Privacy Policy

Last updated: 24 April, 2024

1. Introduction

We are Creator Technologies Ltd

If you have any questions about this policy, including any requests to exercise your legal rights, please contact us at privacy@trudy.app or by writing to 7e Lyndhurst Terrace, London, England, NW3 5QA.

This policy was last updated on 24th April 2024.

2. How we use your personal data

  • When you contact us either by phone, email, via our 'Let's Talk' page or on social media, we will usually collect your name, social media handle and contact details, because it’s in our legitimate interest to make sure we can properly respond to your query.
  • When we on-board you as a customer we will collect your name, email address, phone number, address, company name and address (if applicable) and your payment details. We collect this in order to take steps to enter into a contract with you to use our services either as an organisation purchasing our services or as an influencer agent working with us to promote your services.
  • When we on-board you as an influencer we will collect (either directly or through a third-party agency) your, name, email address, phone number, address, social media profile information and (if appliable when we are contracting with you directly and not through an agency) your company name and address, and payment details. Your social media profile information will include any data you have made public, including but not limited to your images, gender, date of birth, interests and hobbies, educational details and employment details. We collect this information for the purposes of entering into a contract with your or your agent to use our services.
  • When you sign up to receive our updates we will collect your name and email address to provide you with our news updates in line with any preferences you have told us about. When we send you our news updates because you have opted-in to receive them, we rely on your consent to contact you.
  • You can unsubscribe from our updates at any time by responding to any email you receive from us to tell us you wish to unsubscribe or by emailing privacy@trudy.app.
  • When you use our website and consent to our use of cookies we will collect information about how you use our website including your IP address, geolocation, browser type and version, operating system, referral source, length of visit, page views and website and app navigation paths, as well as information about the timing, frequency and pattern of your use. We use this information to improve our website and to better understand how people use it. More detail on the information we collect and how we do this is set out in our Cookie Policy below.
  • When we believe you are a suitable candidate for our product Trudy (www.trudy.app) we will collect any data you have made public on your social media profiles, including but not limited to your images, gender, date of birth, interests and hobbies, educational details and employment details. You can let us know you would prefer we did not use your data in this way at any time by emailing privacy@trudy.app.
  • When you attend one of our events or a third-party event we also attend (including virtual events), we will usually collect your name, address, email address and phone number. We collect this information because it’s in our legitimate interests to promote our business and to know who’s attending our events.
  • When you apply for a job with us we may collect your name, contact details, recruitment information (e.g. right to work documentation and references), test results, qualifications, accreditations and any additional information we may receive from you or our recruitment partners.
  • We will use your personal information to assess your suitability for our available roles. We do this to perform our contract obligations or to take steps at your request, before entering into a contract. Where we process your right to work documentation, we will do so to comply with our legal obligations.
  • If our business is sold we process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the buyer of our business may not be able to provide services to you.

3. Who sees your data

  • Our group companies, business partners, suppliers and subcontractors for the performance of the contract we enter into with them or you.
  • Where you are an influencer - marketing organisations and brands for the purposes of promoting your profile for prospective opportunities.
  • Where you are a customer – influencers and other customers for the purposes of engaging influencers to promote your brand and to promote collaboration opportunities.
  • Regulators/ Authorities/ Enforcement Agencies if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of our clients or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
  • Insurers and Advisers for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims.
  • Prospective buyers of our business under our legitimate interest to ensure our business can be continued by the buyer.

4. How your data is stored

  • We store your data on third party servers which are based both in the UK and EU, and outside the UK and EU. When working with third parties we may need to transfer your personal data outside of the UK / EU. Whenever we transfer your personal information outside of the UK and the EU, we ensure it receives additional protection as required by law. To keep this policy as short and easy to understand as possible, we haven’t set out the specific circumstances when each of these protection measures are used. You can contact us at privacy@trudy.app for more detail on this.

