Last Updated: May 25, 2018
1. Protection of Personal Information
Canadian law governs the collection, use and disclosure of personal information in a manner that recognizes individuals’ right of privacy with respect to their personal information. The federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) sets out rules and principles for the management of personal information by commercial organizations.
InNetwork services are made available to Influencers and third-party companies across Canada. PIPEDA applies to InNetwork because it is an organization headquartered in Nova Scotia, Canada. The type of personal information protected includes almost any information about an identifiable individual, such as your name, address, telephone number, age, sex, marital status and nationality.
PIPEDA provides certain fundamental principles which apply to the collection, use and disclosure of your personal information. One of the most significant is your personal information generally cannot be collected, used or disclosed without your consent. It also allows you to find out why your personal information is being collected, how it is being used, where it’s being stored and to whom it’s been disclosed. It requires the use of appropriate safeguards to secure your personal information. It also grants you access to your personal information and provides mechanisms for ensuring compliance. InNetwork does not collect, use or disclose your personal information without your consent except where required or allowed by law. Those customers or influencers who reside within the European Union are also subject to additional rights within the protections of the General Data Protection Regulations 2016 “GDPR”.
2. What Information Do We Collect
InNetwork requests certain information from you if you elect to register as a user of this site (“Registration Information”). Registration Information, at a minimum, includes your full name, email address, phone number and postal code. Your registration may contain additional information such as your experience, education, achievements or any other information about yourself you decide to provide. At times, we may ask you to provide us with general information about you to assist us in meeting your needs or to better understand requirements including profiles and experience. We collect and analyze personal information from online from sources such as LeadSift, Full Contact, Facebook, LinkedIn, Tumblr, Pinterest, Instagram, and Twitter. This collection of “Influencer” information may include your personal information, even if you have not directly signed up for the InNetwork service. InNetwork will generate additional profile information through our own proprietary automated scoring methodology related to an Influencer’s performance in past campaigns and the Influencer’s impact in generating results.
You can visit this site without telling us who you are and without providing InNetwork with any information about yourself. However, certain anonymous information (“Anonymous Information”) may be collected by us our third-party technology partners automatically. Our web server may collect the IP address and the name of the Internet Service Provider (“ISP”) associated with the computer from which you accessed this site, the type and version of web browser and operating system you are using, and the address of the website/page you visited prior to this site. If your web browser is configured to accept cookies, we may place either temporary cookies (only until you exit your current browser window) or permanent cookies (until you manually disable or delete the cookie using your browser software) on your computer. A “cookie” is a small piece of information our Web server automatically sends to your browser for storage on your computer, which then permits our web server to recall information about your preferences as a part of the Anonymous Information. Please note portions of this site will not function if you do not accept cookies.
With the exception of the Anonymous Information described above, you will always know when we are collecting information from you and therefore have the opportunity to not provide the information.
We do not knowingly solicit information from children and we do not knowingly market our services to minors.
3. Use of Information by InNetwork
Influencer Information is collected for the purpose of building a database of influencers, which can be accessed by third-party companies interested in building a network of Influencers to help them achieve their marketing objectives. Companies will be able to query the database, build and edit their network, and then send their network of influencers a marketing campaign brief. Influencer information is used to present marketers with a complete profile, so they are more likely selected for paid opportunities. Influencers always maintain complete autonomy and can choose if they’d like to accept or decline the engagement.
The types of people who will be viewing Influencer profiles include Account Directors, Consultants, Associate Consultants, Account Planners, Digital and Social Media Planners, VPs of Marketing, Media Managers and Brand Managers. Influencers will be provided with their choice of either accepting or declining to participate in campaigns.
Marketer Information will be used for the purposes of registration, running credit checks and correspondence. InNetwork reserves the rights to deny or accept all marketing applicants. All marketing briefs will remain in the strictest confidence and only viewable by InNetwork employees such as Account Managers and Planners and the selected Influencers who receive said briefs.
InNetwork makes every effort through contractual means and through the use of user IDs and passwords to restrict those who have access to our Influencer database and marketing briefs for the purpose of fulfilling marketing campaigns. However, InNetwork cannot guarantee all employers, third-party companies and other persons with access will adhere to the limitations we impose on them, or unauthorized persons will not gain access to the database. If at any time you would like your Influencer profile removed from our site, you may do so by using the “Delete Profile” function located on the site. Similarly, marketers may choose to terminate using our service however, those who have subscribed for access to the database, or for briefs already submitted, someone may already have retained a copy in their own systems and databases.
