Privacy Policy

Privacy Policy

Last Updated: 14 March 2018

Your privacy is one of our fundamental commitments here at Sether, and therefore, we take utmost care to process your personal data in accordance with the principles set forth in the applicable legislation. We recognize the importance of maintaining the confidentiality, integrity, and security of your personal information (“Personal Data”) and have written this Privacy Policy to explain how your Personal Data is collected, stored, used and disclosed by MWARE SOLUTIONS SRL, a company incorporated under the Romanian law, having its headquarters at 77 Popa Savu Street, Bucharest, Romania („Sether”, „we”, „us”), as a data controller, with respect to your access and use of our website www.sether.com (the “Platform”). Each time we are required by applicable law, we will ask for your free, informed, specific and unambiguous consent for the processing of your Personal Data. By expressing your consent, you will agree that we can collect, use, disclose, process and transfer your information as described in this Privacy Policy.

We reserve the right to change the provisions of this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will make the updated version available on the Platform and update the “Last Updated” date found at the top of this Privacy Policy. We encourage you to review this Privacy Policy from time-to-time to make sure that you understand how your Personal Data will be used. Any changes to the Privacy Policy will apply on the date that they are made, with the exception of changes which require your prior consent and which will apply as of the moment when you express such consent.

1. Type of data and purpose of processing

1.1 Browsing Data

Computer systems and software procedures used for the Platform’s operation acquire, during their normal operation, some Personal Data (so-called log files), the transmission of which is implicit in the use of internet communication protocols.
This information is not collected in order to be associated to identified persons, but due to its nature can, by means of processing and integration with data held by third parties, allow users to be identified. Such information includes the IP addresses or domain names of the computers used by the users to connect to the Platform, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the reply given by the server (done, error, etc.) and other parameters concerning the user’s operating system and computer environment.

We use this data for the sole purpose of obtaining anonymous statistical information concerning the use of the Platform and to check its correct operation.

The legal grounds for processing the browsing data consist of our rightful interest in the improvement of our Platform and in managing the server capacities, and in the bug-free preservation of our Platform as well as in allowing us to comply with our legal duties related to safeguarding IT security.

1.2. Data processing in order to provide the Platform

1.2.1. If you are an Influencer

A. Registration

a. Directly on our Platform

If you are an influencer and want to join our platform, you can register on our Platform and create an account. When you create such an account you need to provide a username and your email address. We will use this data in order to offer you the possibility of creating the account and to give you access to all the features available for influencers.

b. Registration with Facebook or Twitter accounts

On our Platform, as in influencer, you also have the possibility to register with your Facebook or Twitter accounts.

Facebook Login

The Platform offers you the possibility to register using your Facebook access (the so-called Facebook-Connect feature). Facebook-Connect is a service of the social network Facebook, operated by Facebook Inc. (1601 Willow Road, Menlo Park, California 94025, USA (“Facebook”)). Before registering, you are lead to a Facebook page where you can log in using your Facebook username and password. As a consequence, the Platform will be connected to your Facebook profile. The connection automatically causes the Platform to receive from Facebook the information you agreed to: email address, first name, last name, profile picture, gender and age range. This information will be processed by us in order to offer you the possibility of creating the account and to the extent necessary to identify you in the context of the features offered by the Platform and to offer you the various features on our Platform.

We are not responsible for the processing on Facebook of your Personal Data. For further information about Facebook’s privacy settings, please refer to Facebook’s privacy policy: https://www.facebook.com/about/privacy.

Twitter Login

The Platform also offers you the possibility to register using your Twitter access (the so-called Sign in with Twitter feature). Sign in with Twitter is a service of the social network Twitter, operated by Twitter Inc. (1355 Market Street, Suite 900, San Francisco, CA 94103 U.S.A. (“Twitter”)). Before registering, you are lead to a Twitter page where you can log in using your Twitter username and password. As a consequence, the Platform will be connected to your Twitter profile. The connection automatically causes the Platform to receive from Twitter the information you agreed to: email, your tweets, home timeline and profile information. This information will be processed by us in order to offer you the possibility of creating the account and to the extent necessary to identify you in the context of the features offered by the Platform and to offer you the various features on our Platform.

We are not responsible for the processing by Twitter of your Personal Data. For further information about Twitter privacy settings, please refer to Twitter’s privacy policy: https://twitter.com/privacy.

B. Facebook and Twitter profiles

Even if you choose to register directly on the Platform, without your Facebook or Twitter accounts, you have the possibility to link your Facebook or Twitter accounts to your Platform account.

In such cases, as well as in the cases in which you have registered with your Facebook or Twitter accounts, the Platform will be connected to your Facebook or Twitter profile and we will receive the certain information you have agreed to.

