Privacy notice

SEENIT PRIVACY NOTICE

SEENIT respects the privacy of every person who uses SEENIT and we are committed to ensuring high standards of data protection compliance in everything we do.

1 WHAT IS THE PURPOSE OF THIS NOTICE?

1.1 This privacy notice applies to all services we provide across our apps, the web, social media and elsewhere (the “SEENIT Services”). It explains our approach to how we use any personal information that is provided to or collected by us in connection with your use of the SEENIT Services or any other interaction you have with SEENIT, including who we share it with.

1.2 Please be aware when you use the SEENIT Service to join or submit content to one of our brand Partner’s Projects, we will need to pass them some of your personal information and the content, as explained below. At that point please note that their privacy notice will also apply and you should check that you are happy with how they will store and use your personal information before you join a Project.

1.3 This privacy notice also sets out the legal basis on which we are permitted to process your personal information, your rights in respect of our use of your personal information, how you can verify what personal information is held by us, and how you can request that we delete, update or transfer it.

1.4 This privacy notice is intended to assist you in making informed decisions when using the SEENIT Services. Please read it thoroughly and note that it should be read in conjunction with our Terms of Use.

2 WHO ARE WE AND WHAT DO WE DO?

2.1 The SEENIT Services are operated by SEENIT DIGITAL LIMITED (“SEENIT”, “we” “us” or “our”).

2.2 SEENIT Limited is an English company with company number: 08838909 and whose registered office address is Stapleton House Block A, 2nd Floor, 110 Clifton Street, London, United Kingdom, EC2A 4HT.

2.3 The SEENIT Service enables brands to create videos with the help of various participants and contributors. To do this, we partner with brands (our brand “Partners”) to allow you to submit content to those brand Partners for their use on a particular project (“Project”). When you join a Partner’s Project via the SEENIT Service we will need to share your contact details with the relevant Partner so they can contact you about the Project as explained below. They will hold and deal with your personal information in accordance with their own privacy notice.

3 HOW TO CONTACT US?

3.1 If you have any questions about this privacy notice or want to exercise your rights, please contact us by:

  • sending an email to dataprotection@seenit.io; or
  • writing to us at Seenit Digital Limited, 9th Floor, 9 Appold Street, London, EC2A 2AP

4 WHAT PERSONAL INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?

4.1 Personal information may be collected from you in the following ways (see in the following section for information on how and why we use the information):

Information you voluntarily provide to us directly.

We collect and maintain personal information that you voluntarily submit to us during your use of the SEENIT Services or other contact with us. For example when you sign up to use the SEENIT app, register on the website, submit content contributions, post comments or for example use our chat function.

This may include registration information (some of which will be optional):

  • Name;
  • Email Address;
  • City or Country;
  • Phone number;
  • Company name;
  • Profile picture;
  • Social media username or handle.

And may include information in the content you submit:

  • Your image or likeness (or that of others who also appear) in the content you upload;
  • Other information about yourself (or that of others who also appear) in the content you upload;
  • Other information about yourself (or that of others who are also mentioned) in the messages you send to us.

Further information you voluntarily provide to us through social media log in.

If you sign up or register using our social media (such as Facebook) login functionality, we collect and maintain personal information from your social media profile that you voluntarily agree to be provided to us.

This may include:

  • Name;
  • Email address;
  • Date of Birth (not retained or used);
  • Gender (not retained or used);
  • Profile picture;
  • Facebook profile ID;
  • Social media usernames or handles.

Information we collect through your use of the SEENIT Service.

We collect, through our use of cookies, pixels, beacons, log files or other technologies, information about your use of and navigation around the SEENIT Services, including information regarding your mobile device or the computer hardware and software used to access the SEENIT Services.

This may include the following:

  • IP address of device(s);
  • browser type;
  • operating system and device type;
  • your device’s IMEI number;
  • the MAC address of the device’s wireless network interface;
  • the mobile phone number used by the device;
  • metadata relating to the content you submit including upload times, dates and location;
  • mobile network information;
  • your mobile operating systems;
  • your time zone setting;
  • access times and dates;
  • referring website addresses;
  • navigation around the site;
  • links followed, including in emails;
  • time spent on pages or viewing content;
  • types of content viewed and shared;

Please see the Data Analytics and Insight section below and our Cookie Policy for further information.

Information we receive from third party brand Partners.

