MightyCheck

MightyCheck Privacy Policy

Effective:

September 12, 2019

This privacy policy applies to https://www.mightycheck.com/ (the Site), a website operated by Anderson X (the “Company,” “us,” ”we” or “our”).

The Site provides the "Service" as defined in the Terms of Use. This Privacy Policy explains how we collect and use personal data of “Businesses” (users of our Services), “Customers” (users of our Services) and users of social networks; including Instagram; Facebook; LinkedIn; Snapchat, and Twitter(“Creators”, “Influencers”, “Social Media Influencers”) and Influencer websites.

About MightyCheck

MightyCheck is a tool for digital marketers, businesses, and creators that helps them analyze social data in minutes. We use proprietary technology to make understanding your audience and sharing it with others simple. More details about the Company, products, and services we offer can be found on our website at www.mightycheck.com.

Anderson X is the data controller and is responsible for your personal data. Our contact information is:

Singel 542

1017 AZ, Amsterdam, The Netherlands

PHONE: +17604158439

EMAIL: [email protected]

If you have any questions about this Privacy Policy or how your personal data is used, please contact [email protected]

Information Collected

We collect various types of information about Customers, Businesses, and Creators.

Customer Data

Customer data collected is provided by the Customer and includes:

Name
Last Name
Title
Company/Entity Affiliation Name
Email
Phone Number
Service Account Password (Password)
Billing Information to pass to Stripe for processing
Credit Card Information to pass to Stripe for processing
Service Queries
Service Queries history
Device information (type of device used to access service)
When the service is accessed.

Business and Creator Data

We collect, use, store, and transfer different kinds of data about businesses and social media creators like you that is publicly available via social networks and in the public domain, that allow our Customers to engage with Creators in a strategic, meaningful, and targeted manner. This information includes (to the extent made publicly available by the creator):

Prefix
Name
Job Title
Publicly available biographical information disclosed on , social media sites , websites, and profiles
Areas of interest to the creator
Education History
Employment History
Work address
Work Telephone Number
Email Address
Creator website
Public Social Media profiles and handles
Twitter handle

Instagram name
Facebook profile
LinkedIn profile
Snapchat name
Web page URL
YouTube Channel

Number of social media followers on each platform
Target/Niche groups or audiences
Subject area expertise
Facial recognition via third party software (non-biometric data)
Location of public photos

We do not collect sensitive personal sensitive data about you (race, ethnicity, religious or philosophical beliefs, sexual preferences or orientation, political opinions or memberships, trade union memberships, health information; genetic or bio metric data) unless you have undoubtedly put such data into the public domain yourself (you have made such information available to the public by writing about it or posting it on your social media profile(s) or website).

Creator Audience/Niche Data

Audience data is relevant to the Creator and Businesses they interact with. It is kept in an aggregated form together with information about the creator. Once the creator data is deleted that audience data of the particular creator is removed.

How personal data is collected

Customers

The data collected from Customers is provided by the customers at the time of sign up and in order for us to provide the service.

Creators and Businesses

Legitimate Interest in Processing - We are processors that create reports regarding creators and businesses for third parties at their direction. Pursuant to our contractual obligations, we organize reports on creators based on their data accessible through the Instagram API and public profiles from the sources listed below. Since this information was voluntarily made public by the Creator as a part of their business operations and shared with businesses they're interested in working with, we believe that there is a reasonable expectation that creators will expect that people interested in utilizing their influence will seek them out and collect information on them to assess the value of a possible business relationship. Further, since we comply with our obligations to respect and comply with data subject rights exercised by European Union data subjects, we do not believe that accessing and sharing such information infringes on any of the fundamental freedoms or rights of Creators located in the European Economic Area, Switzerland or elsewhere.

The information we hold about creators is obtained from the Instagram API and publicly available sources. This includes publicly available social media profiles and websites; information from articles the creators may have written or was written about the creator. This information is gathered by our technical team from many sources.

