Privacy Policy

This Privacy Policy governs the manner in which Susurrus collects, uses, maintains and discloses information collected from users (each, a “User”) of the www.susurrus.io website (“Site”). This privacy policy (“Policy”) applies to the Site and all products and services offered by Susurrus (Services).

We collect the personal information you voluntarily provide to us. If you sign up for a user or client account with Susurrus, we collect information from the social networks you connect in accordance with the permissions enabled by such service (such as information about your profile, location, photos, email address), as well as your name, email address, user name, and any other information you choose to provide. You may also choose to provide us with additional personal information, such as your phone number, bio, location, address, gender and age information, as well as your compensation per sponsored activity. If you correspond with us, we will also collect the information you provide us, such as the content of your message, your email address, and your contact information.

Some information we use on non-verified accounts is estimated according to industry standards, such as prices per sponsored activity or occupations and interests of the influencer.

Susurrus works by collecting and analyzing data that is made publicly available, such as public engagements on your posts, and public and non-public data from the social networks you connect, such as non-public impression data, in order to measure influence for its customers. Susurrus also collects data about campaigns that you participate in through our Services.

When you visit our websites or enable our Services to collect data from your social networks, we automatically collect certain information from your device, as follows:

• Log information: We log information about the use of our Services, including the type of browser used, access times, pages viewed, IP address and pages visited.


• Device information: We collect information about the computer or mobile device used to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.


• Information Collected by Cookies and Other Tracking Technologies: We use various tracking technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly. Web beacons are electronic images that may be used in our Services to help deliver cookies, count visits, and understand usage and campaign effectiveness.

You may use our Services in conjunction with a related third-party service. For example, in signing up as a User, you may authorize us to connect with a third-party service such as Facebook (for influencers) or other management service. In doing so, you authorize us to access personal information that may have been collected by those third-party services, and to use it in accordance with the Policy. Those third-party services will have their own policies around the collection of information and you should make yourself aware of their terms.

We use the personal information we collect to provide, maintain, and improve our Services. We may use the information we collect to:

• create a User. We use your personal information to sign you up for Susurrus as a User. We cannot sign you up unless we have your personal information which allows us to identify you, and authorization to access relevant third-party services which are integral to Susurrus. Mandatory personal information includes your name, gender, location, social media accounts or blog (and associated information)


• improve and provision our Services. Having your personal information allows us to operate. For example, having your personal information is key for Susurrus to be in touch with you regarding services you may provide through our Services, to inform you about campaigns you may be interested in or for us to provide you with specific products and services. We also use personal information so we can generally provide support to Users, improve our services and the features and functionality of our websites


• display your profile, including your posts and other information about the social networks you connect to your Susurrus account, on our Services. Also, we may make inferences about your profile, like what topics you may be interested in or known for, that you can modify through our Services


• communicate with others about you, in connection with the operation, promotion, or marketing of our Services, including to provide personal information about you to our customers


• monitor and analyze trends, usage and activities in connection with our Services, including the performance of your posts and campaigns


• detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights, safety and property of Susurrus and others

We may allow others to collect data on the Services. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by Susurrus and others to, among other things, analyze and track data, determine the popularity of certain content and better understand your online activity.

If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

We may share information about you as follows or as otherwise described in this Policy:

• With Susurrus customers (such as brands and agencies) and potential customers. We may provide limited personal information of yours to customers who may be interested in your services for campaigns. Those customers are required by the terms of their contract with us to keep your information confidential;


• With vendors, consultants and other service providers who need access to such information to carry out work on our behalf. Those third-party providers are only permitted under the terms of their contracts with us to use personal information of yours which we provide to them for the limited purposes for which we provide it and keep such information confidential;


• In response to a request for information if we believe disclosure is in accordance with, or reasonably required by, any applicable law, regulation, legal process, or governmental request;


• To protect the safety or integrity of our platform, including to help prevent malicious actors on our Services who act inconsistent with our agreements or policies, or to explain why we have removed content or accounts from our services; to address fraud, security, or technical issues or to protect our rights, property or safety or the rights, property or safety of others;


• When such information is public, such as public information on the social networks that you connect to Susurrus; and


• With your consent or at your direction.

