Seenit Privacy Notice

 

We respect the privacy of every person who registers with our Seenit app and/or uses the services made available by us from the Seenit app (the “Seenit Service”) and we are committed to ensuring a safe online experience.

  1. Purpose of this Privacy Notice

This privacy notice explains our approach to any personal information that you might supply to us (or that might be collected from you) in connection with your use of the Seenit Service and sets out your rights in respect of Seenit’s processing of your personal information.   Please be aware where you use the Seenit Service to join one of our Partner Projects, we will need to pass them your personal information. At that point please note that their privacy notice will also apply and you should check that you’re happy with how they will store and use your personal information before you join a Project. For more information click here.

This Seenit privacy notice will inform you how you can verify which of your personal information is collected by us through the Seenit Service and how you can request that we delete, update or transfer it.

This privacy notice is intended to assist you in making informed decisions when using the Seenit Service. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Terms of Use.

Please also note that this privacy notice only applies to the use of personal information collected by us from your use of the Seenit Service or during your communications with us. It does not apply to personal information collected during your communications with third parties.

  1. Who are we and what do we do?

The Seenit Service is operated by Seenit Digital Limited (“Seenit”) and the service enables brands to create videos with the help of various participants. For more information about Seenit click here. 

Seenit is the data controller responsible for your personal information. Seenit is registered at the UK Information Commissioner’s Office with registration number:  ZA172236

Seenit is an English company with registered company number: 08838909 and whose registered office address is 111 Piccadilly, Manchester, M1 2HY, United Kingdom.

We partner with brands to allow you to submit content directly to those brands for their use.  When you join a Brand Project via the Seenit Service we will also need to share your contact details with the relevant Partner so they can contact you about the Project.  They will hold and deal with your personal information in accordance with their own privacy notice.

  1. How to contact us?

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

  • sending an email to info@seenit.com;
  • writing to us at Seenit Digital Limited, 111 Piccadilly, Manchester, M1 2HY, marking your letter for the attention of The Account Management Team.
  1. What personal information do we collect and how do we collect it?

Our primary goal in collecting personal information from you is to help you use our Seenit Service and to allow us to provide services and features that most likely meet your needs. In order to do so personal information may be collected from you in the following ways:

  • Information you voluntarily provide to us. For more information click here.

We collect and maintain personal information that you voluntarily submit to us during your use of the Seenit Service (e.g. when registering or creating a profile, during the course of email exchanges with customer support).

In particular, when you initially sign up and create an account we require the following personal information from you:

  • name;
  • e-mail address;
  • password;
  • date of birth; and
  • gender

Where you choose to log-in using Facebook, we also collect your Facebook ID, and your then-current Facebook profile photo to use on your Seenit profile.

Through your use of the Seenit Service (for example when submitting videos) we may collect the following additional personal information from you:

  • your image or likeness; and
  • information about your expected likes or interests.

We may also collect information about your likes or interests where you tell us this information through your Seenit account.

If you contact us, we may collect additional information from you such as a telephone number.

  • Information we collect through your use of Seenit. For more information click here.

We may collect through our use of cookies, pixels, beacons, log files and other technologies personal information regarding your mobile device used to access the Seenit Service. This may include the following:

  • Project/content identifier (typically provided on an ad for our service)
  • type of mobile device you use;
  • 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 access times and dates;
  • mobile network information;
  • your mobile operating systems;
  • the type of mobile browser you use;
  • your time zone setting; and
  • location information – we may use GPS or other technology to determine your current location

This personal information allows us to deliver more helpful information, services and tools and to verify that the content you are submitting is legitimate. Please see use of cookies for further information.

  • Information we collect from third parties. For more information click here.

We may also combine personal information that we collect through your use of the Seenit Service with personal information that you have provided to third parties and in respect of which you have given the third party permission to share with Seenit (for example you may give the brands on a particular project permission to share data back with us); and/or b) we have obtained from a search engine search (for example we may use search engines to check if the video you’ve uploaded is already available on the internet).

  1. How do we use your personal information?

We collect and use your personal information to operate the Seenit Service efficiently and to deliver you the very best service. In particular, we may use your personal information for the following purposes:

  • Provision of the Seenit Service. For more information click here.

We shall use your personal information to provide the Seenit Service to you and to help us identify appropriate Partners to work with and improve our offering.  This will include using and analysing your personal information to suggest appropriate Partner projects to you as well as to our Partners.

What is our legal basis?

It is necessary for us to use your personal information to provide the Seenit Service to you and perform our obligations in accordance with any contract that we may have with you. It is also in our legitimate interest to use your personal information in such a way to ensure that we provide the very best service we can.

  • Profiling. For more information click here.

We shall use your personal information for profiling purposes in order to decide whether particular brand projects may be appropriate for you.

What is our legal basis?

