INFLUENCER PRIVACY AND COOKIES POLICY

This Privacy Policy applies to the processing of personal data likely to be carried out by Ykone SAS relating to influencers (the “Influencers”) within the meaning of the French Influencer Act 1 which define them as natural or legal person who, for a fee, mobilize their notoriety with their audience to communicate to the public, by electronic means, content aimed at promoting, directly or indirectly, goods, services or any cause to deploy the business influence activity electronically.

As part of the operation of its Campaygn solution, Ykone SAS only processes personal data concerning Influencers who have at least 5000 followers and whose profiles are made public on social networks. Ykone SAS takes care, when processing personal data concerning the Influencers concerned, to comply with the applicable regulations, including the Data Protection Act of January 6, 1978 amended by Law No. 2004-801 of August 6, 2004 and European Regulation No. 2016/ 679/EU of April 26, 2016 (GDPR).

The purpose of this Privacy Policy (hereinafter the “Policy”) is to inform Influencers whose personal data may be processed by Ykone SAS in the context of the operation of its Campaygn solution and more specifically of the methods of processing carried out and the rights they have.

The persons concerned are invited to regularly read this Policy.

ARTICLE 1. RESPONSIBLE FOR PROCESSING & CONTACT DETAILS

The controller of this personal data is:

Ykone SAS, 3 Rue Moncey, 75009 Paris, registered in the Paris Trade and Companies register under number 508 497 294.

Ykone owns the site https://app.campaygn.com

Campaygn is a platform that connects customers and influencers on social networks (“Campaygn”). Campaygn allows customers to find and track influencer activity.

The data subject may contact Ykone at the following address: data@ykone.com

https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000047663185

ARTICLE 2. SUBCONTRACTOR

Ykone can also act as a subcontractor on behalf of its customers, for part of the processing carried out through the use of Campaygn. For these processing operations (see Article 3), Ykone acts on behalf of its client who is the controller.

ARTICLE 3. METHODS OF COLLECTION & PROCESSED PERSONAL DATA

3.1 Methods of collecting personal data

Ykone collects personal data relating to Influencers from information made public when creating an account on social networks (the “Source Sites”).

Ykone may also collect personal data about users of the Campaygn website, including by depositing and reading cookies on its terminal in accordance with the procedures provided for in Article 9.

In the event that the Influencer has chosen the option of connecting his profile to Campaygn through Phyllo platform, as service provider, the influencer agrees to inform and to connect features about his login through Phyllo including Instagram, TikTok and YouTube login. The influencer agreed that his/her personal information are shared with this platform to create his/her account.

3.2Personal data collected from Source Sites

The categories of personal data processed by Ykone, insofar as they are made available to the public on the Internet, are the following:

● The data subject’s name
● The post data subject’s social network identifier and associated data
● That have been shared publicly on the data subject’s social networks
● The number of followers
● The data subject’s country of residence
● The email address (if mentioned on the data subject’s social network account)

Ykone processes this data to provide more information about the data subject’s profile to brands and customers of the Campaygn solution, in particular:

● Topics covered by the data subject (fashion, sports, beauty, etc.);
● Brands mentioned by the data subject
● Audience data and statistics relating to the data subject (equivalent media,
average engagement rate, deliverable price, etc.)

3.3 Personal data transmitted for the purpose of exercising rights

When the person concerned by the processing exercises their rights of access, rectification, erasure, limitation or opposition in accordance with Article 7 of this Policy, Ykone will collect their e-mail address, name, first name and, if applicable, proof of identity so that Ykone can verify his identity and respond appropriately to his request.

ARTICLE 4. PURPOSES AND LEGAL BASIS OF PROCESSING

Ykone carries out the following processing, as data controller :

● the collection of public data relating to influencers from social networks through subcontracted providers;
● the provision of a database of influencers (the “Influencers”) providing statistics and information on influencers and their community of subscribers
(the “Followers”) as part of the operation of Campaygn by Ykone Customers ;
● the hosting of Campaygn data, provided by a hosting service provider. The servers are located in the Netherlands.

Ykone carries out the following processing, as a subcontractor on behalf of its Clients:

● generation of “casting” from an influencer profile on Campaygn: creation of an influencer presentation template (photos, statistics, audience data, etc.) for a campaign;
● provision of the “Monitors” tool and campaign reports: tracking tool that records and analyzes (statistics and KPIs) the publications of an influencer on a particular campaign;
● provision of the “Forecast” tool: generation of forecast statistics on upcoming campaigns;
● addition of an influencer profile in the database at the request of a Client user;
● recording Instagram stories of an influencer at the request of a Client user. The processing carried out by Ykone is based on the following legal basis:
● Ykone’s legitimate interest (Article 6.1 (f) of the GDPR) for information made public by data subjects on social networks such as Instagram and Facebook.

