Privacy Policy EN

Pursuant to and for the effects of art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of Personal Data and on the free movement of such Data (the “Regulation” or “GDPR“) and Legislative Decree no. 196 of 30 June 2003, “Code regarding the protection of personal data” (“Code“) (Code and Regulation jointly defined as “Legislation“), interested parties (“Data Subjects“) are informed that their Personal Data will be processed in compliance with current legislation and as specified below.

Definitions

• Account means the computer environment made available by the Data Controller for a specific User/Data Subject, implying the possibility, for the latter, to access the Call for creators HUUNO App and use the Services.
• Call for creators HUUNO App means the web application owned by the Data Controller and made available to Users/Data Subjects who want to use the Recruiting Service.
• Authorized Persons means natural persons authorized to carry out Processing operations under the direct authority of the Data Controller or the Processor, pursuant to art. 29 of the Regulation and art. 2-quaterdecies of the Code.
• Communication means giving knowledge of Personal Data to one or more specific subjects other than the Data Subject, the representative of the Data Controller in the State’s territory, the Processor, and the Authorized Persons, in any form, including through their provision or consultation.
• Designated Persons means natural persons assigned specific tasks and functions related to the processing of Personal Data and who operate under the authority of the Data Controller or the Processor, pursuant to art. 2-quaterdecies of the Code.
• Personal Data or Data means any information relating to a natural person, identified or identifiable, even indirectly, by reference to any other information, with particular reference to an identifier such as name, an identification number, location data, an online identifier or one or more elements characteristic of their physical, physiological, genetic, mental, economic, cultural or social identity.
• Dissemination means giving knowledge of Personal Data to indeterminate subjects, in any form, including through their provision or consultation.
• Guarantor means the supervisory authority referred to in art. 51 of the Regulation. Information or Privacy Policy means this document.
• Information or Privacy Policy means this document.
• Data Subject means the User of the Call for creators HUUNO App.
• Security Measures means the set of technical, IT, organizational, logistical and procedural measures adopted by the Data Controller to guarantee an adequate level of security to the risk of Processing, pursuant to art. 32 of the Regulation.
• Registration indicates the computer procedure through which the User is enabled to use the Services offered by the Data Controller through the Application. Registration on the Call for creators HUUNO App takes place by entering the email address by the User and receiving a temporary access link on the same.
• Data Processor means the natural or legal person, public authority, service or other body that processes Personal Data on behalf of the Data Controller.
• Services means all the functionalities that the Data Controller offers to Users through the Call for creators HUUNO App i.e. the service of collecting applications sent by Users to respond to announcements (“Call“) by communication agencies and/or companies and/or subjects interested in proposing sponsorship contracts, influencer marketing, etc. and the related notification to these subjects of the Users deemed most suitable (“Recruiting Service“)
• Website means the website accessible at the address: https://callforcreators.huuno.me/.
• Data Controller means the natural or legal person, public authority, service or other body which, alone or together with others, determines the purposes and means of the Processing of Personal Data; when the purposes and means of such Processing are determined by Union or Member State law, the Controller of the Processing or the specific criteria for its designation may be provided for by Union or Member State law. For the purposes of this Privacy Policy, the terms “Data Controller” and “Count26” are equivalent.
• Data Processing or Processing means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• User means the subject who wants to access the Call for creators HUUNO App. For the purposes of this Privacy Policy, the terms “User” and “Data Subject” are equivalent.

Information on the Processing of Personal Data

1 Types of data processed

1. Data provided by the Data Subject, meaning those data provided by the Data Subject to allow the latter to register, access the Account, and use the Services offered through the Call for creators HUUNO App. In addition to the data necessary for registration (name, surname, email), specific information may be requested for each Call that the User decides to participate in. Such data includes, for example, the following: date of birth, gender, city of residence, educational background, known languages, categories of interest, phone number (optional), information about the activity and experience of a content creator, information about past collaborations with companies. The User may also be required to share past content, link their social media profiles (such as Instagram, TikTok, YouTube), and upload original content. The User is informed that the provision of the aforementioned data is optional, but that, in case of failure to provide them, the Data Subject will not be able to submit an application and therefore use the Recruiting Service.

