Privacy Policy
Privacy Policy
Privacy Policy
We are committed to protecting and respecting your privacy. This privacy policy explains what personal data we collect, how we use it and who you can contact in case of any questions. Please read through this privacy policy carefully so that you are fully aware of how and why we are using your data.
ABOUT US
Koactt, our website www.koactt.com (the "Website") and our app "Koactt" ("App") (together our "Platform"), is operated and managed by Black Astrum Limited. We are a company incorporated in England and Wales (company number 07520381) with our registered office address at Black Astrum, Prospect House, 67 Boston Manor Rd, Brentford TW8 9JQ ("Koactt", "we", "us", "our").
Koactt respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
For the purpose of the Data Protection Act 2018 and the UK GDPR, we are the controller of your personal data.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We will need to ask you for certain personal information to give you the best possible experience when you receive our services or otherwise engage with us (via our Platform, social media channels, email or otherwise).
We do not require you to provide us with any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual origination, political opinions, trade union membership, information about your health, genetic biometric data, and criminal convictions). If you choose to provide us with any special categories of data, we will only process such data if you give us your consent to do so or if we have other legal grounds under the applicable data protection laws for doing so.
We use different methods to collect data from and about you including through:
Direction Interactions. We may collect the following personal data from you directly:
• Any personal data you provide when creating a membership profile with us, including your name, email, telephone number, occupation, date of birth, social media handles, financial and credit card information, personal description and photographs.
• Any personal data you provide when you get in touch by phone, email, through our Platform, social media channels, or otherwise (e.g. name, email, phone).
• Any personal data you provide when you message or communicate with other Brands or Creators, participate in discussion boards, link, reference or otherwise incorporate or use social media platforms, or carry out any other activities on our Platform.
• Any personal data about you which is contained within content that you post or upload to our Platform or that Brands or Creators provide about you. The information you give us may include without limitation your name, address, email address, age, date of birth, phone number, financial and credit card information, personal description and photographs, social media presence/following and the Brands or Creators that you communicate with.
Automated technologies or interactions. We will also collect other information about you and the devices you use to access our Website, or we may ask third parties to do this for us via technologies such as cookies. These are used to distinguish you from other users of our Website and enhance your experience of using our Website.
For more information about the cookies we use and the purposes for which we use them please see our Cookie Policy.
Third parties or publicly available sources. We may receive the following information about you from various third parties or publicly available sources:
• Any personal data you provide through our social media channels (e.g. your name and photos in Instagram Stories or Posts).
• We may receive or collect personal data about you from other third party social media platforms that you refer to on our Platform. For example, we may check Instagram to see that you have the following you claim to have.
• We may use third party partners, to monitor, collect and report to us on the social media content you post in relation to campaigns, as well as on data related to your social media accounts and social media usage.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to.
We use your personal data for the following purposes and in reliance on the following legal bases:
Performance of a contract
• To carry out our obligations that we promise to deliver as Koactt and to provide you with the information and services that you request from us.
• To communicate and manage our relationship with you regarding the services you receive or request from us. For more information, please see How We Contact You below.
• To deal with any enquiries or requests you make of us.
• To enable you to access our Platform and use our services.
Our legitimate interests
• To send you important service updates regarding the Platform, our services and our terms of service (including this Privacy Policy).
• To confirm your identity and authenticate the information you provide for security purposes.
• For our own reporting and analytical purposes to enable us to improve our services and our client relationships and experiences, including through the use of email performance and click-through tracking and Platform usage through analytics.
• For our own record-keeping and general administrative purposes regarding our handling of your personal data and other operational activities.
• To provide you with customer support and resolve any complaints.
• To administer and protect our business and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
• To improve Koactt to ensure that content is presented in the most effective manner for you and for your computer.
• To effectively handle any legal claims or regulatory enforcement actions taken against Koactt, or take appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us.
• To assist with our internal training purposes.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with our legal obligations
• To comply with our legal and regulatory obligations (including under applicable data protection laws).
