Author Privacy Policy

This privacy policy addresses the personally identifiable information (“data”) that we (YouScan Limited, legal entity registered under the laws of Republic of Cyprus with registered address at  Stasinou, 23, 1st floor, Flat/Office 101, Egkomi, 2405, Nicosia, Cyprus; External Data Protection Officer: ePrivacy GmbH represented by Prof. Dr. Christoph Bauer Große Bleichen 21, 20354 Hamburg) collect and process about individual authors of online content (“Author”, “you” or “your”) through the services that we offer to our customers. Basically, if you publish information on publicly available websites, you’re an Author for purposes of this privacy statement.

YouScan offers a brand monitoring service, allowing its customers to analyse information for brand monitoring and analytics purposes. We index publicly available information (including data) from the Internet. We also contract directly with third party providers to gain access to their information (including data). In each case, the information that we have access to is published or made available by Authors. This information is then collated and stored in our database. We offer access to our database, as well as analytics of the data within that database, to third parties (our “YouScan Services”).

Since all of the information that we access is publicly available, the raw information we have about you could be found by anybody with access to the Internet. Some of this information is personal data. For example, your name or username in connection with your on-line profile would be personal data. Other information we process may not be personal data (for example if you publish an anonymous review on a website).

This allows us to provide public brand-related posts, trends, and statistics to our customers allowing them to manage their brands and analyse related communications and topics.

Our customers become data controllers for the data we process on their behalf when they sign up for our YouScan Services.

As an author of this data, you at all times have full control on how data is published through the privacy settings of the Internet platforms you use.

We only process data which has been published or made public by the authors and users of social and web media platforms themselves, through social media or other Internet platforms.

In the context of the YouScan Services, we process the following information to the extent it has been made public by you:

• identification data (name, username, user ID, geographical area);

• the content of the information you have published via that name, username, handle, or other identifier, including comments, expressions, opinions, posts, etc.;

• personal characteristics (age, gender, family status);

• consumer habits;

• hobbies and interests;

• professional and educational background;

• pictures and videos;

• any other information you publish on an Internet website we crawl or on a third-party platform that provides us with data.

We may also process this data in order to detect the general sentiment, language, age, and gender (e.g. based on writing style, your name, or language), or other brand specific interests based on your public data.

We have no control over the correctness of your data, as you are the author of your data and, as such, you have control over what you post and share. You may also at any time change or delete your public posts on social media platforms or alternatively change the privacy controls on social networks to make your posts private, which will prevent any additional collection of your data.

We may also analyse the content of the data you publish and provide our analysis to our customers. For example, if you make a publication stating that you like a certain brand’s product, we may mark that publication as having a positive sentiment toward that brand.

We analyse your data in order to compute, among others, statistics about sentiment, gender, age or general topics of interest. If we ever deduce or conclude something from your data about you, then this is done automatically by our algorithms when performing an analysis. Any such inferences are based on algorithms that analyse the data that you have provided to third-party platforms. Under no circumstances we make any decisions about you based on the data that we process about you, whether deducted or otherwise, as such data is only made available to our customers.

The legal basis for the processing of your data is the legitimate interests acc. to art. 6 para. 1 lit (f) GDPR pursued by YouScan and its customers. Our legitimate interests are in providing our Services to our customers, which includes providing technology that empowers our customers to act with more certainty in a way that is easy-to-access and use. In turn, this allows our customers to learn more about their brand, their customers, their competitors, and other information available on the social web that is relevant to our customers.

We provide services based solely on information and personal data that you decide to post and share publicly. Your public data is used to offer brand monitoring services to our customers on the basis of their legitimate interests to monitor the reputation and other issues affecting their brands on social and web-media platforms. Given the large and growing commercial importance of social and web media platforms, our customers legitimately need to know what is published about their brands on such platforms, in addition to what is being said about the brands in the traditional press. Our customers also have a legitimate interest to timely know about any issues which may affect their products and services in order to enable them to react to any issues, such as fake news or safety related issues, to adapt the products’ or services’ offering or to optimise the provision of goods or services.

The information that is processed is public information. Any user of social media may freely decide not to publicly share his/her personal data at any time by putting in place the appropriate privacy settings on the social networks. To the extent a user is willingly making this information public in order to be accessed or shared over the internet (as well as outside of the European Union), the interests, fundamental rights and freedoms of such a user is respected taking into account that the processing of personal data concerns data made publicly available by the data subject.

Although it is the responsibility of our customers to use our Services properly, we do put in place safeguards to protect your data. We require our customers to comply with applicable law, including data privacy law, when using our Services. We also prohibit our customers from using our Services, including your data, in a way that is outside of your reasonable expectations.

We also use the data in ways related to, but ancillary, to the Services that we offer. For example, we may use the data to comply with our legal obligations or enforce our rights, including the legal obligations or enforcement of rights of third parties. We may also use the data to improve our Services.

