PLEASE READ THE FOLLOWING PRIVACY POLICY FOR INFLUENCERS CAREFULLY

This Privacy Policy for Influencers is applicable to the collection and processing of personal data of influencers ("Influencers") through this website: http://sozialens.com (hereinafter, the "Website").

We take your privacy seriously. Please feel free to contact us with any concerns or questions at the following email address: [email protected].

We regularly update this policy. If you have an active Sozialens account, we will let you know when we do so via email or in-app notification.

Finally, we know that privacy terms can sometimes be difficult to navigate, so we wanted to give you a roadmap of the Policy:

LIST OF CONTENTS

In this Privacy Policy for Influencers you will find all the information related to the processing of personal data and your right to maintain control over it. You will find information about:

• Who is responsible for the processing of your data.
• What are the requirements for providing us with your personal data
• What data processing we carry out through the Website and what are its main characteristics:
• a. What data is collected and how it is collected.
• b. Purposes of the processing of your personal data.
• c. What is the legal basis for data processing.
• d. How long the data is kept.
• To whom we disclose your personal information.
• Existence of transfers of your data to third countries.
• What rights you have and how you can exercise them.
• How we guarantee the confidentiality of your information.
• Modifications to this policy.

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?

Your personal data will be processed by the company Sozialens, S.L. ("Sozialens"), with Tax Identification Number ESB98684574 and the contact details are as follows:

Address: Paseo De La Castellana, 194 - BJ B Madrid (28046), Madrid, España CIF B70690953.

Contact email: [email protected]

Sozialens role as data processor:

With respect to personal information entered by our Clients when they use our Platform and Services (excluding data for which Sozialens is the controller), Sozialens will process such data as a data processor, acting on behalf of that Client.

With respect to Sozialens processing of your personal data as a processor, this Privacy Policy for Influencers will not apply, and in that case it will be the Client's responsibility to inform you about its privacy practices and the processing of your personal data.

2. WHAT ARE THE REQUIREMENTS FOR PROVIDING YOUR PERSONAL DATA?

2.1. Minimum age. To provide us with your personal data, you must be at least 18 years of age and/or have sufficient legal capacity to use this website.

2.2. Truthfulness. When you provide us with your data to use our services, you guarantee that the data and information provided are real, true, up-to-date and belong to you and not to third parties.

In addition, you must notify us of any changes that occur in the data provided, responding in all cases to the truthfulness and accuracy of the data provided at all times.

2.3. Age and truthfulness control. Sozialens reserves the right to verify your age and identification information at any time, if necessary, including by requesting official proof of age or equivalent procedure and, in the event of fraud detection that demonstrates or is suspected that you are under the age indicated, to delete, temporarily disable and/or cancel your account.

3. WHAT DATA PROCESSING DO WE CARRY OUT THROUGH THE WEBSITE AND WHAT ARE ITS MAIN CHARACTERISTICS?

Below we explain how we process your personal information and provide you, in detail, with all relevant information about your privacy:

What are the data collection methods? We collect publicly available information obtained directly or indirectly through various data sources, such as social networks and other sources; and/or Platform Registration and Use form.

What data do we collect? Publicly available information may include identification and contact information. We collect your identification information (name, username), publicly available information about your social network profile, and any other information that is made publicly available.

When you register through our Platform, we may collect the same information, as well as email address and password, and other identification information that you may include in your account voluntarily (gender, phone number, date of birth, link to your social media accounts, rates for posting and creating content, profile description and images).

You may also need to give us permission to collect personal information from your social media accounts through API.

Profiling: We collect and create profiles about you as an influencer to create a ranking based on: your reach (number of followers, audience, etc.); the context of your followers (country, demographic information, industry, activities or products you create content about, potential target audience) and other significant variables in relation to the social networks you are present on.

What are the purposes of processing your personal data? When you register on our Platform, we will process your data to manage your account and give you access to the different functionalities available.

The main purpose of processing your personal data, through your account, is to allow our clients to find Influencers who may fit their values, target audience and other requirements and to help them connect with Influencers to create and manage marketing campaigns.

You can also manage permissions for our various clients through your account, so that they can (i) see your personal information added to your account; (ii) contact you; and (iii) offer you to participate in their campaigns.

Please note that our clients may use your information and personal data in accordance with their own privacy policy.

What is the legitimate basis that allows us to process your data? Is it mandatory to provide this data? We collect and process your personal information based on our legitimate interests to enable our clients and you, as an influencer, to connect and create marketing campaigns. There is a mutual benefit for both businesses and influencers in providing a channel for them to meet and communicate with each other through our platform. For more information on the balance of legitimate interests in this case, please contact us at [email protected].