• For preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
• To fulfil our duties to our members, colleagues and other stakeholders.
Where you have provided your consent
• To send third party direct marketing communications to you by text or email.
• To allow third party partners, to monitor, collect and report to us on the social media content you post in relation to campaigns and on data related to your social media accounts and social media usage.
• To provide you with emails and/or push notifications relating to updates and maintenance to the Platform; opportunities, bids and messages from other users of the Platform; and/or newsletters containing periodic updates.
WHO WE SHARE YOUR DATA WITH
Disclosure by you: When you communicate with Brands or Creators on our Platform, you choose who can see any personal data in that content. For example, when a Creator messages a Brand, they acknowledge that the brand and its connected individuals will receive certain information, photographs, messages and other personal data about them.
Disclosure by us: We may disclose your personal data to the following third parties:
• Analytics and search engine providers that assist us in the improvement and optimisation of our Website.
• Our third party providers of operational and business services, who are authorised to process your personal data on our behalf and pursuant to our instructions as necessary to run our business and provide you with the services you request from us, including our marketing, IT, payment and accounting providers.
• Our third party partners, who are based in the UK and who provide us with marketing data and insights.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Any third parties with whom we are required to share your personal data in order to comply with our legal obligations, to enforce our terms and conditions or to protect the rights, property, or safety of our Platform, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You can request to:
• Access a copy of the personal data we hold about you.
• Rectify any incorrect or incomplete data we hold about you. It is both in our interest and yours that any personal data we hold about you is accurate, complete and current. If the data we hold about you is inaccurate in any way, please contact us to have your personal data corrected.
• Delete or remove the data we hold about you. You can request to delete all personal data we hold about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Transfer your personal data that we hold to you or to a third party.
• Object to any further processing of your data, if we are processing your personal data on the basis of our legitimate interests, or for direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Restrict the processing of your personal data in certain circumstances.
• Withdraw your consent where we are relying on consent as the legal basis to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
You can exercise all the rights applicable to you at any time by contacting us.
We will endeavour to respond to your requests within one month and free of charge. Please note that in respect of all these rights, we reserve the right to:
• Refuse your request based on the exemptions set out in the applicable data protection laws.
• Request proof of your ID to process the request or request further information.
• Charge you a reasonable administrative fee for any repetitive, manifestly unfounded or excessive requests.
• Request more time to respond to you if your request is particularly complex or if you have made a number of requests.
If we refuse your request to exercise these rights, we will give reasons for our refusal and allow you to challenge our decision. If we have shared your personal data with others, we will tell them about your request to rectify, erase, restrict or object to the processing where possible.
If you have any concerns about how we handle your data, please Contact Us. If you are not satisfied after we’ve tried to resolve your issue, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK regulator for data protection issues.
WHERE WE SHARE YOUR PERSONAL DATA
Where we need to transfer your personal data to any countries outside the UK, we ensure that such transfers are made subject to appropriate safeguards as required by applicable data protection laws to ensure that a similar degree of protection is afforded to your personal data, including by ensuring that overseas recipients of your data are located in a country deemed to hold adequacy status, through the use of ICO-approved standard contractual clauses (SCCs), or otherwise.
This includes in relation to our CRM platform which is provided by HubSpot Inc. HubSpot Inc are located in the US and so their processing of your personal data will involve a transfer of data outside the UK. We ensure that such transfers are covered by SCCs or such other appropriate safeguards as may be suitable from time to time.
Please Contact Us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
HOW WE CONTACT YOU
Koactt may need to contact you. This can be via email, or push notifications.
Some emails are service-related and necessary for members. These are related to your account and security. Examples of service-related messages include an email address confirmation/welcome email when you register your account, confirmation of your acceptance, and correspondence with our support and accounts team.
We also have optional emails, which you can subscribe or unsubscribe from, and push notifications which you can opt in/out of, at any time. These relate to:
• Updates and maintenance - we let you know when the site will be scheduled to be down for maintenance, or any exciting updates to the system.
