Privacy Policy – True Followers
Last updated 2022-08-10
Who are we:
Our website adress is: (www.truefollowrs.com)
True Followrs is a platform for influencers and entrepreneurs who want to monetize their exclusive content. This Privacy Policy applies to Followrs, Influencers and all users of the True Followrs Platform and is part of our Terms and Conditions.
True Followrs is a Danish-based company with a global perspective. When you use the True Followrs Platform, you agree that your personal data that you provide directly to us or that we collect through your use of the True Followrs Platform may be transferred to and stored in Sweden for the time being and processed as described in this Policy.
Information you provide through your account
This is information that you provide to us via text fields, such as your name, payment information etc. The information we collect varies depending on whether you create an account, become a Followr or become a verified Influencer.
First and last name
Email address
User name
Password
Country of residence
You can also sign up using a Facebook or Google account. We ask for permission to access basic information from your Facebook or Google account, such as your name, email and profile picture. You can choose to no longer share this information with us at any time by going to Facebook or Google to remove True Followrs’ access to that account and your ability to log in. Notwithstanding, you still need to go through the necessary True Followrs KYC process.
You also have the option to add additional information to your public profile, such as a location, social media links, and an about section, which we store along with any comments or messages you submit on True Followrs.
A True Followr (“a Followr”)
A true Followr is a person who joins the True Followrs Platform and sign up to a subscription plan to follow and support an Influencers content (“a Followr”). As a Followr, you must provide your payment information to our payment provider.
At this point, we do not receive your full card number. Our payment provider provides us with a tokenization including symbol representing your account, your card’s expiry date, card type and the last four digits of your card number. If you are required to provide your name and email address to the payment provider, they will also provide us with this information.
We collect and process information about the Influencers you support, the level at which you support them, what content you receive and how often you support them.
An Influencer (“Influencer”)
An Influencer is a person who creates and delivers content to their Followrs via the True Followrs Platform (“an Influencer”). To become a verified Influencer, you must create a page describing what you deliver, your age and upload a valid ID proof that verifies your identity. To receive payouts, you must have a credit card. We may also ask you for your bank account details in order to complete withdrawals. You may also provide us with additional information for tax purposes. Depending on where you live, you may need to fill out a form with a combination of:
First and last name
Address
CPR
Personal ID with picture
Country of citizenship
Country of nationality
Date of birth
Account information for withdrawals
Phone number
Additional information we collect
Automatically collected information
We collect information automatically when you navigate the website or through our third-party analytics providers. We may store usage information such as the type of device you use to access the True Followrs Platform, your operating system, browser type, IP address and device ID, the pages you visit or request, links you click, referring websites, user interactions and your keywords. We also derive your location from your self-reported country, your IP address and from your payment card.
Comments and messages
When you send messages or write comments, we can collect the things you share and record the activity on the website where users have replied, who they have communicated with, private messages, IP address and where the user was last logged in from.
User surveys
From time to time, we may ask you to participate in user surveys. We may ask you for demographic information, including information about gender, ethnicity, race, age, sexual orientation, earnings and accessibility to better understand and serve our user base – you can choose to share this information or not. We collect such information to ensure that we provide fair and equal access to our services and to highlight Influencers to Followrs so they are easier to spot. We save your questionnaire answers to the extent that you participate.
Information about events
For in-person and online events, we may ask you for information. This is done to better acclimatize the event experience to the participants. This information may include name, email address, payment information, mobile phone number and QR code, demographic information, social media and other online accounts that you have, information about the types of works you create, and responses to surveys or feedback.
Information collected by third parties
Cookies
On our website, we use cookies that collect information so that we and third parties can understand your use of True Followrs. See our Cookie Policy to learn more about our use of cookies on True Followrs.