In some situations we may receive your email address from your employer or other third party company who validly holds your details and is permitted to share them with us. This will be used solely to invite you to take part in their Project. We will not store or use your email address for any other purposes.

5 HOW DO WE USE YOUR PERSONAL INFORMATION?

5.1 We use the personal information we collect from or about you for the following purposes:

Provision of the SEENIT Service.

We use your registration information to register you and create your user account, log you in, verify who you are and otherwise to provide you with our access to the SEENIT Services.

What is our legal basis?

It is necessary for the performance and fulfilment of the contract between us to provide you with services for which you have registered.

Sharing your registration data with brand Partners.

Where you join a particular Project, we will share your name and email address with the relevant brand Partner. This is to enable them to contact you about their use of the content you submit and check on rights clearances etc. The rest of your registration information will be available to the relevant brand Partner to enable them to review and select content for their use.

What is our legal basis?

It is necessary for the performance and fulfilment of the contract between us to provide you with services for which you have registered. As such, when you submit information for these purposes we will take that as consent to use your personal information in this way.

Use of the content you submit.

Where you submit content (e.g. videos or photos) to a Project, this content may contain your personal information, or those of others who also appear or are mentioned, in the form of images or other information that may identify you or them. This information is used inherently when we or the relevant brand Partner use the content in a Project. We may also use this content to promote SEENIT Service and demo the functionality and content contributions we receive.

What is our legal basis for doing this?

It is necessary for the performance and fulfilment of the contract between us to provide you with services for which you have registered.

It is in our legitimate interest to use your content information to demo and promote our services. To the extent this content contains sensitive personal data (for example about your sexuality, religion, health or political views) we will take the fact that you submitted the content to us as consent to use your content and the personal information in this way, and confirmation that you have the consent of any others appearing in the content.

Sharing your content with brand Partners

Where you submit content for a particular Project, we will share this content with the relevant brand Partner. This is for their independent use in accordance with the Terms of Use of the SEENIT Service and the Project specific Content Terms which you can access when you sign up for a Project.

What is our legal basis for doing this?

It is necessary for the performance and fulfilment of the contract between us to provide you with services for which you have registered. As such, when you submit content for these purposes we will take that as consent to use your content and the personal information in this way, and confirmation that you have the consent of any others appearing in the content.

Derivative content

Where you submit content to us, we create transcripts and other derived metadata and tags relating to the content from video and image analysis/recognition, such as:

  • transcripts;
  • location / type of scene description (inside/outside/crowds etc);
  • emotions, sentiment, mood depicted;
  • gender and other physical (traits such as facial hair).

This information is logged against the videos or content, not the users, and enables us to analyse, categorise and search content. This derivative information will be available to the relevant brand Partner to enable them to review and select content for their use.

What is our legal basis for doing this?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will not constitute “personal information” that is regulated under data protection laws.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best services to you and our other users.

Inviting you to take part in a Project.

Were we have received your email address from a brand Partner or from your employer who validly holds your details and is permitted to share them with us, we will use this information solely to invite you to take part in their Project.

What is our legal basis for doing this?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.

Recommending further Projects to you.

We analyse information about you and your content to create insights about what further projects may be of interest to you. We use these insights to identify and recommend further projects from other brand partners that we think may be of interest to you.

What is our legal basis for doing this?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can and to give you the opportunity to take part on other projects that may be of interest to you.

Data Analytics and Insight.

We analyse usage information including that which we observe about users from their interactions with our SEENIT Service, and/or the content submitted or viewed.

This information is used to create insights about usage and viewing habits across our services. By using this information, we are able to measure the effectiveness of our service and how users use SEENIT Services and improve the functionality of our services.

What is our legal basis for doing this?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will not constitute “personal information” that is regulated under data protection laws.

However, our collection and use of such anonymised personal information may still be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best services to you and our other users.

Sending you newsletters or other marketing communications (from SEENIT) for which you have subscribed.

Where you have given your consent we use your personal information to send you marketing materials about SEENIT products and services which we think you might be of interest to you.

What is our legal basis for this?

We rely on your consent to be able to do this – given at the time that you request the marketing communications.

Sharing information with third party processors.

We may share your personal information with third party processors in order to provide the SEENIT Services to you. This includes companies that for example who host our servers or manage or databases for us, or provide other technology solutions. They have no independent rights to use your data and are strictly controlled by us under contract.

What is our legal basis for doing this?

It is in our legitimate interests to share your personal information in such a way to ensure that we provide the very best service we can to you.

