Listagram provides a software service named Collabs, with the purpose to facilitate the connection and interaction between advertisers and influencers for marketing purposes. This privacy policy explains how we collect and use your personal data and cookies. It also describes your rights towards us and how you can exercise them. We will only use the information you provide in accordance with this privacy policy and the General Data Protection Regulation (EU 2016/679), also known as the GDPR.

Listagram AB is the data controller for personal data processed in accordance with this privacy policy, unless stated otherwise.

COLLECTION OF PERSONAL DATA

We will receive and collect personal data from you and from third parties when you are using Collabs.

1. CATEGORIES OF DATA SUBJECTS
   1. We may process personal data relating to different data subjects, determined by in which capacity you interact with Listagram and/or use Collabs. We will process personal data relating to the following data subjects:
      • (a)Influencers: Individuals providing services within the field of marketing through their digital channels, i.e. Instagram.
      • (b)Representatives of advertisers: Individuals representing a company or other legal entity and using Collabs to collaborate with Influencers for marketing purposes.
      • (c)End-users using Collabs: Individuals using the Collabs service, for example influencers and representatives of advertisers, as described above, as well as other individuals.
      • (d)Business partners and/or representatives of business partners: Individuals - or representatives of a company or other legal entity - that are business partners of Listagram, e.g. suppliers, consultants and collaboration partners.
      • (e)Individuals contacting Listagram: Individuals choosing to contact or interact with Listagram, such as by visiting the Listagram website or offices or by contacting Listagram via telephone or its digital channels.
2. PERSONAL DATA THAT YOU GIVE US
   1. You may choose to give us your personal data. This includes information submitted when you use Collabs or if you contact us. We will process the following categories of personal data that you give us:
      • (f)When you create a user account and/or use Collabs: name and email address.
      • (g)Additional personal data if you represent an advertiser: address, phone number, the company you represent, billing address, payment details, and campaign details.
      • (h)Additional personal data if you use Collabs as an influencer: gender, age, Instagram profile name, Instagram account details, billing information, country of residence, and number of followers on Instagram.
      • (i)If you are or represent a business partner of Listagram: name, email address, phone number, the company you represent (if any), address, billing information (if necessary) and other personal data as required to fulfill the requirements of the specific agreement.
      • (j)If you contact us: We may ask for additional personal data other than as informed above, in order to assist you.
3. PERSONAL DATA THAT WE COLLECT FROM YOUR USE OF COLLABS
   1. We may collect the following categories of personal data when you use Collabs:
      • (k)Device information: We will use cookies to collect information about the device you use to access Collabs, including the device identifier, geolocation, and IP-address.
      • (l)How you use Collabs: We will collect information on how you use Collabs, such as information regarding how often you visit Collabs, which pages you visit on Collabs, and which influencers/advertisers you interact with through Collabs, as the case may be.
4. PERSONAL DATA THAT WE COLLECT FROM THIRD-PARTY SOURCES
   1. We will process personal data that we collect from third-party sources. We collect personal data relating to influencers from information publicly available on Instagram. We will collect the following categories of personal data relating to influencers: Instagram profile name, age, gender, country of residence and number of followers on Instagram.

OUR USE OF PERSONAL DATA

5. HOW WE USE AND KEEP YOUR PERSONAL DATA
   1. We use your personal data to be able to provide Collabs and fulfill our commitments towards you. We process personal data in accordance with the following.

   Purpose	Legal basis	Categories of data subjects	Categories of personal data	How long we store the personal data
   To create end-user accounts.	If Individual: Fulfill our contractual obligations. If on behalf of a company: Pursue legitimate interest.	As informed in Section(s): 1.1 (c)	As informed in Section(s): 2.1 (a), as well as; 2.1 (b) or (c)	For three (3) months’ following termination of the account, or for two (2) years following your last visit on Collabs.
   To provide all parts of Collabs to you and to administer your account.	If Individual: Fulfill our contractual obligations. If on behalf of a company: Pursue legitimate interest.	As informed in Section(s): 1.1 (c)	As informed in Section(s): 2.1 (a), as well as; 2.1 (b) or (c). For influencers, Section 4.1. also applies.	For three (3) months’ following termination of the account, or for two (2) years following your last visit on Collabs.
   To ensure that content is presented in the most effective manner for you and for your device.	Pursue legitimate interest.	Any of the categories described in Section 1.1 visiting our websites, including the Collabs website.	As informed in Section(s): 3.1 (a)	During the web session.
   To provide information in Collabs relating to influencers for advertisers to interact with.	Pursue legitimate interest.	As informed in Section(s): 1.1 (a)	As informed in Section(s): 4.1.	For two (2) years following the collection of such personal data.
   Send you information and marketing regarding Listagram, Collabs and relevant campaigns.	Pursue legitimate interests.	Any of the categories described in Section 1.1.	Email address	For as long as we send out such information, unless you unsubscribe.
   To provide customer support.	Pursue legitimate interests.	As informed in Section(s): 1.1 (c)	As informed in Section(s): 2.1 (e)	For as long as is necessary to assist you.
   To understand user behaviour and preferences.	Pursue legitimate interests	As informed in Section(s): 1.1 (c)	As informed in Section(s): 2.1 (a) 3.1 (a) 3.1 (b)	For six (6) months.
   To improve Collabs, for general business development purposes and to develop new products and features.	Pursue legitimate interest.	As informed in Section(s): 1.1 (c)	As informed in Section(s): 3.1 (a) 3.1 (b)	For six (6) months.
   To administer payments and remuneration.	If Individual: Fulfil our contractual obligations. If on behalf of a company: Pursue legitimate interest.	Any of the categories described in Section 1.1, as the case may be.	As informed in the relevant Section(s): 2.1 (a) – (d), as well as 3.1 (b).	For the longer of six (6) months or until the invoice is paid by the third party.
   To comply with applicable law, such as bookkeeping and anti-money laundering laws.	Comply with applicable law	Any of the categories described in Section 1.1, as the case may be.	As informed in Section(s): 2.1 (a) – (d).	As long as required in accordance with applicable law, such as seven (7) years for bookkeeping purposes.