How we use your information
We process your information to:
confirm your identity to comply with Danish and international laws
allow you to log into your account
allow you to support an Influencer’s subscription plan on the True Followrs Platform
process member payments and payouts
send you e-mails that are relevant to your use in relation to your e-mail preferences
answer your questions
provide you with existing and enhanced services related to your True Followrs account
advertise your True Followrs account in order to increase its visibility
highlight and celebrate Influencers
market True Followrs products and services to you or to audiences similar to you, based on your networks and commonalities that others have with you, unless you opt-out in relation to your email preferences
understand how you use the True Followrs Platform and create better tools for Influencers to service their Followrs
conduct research and development to improve True Followrs and develop future products
prevent fraud and abuse on True Followrs
Information we share with Influencers
By becoming a Followr of an Influencer, you agree to have the following information shared with that Influencer:
your name and email address and other profile information you have provided
messages you send to Influencers via the True Followrs Platform
all information about your contribution, including amount and start date, but not your full payment card details
some aggregated and anonymized data about how you use True Followrs that cannot be traced back to you or to an individual user
As an Influencer or entrepreneur, you accept the terms of our Data Processing Agreement (DPA) when you start your journey as a verified Influencer. You can view a copy of the Influencer DPA further down below.
Information we share with third parties
We never sell your information to third parties. Except with Influencers, we only share data with third parties under the following circumstances:
with our service providers, which are companies contractually engaged with us to provide services to us, such as email management, data trend analysis, credit card processing, multi-currency settlement solutions, increasing our brand awareness and user engagement with marketing initiatives and fraud detection and prevention. These companies may have access to your data to perform their services and are contractually obligated to protect the data they receive from us to the same extent that True Followrs protects it.
to protect our security or integrity and to protect the rights, property or safety of True Followr ApS, its employees, users or others if we believe disclosure is reasonably necessary to comply with a law, regulation or other valid legal process (eg subpoenas or arrest warrants served on True Followrs). If we release your data, we will do our best to notify you immediately by email, unless the law prohibits us from doing so.
in connection with a sale, merger, bankruptcy, sale of assets or reorganization of our business. We will notify you if another company receives your data. The promises in this Privacy Policy apply to all data transferred to a new company
with partners in our partner register who may have access to your data to perform their services and who are contractually obligated to protect the data they receive from us to the same extent that True Followrs protects it.
Information True Followrs collects from third-party apps
When you create a True Followrs account, you can choose to link one or more social accounts (e.g. Facebook or Google) to True Followrs, as we may thus collect and store some social information from these platforms.
This social information allows us to provide you with a better experience on True Followrs and creates space to develop the True Followrs Platform. We use this data to:
help Influencers and Followrs find each other on the True Followrs Platform
assess how we can give Influencers greater success on the True Followrs Platform
analyze and develop our business
Information we share with the public
The following information is publicly available:
your profile and your social media links and location if you add this information
anonymized posts, amount of likes or comments
Your aggregated or anonymized usage data in posts, press releases or in other ways to share information about the use of the True Followrs Platform. Aggregated or anonymized data cannot be traced back to an individual True Followrs user.
Your preferences and rights over data
Marketing activities
By accepting our Terms and Conditions, you expressly agree that True Followrs may:
provide you with information about your service, service improvements or new True Followrs feature while you are on our website.
send you notices regarding your existing service or improvements related to your existing service when you are not on the True Followrs Platform, via email.
send you messages related to services we provide that are separate from your existing service via email that you can opt out of
Market the True Followrs Platform to you and audiences similar to you based on your networks and commonalities others have with you, unless you opt out.
send you marketing-related emails or text messages if you do not have a True Followrs account but have consented to receive such messages, which you can opt-out of.
ask for demographic information to highlight and celebrate Influencers.
advertise your True Followrs account in order to increase its visibility.
Opting out of marketing
You can object to the use of your data for marketing purposes at any time – and completely free of charge – when we collect your personal data and in all marketing communications. You can also object to the use of your data for marketing when you create your account, or at any time thereafter, by emailing support@truefollowrs.com.
By opting out, marketing-related emails are stopped. It may take up to 30 days before your opt-out request is processed. If you have an account with True Followrs, you may continue to receive service-related emails.
We never sell your information to third parties for marketing purposes without your prior consent.
Access, update or export information in relation to your account
You may access, update and export certain information associated with your account by contacting support@truefollowrs.com.
Protection of personal data
True Followrs is an international company that complies with the General Data Protection Regulation (GDPR). We act as data controllers, as defined in the GDPR, and process personal data based on our legitimate interests and contractual necessity in order to offer you the service as described below. We also process and share personal data based on notification and users’ consent, which our users can revoke at any time.
Personal information, purpose and legal basis, etc.