Data collection is carried out for prospecting purposes, and influencers are considered professionals here.

ARTICLE 5. PERIODS OF STORAGE OF PERSONAL DATA

Ykone keeps the personal data collected in a form allowing the identification of the
persons concerned only for the time to achieve the purpose for which the data was
collected according to the methods of article 3. The publications of influencers are kept for a period of 3 years from the date of collection.

Data related to influencer profiles is deleted at the same time as the deletion of the influencer’s account on social networks. The retention of profile data is strictly necessary for the purpose of prospecting and providing influencer profiles.

ARTICLE 6. RECIPIENTS OF PERSONAL DATA OF INFLUENCERS

Access to personal data is strictly limited. Ykone may nevertheless be required to
transmit the personal data of the person concerned to certain recipients:

● Internally: to the personnel of the Ykone teams in charge of managing the Campaygn solution and the processing identified, subject to an obligation of confidentiality in the performance of their duties.
● Externally: Ykone may communicate the personal data of the Influencers concerned to its Customers and its technical service providers.
● To other third parties: if such communication is required by law, a regulatory provision or a judicial decision or to respond to possible complaints or protect the security of personal data.

ARTICLE 7. TRANSFER OF PERSONAL DATA OUTSIDE THE EU

Ykone may need to transfer data personal to third countries outside the European Union, by some of its service providers to its staff or to some of its customers.

If this third country has not been the subject of an adequate level of protection decision by the European Commission in accordance with Article 45 of the GDPR, Ykone and its client sign standard contractual clauses in accordance with Article 46 of the GDPR to cover the transfer of personal data. You can obtain a copy of these standard contractual clauses by contacting us at data@ykone.com

ARTICLE 8. EXERCISE OF RIGHTS AND COMPLAINTS

In application of the applicable regulations, the person concerned by the processing has the following rights over the personal data concerning him:

● Right of access to know what personal data is processed by Ykone.
● Right of limitation so that the processing of his personal data is suspended.
● Right to erasure so that Ykone no longer processes all or part of his personal data.
● Right to object if the data subject wishes that his personal data no longer be processed by Ykone for reasons relating to a particular situation.
● Right of portability if the data subject wishes to recover their personal data or have them recovered by a third party (receive in a structured, commonly used and machine-readable format the personal data collected as part of the Seller Form).
● Right to rectify (complete, update, block) personal data that is inaccurate, incomplete, ambiguous, outdated or whose collection, use or communication or storage is prohibited.
● Right to define directives on the fate of his personal data after his death.
● Right to withdraw consent at any time for data submitted via the Recommendation Form.

In accordance with Article 12.5 of the GDPR, Ykone may refuse to comply with a request if it is clearly unfounded or excessive. Any person concerned by the processing identified may exercise their rights by sending an email to data@ykone.com, indicating their first and last name and attaching proof of identity.

You are informed that Ykone reproduces the information that you have made public on the Source Sites. In order to modify the information concerning you which is collected by Ykone from the Source Sites, you must correct it yourself directly on the social network concerned, Ykone cannot intervene on the latter.

In accordance with article 85 of law n°78-17 relating to data processing, files and freedoms of January 6, 1978 as amended by the Data Protection Act, you can define the directives relating to the storage, erasure or communication of your personal data after your death.

● If these are general directives concerning all of your personal data, they may be recorded with a trusted digital third party certified by the National Commission for Computing and Liberties (the “CNIL”).
● If these are directives specific to the personal data collected by Ykone, they are registered with Ykone. You can change or revoke your guidelines at any time.

You can file a complaint with the CNIL, the supervisory authority responsible for the protection of personal data.

ARTICLE 9. COOKIE MANAGEMENT

When browsing the site https://app.campaygn.com/ cookies are deposited and/or read by Ykone on your terminal.

9.1 Definition of a cookie

Cookies are files recorded on your computer medium which record specific parameters and data for an exchange with our system via your browser. Saving allows us to design the website accordingly for you and makes it easier for you to use it, insofar as you save, for example, specific entries in such a way that you do not have to repeat them over and over again.

Cookies make it possible, for example, to record your actions, your preferences and some of your characteristics during the period of validity of the cookie concerned. Not all cookies contain personal data, but when they do we treat them in accordance with our privacy policy.

9.2 What cookies are deposited/read by YKONE?

During your first visit to Campaygn, a banner informs you of the presence of these
cookies and invites you to indicate your choice. Cookies requiring your consent in accordance with the regulations are only deposited if you accept them. You can inform yourself at any time and configure cookies to accept or refuse them by going to the page at the bottom of each page of the site or by configuring your browser.