We collect Creator data either directly from publicly available sources such as:

Articles or blogs you may have written or may have written about you in the public domain
Vlogs you may have created in the public domain
Your own website
Your publisher's website(s)
Your publicly available social media profile from sources including:

Instagram - Data Policy DPO: Stephen Deadman Help Page

We also may search other publicly available social media profile sources including:

Facebook - Data Policy DPO: Stephen Deadman
Snapchat - Privacy Policy DPO: [email protected]
Twitter - Privacy Policy DPO: Web Page Form
YouTube - Privacy Policy DPO: Web Page F orm
LinkedIn - Privacy Policy DPO: Web Page Form
Others we may add to this list in the future

Other publicly available online sources

We also collect data from other sources including:

The Instagram API
Your manager
Press team, if applicable

How do we use your Data?

Customer

Customer data is used to provide the Service; process Services payments; customer service support; and fulfill customer queries. Customer’s failure to provide the personal data we need, we may be unable to complete the transaction.

Legitimate Interest for processing and profiling Business and Creator personal data

We are processors that create reports regarding creators for third parties at their direction. Pursuant to our contractual obligations, we organize reports on creators based on their public profiles from the sources listed below. Creators utilize their public persona, profiles postings and follower count to discuss issues, products or services and often make recommendations or promote such issues, products, goods or services. Since this information was voluntarily made public by the Creator as a part of their business operations in order to attract attention and notariety, we believe that there is a reasonable expectation that creators will expect that people interested in utilizing their influence will seek them out and collect information on them to conduct due diligence and assess the value of a possible business relationship. Further, since we comply with our obligations to respect and comply with data subject rights exercised by European Union data subjects , we do not believe that accessing and sharing such information infringes on any of the fundamental freedoms or rights of Creators located in the European Economic Area, Switzerland or elsewhere.

Creator profiles on social media rarely contain email contact information. Because of the limitations of the technology involved, limitations on public information provided by Creators (including limited contact information) and the number of creators would require a disproportionate effort granted the limited effects on the fundamental rights and freedoms of the persons involved, but we respect the privacy of creators and will comply with our legal obligations related to EU data subject requests.

Creators

Using the Creator data collected from the public domain; We are capable of creating an creator profile for you and include it in our social media creator searches.

Our customers access our social media creator search services via one of our online platform(s) to allow our customers to view social media creators profile(s) according to whatever criteria they believe is important and send you information that they believe you might be interested in.

This is also beneficial for you because it will allow you to receive targeted news and other information that may be helpful to you as well as identify possible creators that would be helpful to your marketing efforts. Our primary role is to facilitate communication between our customer(s), businesses, and social media creators. Company customers and businesses can also use our social media creators search functionality to create their own lists of creators; add their own data about creators (which only they can access); and monitor your interaction with the communications that they send you (for example, whether you have opened an email sent via one of our customer facing platforms or clicked on any links contained in that email).

The main purpose for using your personal data is to create a database regarding people who hold themselves out as creators (the social media creators search), and make that service available to our customers on a for tailored searches. Your personal data may also be processed in one or more of the following ways:

Browsing the social media creators search function ; our customers can browse via our online platform(s);
Customers and Businesses can create lists of creators
Customers and Businesses can export creator data from our social media creator search function provided the data is used in accordance with all applicable laws and in accordance with our terms of use.
Wholesale access to data: Some of our customers can purchase wholesale access or copies of data but only if they promise to use it in compliance with the law
Please see Profiling and Tracking to see how your data is used for profiling and tracking.

Validating Access to Content

For Customers, we use the Personal Data of customers to validate their right to use our Services.

Direct Marketing

Customers

Customers can opt out of receiving marketing materials via email or mail at any time while receiving the service. If you receive newsletter or marketing communications from us and no longer wish to receive them, please follow the removal instructions in the email or change your account settings.

EEA/EU Data Subject Rights

The following rights apply to persons located within the European Economic Area and Switzerland:

Right of erasure/ Right to be forgotten

Customers

You have the right to have your personal data erased and no longer processed where the personal data are no longer necessary in relation to the purposes for which they are collected or otherwise processed; where you have withdrawn your consent or object to the processing of personal data concerning you, or where the processing of your personal data does not otherwise comply with this Regulation. You may request that we delete your personal data. Please contact us at: [email protected]

Deleting your Personal Data does not mean that all of it will be removed. We take steps to delete Personal Data that is no longer necessary in relation to provide our Services by deleting it within 30 days of your request. We may be required by law, to retain it to exercise or defend legal claims, or contractual obligations with our you and Customers to retain some information in connection with our obligation to provide the Services. We may de-identify and anonymize some data for purposes of retaining it.