If you request to register and be listed on our Platform, we collect and process your Personal Data and access the information contained in your social media account with your consent or for the performance of a contract (i.e. the terms of use applicable to influencers available at https://sozialens.com/legal/legal-notice).

How long do we retain your information? All your personal information will be processed for as long as necessary to fulfill the purposes stated above. We may retain your personal information for longer if it may be the subject of a legal claim, or may be relevant to future litigation.

Website navigation (cookies)

We use cookies or other tracking and tracing tools on this website to collect information about how users use the website.

For more information on how we use these tracking tools, please visit our Cookie Policy.

4. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

In general, Sozialens will not communicate your data to third parties. However, in addition to the transfers that we specifically indicate in the section in which we explain the characteristics of the different operations (point 3), we inform you of the communications that we can make, in general, and that affect all previous treatments and their legitimate reasons.

i. Clients, certain personal information will be available to our clients so that they can evaluate your suitability to participate in their campaigns. This information may include your name, public information from your social media account(s) and estimated related statistics.

ii. Service providers, (for example, hosting companies or platforms for sending commercial communications). Without prejudice to the foregoing, these entities have signed the corresponding confidentiality agreements and will only process your data in accordance with our instructions, and may not use them for their own purposes or for purposes other than the service they provide us.

The current list of processors is included in the following link: https://sozialens.com/en/legal/list-of-processors

iii. Public authorities. We may disclose to the competent public authorities the data and any other information in our possession or accessible through our systems when there is a legal obligation to do so, as well as when necessary, for example, when the purpose is to prevent or pursue abuse of services or fraudulent activities through our website or web page. In such cases, the personal data you provide to us will be retained and made available to administrative or judicial authorities.

iv. In the event of a corporate transaction: in the event of a merger, acquisition, sale of all or part of its assets, or any other type of corporate transaction involving a third party, we may share, disclose or transfer user data to the successor entity (including during the pre-transaction phase).

v. To third parties after aggregation or anonymization: We may disclose or use aggregated or anonymized data (i.e. data that cannot be linked to an identified or identifiable natural person) for any purpose.

vi. To third parties with your consent or other legitimate basis: In the event that we want to share data with third parties outside the scope of this Privacy Policy, we will always seek your consent or inform you of your consent and legitimate basis.

We also inform you that this Privacy Policy only concerns the collection, processing and use of information (related to personal data) by us through your interaction with our website. Access to third party websites that you may access through links from the website have their own privacy policies over which we have no control. Therefore, before providing them with any personal information, we recommend that you read their privacy policies.

5. ARE YOUR PERSONAL DATA TRANSFERRED TO THIRD COUNTRIES OUTSIDE THE EUROPEAN ECONOMIC AREA?

Some of our service providers are located in countries outside the European Economic Area ("EEA").

The location of these companies outside the EEA implies the existence of an international transfer of your personal data, which could result in a lower level of protection than that provided for in European legislation. However, Sozialens has implemented measures to ensure that such transfers do not result in a lower level of protection of your personal data.

In this regard, service providers outside the EEA have signed the corresponding standard contractual clauses approved by the European Commission ("STC"), an agreement signed between the two entities by which the non-EU company guarantees that it applies European data protection standards.

Therefore, the use of these providers does not result in a lower degree of protection of your personal data than the use of providers located in the European Union. You can consult the content of the TCH at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/publications/standard-contractual-clauses-controllers-and-processors_en

6. WHAT RIGHTS CAN YOU EXERCISE AS A DATA SUBJECT AND HOW CAN YOU EXERCISE THEM?

You can exercise the rights guaranteed by law in relation to the processing of your personal data by contacting us via email at [email protected].

Any claim we receive will be resolved as soon as possible and, in any case, within the maximum period established by law from the moment we receive it. In some cases, it may be necessary to request a copy of your identity document or other identification document if we need to verify your identity.

The rights that correspond to you as an interested party are the following:

i. Right to withdraw consent given

You can revoke your consent in relation to all processing based on it. However, we remind you that the revocation of consent will not affect the legality of processing based on consent prior to revocation.

ii. Right of access

You have the right to know what data is being processed, if applicable, and, if so, to obtain a copy of it, as well as to obtain information regarding:

• the origin and recipients of the data;
• the purposes for which they are processed;
• whether there is an automated decision-making process, including profiling;
• the period of data retention; and
• the rights provided by law.

iii. Right to rectification

You have the right to request the deletion of your personal data if it is no longer necessary for the purpose for which it was collected or if we are no longer authorised to process it.

iv. Right to deletion

You have the right to request the deletion of your personal data if it is no longer necessary for the purpose for which it was collected or, where applicable, if we are no longer authorised to process it.

