CREATORDEN PRIVACY NOTICE

Introduction

CreatorDen Pazarlama Teknolojileri Ticaret A.Ş.  (“CreatorDen” or “We”, “us”), respects your privacy and we are committed to protecting your privacy through our compliance with this policy. 

CreatorDen enables brands identify, activate and collaborate with brand-appropriate influencers in terms of target auidence, marketing goals and social media performance. CreatorDen prioritizes real engagement, engaging content, measurable campaign goals and relevant brand communication for high performing influencer marketing campaigns. In order to ensure a data oriented approach for influencer marketing for both campaign and influencer success, we track and analyse relevant social media data.

This policy describes our practices in connection with information that we collect through our SocialHub Influencer Analysis and CreatorDen Link Shortener platforms and applications as well as CreatorDen’s privacy practices in relation to the use of CreatorDen’s websites.

Our contact details 

You can contact us at team@creatorden.com for any issues regarding our Privacy Policy.
Keep in mind that you can find recent information on our company activities at our official website https://creatorden.com
Our office is located at Levent Loft Büyükdere Cad. Esentepe/Şişli, İstanbul, Turkey
You can contact Ozan Tabak (ozan@creatorden.com) for any privacy related questions.


Which one are you?

This policy applies to the following classification of individuals that interact with CreatorDen:

CUSTOMERS: Customers are individuals that are employees or associates of CreatorDen’s direct customers (for example, event planners, brands and organizations), including customer personnel that has access to  CreatorDen project materials or SocialHub links.

INFLUENCERS: Influencers are individuals that own specific and active social media accounts used to create, publish or distribute content  that have over a minimum limit  of followers or subscribers and average engagement(likes, comments, retweets etc.) such as celebrities and social media content creators.

USERS: Individuals, who interact with our Websites and Applications or digitally and publicly interact with Influencers by, but not limited to, subscribing, following, commenting or liking content

What type of information we have? 


Under the General Data Protection Regulation (GDPR), the main lawful bases we rely on for processing this information are: 

  • We have a legitimate interest in processing influencer’s personal data. As mentioned below in detail, our processing activities benefit both parties as they bring influencers and marketers together. Shortly, influencers profit from their social media activities, therefore, interests of influencers are not overridden by the interests or fundamental rights and freedoms of the data subject. 
  • We process customer and user data as processing is necessary for the performance of a contract to which they are a party or in order to take steps at their request prior to entering into a contract. Our processing is limited to our contractual relationship.
  • Finally, our processing is necessary for compliance with a legal obligation to which the controller is subject. These legal obligations include, but not limited to, issuing invoices, responding to duly authority requests and data security.

In detail;

We establish collaborations between social media content creators, celebrities, influencers and collaborators which include brands,organizations, companies, institutions and associations. Collaborations may include but not limited to content creation, content production, publishing content on owned social media channels, online interactions such as commenting or liking, digital marketing,digital content distribution.

FOR INFLUENCERS:
For us to create successful and relevant collaborations  understanding your audience is crucial. CreatorDen collects the data below to understand and track your performance, look for a match between yours and collaborator’s target audience  to suggest for or against your inclusion to a marketing campaign that will benefit you through financial gain, free products or free services in return for attending an event, posting branded content or posting a review in parallel to collaborator’s marketing objectives. CreatorDen will never assign a marketing campaign to you before taking your consent and approval to be involved in and with that specific campaign and brand. CreatorDen uses your publicly available data to name you or not name you as a potential candidate for a marketing campaign.

In order to determine which social media creators, influencers and celebrities CreatorDen should recommend to the collaborator, CreatorDen collects public data from Instagram accounts. The Instagram accounts CreatorDen collects data from are limited to the following:

a)Public accounts with over 1000 followers
b)Public accounts that follows or engages with public accounts over 1000 followers

From the accounts specified above, we may collect the following data:
a)Follower count
b)Following count
c)Profile photo
d)Number of posts shared
e)Bio, email, phone number
f)Shared and not archived public content
g)Captions, mentions, hashtags, accessibility info of these content
h)Publicly available number of likes, comments, views 
i) List of people engaged with the content
j) List of people that follows a specific account
k)Number of impressions, link clicks, reach, saves of a specific content
l) Types of objects included in your content
i)Username/Account ID/Channel ID

FOR USERS:

a)Username
b)Profile photo
c)Shared and not archived public content
d)Bio or description
e)Captions, mentions, hashtags, accessibility info of these content

CreatorDen uses machine learning and artificial intelligence appliances to analyze accounts that interact with Influencers to facilitate relevant marketing collaborations. CreatorDen uses pseudonymization and anonymization techniques to protect your privacy, only generate general statistics describing an audience but not an individual. We use your data to deliver collaborations that you are interested in rather than irrelevant marketing offers through branded content.     