Service Administration.

We may also use your personal information to:

  • help improve the SEENIT Services; and
  • contact you to answer any queries you may have sent to us or to seek feedback from you.

What is our legal basis for doing this?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can to you.

Business administration, record keeping and legal compliance.

We use your personal information for the following business administration and legal compliance purposes:

  • to comply with our legal obligations;
  • to enforce our legal rights;
  • protect rights of third parties; and
  • in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Use in this way may involve us sharing your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

What is our legal basis?

It is in our legitimate interest to ensure that we keep our records up-to-date and use them in connection with a business transition, enforce our legal rights, or to protect the rights of third parties. Otherwise, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us or other laws regulations that we are subject to.

6.1 Where use of your personal information by us requires your consent, you may provide such consent:

  • at the time we collect your personal information by following the options we provide;
  • by submitting information or content with a clear understanding of what it will be used for; or
  • by informing us using the contact details set out in this privacy notice.

7 USE OF COOKIES

7.1 The SEENIT Services may use certain cookies and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

8.1 The SEENIT Services may contain links to third party brands, websites and services. Please remember that when you use a link to go from the SEENIT Services to another website or you request a service from a third party, this privacy notice no longer applies.

8.2 In particular be aware when you use the SEENIT Service to join or submit content to one of our brand Partner’s Projects, we will need to pass them some of your personal information as explained below. At that point please note that their privacy notice will also apply and you should check that you are happy with how they will store and use your personal information before you join a Project.

8.3 Your browsing and interaction on any other website, or your dealings with any other third party brand Partner and/or service provider, is subject to that website’s or third party’s own rules and policies.

8.4 We do not monitor, control, or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

9 TRANSFERS OUTSIDE THE EEA

9.1 Although our offices and servers are based within the United Kingdom, in certain circumstances we may transfer your personal data outside the EEA to processors or subcontractors working for us, including in the USA, in connection with our business or for legal reasons. We will ensure that the transfer is lawful and that there are appropriate security arrangements.

9.2 If the European Commission has decided that a country does not provide an adequate level of protection in relation to data that is transferred there, we will enter into an agreement ensuring appropriate and suitable safeguards with our group member, processors or other transferee, or that there is another approved transfer mechanism in place. This may be via binding corporate rules or on standard terms adopted by the Information Commissioner and approved by the European Commission.

10 HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We do not keep your personal data for any specific period but will not keep it for longer than is necessary for our purposes. In considering how long to keep it, we will take into account its relevance to our business and our legal and regulatory obligations.

11 CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL INFORMATION

11.1 We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect it from loss, misuse or alteration.

11.2 We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

  • unauthorised access;
  • improper use or disclosure;
  • unauthorised modification; and
  • unlawful destruction or accidental loss.

11.3 All our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the SEENIT Services.

12 HOW TO ACCESS YOUR INFORMATION AND YOUR OTHER RIGHTS?

12.1 You have the following rights in relation to the personal information we hold about you:

Your right of access.

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Your right to data portability.

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or ask us to transfer this to a third party of your choice.

Your right to object. You can ask us to stop processing your personal information, and we will do so, if we’re:

  • relying on our own or someone else’s legitimate interests to process your personal information except if we can demonstrate compelling legal grounds for the processing;
  • processing your personal information for direct marketing; or
  • processing your personal information for research unless such processing is necessary for the performance of a task carried out in the public interest.

Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, and it produces a legal effect or similarly significantly affects you unless such profiling in necessary for entering into, or the performance of, a contract between you and us.

Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information for certain uses, you have the right to withdraw that consent at any time for those uses.

Your right to lodge a complaint with the supervisory authority. If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

13 CHANGE TO THIS PRIVACY NOTICE

13.1 We may make changes to this privacy notice from time to time

13.2 To ensure that you are always aware of how we use your personal information we will update this privacy notice from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We may notify you by email of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how we use your personal information.

14 CHILDREN

14.1 You are required to be at least 13 years old to use the SEENIT Service so we do not intentionally collect personal information from anyone under 13, and no one under 13 should attempt to submit any personal information to SEENIT. Should we discover that any such personal information has been submitted we will not use such information or content containing it without further consent. Where you are aged between 13 and 18 you can download the app and register with SEENIT but we will typically ask for parental consent before accepting any uploads of content via our SEENIT Service and we may need you and your parent or guardian to sign a separate consent document,

Last updated: May 2018