We may place different types of cookies for several different purposes:

● Cookies necessary for the personalization and operation of the site: they allow you to use the main functionalities of the Site and in particular to save information between two visits to the site on the same device, to save session connection identifiers or interface customization elements (choice of language or presentation). They do not require your prior consent. These cookies are essential for the proper functioning of the Site. If you refuse the registration of these cookies in your terminal or its browser, or if you delete those which are registered there, you will be informed that your navigation and your experience on the Site may be limited.
● Analytical cookies, statistics or audience measurement cookies for the website which allow us to know the use and audience performance of the site and to improve its operation for our visitors, for example, to establish statistics and volumes of visits and use of the various elements making up the site (headings and content visited, routes), in order to improve the interest and ergonomics of the site.
● Social network cookies placed by social networks when you share content from our Sites with other people or let them know your opinion on this content via an application button. These cookies are only placed when you have expressly consented to them through the banner presented during your first connection. We have no control over the process used by these social networks to collect information relating to your browsing on our sites and associated sites as well as the Personal Data they have. We invite you to consult their data protection policies in order to know your rights with respect to each of them, and to manage your privacy settings.
● So-called advertising cookies that allow us to choose in real time which advertising to display on third-party sites. These cookies are only placed when you have expressly consented to them through the banner presented during your first connection.

Ykone uses the following cookies to make the website work, to optimize your navigation and to get to know you in order to improve your experience: analytics We collect your consent for the deposit of these cookies. If you accept their deposit, we will be able to obtain information about your visits to the website. If you refuse their deposit, no consequences will affect your visit to the website.

9.3 What data are collected through cookies?

All data relating to a terminal at a given time can be collected via cookies, in particular:

● One or more technical identifier(s) to identify your internet box;
● The date, time and duration of connection of a terminal to a Website;
● The Internet address of the originating page of the terminal accessing the Website;
● The type of operating system of the terminal (ex: Windows, MacOs, Linux, Unix, etc.);
● The type and version of browser software used by the terminal (Internet Explorer, Firefox, Safari, Chrome, Opera, etc.);
● The make and model of the mobile device or tablet;
● Possible download errors;
● The language of use of the navigation software used by the terminal;
● The characteristics of the content consulted and shared.

9.4 Who places cookies?

The entities depositing cookies on the website are:

● The publisher of the site is Ykone as well as the technical service providers who process your browsing data on behalf of Ykone;
● The social network publishers that can place cookies on the website are: Facebook, Instagram, LinkedIn.

9.5 How to access your settings and change or withdraw your consent?

With the exception of functional technical cookies, strictly necessary for the use of the website, you can accept or refuse the deposit of the cookies mentioned above via the Consent Management banner. Unless opposed in advance, the period of validity of your consent to the deposit of cookies is 30 minutes for session cookies and one year for audience measurement and navigation tracking cookies. We inform you that you can modify or withdraw your consent at any time by clicking on the dedicated section accessible on the website.

9.6 How to configure cookies on web browsers?

You have the choice to configure your browser to accept or refuse all cookies, to delete cookies periodically or to see when a cookie is issued, its validity period, and its content, and refuse to save it on your hard drive.

You can at any time choose to block or deactivate these cookies by configuring the internet browser of your computer, your tablet or your mobile, in accordance with the instructions established by your internet browser provider and appearing on the Websites mentioned below:

– On Internet Explorer:
Open the “Tools” menu, then select “Internet Options”; click on the “Privacy” tab then the “Advanced” tab choose the desired level or follow the following link:
https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies

– On Microsoft Edge:
Open the “Tools” menu, then select “Internet Options”; click on the “Privacy” tab then the “Advanced” tab choose the desired level or follow the following link:
https://support.microsoft.com/fr-fr/help/4027947/microsoft-edge-delete-cookies

– On Mozilla Firefox:

Open the “Tools” menu, then select “Options”; click on the “Privacy” tab then choose the desired options or follow this link:
https://support.mozilla.org/en/products/firefox/protect-your-privacy/cookies

– On Safari Mac/Iphone/Ipad:
Choose “Safari > Preferences” then click on “Security”; In the “Accept cookies” section, choose the desired options or follow this link:
https://support.apple.com/fr-fr/HT201265 or
https://support.apple.com/fr-fr/guide/safari/sfri11471/mac

– On Google Chrome;
Open the configuration menu (wrench logo), then select “Options”; click on “Advanced options” then in the “Privacy” section, click on “Content settings”, and choose the desired options or follow the following link:

https://support.google.com/chrome/answer/95647?hl=en

– On iOS:

https://support.apple.com/fr-fr/guide/safari/sfri11471/mac
For more details, you can also consult the CNIL website:
https://www.cnil.fr/cnil-direct/question/198>

9.7 Modification of the cookies policy ?

We inform you that this policy may be subject to modifications, in particular depending on the evolution of our technological solution and the applicable legal or regulatory provisions.