   2. We will delete or anonymize your personal data when the processing is no longer necessary for the purposes stated above, except if required by applicable laws. In such case, we keep the data only as long as necessary or mandated by law for such purpose, such as for bookkeeping purposes.
   3. Listagram has legitimate commercial interest in processing personal data as informed in Section 5.1 above, to be able to provide the software service named Collabs. Listagram processes personal data relating to influencers with a public Instagram profile with many followers. Listagram is dedicated to ensure the privacy of such individuals. Therefore, Listagram only processes personal data made publicly available through the respective influencer’s Instagram profiles.
6. TRANSFER OF PERSONAL DATA
   1. If you as an influencer apply to participate in a campaign, we may transfer personal data to the advertiser responsible for the campaign. We will transfer relevant parts of the personal data you have chosen to provide to us as described in the Sections 2.1 (a) and (c), as well as personal data collected under Section 4.1.
   2. We use subcontractors to provide Collabs. When doing so we may transfer your personal data to subcontractors for the performance of our contractual obligations towards you and for the other purposes described in this privacy policy. We use the following categories of subcontractors:

Subcontractor name	Provided from	Transfer mechanism	Services provided
Lantirn Incorporated	United States	EU-U.S. Privacy Shield Framework	Re:Amaze, a customer support and interaction platform.
Fullstory, Inc.	United States	EU-U.S. Privacy Shield Framework	Tools for analysis and statistics
Message Systems, Inc.	United States	EU-U.S. Privacy Shield Framework	Email administration tools
Hotjar Ltd	Malta (EU)	No transfer mechanism required	Tools for analysis and statistics
Google, Inc	United States	EU-U.S. Privacy Shield Framework	Google cloud platform

7. Some of the subcontractors we share your personal data with are located outside the EU/EEA (in a third country). Depending on which part of Collabs you use, your personal data may be transferred to the United States. When doing so we are committed to protect your data and comply with applicable data protection laws and will therefore put in place adequate safeguards to protect your personal data, such as to transfer personal data to parties certified under the EU-U.S. Privacy Shield Framework or by using the EU Commission’s Standard Contractual Clauses.
8. We may disclose necessary personal data to authorities such as the police, tax agencies or other authorities if we are required by law or you have agreed to it. An example of legally required sharing is for the purposes of anti-money laundering and counter-terrorist financing.
9. COOKIES
   1. We use cookies when providing Collabs, to enhance and facilitate your experience, and to create statistics regarding your use of Collabs. A cookie is a small text file that contains text information which is saved on your device. We use two types of cookies, session cookies that expire when you close your web browser, and permanent cookies which are stored until they expire.
   2. If you do not want to accept cookies, you may adjust your web browser settings either to not accept cookies or to indicate when a cookie is used. Please note, by disabling cookies some features on Collabs might not work as intended.

MISCELLANEOUS

10. YOUR RIGHTS
    1. You have a right to access your personal data. Therefore, you may request a transcript of records if you would like to know and verify your personal data stored and processed by us. The request must be made in writing including a verification of you, and sent to the address below.
    2. We take all reasonable steps to ensure that your personal data is correct and up-to-date. You have the right to correct inaccurate or incomplete information about yourself. If you believe that your personal data stored by us is incorrect, please notify us and provide us with the correct data.
    3. You have the right to request the deletion of your personal data insofar as this personal data is no longer necessary for the purpose it was collected (“right to be forgotten”). However, certain legal obligations prevent us from immediately deleting all your data, such as obligations in accounting laws, tax laws and anti-money laundering laws. Data that must be preserved for legal reasons will be blocked from use for any other purposes than meeting such legal requirements.
    4. You have the right to object to our processing of your personal data. The effect may be that you are no longer able to use Collabs. If you object, we will stop the processing of your personal data.
    5. You have a right to data portability. In case you want to utilize such right, please contact us by using the information below.
    6. If you have any inquiries regarding our processing of your personal data, please contact us. If you are displeased with our processing of personal data, you may file a complaint to the Swedish Data Protection Authority (Sw. Datainspektionen), www.datainspektionen.se, the equivalent authority in the EU-member state where you reside, or with the relevant authority in your country of residence, if any.
11. SECURITY
    1. We are using adequate technical and organizational security measures to ensure that your personal data is not misused, lost, or unlawfully accessed. We only give access to your personal data to those employees who require it to provide Collabs.
12. UPDATES TO THIS POLICY
    1. We may occasionally update this privacy policy. If we make significant changes, we will notify you of the changes through Collabs or through other means, such as email. To the extent permitted under applicable law, by using Collabs after such notice, you accept the updates.
    2. We encourage you to review this privacy policy from time to time for the latest information on our privacy practices.