When you visit our website, we use cookies and similar tracking technologies to collect data about your visits, including e.g., your navigation on the True Followrs Platform the type of browser or device you use and your IP address. This data may contain personal data.
For the True Followrs Platform, we collect the data to ensure a stable, secure and user-friendly experience on the True Followrs Platform, as well as to keep statistics on the True Followrs Platform visitors. In some cases, data is processed to target marketing based on web browser behavior.
The legal basis for our processing is:
for necessary (technical) cookies on the True Followrs Platform: Article 6(1)(f) of the GDPR, as we pursue our legitimate interest in ensuring functionality and security on our website, and
for other cookies and similar technologies on the True Followrs Platform: Article 6(1)(a) of the GDPR, since you have given your consent to, for example, targeted marketing.
We disclose information about your use of the True Followrs Platform to any third-party service providers that you have permitted to place cookies and/or similar tracking technologies when you use the True Followrs Platform. If you have given your consent, such third parties include:
Personal data contained in cookies will be deleted in accordance with the lifetime/period of each specific cookie. Read more about our cookies in our Cookie Policy. You can read more about the processing of your personal data in the third-party provider’s own privacy policies.
When you create an account and use the True Followrs Platform
When you create an account to access True Followrs, you will be asked to enter your name and contact information, email address, and a password of your choosing. We collect such information from you in order to provide you with access to the True Followrs Platform and to ensure that your access account is secured with your own individual password. In addition, we will have access to information about your geographical location, gender and age. We collect information about your gender and age in order to tailor your experience of True Followrs to the best possible experience.
If you choose to link your True Followrs profile to Facebook, Google or a similar third-party service that manages personal data, True Followrs may collect and process information that you authorize the relevant third party to share with True Followrs. You can read more about the third-party providers’ processing of your personal data in the third-party providers’ own privacy policies.
With respect to Followrs with a paid subscription to an Influencer on the True Followrs Platform, we will also collect payment information to provide you with access to your subscription. However, since True Followrs works with third-party payment service providers that operate independently in systems separate from True Followrs, no complete payment data, such as complete credit card numbers, will be stored by True Followrs.
Additionally, where the option is available, you may choose to provide us with additional information. We collect such additional information from you to provide you with suggestions for content that may be of interest to you based on the information provided. However, such information is not required and completely optional.
We also collect information about the source of your subscription, for example through our own channels, and in case you sign up to the True Followrs Platform as part of a promotion, or partnership with a third-party brand, product or service, we process this information to enable us to ensure that you receive the content of the subscription you have signed up for, to manage our relationships with partners and to measure campaign success.
In addition, we will have access to information about how you interact with the True Followrs Platform, including what content you have searched for, interacted with, viewed and saved in your profile. This includes the processing of technical data (such as unique platform ID, device IP address). We collect such information from you to improve your use of the True Followrs Platform, including to make suggestions for related content, to analyze engagement with the True Followrs Platform, and to ensure that we are able to properly reward Influencers for consumption of their content.
We process personal data: i) to provide the True Followrs Platform, including personal data that you choose to provide us in order to use the True Followrs Platform; and ii) to establish the source of subscription, is based on Article 6(1)(b) of the GDPR, as the information is necessary for the performance of a relationship with you.
Personal data processed to analyze your use of the True Followrs Platform and measure the success of campaigns is based on Article 6(1)(f) of the GDPR as we pursue our legitimate interests in operating and developing the True Followrs Platform.
We only keep your data as long as it is relevant to us, and we have a legitimate purpose for keeping it. Your data will therefore be deleted in accordance with applicable data protection legislation and, as a general rule, your data will be deleted 5 years after the end of the financial year in which you choose to deregister from the True Followrs Platform.
In specific situations, we may extend our general retention periods (in the event of, for example, complaints, objections or other specific situations).
We pass on personal data included in our account registration to the relevant public authorities, including the tax and customs authorities, in connection with our statutory bookkeeping etc.
In addition, we pass on your personal data to the service providers of the online payment provider that we use. Finally, we make your personal data available to our group companies and data processors, such as host, developers and responsible for our IT systems and to provide analytics services connected to the True Followrs Platform.