5. How long your data is stored

  • We will only retain your personal information for as long as we need it unless we are required to keep it for longer to comply with our legal, accounting or regulatory requirements.
  • In some circumstances we may carefully anonymise your personal data so that it can no longer be associated with you, and we may use this anonymised information indefinitely without notifying you. We use this anonymised information to improve the way we work and our services.

6. Your rights under data protection law

  • You have various other rights under applicable data protection laws, including the right to:
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  • access your personal data (also known as a “subject access request”);
  • correct incomplete or inaccurate data we hold about you;
  • ask us to erase the personal data we hold about you;
  • ask us to restrict our handling of your personal data;
  • ask us to transfer your personal data to a third party; 
  • object to how we are using your personal data; and
  • withdraw your consent to us handling your personal data.
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  • You also have the right to lodge a complaint with us or the Information Commissioner's Office, the supervisory authority for data protection issues in England and Wales. If you are based in the EU you can find your relevant supervisory authority here.
  • Please keep in mind that privacy law is complicated, and these rights will not always be available to you all of the time.

7. Updates to this policy

  • We may update this policy from time to time by publishing a new version on our website. You can check the last publication date at the start of the policy.
  • You should check this policy regularly to ensure you are happy with the most recent version, but we will update you of any significant changes by posting a notice on our website.

8. Cookie policy

A cookie is a small file of letters and numbers that we store on your browser or in your device's storage.

Essential Cookies

  • We use essential cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you use our website. We are permitted to place these cookies without your prior consent, but you can block all cookies, including essential cookies by changing your browser settings. Please note if you block all cookies, you might not be able to see or access all parts of our website.

Non-Essential Cookies 

  • The other types of cookies we use are non-essential cookies. We use these to help us make improvements to our products and services. We have listed all non-essential cookies we might use and that we might allow our partners to use in the list below. We only use (and store) non-essential cookies if you provide your consent.

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HotJar

Purpose: Registers a unique ID that is used to generate statistical data on how you use our website. More info.

Duration: 1 year

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Google Analytics

Purpose: This helps us understand how you use the Website and helps us to improve your experience. These cookies may track how long you spend on the website and the pages you visit. More info.

Duration: The retention period will be between 1 minute and 2 years depending on the type of cookie used. 

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Google Ads

Purpose: This enables us to display adverts that correspond to your interests. More info.

Duration: The retention period will be between 2 weeks and 90 days depending on the type of cookie used.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website. 

9. Lawful basis

Legitimate interest - We may process Personal Data if we have assessed that a legitimate interest overrides the interest of fundamental rights and freedoms of the Data Subject, and if the processing is necessary for the purpose in question

Performance of a contract - The Processing is necessary for the performance of a contract entered between us and the Data Subject, or to prepare for entering into an agreement with the Data Subject.

Consent - We may process your Personal Data after you have given your consent to the Processing. Information regarding the processing is always provided in connection to the request of consent.

How long do we store your Personal Data?

We will keep your Personal Data for no longer than is necessary for the purpose for which it was collected. Depending on the lawful basis on which we justify the Processing, this may: a) be regulated in a contract, b) be dependent on valid consent, c) be stated in legislation or d) be based on a legitimate interest assessment (LIA).

10. Description of the processing

  • Nature: Trudy is a browser add-on that brands can download to assess the Metrics of an Influencers' profile.
  • Scope: To generate the Metrics Trudy will collect:‍
    • Influencer and subscriber personal data: Country of the Influencer and their subscribers (detected, for example, from geo-tags and flag images in their profiles), age and interests.
    • ‍Influencer and subscriber special category personal data: This data is captured based on keywords spoken by the Influencer and the comments left on their profile and may include data that is categorised as religion, sex, gender, disability, ethnic origin, political issues and ethnicity. This data is not used for profiling or categorising influencers and does not form any part of the influencer profile. As such, this data relates to a topic the Influencer is discussing but may not actually be relevant to the Influencer or their subscribers.
    • ‍Quantity of data: Trudy will collect a number of data points from Influencers' profiles and will automatically detect this information from profiles with over 10,000 subscribers.

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