Right to Redress

If you are a subject of the European Union or European Economic Area and Switzerland and you believe we have violated any data protection laws that apply to you, you have a right to file a complaint. Please contact the Information Commissioner’s Office in the United Kingdom or EEA Data Protection Authority where the complainant is located.

Data Portability

Customers, Businesses, and Creators

If you would like us to transmit your Personal Data to another company providing similar services, we will work with them to do so upon request and verification of such request with both the requestor and the company receiving the Personal Data.

Minors Under 16 years of Age:

Company does not knowingly collect or store any personal information from or about children under the age of 16.

If you believe a child under the age of 16 has under any circumstances provided us with personal information and data, a parent or legal guardian can email us at [email protected] to request that their children’s information be deleted from our records.

Do not track

“Do Not Track” or DNT is a feature enabled on some browsers that sends a signal to request that a web application disable its tracking or cross-site user tracking. At present, our Site does not respond to or alter its practices when a DNT signal is received.

Personal data for profiling and tracking

Customers

Customer tracking is used to improve the services and site and includes: length of use; time and date service was used; search queries; how the service was accessed (app; desktop; phone);

Businesses and Creators

We and third party service providers may collect certain tracking information about your personal data for automated profiling purposes. The profiling we do is limited and collected from the Instagram API and the public domain and public profile information or social media posts you publish. For example, we collect:

your publicly available personal preferences, interests, behavior and audience/niche and make this available to our customers in response to particular queries that they may make via our service.

We may, for example, use profiling to help our customers understand what subjects you like to talk about (taken from the nature of the content you produce) and the extent of your audience/niche (from the number of social media followers you have).

This helps our customers direct their communications to you more efficiently and effectively.

The results of this profiling are available in the social media creator search tool and database.

You have the right to object to us profiling your personal data. Creators who would like to to stop profiling them should contact us via [email protected] so that we may confirm your identity and verify the request.

Profiling and Searches

We provide tools to allow customers to combine the personal data from your creator profile with the publicly available content that you have produced and present this information to our customers via our service. Our customers are then able to search the publicly available data sets and:

Target: Our customers can understand your subject matter expertise, areas of interest, or subjects you are interested in thereby allowing our customer to target social creators for partnerships in social media posts, etc.

View and evaluate your content: Via our service, a customer can search your name and the names of other social media creators and view content you have produced. Your content may then be given an automatically generated “favorability” score', which is calculated by analyzing the words you have used in the content concerned against a list of words that the customer considers to be “favorable” or “unfavorable” according to their preferences/industry/messaging/ marketing focus.

Understand your audience/niche and its location: Our customers are able to see your publicly available social media feeds via our service together with data from those feeds including for example how many Instagram followers you have and (using data provided to us directly by Instagram) roughly where they are based geographically.

Automated decision-making: We do not make any automated decisions based on profiling nor is our scoring the sole basis for any business decisions made by us or our clients. The results of the profiling that we do carry out are to enable our customers to better identify creators that are interested in the kind of communications our customers want to send.

There is no automated decision-making and profiling based on ethnic origin or biometric data of the Creator.

Cookie Policy

MightyCheck may collect information automatically using web tracking technologies such as cookies, web beacons, pixel tags, clear GIFs and third party tracking services in order to ensure that the Sites and Services operate efficiently and to collect data related to usage of the Sites and Services such as, but not limited to, the browser type, language preference, referring site, and the date and time of each visitor request (“Tracking Information”).

Cookies and Tracking

Customers, Businesses, and Creators

We use both session-based and persistent cookies. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire. They are unique and allow us to do site analytics and customization, among other similar things. If you access our Site through your browser, you can manage your cookie settings.

In order to collect Tracking Information, make your use of the Sites and Services more efficient and responsive to your needs, MightyCheck and its cookie service providers, detailed in the Cookie Policy, store cookies on your computer. MightyCheck also uses cookies and web beacons that are placed in web pages on the Sites and Services to collect information and learn about actions users take when they interact with the Sites and Services.