FOR CUSTOMERS:

a)Name and surname

b)Signature

c)Position in the company

d)Communication details (e-mail address, company address, phone number)


How we get the information and why we do we have it

We may collect information in a variety of ways, including:

a)From you directly.

b)Through crowdsourcing

c)Through your business partners.

d)From other sources: We may receive information from other sources, such as public databases; joint marketing partners; social media platforms; or other third parties.

e)Through cookies

What we do with the information 

a)Data storage and administration;

b)Data security;


FOR INFLUENCERS:

c)Match you with appropriate collaboration opportunities 

d)Use it to contact you through your preferred contact channel

e)To share a summary of these data to a collaborator CreatorDen may or may not be in partnership with.

f)To share performance analysis to specific collaborators that already collaborated with you on that specific content  

g)List content that is created in or for a specific collaborator or event. 


FOR INFLUENCERS AND USERS:

h)Calculate the number of unique users that interacts with or follows a roster of Influencers

i)Make predictions using Artificial Intelligence and Machine Learning techniques about you or your audience in terms of but not limited to demographic breakdown, interest verticals, location breakdown.

We may share INFLUENCER information with CUSTOMERS to plan, execute or report on marketing campaign activities. CreatorDen will not be sharing pseudonymised or non pseudonymized USER individual data with any third party business partners or CUSTOMERS. 

FOR CUSTOMERS:

j)Manage contact lists to be able to communicate with you when necessary

k)Perform and draft contracts

l)Provide support when necessary

How we store your information

CreatorDen is a technology company, looking to use the best technology available for its services. CreatorDen uses various services that stores your data inside European Economic Area. 


CreatorDen intends to keep the data for INFLUENCERS as long as their accounts are public, published content in the last 12 months,not actively participating in a collaboration through CreatorDen.


CreatorDen intends to keep pseudonymized USER’s username data associated with a specific INFLUENCER until the influencer is no longer active or have the requirements to be classified as an INFLUENCER. CreatorDen destroys any photos or content owned by a USER after 1 year it has been initailly processed.

Third Party Cookies

With respect to analytics, we use cookies from third-party service providers. For each third party cookie used, you can find below a description and a link leading you to the privacy policies of these third parties for further inquiries. We use the following third party cookies:

Google Analytics

This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

  1. These cookies are called _utma, _utmz, _ga, _gid and attribution_x_
  2. For more information on Google’s privacy and cookie policy, please visit Google’s privacy policy https://policies.google.com/privacy.

Hotjar

CreatorDen uses “HotJar” for creatorden.com and sosy.al. We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback.

Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor CreatorDen will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy here https://www.hotjar.com/legal/policies/privacy

You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this https://www.hotjar.com/legal/compliance/opt-out

Facebook

CreatorDen uses Facebook’s Pixel for cden.co ReMarketing and audience analysis purposes. Facebook Pixel allows us and our partners to serve you relevant ads according to the links you clicked earlier through links collaborating celebrities, influencers, social media content creators share on social media platforms.  

Facebook uses cookies and other technologies to collect data on our users’ behaviour and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). CreatorDen may give access to third party business partners to the audiences created through Facebook Pixel with the same intent explained above. CreatorDen never intends to use this information to identify individuals, using it only for pseudonymized user persona targeting, in parallel to what Facebook Pixel tool offers. 

For further details, please see Facebook’s privacy policy here https://www.facebook.com/policy.php

Your data protection rights

Under data protection law, you have rights including:

Your right of access – You have the right to ask us for copies of your personal information. 

Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 

Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances. 

Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances. 

Your right to object to processing – You have the the right to object to the processing of your personal data in certain circumstances.

Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at  team@creatorden.com if you wish to make a request. Remember that requesting a complete removal of your data could result us not to carry on our services at your disadvantage.   We will be granting access to requested documents in 30 days. 

How to complain

You can complain to a supervisory authority if you are unhappy with how we have used your data. As we are not based in the EU, you may complain to the supervisory authority of your country.