The General Data Protection Regulation (GDPR) provides various legal bases on which personal data can be processed lawfully. We base the processing of your data on the following legal bases:

• Your consent, if you have given us such consent (Art. 6 para. 1 lit. a) GDPR);

• The initiation or execution of a contract with you (Art. 6 para. 1 lit. b) GDPR);

• The fulfilment of a legal obligation (Art. 6 para. 1 lit. c) GDPR);

• Our legitimate interests (Art. 6 para. 1 lit. (f) GDPR).

In the context of the YouScan Service, we may share your data with:

• our customers for the purpose of brand monitoring;

• YouScan group of companies;

• with selected third parties, including business partners, suppliers, and sub-contractors (providers of web analysis tools, web hosting and web development providers, service providers for IT development services, ticket and customer support software providers, marketing and advertising agencies, sales service providers, payment service providers, logistics service providers, receivables management and collection service providers, credit agencies, call centers, e-mail and newsletter providers, service providers for editing and translations, CRM system service providers, cloud services, conference and webinar software, service providers for online surveys, service providers for chat software, social media platforms, service providers for bookkeeping and invoicing, providers for external document management, provider for application management software, etc.), for the performance of any contract we enter into with them. We may also share your data with analytics and search engine providers that assist us in the improvement of our website;

• we may also show your public data to potential business partners if they want to test our Service.

We put technical and organizational security and contractual safeguards in place to protect your personal data. If third parties (e.g. our hosting provider) process your data, we make sure their security measures are no less protective than our own.

YouScan is hosted and provided from and within the European Union. We transfer your data to, and store it in, countries outside the European Economic Area. That country may not provide the same level of data protection as your own country. This transfer takes place on the basis of contractual regulations provided for by law, which are intended to ensure adequate protection of your data and which you can review on request. If you are located in Europe, you may contact us for a copy of the safeguards which we have put in place to protect your personal information and privacy rights in these circumstances.

We only keep your data for as long as needed to perform brand monitoring services and then we automatically delete it. However, if you request that we delete your data, or if you delete your data from the platform in which it was originally published, we will also delete your data from our Services.

As a data subject within the meaning of the General Data Protection Regulation (GDPR), you have several rights you execute. Those include:

• the right to request information on the processing of your data and to receive a copy of your personal data for free. You can request information on, among other things, the purposes of the processing, the categories of personal data processed, the recipients of the data (if a transfer is happening), the storage duration or the criteria for determining the duration;

• the right to correct your data. If your personal data is incomplete, you have the right to complete the data record, taking into account the purposes of processing;

• the right to have your data deleted or blocked. Reasons for the existence of a claim for cancellation/blocking may include

• the withdrawal of the previously given consent on which the processing is based,

• the data subject lodges an opposition to the processing,

• the personal data was collected and processed unlawfully;

• the right to have the processing restricted;

• the right to object to the processing of your data;

• the right to revoke your consent to the processing of your data for the future and

• the right to complain to the responsible regulatory authority about unauthorised data processing.

You may at any time change or delete your public posts on social media platforms or alternatively change the privacy controls on social networks to make your posts private, which will prevent any additional collection of your data.

Wherever technically possible, we also detect the deletion or unpublication of your data at the source and also delete it from our processing servers.

To exercise any rights listed above, please email us at privacy@youscan.io or complete the application form available at https://youscan.io/data-subject-access-optout-request/.

We will handle all requests in a timely manner, but we may in our discretion ask for additional information in order to confirm your identity.

We may not always be able to immediately remove all your personal data, for example, if the law requires us to keep such data (e.g. for compliance, financial reporting or legal retention purposes).

We will do our best to execute your requests. In case of a breach, you can also file a complaint with the local authority on data privacy in the country where you reside.

If any questions about our data protection measures, the processing of your data or the protection of your data subject rights occur, you can contact our data protection officer as follows:

External data protection officer

ePrivacy GmbH

represented by Prof. Dr. Christoph Bauer

Große Bleichen 21

20354 Hamburg

Germany

e-mail address: privacy@youscan.io

If you have a particularly sensitive request, please contact our data protection officer through postal mail, as communication by e-mail can always be subject to security gaps.

This Author Privacy Policy shall be governed and construed in accordance with the laws of Republic of Cyprus. The courts of the judicial district of Nicosia, Cyprus have exclusive jurisdiction in relation to any dispute arising out of or in relation with this Author Privacy Policy.

This statement only addresses the processing of your data by YouScan. Our customers and other third parties, which may have access to your data, may process your data differently in accordance with their laws, their own privacy policies and the different social media platform policies.

If our processes change, we adjust the information in this Author Privacy Policy.

Status of this this Author Privacy Policy: June 30, 2022.