Our Services might include links or click-throughs to websites, apps, social media, or other services provided by third parties. If you provide information in those places, you are providing information to a third-party, and not us. In doing that, we are not responsible for the practices of those third parties – you should take time to familiarize yourself with the policies of any third parties when providing them with your personal information.

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Services. If our data security is breached, we will inform all relevant authorities in accordance with applicable laws.

You have the right to:

• access and/or take your personal information – we keep your personal data in a portable, machine-readable format which readily allows us to provide you with access to your personal information. You can ask for a copy of your personal information. That notwithstanding, we may require you to comply with certain procedures before we allow access to or amendment of your personal information to ensure the integrity and security of information that we hold. Depending on the nature of your request, this may include verifying your identity to our satisfaction to ensure the integrity of your personal information;


• delete, change and/or correct of your personal information – you may update, correct or ask us to erase or delete some, or all of your personal information at any time through your account settings in the Site. We will update that personal information quickly but may retain backups for the purposes of archiving, fraud prevention, abuse or satisfaction of obligations, or where we otherwise reasonably believe we have a reason to do so. If you believe that you are unable to update, correct or delete any personal information you have provided to us in the manner described above, then please contact us. If you wish to close your account, you can contact us using the information in the “Contact Us” section below, but note that we may retain certain information as required by law or for legitimate business purposes. If you delete your User account, your personal information will also be deleted by us. If your personal information is obtained through your authorization of a third-party integration, you will need to either modify permissions, or deal with your personal information through that third-party platform, if you do not wish us to have access to it; and


• object to, limit or restrict use of your personal information – at any time, you may object to the processing of your personal data, on legitimate grounds, except if otherwise permitted by applicable law. You may also make complaints to the relevant data protection authority. We may refuse to allow access or to amend your personal information if we are legally required or entitled to do so. Please be aware that if you ask us to delete or not process your personal information in a certain manner, we may not be able to provide the Services to you or allow you to use the Site.

We will take reasonable steps to ensure that the personal information that we collect is accurate, up-to-date and complete and the personal information we use and disclose is accurate, up-to-date, complete and relevant. If we are satisfied that any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will amend our records accordingly.

Where we rely on your consent to process personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent prior to its withdrawal, and removing consent to process information necessary for the function of a product or service may cause that product or service to no longer work.

You may opt out of receiving promotional emails from Susurrus by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

If you are located in the European Union or EFTA States, our legal basis for collecting and using your personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (1) we need the personal information to perform a contract with you (such as delivering products or services you requested), (2) we have your consent to do so, or (3) the processing is in our or a third party's legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information, or may otherwise need the personal information to protect your vital interests or those of another person.

Our Services are not directed to children under the age of 16, and we do not knowingly collect any personal information from children, unless there is parental consent. If you are under the age of 16, we ask that you do not use our Services. We will delete any personal information relating to children should we become aware of it. Please contact us promptly if you become aware of anything that would breach our Policy in this regard.

We may update the Policy from time-to-time. If we do so, we will inform all Users at the time of its update, indicating the date of revision. Any continued use of the Service after that time will be subject to the updated Policy notified to Users.

This Policy was last updated in May 2018.

If you wish to correct personal information, have your personal information or your account deleted, or if you wish to make an enquiry or believe your privacy rights have been infringed upon, please contact our Privacy / Data Protection Officer at:

Dennis Rodis
dennis@susurrus.io

5F 501 Rotana Office Complex
TwoFour54 Khalifa Park
Abu Dhabi, United Arab Emirates
P.O. Box: 769344
+30 694 061 7152, +971 50 917 3533
info@susurrus.io

We will aim to respond to any query, complaint or request within a reasonable time (usually within 48 hours). If your query, complaint or request is extensive, we may require more time than usual to respond.