MightyCheck does not link Tracking Information to individual user Personal Information; nor does it include the Personal Information with the Tracking Information that MightyCheck shares with the web tracking companies that use and process the Tracking Information, except as strictly necessary to provide and improve the Services (including customer support services). Some Tracking Information may include log or other data, such as IP address data, that is unique to you. You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the Sites and Services, but this may affect the performance of the Sites and Services.

If you do not wish to receive cookies, you may deactivate storing cookies on your computer by changing your browser settings accordingly. Please note that the functionality of the Sites and Services may be impaired and the range of functionalities may be severely limited if you deactivate cookies.

Specifics of which cookies we use can be found on our Cookie Policy page – LINK

How do we share your data:

We will not sell, rent, or share personal data with third parties outside of our company without your consent, except in the following ways:

We may share your personal data collected from public sources or provided by Customers with one or all of the following:

Customers: (Applicable to Creators) Our customers are typically communications and marketing departments within businesses or other institutions, or PR agencies. Our customers come from all sectors. We share your data with our customers by allowing them access to the social media search function through our online service/platform. Creators may receive focused information from our customers, often ahead of general releases, thereby providing them with relevant material to you and your audience or niche or allow them to develop partnerships or collaborations with our customers. We do not share or use your personal data for activities where we believe that our interests are overridden by any unwarranted adverse impact on you.

Law Enforcement and Internal Operations: Personal Data may be provided where we are required to do so by law, or if we believe in good faith that it is reasonably necessary (i) to respond to claims asserted against Company or to comply with the legal process (for example, discovery requests, subpoenas or warrants); (ii) to enforce or administer our policies and agreements with users; (iii) for fraud prevention, risk assessment, investigation, customer support, product development and de-bugging purposes; or (iv) to protect the rights, property or safety of Company, its users or members of the general public. We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to any third party request to compel disclosure of your information.

Business Transfer: Company may sell, transfer or otherwise share some or all of its assets, including your Personal Data, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. Under such circumstances, Company will use commercially reasonable efforts to notify its users if their personal information is to be disclosed or transferred and/or becomes subject to a different privacy policy.

Third Parties: We sometimes contract with other companies and individuals to perform functions or services on our behalf. Our categories of service providers include: software maintenance, data hosting, sending email messages, project management and customer service. We necessarily have to share your Personal Data with such third parties as may be required to perform their functions. We take steps to ensure that these parties take protecting your privacy as seriously as we do, including entering into Data Processing Addendum, EU Model Clauses and/or ensuring they have EU-U.S. and Swiss-US Privacy Shield certification since all of our service providers are in the United States.

Third Party Service Providers

Third Parties that collect and share Personal Data with us regarding End Users or Customers:

TechnoHeight

TechnoHeight is a business process outsourcing company helping the Company with cost effective virtual assistance, lead generation & data management solutions. TechnoHeight collects key contact’s name, email address; data we collect for CRM and sales outreach. For more information, go their privacy policy at: https://technoheight.com/privacy-policy/

Instagram

Instagram is a social networking app made for sharing photos and videos from a smartphone. Similar to Facebook or Twitter, everyone who creates an Instagram account has a profile and a news feed. When you post a photo or video on Instagram, it will be displayed on your profile. Instagram is used to identify creators and followers/niche groups. For more information, go their privacy policy at: https://help.instagram.com/519522125107875?helpref=page_content

Facebook Pixel

Facebook pixel is code that we place on our site to help us track conversions from Facebook ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads—people who have already taken some kind of action on your website. Facebook is US-EU Privacy Shield certified. For more information, go their website at: https://www.facebook.com/business/learn/facebook-ads-pixel?ref=sem_smb&utm_source=GOOGLE&utm_medium=fbsmbsem&utm_campaign=G_S_Beta_AdvertiserPixelRefresh_Brand_US_EN&kenid=39422d7e-08b9-418b-9697-09063677dd3a&gclid=EAIaIQobChMIlbHMrvae2wIViPhkCh3yDwcxEAAYASAAEgIPJPD_BwE