v. Right to data portability

You have the right to request data portability in the case of the processing of your data based on your consent or the execution of a contract, as well as when the processing is carried out by automated means. If you exercise this right, you will receive your personal data in a structured format, commonly used and readable by any electronic device. However, you may also request, where possible, that your data be transmitted directly to another company.

vi. Right to limit the processing of your personal data

You have the right to limit the processing of your data in the following cases:

• a) When you have requested the rectification of your personal data during the period in which we verify the veracity of the same.
• b) When you consider that we are not authorized to process your data. In that case, you can ask us to limit its use instead of requesting its deletion.
• c) When you consider that it is no longer necessary for us to continue processing your data and you wish us to keep it for the purpose of exercising or defending claims.
• d) In cases where there is processing based on our legitimate interest and you have exercised your right to object, you can ask us to restrict the use of your data while we verify the prevalence of said interests over yours.

vii. Right to object

You have the right to object at any time to the processing of your personal data based on our legitimate interest, including profiling.

viii. Right to lodge a complaint with the Supervisory Authority

Please remember that, at any time, and in the event that you consider that we have violated your right to the protection of your data, you may lodge a complaint with the corresponding Data Protection Control Authority, in the case of Spain, the Spanish Data Protection Agency (http://www.agpd.es).

ix. Information from your social networks

Sozialens uses authorized data from Instagram, YouTube, Google, Facebook, Instagram, LinkedIn, Twitter and other platforms ("Social Platforms"). Such data is collected and stored to power the functions of Sozialens. You can request the deletion of your authorized data from Sozialens by contacting [email protected]

For example, Sozialens uses the APIs of YouTube, Google, Facebook, Instagram, LinkedIn, Twitter and other social platforms to collect authorized data. You can learn more about the terms of service and privacy policies of each respective social platform through the links below:

• Social Platform Terms of Service:
• Google: https://www.google.com/intl/en/policies/terms/
• YouTube: https://www.youtube.com/t/terms
• YouTube API Client: https://developers.google.com/youtube/terms/api-services-terms-of-service
• Facebook: https://www.facebook.com/legal/terms
• Instagram: https://help.instagram.com/478745558852511
• Twitter: https://twitter.com/en/tos
• LinkedIn: https://www.linkedin.com/legal/user-agreement

Social Platform Privacy Policies:

• Google and YouTube: http://www.google.com/policies/privacy
• Facebook: https://www.facebook.com/privacy/explanation
• Instagram: https://help.instagram.com/155833707900388
• Twitter: https://twitter.com/en/privacy
• LinkedIn: https://www.linkedin.com/legal/privacy-policy

You may also withdraw Sozialens permission to access your data from social media platforms at any time through the settings of each social media platform respectively. Please note that by withdrawing your permission, your experience on our Platform may be limited and certain functionalities will be removed.

• YouTube and Google: https://security.google.com/settings/security/permissions
• Facebook: https://www.facebook.com/settings?tab=applications
• Instagram: https://www.instagram.com/accounts/manage_access/
• Twitter: https://twitter.com/settings/applications
• LinkedIn: https://www.linkedin.com/psettings/permitted-services

Subject to legal considerations and other permissions, we will make reasonable efforts to comply with your request promptly or inform you if we require further information to comply with your request. In processing your request, for security reasons we may ask you for additional information to confirm your identity before disclosing the Personal Data requested. We reserve the right to charge a fee where permitted by law, for example if your request is manifestly unfounded or excessive. If your request would adversely affect the rights and freedoms of others (for example, if it would affect the duty of confidentiality we owe to others) or if we have a legal right to treat your request in a manner different from that initially requested, we will accommodate your request to the fullest extent possible, all in accordance with applicable law.

7. HOW DO WE GUARANTEE THE CONFIDENTIALITY OF YOUR INFORMATION?

The security of your personal data is a priority for us. Therefore, Sozialens has implemented all the necessary security measures to guarantee effective use and treatment of the personal data provided by the user, safeguarding their privacy, confidentiality and integrity.

Consequently, we comply with the recommended security standards to protect your data. However, it is impossible to fully guarantee your security due to the nature of the Internet and because there may be fraudulent actions by third parties beyond our control.

We are committed to acting quickly and diligently if data security is compromised or compromised, and to inform you of this when relevant.

8. MODIFICATIONS TO THIS POLICY

Sozialens may modify the content of the privacy policy at any time, especially when there are changes in legislation, jurisprudence or interpretation of the Spanish Data Protection Agency that affect the processing of data by Sozialens through this Website. Any new version of this Privacy Policy will come into effect on the published effective date.

If the revised version includes a material change that affects the processing of your data, we will notify you at least 30 days in advance by posting a notice on our website or communicating it to you by email. In any case, we recommend that you periodically review this Privacy Policy to be informed of how your personal data is processed and protected, as well as the rights you have.