• Notifications – about opportunities, bids and messages from other users on the Platform.
• Newsletter – periodic updates with a selection of new opportunities.
MARKETING
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
HOW WE KEEP YOUR PERSONAL DATA SECURE
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WE KEEP YOUR PERSONAL DATA FOR
We keep your data for as long as it’s necessary to meet the relevant purposes for which we’ve collected your data, including for the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate length of time for holding your data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm, from unauthorised use or disclosure of your personal data, the purpose for which we process your data and whether we can achieve those purposes through other means, along with the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
CHANGES TO THIS PRIVACY POLICY
We may need to update this privacy policy to reflect changes to our practices, technology and legal requirements. We will post any changes to this privacy policy on our Website from time to time and, where appropriate, notify you by e-mail.
All personal data held by us will be governed by the most recent privacy policy posted on our Platform, so please regularly check back to see any updates or changes.
THIRD PARTIES
This privacy policy only addresses Koactt’s use and disclosure of your personal data.
Our Platform may contain links to other websites, plug-ins and applications, including those of our business partners and social media pages. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our Platform, we encourage you to read the privacy policy of every website you visit before you submit any personal data to that website.
CONTACT US
If you have any questions about this privacy policy or anything else about Koactt, please contact us at support@koactt.com.
We are committed to protecting and respecting your privacy. This privacy policy explains what personal data we collect, how we use it and who you can contact in case of any questions. Please read through this privacy policy carefully so that you are fully aware of how and why we are using your data.
ABOUT US
Koactt, our website www.koactt.com (the "Website") and our app "Koactt" ("App") (together our "Platform"), is operated and managed by Black Astrum Limited. We are a company incorporated in England and Wales (company number 07520381) with our registered office address at Black Astrum, Prospect House, 67 Boston Manor Rd, Brentford TW8 9JQ ("Koactt", "we", "us", "our").
Koactt respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
For the purpose of the Data Protection Act 2018 and the UK GDPR, we are the controller of your personal data.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We will need to ask you for certain personal information to give you the best possible experience when you receive our services or otherwise engage with us (via our Platform, social media channels, email or otherwise).
We do not require you to provide us with any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual origination, political opinions, trade union membership, information about your health, genetic biometric data, and criminal convictions). If you choose to provide us with any special categories of data, we will only process such data if you give us your consent to do so or if we have other legal grounds under the applicable data protection laws for doing so.
We use different methods to collect data from and about you including through:
Direction Interactions. We may collect the following personal data from you directly:
• Any personal data you provide when creating a membership profile with us, including your name, email, telephone number, occupation, date of birth, social media handles, financial and credit card information, personal description and photographs.
• Any personal data you provide when you get in touch by phone, email, through our Platform, social media channels, or otherwise (e.g. name, email, phone).
• Any personal data you provide when you message or communicate with other Brands or Creators, participate in discussion boards, link, reference or otherwise incorporate or use social media platforms, or carry out any other activities on our Platform.
• Any personal data about you which is contained within content that you post or upload to our Platform or that Brands or Creators provide about you. The information you give us may include without limitation your name, address, email address, age, date of birth, phone number, financial and credit card information, personal description and photographs, social media presence/following and the Brands or Creators that you communicate with.
Automated technologies or interactions. We will also collect other information about you and the devices you use to access our Website, or we may ask third parties to do this for us via technologies such as cookies. These are used to distinguish you from other users of our Website and enhance your experience of using our Website.
For more information about the cookies we use and the purposes for which we use them please see our Cookie Policy.
Third parties or publicly available sources. We may receive the following information about you from various third parties or publicly available sources:
• Any personal data you provide through our social media channels (e.g. your name and photos in Instagram Stories or Posts).
• We may receive or collect personal data about you from other third party social media platforms that you refer to on our Platform. For example, we may check Instagram to see that you have the following you claim to have.
