Privacy Notice

This Privacy Notice provides information about the way MSL collects and processes your Personal Information.

If you have any questions about MSL’s collection of your Personal Information please contact the Publicis Chief Data Privacy Officer on privacyofficer@publicisgroupe.com. MSL can be contacted at: 1675 Broadway, 7th Fl, New York NY 10019.

Introduction

Any data collected through the MSL Fluency platform (the “MSL Fluency Platform”) including Personal Information (defined in Section II. Below), will only be used to (i) communicate with you regarding business opportunities; and (ii) identify and evaluate influencers and creators for business opportunities with MSL and/or its clients; and (iii) manage campaigns and contracts for which you are engaged by MSL or any MSL client. MSL is regarded as the data controller.

We take the protection of data privacy very seriously. All Personal Information collected will be treated as strictly confidential and will only be used as set out in this Privacy Notice. The applicable data protection laws shall be respected in full.

Therefore, please read this Privacy Notice thoroughly. If you disagree with the way Personal Information will be used by MSL, please do not use this MSL Fluency Platform or provide your Personal Information through linking your social accounts (e.g., Facebook, Twitter, Instagram, etc.), email, or other form of communication with MSL.

  1. Purpose of data collection
    The main purposes of collecting Personal Information through the MSL Fluency Platform is to (i) communicate with you regarding business opportunities; and (ii) identify and evaluate influencers and creators for business opportunities with MSL and/or its clients; and (iii) manage campaigns and contracts for which you are engaged by MSL or any MSL client.
  2. What Personal Information do we collect and how is it processed?
    Personal Information means any information relating to an identified or identifiable natural person (i.e. living individual).

    We collect and process the following Personal Information:

    1. Information from SocialEdge, Inc. dba CreatorIQ: The source of the information we use to initially contact you, such as your name, handle, and email address, was sourced from SocialEdge, Inc.’s platform (“CreatorIQ Platform”). To learn more about use of data on the CreatorIQ Platform please review their Terms of Use and Privacy Policy. With respect to the Personal Information available on the CreatorIQ Platform, SocialEdge, Inc. is the data controller.
    2. Information you provide to MSL: If you choose to link your social account(s) directly to the MSL Fluency Platform, specifically authorize your data to be used by MSL through the CreatorIQ Platform, or provide information directly to MSL, we will also have access to the following information: name, bio, interests, profile picture, email address, friends list, public posting activity, public conversations, engagement,followers, follower counts, metrics and other data related to your linked social account. In addition, if you are engaged for a business opportunity with MSL and/or its clients, we may also collect and process the following: billing information, campaign information (e.g. campaigns you have participated in, statistics regarding campaigns, etc.), and any other content you submit to the MSL Fluency Platform (e.g. media files, content to be published, etc.). With respect to the Personal Information that you provide to the MSL Fluency Platform and the Personal Information MSL collects directly from you, MSL is the data controller.
  3. How do we use your Personal Information and what legal ground(s) do we rely on?
    We collect and process your Personal Information for our and our clients’ legitimate business interests including:

    1. Identify and evaluate influencers and creators for business opportunities; and
    2. Communicate with influencers and creators regarding business opportunities.

    Where we or our clients contract with you for a campaign and/or other business opportunity
    we also need to process your Personal Information in order to perform and manage that contract (including metrics, invoicing, payments, recordkeeping etc.).

    We may also need to process your Personal Information in order to comply with our legal obligations (e.g. under tax, accounting or recordkeeping laws).

    Please note that you can “Remove” your linked social account at any time. You always have a choice concerning whether or not you “Connect” or “Remove” your social account. In addition, you can opt-out of inclusion in the MSL Fluency Platform by completing this Opt-Out page.

  4. With whom do we share Personal Information?
    We will share your Personal Information with SocialEdge, Inc. who provide services to us in hosting the MSL Fluency Platform. In addition, we will share your Personal Information with MSL clients in order to identify and evaluate your participation in a potential business opportunity and when you are engaged for a business opportunity. We will not disclose your Personal Information to anyone else under any circumstances except as otherwise stated in this Privacy Notice, to successors in title to our business, to establish, exercise or defend our rights, or where required by law.
  5. Who is processing the Personal Information?
    We have engaged SocialEdge, Inc. to help with data storage. Any processing of the Personal Information by SocialEdge, Inc. is in accordance with our instructions.

    If the services of third parties for the technical maintenance, administration or processing of data are required, the Personal Information will be accessed by these parties only to the extent that is required to ensure a smooth and secure technical handling of the MSL Fluency Platform and in compliance with applicable law, including with respect to data confidentiality, privacy and security.

  6. Accessing, Editing, Updating or Deletion of your Personal Information:
    Please contact contactprivacy.mslfluency@mslgroup.com if you want to access any Personal Information stored about you in our records. We will honor your legal right to view your Personal Information in accordance with applicable privacy law. If you think that any of the Personal Information collected through the MSL Fluency Platform is incorrect, confusing or incomplete, please contact contactprivacy.mslfluency@mslgroup.com. You may also ask us to erase, restrict or port your Personal Information and you may tell us if you object to our use of your PersonalInformation. In addition, you can opt-out of inclusion in the MSL Fluency Platform by completing this Opt-Out page.

    You are not required to provide any Personal Information to MSL unless our clients or we have a contractual relationship with you. If you decide not to provide Personal Information, or ask for it to be erased, then you may not be eligible or discoverable for potential business opportunities through the MSL Fluency Platform.

  7. Retention Periods for Personal Information
    We will store Personal Information in accordance with our applicable data retention requirements and corporate policies. MSL will not keep your data for any longer than necessary for the purpose for which it was obtained. Where we have a contractual relationship with you then this period will be at least for the applicable legal limitation period to enable MSL to respond to any contractual claims. Accounting, tax and recordkeeping laws may also require MSL to retain data for longer periods to comply with those laws.
  8. Data Security
    We use a variety of methods, such as firewalls, intrusion detection software and manual security procedures, to secure your data against loss or damage and to help protect the accuracy and security of Personal Information and to prevent unauthorized access or improper use. If you think that the MSL Fluency Platform or any Personal Information is not secure or that there has been unauthorized access to the MSL Fluency Platform or your Personal Information, please contact contactprivacy.mslfluency@mslgroup.com immediately.
  9. Confidentiality
    Please note that we treat Personal Information as strictly confidential.
  10. Data Transfers
    Your Personal Information may be accessed by MSL employees working in different countries within MSL, including, but not limited to the US, India, and Australia, which are not considered to have the same level of data protection as in the EU. However, we ensure all data transfers comply with applicable legal requirements (for example under intercompany agreements with appropriate contractual protections). Should you wish to know more about how data is protected or wish to request a copy of the contractual protections please contact privacyofficer@publicisgroupe.com.
  11. Use of cookies
    A “cookie” is a small data text file that is placed in your browser and allows MSL to recognize you each time you visit the MSL Fluency Platform (customization, etc.). Cookies themselves do not contain any Personal Information, and MSL does not use cookies to collect Personal Information.
  12. Notification of changes
    Any changes to this Privacy Notice will be promptly communicated on this page and you should check back to see whether there are any changes. Continued use of the MSL Fluency Platform after a change in the Privacy Notice indicates your acknowledgement and acceptance of the use of Personal Information in accordance with the amended Privacy Notice.

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  13. Further Information
    For further information on MSL, please visit our website – https://mslgroup.com/.

    If you consider that we are not complying with this Privacy Notice or if you have any questions in relation to this Privacy Notice, please contact privacyofficer@publicisgroupe.com. You may also lodge a formal complaint with your competent data protection authority.

Updated: April 22, 2019