUREPLY COLLECTS, HOLDS, USES AND DISCLOSES PERSONAL INFORMATION
Personal information collected will be used for the following primary purposes:
For the purposes stated in a privacy collection statement on a particular Collection Channel.
To maintain the functionality of a Website, including the provision of information to you relating to the content available on the Website and e-commerce transactions conducted via the Website.
To send you any technical, administrative or legal notices important to our Websites.
To allow you to respond to opportunities, briefs or campaigns created by other users of a Collection Channel;
To allow you to publish posts to your social media channels via a Collection Channel.
To facilitate payments from you and to you via a Collection Channel.
To provide you with information about your transactions (including uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), content, services, and products.
To provide direct marketing materials, events, special offers, competitions and promotions in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email) or any other form of electronic, emerging, digital or conventional communications channel.
To provide you with relevant advertising when you use our Websites or those of a third party.
To maintain our relationship with you.
To render services related to our company (such as after-sales services and inquiries).
To provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages.
To respond to customer inquiries, complaints, and complaints handling.
To improve Website and system administration.
To obtain opinions or comments about products and/or services and to conduct other research and development.
To record statistical data for marketing analysis and to conduct market research.
To share personal information with our group companies, our promotional partners, trusted brands using a particular Collection Channel and their related bodies corporate and agents, and other trusted third parties in the manner described below.
If you are a business we trade with, to carry on our trading relationship with you including identifying and contacting you, invoicing your correctly, assessing the risks of providing credit to you or your business, and securing and recovering any debts owed to us.
Any other purpose as may be deemed reasonably necessary by Influprely in the circumstances.
CONSEQUENCES OF NOT PROVIDING INFORMATION
Failure to provide personal information may result in you being unable to access or use certain Collection Channels, products or services or in Influreply being unable to provide you with certain content, information, products, services, upcoming opportunities, promotions, event or product information and/or accept content from you (where applicable).
HOW WE MAY SHARE YOUR PERSONAL INFORMATION
For the purposes described above, personal information may be shared with Influreply group companies, Influreply promotional partners and their related bodies corporate, and other trusted third parties including brands and companies using the Influreply Platform (and their directors, servants, and agents). Failure to provide personal information may result in Influreply being unable to provide you with certain content, information, upcoming opportunity, promotion, event or product information and/or accept content and promotion entries (where applicable).
In order to operate a Website or deliver a service (including for example, processing of credit card payments), personal information may also be shared with Influreply group companies, selected service providers and their related bodies corporate, and/or other trusted third parties. Influreply group companies, selected service providers and/or other trusted third parties may be engaged by Influreply to perform a variety of functions, such as legal and accounting services, data storage, fulfilling orders, conducting market research, processing credit card payments, assisting with promotions, marketing and email services, and providing technical services for our Websites. These companies may have access to personal information if needed to perform such functions. Your credit card details are only used to facilitate your purchase. They are not used for any other purpose and will never be supplied to a third party other than Influreply or our relevant service provider. If you are a business we trade with, we may disclose your information to debt recovery agents or credit reporting bodies if necessary.
CONTACT BY Influreply
Influreply group companies (and their directors, servants, and agents), Influreply promotional partners and their related bodies corporate or trusted third parties (including users of a Collection Channel) and other selected service providers and other non-Influreply companies or professionals, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the primary purposes for collection of personal information as stated above.
Please allow 30 days for this request to be processed.
Despite removing your name from the database from receiving future advertising and marketing information, Influreply may send you non-commercial “Administrative Emails”. Administrative Emails relate to an Influreply user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular Influreply user account. If you do not wish to receive such communications from Influreply, you may remove your name from the database by utilizing the functional unsubscribe facility.
ABILITY OF OTHERS TO VIEW INFORMATION
Influreply may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users including commercial users and brands, provide reviews for content, products and/or services, utilize functionalities that allow you to post content to your own social media channels, or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others either on our Websites or outside of our Websites. Influreply is not responsible for the conduct of others who may read, collect and use this information.
YOUR PRIVACY RIGHTS
You have a number of rights under the privacy law of various states in the United States. These include:
(access) to request access to your personal information from us, in a commonly used electronic format. On a case by case basis, Influreply may determine that it is not legally required to give an individual access to personal information, in which case Influreply will provide you with a written notice of its refusal to provide access;
(correction) to request that we correct your personal information;
(withdrawing consent) to withdraw your consent for us to use your personal information. Please note that you can also opt-out of online marketing communications at any time by using the unsubscribe feature in each electronic commercial message;
(transparency) to be informed generally about the collection and use of your personal data, including where we intend to further process your personal data for additional purposes other than as discussed above
(complaint) to complain about a breach of the Australian Privacy Principles (or applicable privacy law); and
(deletion) you may also request that we delete your personal information, and all reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in Influreply and its service providers or partners being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website), other product content, or services information, upcoming promotion, competition or event information, and/or provide certain content, goods or services. Unless required by applicable law, we are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this policy.
If you are an individual in the EU, you have additional rights under the GDPR that you can exercise against the “controller” of your data. Where we are the controller of your data, your rights include:
(access) to request that we transfer your personal information to another service provider of your choosing;
(erasure) to request that we erase your personal data. All reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in us being unable to facilitate or provide you with information about certain services (including the uploading, access to, and receipt of content on a website or the Influreply Application, and purchase transactions undertaken on a website);
(objection and restriction) in some circumstances, to object to the use of your personal data by us and request that we restrict our use of your personal information; and
(complaint) to lodge a complaint in relation to our processing of your personal data with a data protection supervisory authority under the GDPR.
Influreply does not make decisions that produce significant effects on you which are solely based on automated decision making. Influreply may use limited automated decision-making based on your social media following to determine your eligibility to utilize aspects of the Influreply Platform.
STORAGE AND SECURITY OF PERSONAL INFORMATION
Influreply takes appropriate security measures to keep personal information secure and to prevent unauthorized access, disclosure, modification or destruction of personal information. Influreply, its employees and its subcontractors are obliged to respect the confidentiality of any personal information held by Influreply.
DISCLOSURE OF PERSONAL INFORMATION TO OVERSEAS RECIPIENTS
For individuals in the EU, please note that the recipients of your personal information may be located in countries in which the privacy or data protection laws differ from those of the European Union, and which are not the subject of an adequacy decision by the European Commission. For recipients of your personal information in Australia, the United States, and the Philippines appropriate or suitable safeguards over your personal data have been put in place by virtue of our compliance with the standard data protection contract clauses approved by the European Commission. Please contact our Privacy Officer for more information. For New Zealand, a data protection adequacy decision has been made by the European Commission.
In some cases, Influreply may disclose your personal information to overseas recipients, including but not limited to recipients in New Zealand, the United States, the Philippines, and the United Kingdom. Influreply employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by Influreply. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. Influreply will not be held responsible for events arising from unauthorized access to personal information.
INFLUREPLY AND LINKS TO OTHER WEBSITES
Our Websites may, from time to time, contain links to the websites of other organizations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. Influreply is not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.
We may use third party advertisements on our Websites. All third party advertising, if paid for, is paid for by the relevant third party advertisers and are not recommendations or endorsements by Influreply or any of its affiliates. Influreply is not responsible for the content (including representations) of any third party advertisement on a Website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties.
RELATED INFLUREPLY WEBSITES
SALE OF THE COMPANY
PROBLEMS OR QUERIES
Please allow 30 days for this request to be processed. On receipt of your query, problem or complaint a review will be conducted and findings will be communicated to you where required. If you do not receive a satisfactory response to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to certain organizations.