Last update: February 06, 2023
Launchmetrics Spotlight connects brands and creators around fashion, luxury, & beauty content, both visual and otherwise. It provides editors, stylists, etc. visual content in high quality and digital publishing solutions, and it helps them manage their event attendance, or request lookbooks and samples for brands. It helps brands amplify their collection launches, publish events, get sample requests, and broadcast content.
When we refer to Launchmetrics (collectively referred to as "we", "us", or "our"), we mean Fashion Tree S.r.l. as part of the Launchmetrics Group with registered offices at Via Solari 11, 20144 Milan, Italy, Vat. No. 07535290964, that acts as the Controller or Processor pursuant to the EU General Data Protection Regulation 2016/679 (“GDPR”) (or Business and Service Provider under the California Consumer Protection Act - “CCPA”) of your personal data, or personal information (“Personal Data” or “Personal Information”) within Launchmetrics Spotlight. Any term indicated in capital letters shall have the meaning attributed to it within the GDPR or in the CCPA, or otherwise provided hereto.
When we refer to users (“Users“ or “you") we mean all individuals who access and use Launchmetrics Spotlight, or any other services provided via the Launchmetrics Brand Performance Cloud (“BPC”) and have a login, including those users granted access to Launchmetrics Spotlight via their employer or another company ("Customer").
When we refer to Launchmetrics Network (“Launchmetrics Network”) we refer to a brand or agency or media or buyer or retailer or User that has subscribed to Launchmetrics Spotlight paying or non-paying Services including Launchmetrics employees.
When we refer to Launchmetrics Industry List (“Industry List”) we refer to an exclusive list composed by stylist, editor, publisher, influencer. anyone or any entity who creates content and shares it with the public, editorially or otherwise (“Media Creators”).
As a general principle, please consider that all the Processing of the Personal Data carried out by Launchmetrics for the purposes described herein is made in compliance with the applicable data protection laws (“Applicable Data Protection Laws” - including but not limited to GDPR and CCPA, CPRA etc.), and is based on the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and accountability.
Please read this statement carefully to understand our policies and practices regarding your Personal Information and how we will treat it, and in case of doubts or questions please feel free to contact us at email@example.com.
In particular, if you’re a Media Creators by registering to Launchmetrics Spotlight you are consenting to be included in the Industry List and to be contacted by members the Launchmetrics Network for:
- events invitation and attendance emails;
- samples loans;
- all types of visual content associated with a fashion collection launch; and,
- newsletters, press releases, email campaigns sharing.
For the purposes described above, if you are a Media Creator we may share your name, surname, email address and company affiliation, job title, magazine, with the members of the Launchmetrics Network by allowing them access to the Industry List. In addition, since Launchmetrics Spotlight is designed to help you share information and amplify your content, if you are a Media Creator, by registering on Launchmetrics Spotlight you agree that some of the information generated through Launchmetrics Spotlight and your use of the Service is shared with members of the Launchmetrics Network.
In addition, a separate agreement governs delivery, access and use of the Services (the "Service Provider Agreement") as well as a data processing agreement governs the processing of customer data (data related to the Service Provider Agreement, "Customer Data") that We may receive from our Customer for the purpose of providing the Services.
What Information Do We Collect and Receive?
The information we gather enables us to provide, personalize, improve and continue to operate Launchmetrics Spotlight. In connection with certain aspects of Launchmetrics Spotlight, we may request, collect and/or display some of your Personal Information. We collect and receive Personal Information and other information in different ways:
- Information you provide to us: Users routinely submit Personal Information to Launchmetrics when using the Services (“User Data” or “Account Information”).
- You acknowledge that this information may be personal to you, and by creating an Account on Launchmetrics Spotlight and providing Personal Information to us, you allow others, including us, to identify you. An Account can either be created by us or a User or a Customer on your end, for this reason we will receive information that could be Personal Information, such as your:
- Business contact Information (First name, Last name, Email address, Telephone number, Job Title, Country, Industry, Preferences);
- Account Information (Username and/or Email address, Password);
- Support Data (Account Information for the Service used and related to the support inquiry).
Launchmetrics also collects, generates and/or receives other information, including:
- Information provided by Customers: our Customer may submit your Personal Information such as, name, surname, company affiliation and contact details for the purposes of using the Services (and to create an Account, see above). In this context, please consider that the Customer will be the Controller of your Personal Information, while Launchmetrics will be considered the Processor and we will process your Personal Information in compliance with the instructions received by Customers and with the relevant data processing agreement.
- Information collected automatically: We automatically receive and record information from your web browser when you interact with Launchmetrics Spotlight and or the BPC, including your IP address, device, and usage Information. In particular,
- Log Data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Launchmetrics Spotlight or the BPC and record it in log files. This log data may include the Internet Protocol (IP) address, user names, the address of the web page visited before using Launchmetrics Spotlight or any of the Services, browser type and settings, the date and time Launchmetrics Spotlight or any of the Services was last used, information about browser configuration and plugins, language preferences and cookie data.
