DATA PROTECTION POLICY FOR WEB USERS 

Linkfluence (France) SAS is committed to respecting data protection and privacy, and in particular to respecting the provisions of the General Data Protection Regulation (EU Regulation 2016/679) or "GDPR" and the French law "informatique et libertés" of January 6, 1978, as amended.
This Data Protection Policy addresses the personal data concerning individuals who generated content that is publicly available on the Internet (“Web Users”). This Data Protection Policy describes the way Linkfluence France SAS collects, uses and shares personal data in the course of providing our “social listening” services.
Linkfluence (France) SAS acts as the data controller for personal data processed in connection with the collection of Web Users’ personal data from the Internet. The identity and contact details of the data controller are:
Linkfluence (France) SAS
French corporation (société par actions simplifiée)
registered with the commercial and companies register of Paris under number 491 601 936
having its registered office at Raiselab, 18 rue de la Fontaine au Roi, 75011, Paris

(hereinafter “we”, “us”, “our” or “Linkfluence”).

 

1. WHO ARE WE?

We are a provider of “social listening” and market intelligence services, through our proprietary platform “Radarly” (together, the “Services”). 

To provide our Services, we crawl various sources on the Internet (e.g. websites, blogs, forums, social networks) and collect publicly available information, including personal data. Then, we analyze and index such information and save the results. We only use information published or made publicly available by Web Users on the Internet. Please note that Linkfluence does not collect nor process information which access is private or technically restricted, i.e. that is not generally publicly available on the Internet, regardless of the source.

This Data Protection Policy only governs the collection and use of your personal data by Linkfluence. Any third-party service or site you may use (e.g. forums, social network) process your personal data in accordance with their own privacy practices. Please refer to the privacy policy provided by any third-party service or site before you use them.

 

2. HOW DO WE PROCESS WEB USERS’ DATA

2.1. Collection of Web Users’ Data

Where and how do we collect data?


We collect Web Users’ personal data from social networks (eg. Twitter, Facebook, Instagram, Google+, Sina Weibo, Youtube, Dailymotion, Buzilla, GSdata, SocialGist, Sinamidu, Linkedin, Twitch, ВКонтакте) via third party data providers connectors and/or API connectors. We comply with the requests and the rules of the third parties data providers governing the collection of public raw data.
We also collect Web Users’ personal data from diverse web pages (eg. traditional web page, blog posts and blog comments, news article and associated commentary, forum post and reply to a forum post, product sheet and product review) via crawlers. Our crawlers comply with the usual industrial rules for this type of software, that is to say we respect robots.txt files, limitation of download speed and number of connections.


What types of data do we collect?


Depending on the source and restrictions which may apply (e.g. what you choose to make available or what the Internet source makes available), the data we collect about Web Users encompasses the following information. Please keep in mind that such information is only information you disclosed on the Internet and which is publicly available therefrom:
• your name, username, pseudonym or other identifier;
• your profile, including e.g. picture, bio, gender, location, date of birth, interest description etc.;
• content you published using that name, username, pseudonym or other identifier, including e.g. posts, comments, expressions, opinions, etc.;
• your interactions including e.g. likes, tweets, shares etc.;
• other images or videos that you post or interact with;
• your location, as provided to us by any third-party website, page, forum, social network that shares such data with us, subject to your choices and preferences on such third-party website, page, forum, social network;
• any other information you made generally available on a website, page, forum, social network we are authorized to crawl or that shares data with us.

2.2. Storage of Web Users’ Data

We store the data we collect on protected servers in partnership with known service providers. We ensure that the storage of personal data is secured. For instance, personal data are encrypted and not accessible to any external providers.

 

2.3. Analysis and inference of Web Users’ Data

How do we analyze the data we collect?

We organize, combine and use the data we collected for the following operations:

  • deduplication;
  • normalization;
  • language detection;
  • named entity recognition;
  • sentiment analysis;
  • location / user enrichment;
  • scoring;
  • clustering;
  • content extraction;
  • computer vision.