• We may use third party partners, to monitor, collect and report to us on the social media content you post in relation to campaigns, as well as on data related to your social media accounts and social media usage.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to.
We use your personal data for the following purposes and in reliance on the following legal bases:
Performance of a contract
• To carry out our obligations that we promise to deliver as Koactt and to provide you with the information and services that you request from us.
• To communicate and manage our relationship with you regarding the services you receive or request from us. For more information, please see How We Contact You below.
• To deal with any enquiries or requests you make of us.
• To enable you to access our Platform and use our services.
Our legitimate interests
• To send you important service updates regarding the Platform, our services and our terms of service (including this Privacy Policy).
• To confirm your identity and authenticate the information you provide for security purposes.
• For our own reporting and analytical purposes to enable us to improve our services and our client relationships and experiences, including through the use of email performance and click-through tracking and Platform usage through analytics.
• For our own record-keeping and general administrative purposes regarding our handling of your personal data and other operational activities.
• To provide you with customer support and resolve any complaints.
• To administer and protect our business and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
• To improve Koactt to ensure that content is presented in the most effective manner for you and for your computer.
• To effectively handle any legal claims or regulatory enforcement actions taken against Koactt, or take appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us.
• To assist with our internal training purposes.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with our legal obligations
• To comply with our legal and regulatory obligations (including under applicable data protection laws).
• For preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
• To fulfil our duties to our members, colleagues and other stakeholders.
Where you have provided your consent
• To send third party direct marketing communications to you by text or email.
• To allow third party partners, to monitor, collect and report to us on the social media content you post in relation to campaigns and on data related to your social media accounts and social media usage.
• To provide you with emails and/or push notifications relating to updates and maintenance to the Platform; opportunities, bids and messages from other users of the Platform; and/or newsletters containing periodic updates.
WHO WE SHARE YOUR DATA WITH
Disclosure by you: When you communicate with Brands or Creators on our Platform, you choose who can see any personal data in that content. For example, when a Creator messages a Brand, they acknowledge that the brand and its connected individuals will receive certain information, photographs, messages and other personal data about them.
Disclosure by us: We may disclose your personal data to the following third parties:
• Analytics and search engine providers that assist us in the improvement and optimisation of our Website.
• Our third party providers of operational and business services, who are authorised to process your personal data on our behalf and pursuant to our instructions as necessary to run our business and provide you with the services you request from us, including our marketing, IT, payment and accounting providers.
• Our third party partners, who are based in the UK and who provide us with marketing data and insights.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Any third parties with whom we are required to share your personal data in order to comply with our legal obligations, to enforce our terms and conditions or to protect the rights, property, or safety of our Platform, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You can request to:
• Access a copy of the personal data we hold about you.
• Rectify any incorrect or incomplete data we hold about you. It is both in our interest and yours that any personal data we hold about you is accurate, complete and current. If the data we hold about you is inaccurate in any way, please contact us to have your personal data corrected.
• Delete or remove the data we hold about you. You can request to delete all personal data we hold about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Transfer your personal data that we hold to you or to a third party.
• Object to any further processing of your data, if we are processing your personal data on the basis of our legitimate interests, or for direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Restrict the processing of your personal data in certain circumstances.
• Withdraw your consent where we are relying on consent as the legal basis to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
You can exercise all the rights applicable to you at any time by contacting us.
We will endeavour to respond to your requests within one month and free of charge. Please note that in respect of all these rights, we reserve the right to:
• Refuse your request based on the exemptions set out in the applicable data protection laws.
• Request proof of your ID to process the request or request further information.
• Charge you a reasonable administrative fee for any repetitive, manifestly unfounded or excessive requests.
• Request more time to respond to you if your request is particularly complex or if you have made a number of requests.
If we refuse your request to exercise these rights, we will give reasons for our refusal and allow you to challenge our decision. If we have shared your personal data with others, we will tell them about your request to rectify, erase, restrict or object to the processing where possible.
If you have any concerns about how we handle your data, please Contact Us. If you are not satisfied after we’ve tried to resolve your issue, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK regulator for data protection issues.