Where we carry out such profiling we do so based on our legitimate interests on the basis that your rights don’t override these.  Please be aware you can object to such profiling at any time by contacting us.

  • Service administration. For more information click here.

We may use your personal information to:

o          develop and improve the Seenit Service;

o          send you administrative e-mails or push notifications  about the Seenit Service; and

o          contact you to answer any queries you may have.

What is our legal basis?

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.

  • User Data Analysis. For more information click here.

We may use your personal information on an anonymised basis to analyse, benchmark and conduct research on users and their interactions with the Seenit Service and Seenit.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis as the information will no longer constitute personal information. However where your personal information is in a pseudonymised form, it is in our legitimate interest to continually evaluate that personal information to ensure we are aware of market trends and ensure that the services we provide and the projects available through the Seenit Service are relevant to you.

  • Internal record keeping and legal compliance. For more information click here.

We may use your personal information for internal record keeping purposes and to check you comply with the Terms of Use.

What is our legal basis?

It is in our legitimate interest to ensure that we keep our records up-to-date in order to monitor who uses the Seenit Service, to comply with our legal obligations and to monitor your compliance with the Terms of Use.

  • Marketing by us. For more information click here.

Where you consent, we may use your personal information to contact you by e-mail about other projects which are available through the app.

What is our legal basis? Your consent.

  • Sharing information with our Partners. For more information click here.

Where you consent and agree to submit your videos to a partner Partner, we will share your contact details with that Partner so they can contact you about using your video content. 

What is our legal basis? Your consent.

  • Sharing information with third party processors. For more information click here.

We may share your personal information with third party processors in order to provide the Seenit Service and associated products and services to you.

What is our legal basis?

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

  • Sharing information with professional advisors, governmental authorities & potential purchasers. For more information click here.

We may share your personal information with professional advisers or governmental or regulatory authorities:

  • to enable them to process your personal information on our behalf in a manner consistent with this privacy notice;
  • to comply with our legal obligations;
  • to enforce our legal rights; or
  • protect rights of third parties.

Your personal information may also be shared with prospective buyers if we go through a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

What is our legal basis?

It is in our legitimate interest to share your personal information with such third parties to enable them to process your information on our behalf, to comply with and/or enforce our legal rights and obligations, to protect the rights of third parties and to facilitate business transitions.

Any other purposes for which we wish to use your personal information will be notified to you from time to time including the legal basis of such use.

  1. How do we obtain your consent?

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

  • at the time we collect your personal information following the instructions provided; or
  • by informing Seenit by e-mail using the contact details set out in this privacy notice.
  1. Children

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 delivered to any of the sites, we will remove that personal information as soon as possible.  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 Service and we may need you and your parent or guardian to sign a separate consent document,

  1. Third Party Links and Services

The Seenit Service contains links to third party websites and services. Please remember that when you submit content via Seenit to a brand the privacy notice no longer applies of the relevant Partner will apply to the content you submit. For more information click here.

Your interaction on any other website, or your dealings with any other third party service provider, including our Partners, is subject to that third party service provider’s own rules and policies. By joining a Project a Partner you agree that we may share your contact details with them and that they will hold that information and your content in accordance with their own privacy notice.

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 that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This privacy notice applies solely to personal information collected by us through the Seenit Service and does not apply to these third party websites and third party service providers.

  1. Transfers outside the EEA

Although our offices and servers are based within the United Kingdom, in certain circumstances we may transfer your personal information, for the purposes listed above, to our third party data processors that are located in the US, whose laws are not recognised by the EU Commission as providing an adequate level of protection to personal information.  Where we do transfer your data to the US we have ensured that appropriate arrangements (including EC approved Model Clauses) are in place with those third parties to ensure the transfers are legitimate.

  1. How long do we keep your personal information for?

We keep your personal information only for as long as necessary to fulfil the purpose it was collected for, where we need to in relation to proving legal relationships or to comply with any of our legal obligations,

  1. Confidentiality and security of your personal information

We are committed to keeping the personal information you provide us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration. For more information click here.

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.

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 Service.

  1. How to access your information and your other rights?

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

  • Your right of access. For more information click here.

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. For more information click here.

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. For more information click here.

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. For more information click here.

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. For more information click here.

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.

  • Your right to object. For more information click here.

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; or
  • processing your personal information for direct marketing.
  • Your rights in relation to automated decision-making and profiling. For more information click here.

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 Seenit.

  • Your right to withdraw consent. For more information click here.

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

  • Your right to lodge a complaint with the supervisory authority. For more information click here.

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, please do contact us.  You can also 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.

To exercise your legal rights please notify us using the contact details provided in section 3 of this privacy notice.

  1. Change to this privacy notice

We may make changes to this privacy notice from time to time. For more information click here.

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 e-mail of any significant changes. However, we encourage you to review this privacy notice periodically to be informed of how Seenit uses your personal information.

Last Updated April 2017

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