Email correspondence is used primarily to update you on the service regarding new developments and information about our services, to answer your questions, and to provide you with the services you have requested. User Information may also be used to determine appropriate new features, content or services for this site, to provide Influencers and companies with aggregate, but not personally identifiable information about our influencers and marketers preferences, including statistical information about the number of influencers and marketers, campaign numbers, aggregate results, and overall usage and trends.
Anonymous Information is used to measure the number of visits, average time spent, page views, and other statistics about visitors to this site. We may also use this data to monitor site performance for systems administration purposes, to make this site easier and more convenient to use, for law enforcement purposes, and to report information in aggregate, but not personally identifiable. If cookies are enabled for your Internet browser, then they may be used to help us measure the number of visits, average time spent, page views, and other statistics relating to your use of this site. If you are performing a search on our site, then a cookie is used to carry the search request data from the request page to the results page. This cookie, by itself, does not tell us your email address or who you are.
When information is collected from you by InNetwork as a part of an online or email-based survey, no personally identifiable information is requested during such surveys and all collected information is used on an aggregated basis only.
5. Communication with InNetwork
If you contact us, we may keep a record of the correspondence, but we do not make any use of the email address or other contact information, other than to respond to the communication.
6. Improper Use of Personal Information
7. Retention of Information
Influencers may choose to delete their profiles from our records at any time. Certain Registration Information regarding your account with us will normally be retained such as your name, email address and postal code should you subsequently wish to use our services. Influencers who fall within the GDPR may request all future references to their personal information be denied. In order to adhere to the GDRP guidelines, a minimal set of personal information (your social network identifiers) will be required to be able to confirm your request to deny future processing. We maintain record retention practices and policies, which apply to personal information no longer necessary or relevant for the identified purposes, or which is no longer required or permitted by law to be retained. All personal information destroyed or erased from our records is done so securely with due regard to the sensitivity of the information.
8. Your Consent
We do not collect, use or disclose your personal information without your consent except where required or permitted by law. We may also disclose personal information without knowledge or consent to a lawyer or other advisor representing InNetwork, to collect a debt, to comply with a subpoena, warrant or other court order or rules, is required for the investigation or enforcement of laws, or as may otherwise be required or authorized by law. Where a request for personal information is made by an organization claiming lawful authority for the request, InNetwork will take reasonable steps to ensure the requesting party properly identifies its legal authority.
We will generally obtain your consent electronically on our site. However, it may also be obtained in writing or verbally. In determining the appropriate form of consent, we will consider the sensitivity of and reasonable expectations regarding the personal information.
9. Disclosure of Information
10. Access and Accuracy and Update of Personal Information
We will take reasonable steps to ensure your personal information is as accurate, complete and up-to-date as is appropriate for its purposes and to minimize the possibility inappropriate information may be used to make a decision about you. InNetwork provides you with the means to access, update, edit or delete the Registration Information and certain other personal information you have provided to us at any time on your own by logging onto the site and changing or deleting your Registration Information and other personal information, as desired. We ask for you to regularly log in to the site and update your personal information and, in particular, your contact information, to ensure its accuracy.
You can update or delete your Influencer Profile at any time by logging on to the site and making the required changes. However, agencies, companies and others who subscribe to the InNetwork database, may already have retained a copy of your Profile in their own systems and databases.
You may similarly contact us to address errors or omissions relating to your personal information by email to firstname.lastname@example.org. If you decide at any time you do not want to receive any updates to which you have subscribed, you can login to the site and change your personal preferences.
An individual shall be able to challenge the accuracy and completeness of the information and have it amended, as appropriate.
12. Data Controller
InNetwork processes personal information as both a “Processor” and a “Controller” as defined within the Directive of the GDPR.
All personal data collected by InNetwork through the use of the product will be stored in a secure hosting facility provided by Amazon Web Services. All hosting is performed within the US in accordance with the highest security regulations.
13. Data Controller
As per the requirements of GDPR, the processing of your personal information is necessary for the purposes of legitimate interests pursued by gShift to whom the data is disclosed, except where the processing is unwarranted by reason of prejudice to the rights and freedoms or legitimate interests of the data subject.
Users located within the European Union have certain rights under the GDPR which include:
- The right to be informed.
- The right of rectification.
- The right to erasure.
- The right to restrict processing.
- The right to data portability.
- The right to object.
- Rights of automated decision making and profiling.
For GDPR specific inquiries please contact our “Data Protection Officer” at GDPR@innetwork.net
If you wish to file a GDPR Subject Access Request, please visit https://app.webpresenceoptimizer.com/GDPR for more information.