Why do we analyze the data we collect?

We use such techniques and operations with the aim to enable our customers to listen and address your publicly available expression on the Internet.

We use the data you disclosed or made publicly available on the Internet to infer other information about you.

What can we infer?

Depending upon the information that is publicly available, we may be in a position to infer the following information about you based on the information you published and your interactions on the Internet:

  • your gender (male or female);
  • your age or age range;
  • your centers of interest;
  • your profession or field of work;
  • your city or geographical location;
  • your influence and visibility on a certain topic;
  • your emotional status (positive or negative);
  • your language;
  • your interest in a company/brand;
  • your marital status (single or in a couple);
  • your parental status (child(ren) or without children).

Please note that we do not further process nor try to infer from information publicly available we collect, any information that reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, data concerning health, data concerning your sex life or sexual orientation. 

 

3. WHY DO WE PROCESS WEB USERS’ DATA

We collect data Web Users publish or otherwise make publicly available on the Internet, store such data, analyze such data and infer data and provide our analysis to our customers only, as part of our Services, like a marketing research agency which would collect information in order to understand consumers’ needs and expectations for the purposes of improving existing services or developing new ones.

For instance, we may collect that written post and photograph you posted on a social network, stating that you love this new bag you just bought and that you recommend it. As part of the Services we provide to the manufacturer of that bag or its representative, we will mark that post as positive toward that bag’s manufacturer reputation on the Internet.

 
4. WHAT IS OUR LEGAL BASIS
 

We process data about Web Users on the basis of our legitimate interest for purposes of providing our Services and improving our Services and the way we provide them, including the accuracy of our market intelligence as well as our technical capabilities. We recall that we offer a social listening service consisting of an analysis that allows our customers to understand what consumers are saying about a specific industry or a particular brand.

Our processing activity is in the interest of our customers who benefit from the provision of aggregate statistics, evaluations and analysis of the type of audience and opinions that Web Users have of them. The following interests of customers can be identified: 

  • knowledge of the public and their publications;
  • understanding public opinion better;
  • improving the business of customers; and
  • the possibility of responding globally to the public expression of Web Users’ needs.

Our processing activity is also of interest for Web Users in that the processing operations carried out can provide a response to their publications and allow them to be heard. Our Services facilitate the impact of publications by Web Users.

Furthermore, we may also process Web Users’ personal data in order to comply with the legal and regulatory requirements bearing on us, for instance to answer requests we may receive from judicial or administrative authorities.

 

5. HOW DO WE SHARE WEB USERS’ DATA

We share information, including personal data, in various ways and with various recipients. When doing so, we always protect your personal data by ensuring that adequate and contractually binding technical and organizational measures are adopted to safeguard your privacy and comply with our legal obligations. In any event, we prohibit the recipients from publicly sharing information we may provide them with.

We share Web Users’ data with:

  • legal entities we control, that controls us or under common control with us (“Affiliates”) located inside and outside of the European Union, as necessary to provide our Services;
  • our customers, who may access such data from our Services. Our standard service agreements require our customers to comply with any applicable legal and regulatory requirement, including data protection and privacy laws as well as intellectual property and author rights (notably with respect to photos and images), when using our Services and accessing data;
  • our business partners and providers, as necessary for them to perform the service they provide us with and under our instructions, or for the performance of the agreements we enter with them.

The above-specified sharing of information sometimes involves cross-border data transfers. For instance, where Customers or Web Users are located in the European Union, their personal information may be transferred to countries outside of the European Union. In any event, we use standard contract clauses approved by the European Commission or other suitable safeguard, as provided by applicable law, to perform data transfers from the European Union to other countries. Standard contractual clauses are commitments drafted by the European Commission that apply between companies transferring personal data, binding them to protect the privacy and security personal data they transfer.

 

6. HOW DO WE SHARE WEB USERS’ DATA

Linkfluence is committed to protecting the privacy of all Web Users. We implement and maintain organizational and technological to protect personal data during processing and retention, to ensure that personal data is not retained any longer than necessary to provide our Services and comply with legal requirements.

