Privacy & Cookie Policy

At commentassist.com ("we", "our" and "us") are committed to protecting the privacy of our users and support a general policy of openness about how we collect, use and disclose your personal information.

This Agreement constitutes a binding contract between you and us and is subject to modification at our sole discretion. Upon any such modification, a revised Agreement will be made available on or through this Website. Save for instances expressly stated herein or mandated by law, court order, or other legal compulsion (in which case, all amended terms shall be effective immediately and your continued use of the Platform shall constitute your acceptance of such revisions), any amendments to this Agreement shall automatically become operative thirty (30) days following their initial posting. In the event of modifications to this Agreement, we shall undertake reasonable efforts to provide you with general, non-specific notification by way of a posting on our Website and/or electronic mail/delivery. This notification shall be maintained for a minimum period of thirty (30) days subsequent to the effective date of the aforementioned amendments. Should you disagree with the amended terms and, consequently, the Agreement, you are hereby prohibited from further utilisation of the Platform. We nonetheless recommend that you periodically review this Website to ensure familiarity with the then-current Agreement. This Agreement may not be amended by any other means absent a written document bearing the signatures of both parties. For the purposes of this provision, the term "writing" shall not encompass electronic mail messages, and "signature" shall not include electronic signatures.

For the purpose of this Privacy Policy, "personal information" means information about an identifiable individual also referred to as personal data.

In instances where we determine the purposes and methods for processing your personal data, we shall act as the "controller" within the meaning of the General Data Protection Regulation (GDPR).

This signifies that we generally assume the role of a controller for the following activities:

• Processing the personal data of Talent in connection with the operation, hosting, and management of Talent's CommentAssist accounts and the provision of CommentAssist services to Talent.
• Processing the personal data of individuals who contact us via our support email address, subscribe to the CommentAssist waiting list or CommentAssist newsletter/marketing/update communications, or utilise the CommentAssist website.

In your capacity as a "Fan," there will be numerous occasions where Talent determines the purposes and methods for processing your personal data. In such instances, we act solely as a "processor" of your personal data, adhering to Talent's instructions and operating on their behalf. The designation of "controller" in these circumstances falls to Talent. This signifies that we generally assume the role of a processor for personal data processed through an individual Talent's CommentAssist page. Examples include instances where you subscribe to a Talent newsletter, click on links to purchase Talent merchandise, or interact with Talent on their page.

This Policy governs the processing of personal data undertaken by us in our capacity as a controller. For details regarding the processing of your personal data by Talent as a controller, please refer to their respective privacy policies, accessible from within any Talent's profile page.

While Talent is contractually bound to comply with all applicable data protection laws, we expressly disclaim any responsibility or liability pertaining to Talent's handling of personal data.

The personal information we may collect in the course of you accessing or using the Website or the Services (including through your initial registration for an account and the subsequent administration of that account) may include the following:

We deploy your personal data for the following delineated purposes:

• Concomitant services to designated participants within the Influencer Marketing industry. These participants specifically encompass Influencers, Talent Management Agencies, Brands, and Agencies. The aforementioned services, including matchmaking, brief and contract generation, facilitation of communication channels, and execution of payment processes, are rendered upon registration.
• Financial Management: To effectuate transactions with users and comply with all relevant accounting and auditing requisites.
• Data-Driven Insights and Reporting: To generate and disseminate pertinent information from the vendor segment of the platform to the purchaser segment. This data empowers informed decision-making with respect to potential collaborators.
• Product Analytics: To glean a comprehensive understanding of user interactions, identify areas susceptible to improvement, optimise product functionalities, and ultimately enhance the overall user experience.
• Sales & Marketing Initiatives: To conduct customer communication activities, cultivate a more profound comprehension of our customer base, and personalise our communication strategies. This enables us to maintain customer relationships, engage with prospective customers, and effectively address the exigencies of the marketplace. In the absence of your exercising your right to opt-out from receiving marketing materials, we may additionally leverage your personal data to promote and market supplementary services and bespoke offerings from our company.
• Public Pricing Calculator: To provide a publicly accessible pricing calculator, fostering transparency within the influencer marketing industry. This tool establishes benchmarks for equitable compensation within the industry.
• Development of Additional Tools and Services: To offer an expanded array of tools and services tailored to Influencers, Talent Management Agencies, Brands, and Agencies.

Except as otherwise expressly set forth under the "Recipients" section of this Policy, we may disclose your personal data to the following categories of third parties:

Affiliated Entities and Service Providers:

We maintain the confidentiality of your personal data; however, disclosure may be necessary to any member of our corporate group, our personnel, or subcontractors. Such disclosure will be limited to the extent reasonably necessary to fulfil the purposes outlined within this Policy. The legal basis for this disclosure rests upon our contractual obligations to you or our legitimate interests in outsourcing specific functionalities to either corporate group members or subcontractors.

Governmental Authorities:

We may additionally disclose your personal data to the extent mandated by law. This may encompass disclosure to government bodies, law enforcement agencies, or in connection with any legal proceedings (current or prospective). We may also disclose your personal data to establish, exercise, or defend our legal rights, including providing information to others for fraud prevention purposes. In each instance, such disclosure is undertaken in accordance with our legal obligations.

Potential Acquirers or Investors:

In the event of a merger, acquisition, or sale of all or a portion of our business or assets, your personal data may be shared. This disclosure is based on the legitimate interests of ourselves, our shareholders, customers, and other parties involved in the transaction. However, such disclosure will only occur if it does not outweigh any potential prejudicial impacts upon you.

Enforcement Purposes:

We reserve the right to disclose your personal data to third parties for the purpose of enforcing or applying the terms of agreements, investigating potential breaches, or protecting the rights, property, or safety of ourselves, our personnel, customers, or others. This disclosure is justified by our legitimate interests in ensuring the lawful and policy-compliant use of our services, and in safeguarding the rights of others from negative impacts arising from the use of our services.

Suppliers and Service Providers:

We may utilise a variety of suppliers and service providers to facilitate the operation of our business.