As such, from your Facebook account we will collect and process, for example, the following Personal Data: location, posts, shares, and likes.

From your Twitter account we will collect and process, for example, the following Personal Data: read access to Twitter resources, including tweets, home timeline, and profile information. It does not allow access to read a user’s Direct Messages.

We will use this information to offer you various features on our Platform.

We are not responsible for the processing by Twitter or by Facebook of your Personal Data. For further information about their privacy settings, please refer to their privacy policies.

B. Loyalty Campaign

As an influencer, you have the chance to participate in our Data Collection Loyalty Campaign. In order for us to offer you this feature, we need to process the following data: phone number, email, address, gender, relationship, country, city.

To the extent that we process your Personal Data in order to provide various features of our Platform and such Personal Data is strictly necessary for providing the features, as for example, when you register on our Platform and when you choose to participate in the loyalty campaign, the legal ground consists in the execution of the agreement. In the absence of your Personal Data, we cannot provide you the services through the Platform. To the extent, we will process Personal Data in connection with the Platform, but which are not strictly necessary for the execution of the agreement, as for example the Personal Data we collect and process from your Facebook or Twitter accounts, we will also request your prior consent.

 

1.2.2. If you represent a company

A. Registration

On our Platform, you have the possibility to register a company and create an account. When you create such an account you need to provide certain information, such as a username, company name, email, Facebook pages, Facebook posts, Twitter profile, tweets, home timeline, and profile information.

We will use the aforementioned data in order to offer you the possibility of creating the account and to give you access to all the features available for a company.

B. Running campaigns

Each company has the possibility to run campaigns on our Platform. When you run a campaign, we will process the following data: Facebook pages, Facebook posts, Twitter profile, tweets, home timeline, and profile information.

We will use the aforementioned data in order to offer you various features of the Platform, including running campaigns and verify the fulfillment of the campaign rules.

Although, generally, this information regards a company and not a natural person, due to its nature can, in certain cases, be associated with a natural person. In such cases, this Privacy Policy becomes applicable.

In case the information received from a company is qualified as Personal Data, the legal grounds for processing such Personal Data are as follows. To the extent that we process your Personal Data in order to provide various features of our Platform, including to register on our Platform or running campaigns on our Platform, the legal ground consists of the execution of the agreement. In the absence of your Personal Data, we cannot provide you the services through the Platform. To the extent, we will process Personal Data in connection with the Platform, but which are not strictly necessary for the execution of the agreement, we will also request your prior consent.

1.3. Contact

On our Platform, it is possible for you to contact us in various ways: e-mail, telephone or directly on the Platform. When you do so, we will use the Personal Data you voluntarily provide to us in that situation only to contact you in the administration of your inquiry.

The legal ground for this processing consists of the administration of or the realization of precontractual or contractual measures at the request of the person contacting us. In the absence of your Personal Data, we cannot contact you in the administration of your inquiry.

1.4. Marketing

When you subscribe to our newsletter, we will use your e-mail address to send newsletter e-mails. You can revoke your prior consent at all times and without any costs, with altering consequences for the future.

The legal basis for processing your e-mail address for the purpose of sending the newsletter requested by you is your consent.

1.5. Other Purposes

We also process your Personal Data in order to validate, to enforce and to protect our rights. The legal basis for such processing is our rightful interest towards the enforcement of our rights.

2. Duration

In principle, we will retain your Personal Data for as long as it is necessary for delivering our services and fulfilling the other purposes listed in this Privacy Policy. In some circumstances, we may retain your Personal data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax or accounting requirements.

In specific circumstances, we may also retain your Personal Data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

3. Transfer of Personal Data

Your Personal Data is filed and stored on the servers of our contractual partners that are helping us to provide our services to you. Currently, the servers are located in Frankfurt, Germany.

While as a rule, we shall not disclose your Personal Data to any third parties, we may transfer the information we collect with third parties, such as authorities, business partners, contractors, or other parties working on our behalf. Such third parties may be located within the EU and outside the EU, including to countries which are not recognized as ensuring an adequate level of protection. We will only transfer your Personal Data provided adequate safeguards are in place, according to the applicable law, and we will take steps to ensure that your Personal Data is adequately protected. In this sense, we rely on several legal guarantees, such as the EU-U.S. Privacy Shield and the EU Model Standard Contractual Clauses. You can receive from us a list of third country recipients as well as a copy of the agreed provisions assuring an adequate level of data protection. Please refer to the contact details below.

Additionally, it is possible, though unlikely, that we might be forced to disclose certain Personal Data in response to legal process or when we believe in good faith that the law requires it, for example, in response to a court order, subpoena or a law enforcement agency’s request.