6.1. Accuracy

We do our best to collect and process data that is accurate and keep it up-to-date. To this end, Linkfluence strives to disregard any information or data that has been collected and subsequently modified on the said social network or website. For instance, the deletion of content published on Twitter is taken into account by Linkfluence with the capture of a data stream.

Since data we collect is publicly available information on the Internet, we advise that you first rectify that data on the original service or site on which you first published it.

However, if you wish to notify us about inaccurate or outdated data, please contact us using the contact details provided in Section 8 below.

6.2. Retention

We will retain data about Web Users for as long as it is necessary for us to provide the Services, or to comply with our legal obligations:

  • raw public data of Web Users is deleted 25 rolling months after initial collection;
  • customer indexes, which include a selection of raw public data of Web Users and inferred data of Web Users, are deleted the end of the relationship between Linkfluence and its customer.

We also archive Web Users’ Personal Data for evidential purposes in accordance with applicable regulation.

In addition, we will delete data concerning you prior to the expiry of these twenty five and seven year periods if you request us to do so, or if you deleted it from the third-party site or service on which you first published it (where such deletion is possible or allowed) and you notified that removal to us.

6.3. Security

We have implemented and maintain appropriate administrative, technical and physical controls that are designed to safeguard any information we process, including industry-standard encryption technology.

We also ensure that our providers which may access or process your data under our instructions are bound by contractual requirements to implement and maintain similar controls.

 

7. YOUR RIGHTS

Pursuant to applicable data protection and privacy laws, you have a number of rights that you may exercise upon personal data concerning you. Generally, you may:

  • ask if we hold personal data concerning you;
  • ask from which source the personal data we hold originate;
  • request access to the personal data concerning you that we hold and, request that we update, rectify or erase such personal data;
  • request that we refrain or restrict from using personal data concerning you in the future;
  • object to the processing of personal data concerning you;
  • if you reside within the European Union, you have the right to ask for a copy of your personal information. Please note that such a request is limited to the only personal information you provided us with and that we hold at that given time and subject to any relevant legal requirements and exemptions.

In respect of the above rights, in order to comply with legal requirements pertaining to data protection and privacy, we may need in certain cases to verify your identity and/or require that you provide additional information before we enforce your rights.

Please refer to the contact details provided in Section 8 to exercise any right listed above.

 

8. QUESTIONS OR COMPLAINTS

Should you have any question or concern relating to this Data Protection Policy or should you wish to initiate a complaint regarding our data protection practices, please contact us in one of the following ways:

Linkfluence Data Protection Officer
Email: privacy@linkfluence.com
Phone: +33 1 80 400 800
Mail: Linkfluence

Attention: Data Protection Officer
Raiselab, 18 rue de la Fontaine au Roi,
75011, Paris
FRANCE

If you are not satisfied with our answer or the way Linkfluence manages your personal data, you have the right to lodge a complaint with a data protection supervisory authority. If you reside within the European Union, you may lodge a complaint with your local data protection authority. The appropriate data protection authority is the authority having jurisdiction over data protection and privacy in the country in which you live. A list of national data protection authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

9. REVISION OF THIS POLICY

This Data Protection Policy is effective as of the date provided in the title section of this document. We may revise this Data Protection Policy to comply with our legal or regulatory obligations or to reflect changes in our Services. Please visit this page regularly and review this policy. In the event we make material changes, we will identify them for your consideration.

 

10. THIRD-PARTY PROVIDERS TERMS & PRIVACY POLICY

Radarly & Search by Linkfluence use APIs from various third-party providers:

10.1. YouTube

Radarly uses YouTube API Services to collect and store data generated by YouTube users in compliance with:

YouTube user data is refreshed every 7 days.

10.2. Google

10.3. Google Data Studio

10.4. Facebook

10.5. Twitter

10.6. Instagram

10.7. Dailymotion

10.8. Vkontakte