LinkedIn Pixel

LinkedIn Pixel is a conversion tracking tool that gathers insights into post-click and view-through conversions of LinkedIn ads campaigns, giving the Company the ability to measure the impact and ROI of Company or client ads. LinkedIn data is processed in the United States and LinkedIn is US-EU Privacy Shield certified. For more information, go their website at: https://www.linkedin.com/help/linkedin/answer/67513/linkedin-conversion-tracking-overview?lang=en

Twitter Pixel

Twitter pixel is a conversion tracking tool for websites enables us or our Customers the ability to measure return on investment by tracking the actions users take after viewing or engaging with your on Twitter. Twitter processing is done in the United States and Twitter is US-EU Privacy Shield certified. For more information go their privacy policy at: https://business.twitter.com/en/help/campaign-measurement-and-analytics/conversion-tracking-for-websites.html

Google Analytics

Google Analytics collects information such as how often users visit our site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site, but in and anonymous form. Google Analytics collects only the IP address assigned to you on the date you visit this site and assigns a user ID code, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information.

Google uses this information to analyze your use of the website, to generate reports about website activities for website operators and to provide further services related to website and internet use. Google may also share such information with third parties to the extent it is legally required to do so and/or to the extent third parties process data on behalf of Google. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy and Data Processing Amendment. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. You may block Google Analytics on some browsers with the help of a browser add-on if you do not want us to use this website analysis. Google’s data processing takes place in the United States and Google has a Data Processing Agreement and is US-EU Privacy Shield certified. The add-on can be downloaded at: ' http://tools.google.com/dlpage/gaoptout?hl=en . For more information on Google Analytics and Google’s privacy practices, please review their privacy policy at https://www.google.com/policies/privacy/

Stripe

Its software allows individuals and businesses to receive payments over the Internet. Stripe provides the technical, fraud prevention, and banking infrastructure required to operate on-line payment systems. Processing takes place in the United States and Stripe is US-EU Privacy Shield certified. For more information, go their privacy policy at: https://stripe.com/us/privacy.

International Transfers

Our servers and operations are located in the United States. If you are providing your Personal Data to us directly to use our Services, we will transmit your data, including your Personal Data, to the United States in order to fulfill our contractual obligations to you.

How is my Data Protected?

We have implemented reasonable administrative, technical and physical security measures to protect Customer and Creator personal information against unauthorized access, destruction or alteration. For example:

SSL encryption (https) everywhere where we deal with personal data.
Data is kept on secure encrypted services, located in the US
Restricting staff access to personal data protected by password logs.
Regular staff privacy and security training
Pseudonymizing data to separate Customer Personal Data from other data.
Payments services are tokenized

However, because no security system can be 100% effective, we cannot completely guarantee the security of any information we store, process or transmit. We are committed to protecting your personal data. We put in place safeguards including robust and appropriate technologies, processes, and contractual arrangements, so that the data we have about you is protected from unauthorized access and improper use, and we will also not keep your personal data for longer than is necessary.

Payments Encryption:

Company utilizes only PCI-DSS compliant third-party payment processors to ensure the security of your personal information.

How long will we use your personal data?

We will keep Customer personal data only for as long as is necessary for the purposes set out in this privacy notice and to fulfill our legal obligations and defend against legal claims . We will not keep more data than we need. However, we do retain pseudonymized data that we separate from your Personal Data

Changes to Privacy Policy

Company reserves the right to amend this Privacy Policy at any time. If Company makes material changes to its Privacy Policy, we will notify you by (1) changing the Effective Date on our Privacy Policy and provide additional notification either (1) via email or other means as we may deem commercially reasonable.

Anderson X – Privacy

Singel 542

1017 AZ, Amsterdam, The Netherlands

Third Party Websites

We may link to other websites. When you click on one of these links, you are ‘clicking’ to another website. Company does not control the data collection or privacy practices of such third party sites. We encourage you to read the privacy policies of any third party sites, as their collection, use and storage practices and policies may differ from ours.

Questions

If you ever have any questions about our online Privacy Policy, please contact us. We respect your rights and privacy, and will be happy to answer any questions or concerns you might have. You may direct any such questions to our Data Protection Officer at [email protected]