WHERE WE SHARE YOUR PERSONAL DATA
Where we need to transfer your personal data to any countries outside the UK, we ensure that such transfers are made subject to appropriate safeguards as required by applicable data protection laws to ensure that a similar degree of protection is afforded to your personal data, including by ensuring that overseas recipients of your data are located in a country deemed to hold adequacy status, through the use of ICO-approved standard contractual clauses (SCCs), or otherwise.
This includes in relation to our CRM platform which is provided by HubSpot Inc. HubSpot Inc are located in the US and so their processing of your personal data will involve a transfer of data outside the UK. We ensure that such transfers are covered by SCCs or such other appropriate safeguards as may be suitable from time to time.
Please Contact Us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
HOW WE CONTACT YOU
Koactt may need to contact you. This can be via email, or push notifications.
Some emails are service-related and necessary for members. These are related to your account and security. Examples of service-related messages include an email address confirmation/welcome email when you register your account, confirmation of your acceptance, and correspondence with our support and accounts team.
We also have optional emails, which you can subscribe or unsubscribe from, and push notifications which you can opt in/out of, at any time. These relate to:
• Updates and maintenance - we let you know when the site will be scheduled to be down for maintenance, or any exciting updates to the system.
• Notifications – about opportunities, bids and messages from other users on the Platform.
• Newsletter – periodic updates with a selection of new opportunities.
MARKETING
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
HOW WE KEEP YOUR PERSONAL DATA SECURE
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WE KEEP YOUR PERSONAL DATA FOR
We keep your data for as long as it’s necessary to meet the relevant purposes for which we’ve collected your data, including for the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate length of time for holding your data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm, from unauthorised use or disclosure of your personal data, the purpose for which we process your data and whether we can achieve those purposes through other means, along with the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
CHANGES TO THIS PRIVACY POLICY
We may need to update this privacy policy to reflect changes to our practices, technology and legal requirements. We will post any changes to this privacy policy on our Website from time to time and, where appropriate, notify you by e-mail.
All personal data held by us will be governed by the most recent privacy policy posted on our Platform, so please regularly check back to see any updates or changes.
THIRD PARTIES
This privacy policy only addresses Koactt’s use and disclosure of your personal data.
Our Platform may contain links to other websites, plug-ins and applications, including those of our business partners and social media pages. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our Platform, we encourage you to read the privacy policy of every website you visit before you submit any personal data to that website.
CONTACT US
If you have any questions about this privacy policy or anything else about Koactt, please contact us at support@koactt.com.
We are committed to protecting and respecting your privacy. This privacy policy explains what personal data we collect, how we use it and who you can contact in case of any questions. Please read through this privacy policy carefully so that you are fully aware of how and why we are using your data.
ABOUT US
Koactt, our website www.koactt.com (the "Website") and our app "Koactt" ("App") (together our "Platform"), is operated and managed by Black Astrum Limited. We are a company incorporated in England and Wales (company number 07520381) with our registered office address at Black Astrum, Prospect House, 67 Boston Manor Rd, Brentford TW8 9JQ ("Koactt", "we", "us", "our").
Koactt respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
For the purpose of the Data Protection Act 2018 and the UK GDPR, we are the controller of your personal data.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We will need to ask you for certain personal information to give you the best possible experience when you receive our services or otherwise engage with us (via our Platform, social media channels, email or otherwise).
We do not require you to provide us with any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual origination, political opinions, trade union membership, information about your health, genetic biometric data, and criminal convictions). If you choose to provide us with any special categories of data, we will only process such data if you give us your consent to do so or if we have other legal grounds under the applicable data protection laws for doing so.
We use different methods to collect data from and about you including through:
Direction Interactions. We may collect the following personal data from you directly:
• Any personal data you provide when creating a membership profile with us, including your name, email, telephone number, occupation, date of birth, social media handles, financial and credit card information, personal description and photographs.