When you register as an Influencer
When you join True Followrs, we record your personal data on the True Followrs Platform and in our IT systems, including name, contact details, country of residence, log-on details and password and bank account details. In addition, we process information about income etc. (where applicable) and information related to your content such as ratings etc. We process this personal data as part of our business, including for the purpose of managing the Influencer relationship, for billing purposes, to provide the services based on our contractual obligations with the Influencers and to make their content available to users.
The legal basis for our processing is Article 6(1)(b) of the GDPR, as the processing is necessary for the performance of our agreement with the Influencers, and Article 6(1)(f) of the GDPR, as we pursue our legitimate interest in the Influencer’s administrative tasks and communications with the Influencers, as well as taking care of accounting and financial tasks.
Personal data will generally be deleted 5 years after the end of the financial year in which the Influencer relationship has ended.
In specific situations, we may extend our general retention periods (in the event of, for example, complaints, objections or other specific situations).
We pass on personal data included in our account registration to the relevant public authorities, including the tax and customs authorities, in connection with our statutory bookkeeping etc.
We may pass on your personal data to our relevant business partners, including external advisers. Furthermore, we make your personal data available to our group companies and data processors, such as host, developers, etc.
Communication with us
When you communicate with us (e.g. via e-mail or via our contact form on our website), your communication may contain personal data, e.g. your contact information (including name and email address) and other personal data you may provide to us.
We process this personal data for the purpose of handling and answering your inquiries. The legal basis for the processing is Article 6(1)(f) of the GDPR, as we pursue our legitimate interests in handling general inquiries.
We only keep your data as long as it is relevant to us and we have a legitimate purpose for keeping it. Your data will therefore be deleted in accordance with applicable data protection legislation. Personal information relating to our general communication with you (such as e-mail enquiries) is deleted 5 years after the end of the financial year in which your last inquiry has been dealt with/ended.
In specific situations, we may extend our general storage periods (in the event of, for example, complaints, objections or other specific situations).
In addition, we pass on your personal data to the service providers of the online payment provider that we use. Finally, we make your personal data available to our group companies and our data processors, such as host, developer and responsible for our IT and CRM systems.
When you are subject to direct marketing
When you subscribe to our newsletter or other marketing communications, we record your name, email address and any additional information you may have provided. We do this to better target our marketing to you. In addition, we process this personal data with the aim of being able to send you targeted communications.
The legal basis for our processing is the consent you have given in accordance with Section 10 of the Marketing Act.
We emphasize that you have the right to object at any time to our processing of your personal data regarding marketing, including direct marketing. In addition, you have the right to withdraw your consent at any time.
Personal information relating to our distribution of marketing communications is deleted 2 years after our last marketing communication has been distributed, unless you have withdrawn your consent before this time.
We make your personal data available to our group companies and data processors, such as host, developers and those responsible for our IT systems.
If you participate in competitions administered by us
If you decide to enter competitions administered by us, for example as part of direct marketing, we may ask you to provide personal data such as your name, email address and other contact details (if you have not already provided this to us). We may also collect other personal information required to provide you with any prize offered in the event that you win the competition.
We process this personal data for the purpose of administering the competition, including contacting winners. The legal basis for the processing is Article 6(1)(f) of the GDPR, as we pursue our legitimate interests in pursuing and conducting promotional activities.
We only keep your data as long as it is relevant to us and we have a legitimate purpose for keeping it. Your data will therefore be deleted in accordance with applicable data protection legislation.
Personal information relating to competition administration is deleted 5 years after the end of the financial year in which the competition or draw has ended.
In specific situations, we may extend our general retention periods (in the event of, for example, complaints, objections or other specific situations).
We make your personal data available to our group companies and data processors, such as host, developers and those responsible for our IT and CRM systems that are used to administer the competition or that help to organize the competition.
Transfer of your personal data to third countries
We may transfer your personal data to countries outside the EU and the EEA if we make data available to any data processors in various third countries.
The basis for such a transfer is either:
Commission decision of 4 June 2021 on standard contractual provisions for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council or;
an EU Commission “Adequacy Decision” based on Article 45 of the GDPR.
Your rights, etc.