2. Data processed by the Controller, meaning those data resulting from the analysis of the information entered, the content shared by the User, the published content and the insights related to the social accounts connected by the User, the original content uploaded by the User, and, therefore, generated by the Call for creators HUUNO App.

3. Data acquired by the Controller for the functioning of the Website, intended as those data automatically collected by the Controller during normal browsing of the Website (e.g. IP address, date and time of the request, etc.). The User is informed that the computer systems and software procedures used for the functioning of the Website acquire, during their normal operation, certain Personal Data whose transmission is implicit in the use of the Internet network. These are not data collected to be associated with identified data subjects, but which, by their very nature, could, through processing and association with data held by third parties, allow users to be identified. As indicated above, this category of data includes “IP addresses” or domain names of computers used by Users who connect to the Website, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the web server, the size of the file obtained in response, the numerical code indicating the status of the response given by the web server (successful, error, etc.) and other parameters related to the operating system and the User’s computer environment. This data is used to verify the correct functioning of the Website (e.g. identification of unauthorized access). It should be noted that the aforementioned data may be used to ascertain responsibility in case of computer crimes committed against the Website of the Controller or through the use of the same. The User is also informed that, in addition to browsing data, for the functioning of certain sections of the Website, some data provided by the Data Subject will also be processed (e.g. username and password for access to the Account). The Data Subject is informed that the provision of this last category of data is optional, but that, in case of non-provision of the same, it will not be possible to access the Account.

    

2 Purpose of the data processing

	Purpose of the data processing	Legal basis	Storage time
A	The Personal Data referred to in Article 1.1 and Article 1.2 are processed to allow the User to register, access the Account, and use the Services offered through the Call for Creators HUUNO App.	The treatments carried out for these purposes are necessary for the performance of contractual obligations or to carry out pre-contractual measures requested by the data subject and do not require specific consent from the data subject.	10 years from the termination of the contractual relationship between the parties.
B	The Personal Data referred to in Article 1.1 are processed in order to respond to requests for clarifications or to provide assistance to the User for accessing the applications and/or using the Services.	The treatments carried out for these purposes are necessary for the performance of contractual obligations or to carry out pre-contractual measures requested by the data subject and do not require specific consent from the data subject.	12 months from the termination of the contractual relationship between the parties.
C	The Personal Data referred to in Article 1.1 (name, surname, email) may be processed by the Controller for the purpose of sending commercial communications via email to the Data Subject regarding the release of new versions (e.g. containing error corrections or new features) of the Call for Creators HUUNO App, or invitations to participate in creator recruiting initiatives and/or content acquisition.	The treatments carried out for this purpose are based on the legitimate interest of the Data Controller (informing Users about the release of new versions of the Call for Creators HUUNO App).	12 months from the termination of the contractual relationship between the parties.
D	The Personal Data referred to in Article 1.1 and Article 1.2 are processed to allow the User to use the Recruiting Service. For this purpose, the aforementioned data may be communicated by the Data Controller to the following categories of subjects: • communication agencies • companies • parties interested in proposing sponsorship contracts, influencer marketing contracts, or contracts with the same object to Users. Users are informed that the aforementioned subjects will operate as independent Data Controllers.	The treatments carried out for these purposes are necessary for the performance of contractual obligations or to carry out pre-contractual measures requested by the data subject and do not require specific consent from the data subject.	10 years from the termination of the contractual relationship between the parties.
E	The Personal Data referred to in Article 1.3 are processed for the purpose of properly providing the Services on the Website.	The treatments carried out for these purposes are based on a legitimate interest of the Controller (proper provision of the Services on the Website).	The browsing data is deleted immediately after processing and, in any case, is not stored for more than 15 days from the time of collection, without prejudice to any need for investigation of crimes by the judicial authority.

3 Processing methods and categories of Recipients

1. Unless otherwise expressly provided in this Privacy Policy, the Data Subject is informed that the Processing of their Personal Data is carried out by manual and/or computerized, telematic or automated systems, in compliance with the principles of relevance, lawfulness, correctness, and purpose provided by the Legislation.