• Any personal data you provide when you get in touch by phone, email, through our Platform, social media channels, or otherwise (e.g. name, email, phone).
• Any personal data you provide when you message or communicate with other Brands or Creators, participate in discussion boards, link, reference or otherwise incorporate or use social media platforms, or carry out any other activities on our Platform.
• Any personal data about you which is contained within content that you post or upload to our Platform or that Brands or Creators provide about you. The information you give us may include without limitation your name, address, email address, age, date of birth, phone number, financial and credit card information, personal description and photographs, social media presence/following and the Brands or Creators that you communicate with.
Automated technologies or interactions. We will also collect other information about you and the devices you use to access our Website, or we may ask third parties to do this for us via technologies such as cookies. These are used to distinguish you from other users of our Website and enhance your experience of using our Website.
For more information about the cookies we use and the purposes for which we use them please see our Cookie Policy.
Third parties or publicly available sources. We may receive the following information about you from various third parties or publicly available sources:
• Any personal data you provide through our social media channels (e.g. your name and photos in Instagram Stories or Posts).
• We may receive or collect personal data about you from other third party social media platforms that you refer to on our Platform. For example, we may check Instagram to see that you have the following you claim to have.
• We may use third party partners, to monitor, collect and report to us on the social media content you post in relation to campaigns, as well as on data related to your social media accounts and social media usage.
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to.
We use your personal data for the following purposes and in reliance on the following legal bases:
Performance of a contract
• To carry out our obligations that we promise to deliver as Koactt and to provide you with the information and services that you request from us.
• To communicate and manage our relationship with you regarding the services you receive or request from us. For more information, please see How We Contact You below.
• To deal with any enquiries or requests you make of us.
• To enable you to access our Platform and use our services.
Our legitimate interests
• To send you important service updates regarding the Platform, our services and our terms of service (including this Privacy Policy).
• To confirm your identity and authenticate the information you provide for security purposes.
• For our own reporting and analytical purposes to enable us to improve our services and our client relationships and experiences, including through the use of email performance and click-through tracking and Platform usage through analytics.
• For our own record-keeping and general administrative purposes regarding our handling of your personal data and other operational activities.
• To provide you with customer support and resolve any complaints.
• To administer and protect our business and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
• To improve Koactt to ensure that content is presented in the most effective manner for you and for your computer.
• To effectively handle any legal claims or regulatory enforcement actions taken against Koactt, or take appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us.
• To assist with our internal training purposes.
We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with our legal obligations
• To comply with our legal and regulatory obligations (including under applicable data protection laws).
• For preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
• To fulfil our duties to our members, colleagues and other stakeholders.
Where you have provided your consent
• To send third party direct marketing communications to you by text or email.
• To allow third party partners, to monitor, collect and report to us on the social media content you post in relation to campaigns and on data related to your social media accounts and social media usage.
• To provide you with emails and/or push notifications relating to updates and maintenance to the Platform; opportunities, bids and messages from other users of the Platform; and/or newsletters containing periodic updates.
WHO WE SHARE YOUR DATA WITH
Disclosure by you: When you communicate with Brands or Creators on our Platform, you choose who can see any personal data in that content. For example, when a Creator messages a Brand, they acknowledge that the brand and its connected individuals will receive certain information, photographs, messages and other personal data about them.
Disclosure by us: We may disclose your personal data to the following third parties:
• Analytics and search engine providers that assist us in the improvement and optimisation of our Website.
• Our third party providers of operational and business services, who are authorised to process your personal data on our behalf and pursuant to our instructions as necessary to run our business and provide you with the services you request from us, including our marketing, IT, payment and accounting providers.
• Our third party partners, who are based in the UK and who provide us with marketing data and insights.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Any third parties with whom we are required to share your personal data in order to comply with our legal obligations, to enforce our terms and conditions or to protect the rights, property, or safety of our Platform, our clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
YOUR RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You can request to:
• Access a copy of the personal data we hold about you.