You have a number of special rights under the Data Protection Regulation to help you control your personal data, and we want to make it easy for you to exercise these rights:
Right to withdraw consent
Where you have given your consent to our processing of your personal data, you have the right to withdraw your consent at any time. You can withdraw your consent easily by contacting us directly at support@truefollowrs.com.
If you withdraw your consent, the withdrawal will not affect the lawfulness of processing that has already been carried out on the basis of your consent.
Right to see information (right of access)
You have the right to be informed whether we collect or process your personal data and, if so, you have the right to request a copy of your personal data in digital format.
Right to rectification
You have the right to demand that we correct any inaccurate personal data about you and that we fill in incomplete personal data.
Right to erasure
In certain circumstances, you have the right to request that we delete personal data about you; for example if it is no longer necessary for the purposes for which it was originally collected.
Right to restrict processing
In certain circumstances, you have the right to request that we restrict the processing of your personal data, e.g. if you believe that the personal data is not correct or lawfully processed.
Right to object to the processing
In certain circumstances, you have the right to request that we stop processing your personal data.
Right to data portability
In certain circumstances, you have the right to receive the personal data you have provided to us in a structured, commonly used, machine-readable format, and the right to have us transfer the data to another device where technically possible.
If you want to exercise your rights, please contact us at support@truefollowrs.com.
You can read more about your rights in the Data Protection Authority’s guidance on the rights of data subjects, which you can find at www.datatilsynet.dk or other relevant local authority.
Security
The security of your personal information is important to us and we follow industry standards to protect it.
Children
True Followrs is not intended for children under the age of 13, and children may not create an account or otherwise use True Followrs.
Changes
We may occasionally make changes to this Privacy Policy. If we make material changes that adversely affect your rights under this policy, you will be notified by email before the changes become effective. If you continue to use True Followrs after a change to this policy, it means that you accept the new policy. If you have any questions, please email support@truefollowrs.com.
Complaint to the Danish Data Protection Authority
You have the right to lodge a complaint with the Danish Data Protection Authority if you are dissatisfied with the way we process your personal data. You will find the Data Protection Authority’s contact information at www.datatilsynet.dk or other relevant local authority.
How to contact our data protection officer
If you have any concerns or questions about the Privacy Policy, you can contact us by email at support@truefollowrs.com.
Legal basis for processing your personal data
The legal basis for our processing of the information in this Privacy Policy follows from:
The Data Protection Regulation, Article 6, subsection 1, point a-b
The Data Protection Regulation, Article 7, subsection 1-4
Data Protection Act, §11, subsection 2, point 2
Data storage period
We retain your account information for ten years after the account was last active. We may continue to retain certain information even after you delete your account if required by us to comply with various international laws.
Influencer – Data Processing Agreement (DPA)
Date: 1 December 2022
Introduction
As part of the Influencers agreement with True Followrs, the following Data Processing Agreement applies between the Data Processor, the Influencers and the Data Controller, True Followrs, unless otherwise expressly specified in other agreements between the Parties.
The purpose of the Data Processing Agreement is to regulate how and for what purpose the Data Processor must process Personal Data on behalf of the Data Controller and to ensure that the Data Controller’s Personal Data is processed in accordance with the Data Controller’s guidelines and instructions as well as applicable data protection legislation.
The subject matter of the data processing, the nature of personal data processed, as well as the categories of data subjects will be defined by, and/or limited to, those necessary to carry out the relationship between the Influencers and their Followrs on the True Followrs Platform.
Categories of Registered and Personal Data that are processed appear in Appendix A.
Definitions
Personal data, special categories of Personal data (Sensitive personal data), Processing of personal data, the Registered, the Data Controller and Data Processor must have the meaning that follows from applicable legislation on processing of personal data, the General Data Protection Regulation (GDPR).
The Data Controller’s obligations
The Data Controller is responsible for ensuring that the processing of Personal Data meets the requirements of the Data Protection Regulation and the Data Protection Act.
When using the services that the Data Processor makes available in accordance with True Followrs Terms and Conditions, the Data Controller is obliged to process Personal Data in accordance with the provisions of applicable legislation, including, among other things, by:
ensure that the processing of Personal Data complies with the Data Protection Regulation,
ensure that those registered are informed about the processing of Personal Data,
ensure that the instruction is legal in relation to the personal data law regulation applicable at any time,
ensure that the instruction is appropriate in relation to this data processing agreement and the main service,
ensure that the data controller’s users are up-to-date,
ensure that they have introduced detailed procedures for safeguarding the registered rights
Obligations of the Data Processor
The Data Processor only processes Personal Data on behalf of and on the basis of instructions from the Data Controller.