2. The Data Controller processes the Data Subject’s Personal Data by adopting appropriate Security Measures aimed at minimizing the risks of unauthorized access, Disclosure, loss, and destruction of such Data, in accordance with the Legislation.

3. The Data Subject is also informed that the Processing of Personal Data for the purposes set forth above may be carried out by the Controller directly or by availing themselves of the collaboration of other subjects, as Data Processors, Designated or Authorized (e.g., employees and/or collaborators of the Controller). In particular, Personal Data may be communicated to the following categories of Data Processors:
   
   • External IT (information technology) consulting and assistance companies, professionals, or firms;
   • Cloud service providers;
   • Accountants and/or tax advisors;
   • E-mail service providers.

4. The list of Data Processors can be consulted at any time, upon request to the email address indicated in the subsequent Article 6.1.

5. The Data Subject is also informed that Personal Data may be communicated to third-party data controllers, who will operate as independent data controllers (see table in Article 2, letter D).

6. The Data Subject is informed, pursuant to Article 22 of the Regulation, that, for the provision of the Recruiting Service, their Personal Data will be subject to processing through an advanced proprietary algorithm based on artificial intelligence technologies that aims to evaluate: (a) the current and/or future performance of the Data Subject using indicators such as reach, impressions, number of comments and likes, views, etc.; (b) the Data Subject’s content creation abilities, through qualitative analysis of the produced content (e.g., photos, videos, audios, texts); (c) the relationship established by the Data Subject with their reference community, using indicators such as the sentiment of the comments, their relevance, and their interest in the topic addressed; (d) the potential performance of the Data Subject as an influencer in different product sectors (for example, evaluating the potential performance of the Data Subject “John” as an influencer in the fashion or luxury sector); (e) the compatibility of the Data Subject with the client’s requests, specified in the Call details.

4. Data Transfer

1. The Data Subject is informed that the Personal Data processed by the Data Controller may be transferred to other countries within the European Union.

2. The Data Subject is informed that the Personal Data processed by the Data Controller may be transferred to countries outside the European Union, for which there is a Commission adequacy decision or in other cases referred to in Article 46 of the Regulation.

5. Data Subject Rights

1. The Data Subject may exercise at any time, by sending a communication to the addresses indicated in the following Article 6.1, the rights provided for by the Regulation pursuant to Articles 15-22. In particular:
   

   • The Data Subject has the right to request access to Personal Data from the Data Controller, pursuant to and within the limits of Article 15 of the Regulation.

   • The Data Subject has the right to request the correction of inaccurate Personal Data from the Data Controller, pursuant to and within the limits of Article 16 of the Regulation.

   • The Data Subject has the right to request the erasure of Personal Data, pursuant to and within the limits of Article 17 of the Regulation.

   • The Data Subject has the right to request the restriction of Processing of Personal Data, pursuant to and within the limits of Article 18 of the Regulation.

   • The Data Subject has the right to receive the Personal Data concerning him or her in a structured, commonly used and machine-readable format and to transmit those data to another controller, pursuant to and within the limits of Article 20 of the Regulation.

   • The Data Subject has the right to object to Processing by the Data Controller, pursuant to and within the limits of Article 21 of the Regulation.

   • The Data Subject has the right to lodge a complaint with a supervisory authority.

   • The Data Subject has the right to withdraw consent with reference to those Processing activities that are based on such legal basis. Pursuant to Article 7, paragraph 3 and Article 13, paragraph 2, letter c) of the Regulation, the Data Subject is informed that, in any case, the withdrawal of consent does not affect the lawfulness of the Processing based on the consent given before such withdrawal.

6. Data Controller

For the purposes of this notice, the term “Data Controller” refers to: Count26 S.r.l., with registered office in 00047 Marino (RM), Via Torre di Messer Paoli 1 – Italy, Tax Code/VAT Number 15928351004, email: hello@huuno.me.

7. Changes to this Privacy Policy

 The Data Controller reserves the right to make changes to this Privacy Policy at any time, by advertising them to Data Subjects through publication on the website and/or by email communication.