• Rectify any incorrect or incomplete data we hold about you. It is both in our interest and yours that any personal data we hold about you is accurate, complete and current. If the data we hold about you is inaccurate in any way, please contact us to have your personal data corrected.
• Delete or remove the data we hold about you. You can request to delete all personal data we hold about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Transfer your personal data that we hold to you or to a third party.
• Object to any further processing of your data, if we are processing your personal data on the basis of our legitimate interests, or for direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Restrict the processing of your personal data in certain circumstances.
• Withdraw your consent where we are relying on consent as the legal basis to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
You can exercise all the rights applicable to you at any time by contacting us.
We will endeavour to respond to your requests within one month and free of charge. Please note that in respect of all these rights, we reserve the right to:
• Refuse your request based on the exemptions set out in the applicable data protection laws.
• Request proof of your ID to process the request or request further information.
• Charge you a reasonable administrative fee for any repetitive, manifestly unfounded or excessive requests.
• Request more time to respond to you if your request is particularly complex or if you have made a number of requests.
If we refuse your request to exercise these rights, we will give reasons for our refusal and allow you to challenge our decision. If we have shared your personal data with others, we will tell them about your request to rectify, erase, restrict or object to the processing where possible.
If you have any concerns about how we handle your data, please Contact Us. If you are not satisfied after we’ve tried to resolve your issue, you have the right to lodge a complaint with the Information Commissioner's Office (ICO), the UK regulator for data protection issues.
WHERE WE SHARE YOUR PERSONAL DATA
Where we need to transfer your personal data to any countries outside the UK, we ensure that such transfers are made subject to appropriate safeguards as required by applicable data protection laws to ensure that a similar degree of protection is afforded to your personal data, including by ensuring that overseas recipients of your data are located in a country deemed to hold adequacy status, through the use of ICO-approved standard contractual clauses (SCCs), or otherwise.
This includes in relation to our CRM platform which is provided by HubSpot Inc. HubSpot Inc are located in the US and so their processing of your personal data will involve a transfer of data outside the UK. We ensure that such transfers are covered by SCCs or such other appropriate safeguards as may be suitable from time to time.
Please Contact Us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
HOW WE CONTACT YOU
Koactt may need to contact you. This can be via email, or push notifications.
Some emails are service-related and necessary for members. These are related to your account and security. Examples of service-related messages include an email address confirmation/welcome email when you register your account, confirmation of your acceptance, and correspondence with our support and accounts team.
We also have optional emails, which you can subscribe or unsubscribe from, and push notifications which you can opt in/out of, at any time. These relate to:
• Updates and maintenance - we let you know when the site will be scheduled to be down for maintenance, or any exciting updates to the system.
• Notifications – about opportunities, bids and messages from other users on the Platform.
• Newsletter – periodic updates with a selection of new opportunities.
MARKETING
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
HOW WE KEEP YOUR PERSONAL DATA SECURE
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WE KEEP YOUR PERSONAL DATA FOR
We keep your data for as long as it’s necessary to meet the relevant purposes for which we’ve collected your data, including for the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate length of time for holding your data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm, from unauthorised use or disclosure of your personal data, the purpose for which we process your data and whether we can achieve those purposes through other means, along with the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
CHANGES TO THIS PRIVACY POLICY
We may need to update this privacy policy to reflect changes to our practices, technology and legal requirements. We will post any changes to this privacy policy on our Website from time to time and, where appropriate, notify you by e-mail.
All personal data held by us will be governed by the most recent privacy policy posted on our Platform, so please regularly check back to see any updates or changes.
THIRD PARTIES
This privacy policy only addresses Koactt’s use and disclosure of your personal data.
Our Platform may contain links to other websites, plug-ins and applications, including those of our business partners and social media pages. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements.
When you leave our Platform, we encourage you to read the privacy policy of every website you visit before you submit any personal data to that website.
CONTACT US
If you have any questions about this privacy policy or anything else about Koactt, please contact us at support@koactt.com.