Data processing must take place in the following way:
Only in accordance with applicable legislation,
To fulfill all obligations under True Followrs Terms and Conditions,
As specified through the Data Controller’s general use of the Data Processor’s services,
As stated in this Data Processor Agreement.
Data Processor notifies Data Controller, if any instruction in the Data Processor’s opinion turns out to be contrary to The Data Protection Regulation or data protection regulations in other EU law or the national law of the Member States.
The Data Processor must ensure that the Personal Data is subject to confidentiality, integrity and availability in accordance with applicable legislation on the processing of personal data.
This provision also applies after the termination of the Agreement between True Followrs and the Influencers.
The Data Processor ensures that the persons who are authorized to process Personal Data on behalf of the Data Controller have committed to confidentiality or are subject to an appropriate statutory duty of confidentiality to protect the Followrs of the Influencers.
The Data Processor must assist the Data Controller with appropriate technical and organizational measures, as far as this is possible, for the fulfillment of the Data Controller’s obligations to respond to requests from Data Subjects and for the general exercise of Data Subjects’ rights in accordance with Chapter 3 and Articles 32 to 36 of the Data Protection Regulation.
The Data Processor shall, without undue delay, notify the Data Controller of incidents which the Data Controller is required by law to notify to the Data Protection Authority or Data Subjects.
In addition, the Data Processor, to the extent that it is legal, notifies the Data Controller of:
Requests for disclosure of Personal Information received from a Data Subject.
Requests for the disclosure of Personal Information from public authorities, such as the police.
The Data Processor does not respond directly to inquiries from Data Subjects, unless there is consent from the Data Controller. The Data Processor does not pass on personal data to public authorities, such as the police, unless there is a legal basis.
The Data Processor does not have ownership of, or control over, whether and how the Data Controller chooses to make use of possible third-party integrations. The responsibility for such integrations with third parties rests solely with the Data Controller.
Security
The Data Processor must implement systematic, organizational and technical measures to ensure an appropriate level of security, taking into account the technology and the costs of implementation in relation to the risks that the processing entails, as well as the nature of the Personal Data that must be protected. The Data Processor provides this level of security through organizational, technical and physical security measures in accordance with the requirements for information security measures, which appear in Article 32 of the Data Protection Regulation.
Control
The Data Controller may carry out checks to ensure that the Data Processor complies with this Agreement, up to once a year.
If it is a legal requirement applicable to the Data Controller, the Data Controller can request more frequent checks.
Duration and Termination
This Data Processing Agreement is valid as long as the Data Processor processes Personal Data on behalf of the Data Controller in accordance with the Agreement – the Influencers relationship with True Followrs. The Data Processing Agreement ends automatically upon termination of the Agreement. Upon termination of this Agreement, the Data Processor deletes, returns or stores the Personal Information processed on behalf of the Data Controller in agreement with the Data Controller.
The Data Processor may withhold Personal Data after termination of the Agreement to the extent required by law, which is subject to the same technical and organizational security measures as set out in this Data Processor Agreement.
If any provision of this Data Processing Agreement becomes invalid, this does not affect the validity of the other provisions. The parties must replace the invalid provision with a legal provision that reflects the purpose of the invalid provision.
Liability
Liability for breach of the provisions of this Data Processing Agreement is governed by the liability provisions in True Followrs Terms and Conditions.
This Data Processing Agreement is an addendum to True Followrs Terms and Conditions and Privacy Polity and shall detail the requirements for Influencers to process Followrs Personal Data in relation to their connection to True Followrs.
Appendix A – Categories of Personal Data and Registered
Categories of Registered and Personal Data subject to processing in accordance with this Agreement
Categories of Data Subjects
The Influencer’s true Followrs who have subscribed to a subscription plan on the True Followrs Platform
Categories of personal data
Contact information such as, but not limited to name, username, email address, address and amounts paid as part of their subscription.
Possibly other personal data that is necessary for the Data Controller to manage the relationship.
Processing activities