4. Cookies

In the interest of giving our Platform an attractive appearance and in order to allow the use of certain functions, we use cookies on various pages of our Platform. They consist of small text files that are stored on your computer. Most of these cookies used by us will be erased from your hard drive immediately after your browser session (so-called session cookies).

Other cookies remain saved to your computer’s hard drive and enable us to recognize your computer in the event of a later visit to our website (so-called persistent cookies). It is particularly these cookies that allow us to make our Platform more user-friendly, effective and safe.

The lifetime of a cookie may significantly vary, depending on the purpose for which it is placed. As mentioned above, certain cookies are used exclusively for a single session (session cookies) and are deleted once the user leaves the website, while other cookies are kept and reused each time the user comes back to the respective website (persistent cookies). However, the cookies may be deleted at any time by adapting to browser settings.

Generally, cookies can be installed by the operator of the website the user is visiting (so-called first party cookies) or by other websites (so-called third party cookies). Note that this Cookie Policy does not cover the use of cookies by such third parties and for more information about such cookies, please access their cookie policies.

The legal grounds for processing the cookie information for our users consists of the execution of the agreement as well as of our rightful interest towards the safe and user-friendly presentation of the Platform.

If you wish, you can limit or delete the cookies using your internet browser settings. However, we remind you that, in the event of limited cookie settings on your computer, you will not be able anymore to use all functions of our Platform to the fullest extent possible.

Cookies used on our Platform

The cookies used on our Platform are categorized as follows:

  • Performance. These cookies collect information about how you use our Platform – e.g. which pages you visit and if you experience any errors.
  • Analytics cookies. These cookies are used to collect aggregate information on the number of visitors and on how they use the Platform.
  • Functional cookies. These cookies allow the user to browse as a function of certain pre-determined criteria in order to improve the service offered.
  • Session cookies. These cookies allow the user to login to the Platform without entering their credentials in order to improve the service offered.

The cookies used on the Platform are listed in the following tables:

First Party Cookies
Cookie name Category Type Purpose Strictly necessary Duration Domain source
JSESSIONID functional session Used to track the user’s session Yes 60 minutes sether.com
XSRF-TOKEN functional session Used to secure requests that belong to a session Yes 60 minutes sether.com
social-authentication functional session Used to authenticate the user in social networks Yes 5 min sether.com

 

Third Party Cookies
Cookie name Category Type Purpose Strictly necessary Duration Domain source
_ga Analytics cookies persistent used to collect Google Analytics data No 2 years Google Analytics
_gat Analytics cookies persistent used to collect Google Analytics data No 1 minute Google Analytics

 

5. Security

Security of your Personal Data is important to us. Therefore, we provide reasonable administrative, technical, and physical security controls to protect your Personal Data. However, despite our efforts, no security controls are in all cases effective. With that in mind, we cannot warrant at all times the security of your Personal Data.

6. Your rights

You have the following rights in connection with the processing of your Personal Data:

Access right: You have the right to access your Personal Data processed by us.

Right of rectification and the right to erasure: At all times, you have the possibility to rectify or erase your Personal Data, provided that the applicable legal requirements are met. In the event of errors, we will, upon notification, immediately correct our information about you. Personal Data will be erased when the legal requirements are met.

Restriction of the processing: If the applicable legal provisions are met, you can require us to restrict the processing of your Personal Data.

Right to data portability: Insofar the Personal Data is processed based on your consent or on the execution of the agreement and the processing is carried out by automated means, you have the right to have the Personal Data transmitted directly to another controller, where technically feasible. This right shall not adversely affect the rights and freedoms of others.

Right to object to the processing of your Personal Data: You have the right to object to the processing of your Personal Data by us. We will cease to process your Personal Data unless we can demonstrate imperative rightful grounds for further processing (according to the applicable legal provisions) that outweigh your objection rights.

Objection to direct marketing: You can also object to the processing of your Personal Data for the purpose of marketing.

Right to object to processing of Personal Data based on the legal ground of your “rightful interest”: You are entitled at all times to object to the processing of Personal Data, based on your rightful interest. We will then cease to process your Personal Data unless we can demonstrate imperative rightful grounds for further processing (according to the applicable legal provisions) that outweigh your objection rights.

Revocation of consent: Insofar you consented to the processing of your Personal Data, you can at all times revoke your consent, without affecting the lawfulness of processing based on consent before its withdrawal.

Right not to be subject to any automatic individual decisions: If the applicable legal provisions are met, you have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

Right to address the courts of law and the supervisory authority: You have the right to lodge a complaint in relation to any breach of your rights regarding the processing of your Personal Data.

To learn more about the manner in which you may exercise the aforementioned rights, please contact us at contact@sether.com.

7. Contact us

If you have any questions or concerns about this Privacy Policy or its implementation, you may contact us at contact@sether.com.