Based on your setting, logs will then be automatically deleted if older than the period of time selected.
- Device Identifiers. For any application downloaded from the App Store or Google Play to access one of our Services (including mobile versions of web browsers), we may access, collect, monitor and/or remotely store one or more "device identifiers", such as a universally unique identifier. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Launchmetrics Cloud. This device identifier may remain persistently on your device, for 24 hours, to help you log in faster and enhance your navigation through the Launchmetrics Cloud. You may also use the remember me feature that will enable you to easily access the Launchmetrics Cloud and each of the Services. Such an identifier is kept for 14 days.
- Usage Information. We collect information about how Users collectively use the Services, such as the number and frequency of Users to the Services, the images downloaded, as well as regarding the performance of the Services ("Aggregate Information"). We may use this data as Aggregate Information, as a statistical measure, but without an explicit consent we will not process that data in a manner that would identify you personally, your Account or your web browser. This type of Aggregate Information enables us and third parties authorized by us to improve the content and operation of the Services and Launchmetrics Spotlight.
How Do We Use The Information Collected?
Under the Applicable Data Protection Laws, we can only use your Personal Information if we have a proper reason for doing so, e.g.:
- To comply with our legal and regulatory obligations;
- For the performance of our contract with you or to take steps at your request before entering into a contract;
- For our legitimate interests. Please note that a legitimate interest is when we have a business or commercial reason to process your Personal Information as long as this is not overridden by your own rights and interests; or
- Where you have given your consent to the relevant processing activities.
Against this backdrop, please make reference to the table below explaining what we use (process) your Personal Information for and our reasons for doing so:
|What we use your Personal Information for
|Creation of the User’s Account and Provision of the Services. Provide Users with our Services, facilitate interaction within the Services, and personalize Users experience.
|To create your User's Account we will need your consent.
For the performance of our contract with our Customer or to take steps at Customer’s request before entering into a contract.
|Inclusion of Media Creator’s contacts’ information on the Industry List. By creating an account on Launchmetrics Spotlight as Media Creator you agree to be included in the Industry List and to be contacted by Launchmetrics’ Network members.
|To be included in the Industry List we will need your consent.
|Communicate with our Users. Respond to User support requests while using Launchmetrics Spotlight, keep track of a reliable Privacy point of contact among Customer Accounts and obtain information as soon as a contact is leaving. We may also use User Account Information to send operational information about Launchmetrics Spotlight to Users. We reserve the right to contact Users but only when we believe it is necessary, such as for account recovery, downtimes or security purposes. If you do not want to be contacted for such a purpose, please email your firstname.lastname@example.org. Although we offer inside Launchmetrics Spotlight several interfaces that might expose Users’ IP address - such as the activity history, we will not directly reveal User’s email addresses to external users (i.e. users not belonging to your company).
|For the performance of our contract with you as a Customer or to take steps at your request before entering into a contract.
To comply with our legal and regulatory obligations.
For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their Services.
|Improve our Services and measure performance. Understand and keep improving our product in terms of usage information, such as the number and frequency of visitors to Launchmetrics Spotlight features, scope and security needs. We may use this data in aggregate form, that is, as a statistical measure, but without an explicit consent we will not process those data in a manner that would identify Users personally. In addition, third parties may share with us non-private, aggregated or otherwise non Personal Information about our Users that they have independently developed or acquired. We do not permit our third-party service providers to use the Personal Information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us. These providers do not collect any Personal Information or store IP addresses locally on their websites.
|For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you.
|Security and Fraud Prevention. Detect or prevent fraud and spam/malware and security incidents, and unauthorized access to a User Account and provide information to Users regarding activity on their Account.
|For our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you.
|Compliance. Satisfy any applicable law, regulation, legal process or public authorities or governmental request, and any other legal requirements, including complying with court orders, valid discovery requests or subpoenas, and other appropriate legal mechanisms.
|To comply with our legal and regulatory obligations.
|To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
|Operate our Business. Provide information to our trusted agents and partners (“Agents”), including attorneys and accountants and other persons with whom we conduct business, and as otherwise specified in this User Policy, to help us comply with legal, accounting, or security requirements based on our legitimate interests. Unless we tell our Users differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. Users hereby consent to our sharing of Personal Information with our Agents.
|To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you.
|Disclosure Pursuant to Business Transfers. If we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, User Information would be one of the assets that is transferred or acquired by a third party. Users acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use User Personal Information as set forth in this User Policy.
|For our legitimate interests or those of a third party.
|Where you have given consent.
Is Information About Me Secured?
We work hard to secure your Personal Information from unauthorized access to or unauthorized processing, alteration, disclosure or destruction of Personal Information we hold by taking appropriate Technical and Organizational Security Measures, having regard to the state of the technological development and the cost of implementing any measures where appropriate, for example, pseudonymisation and encryption of Personal Information.
Your Account Information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.
We seek to protect Account Information to ensure that it is kept private; however, we cannot guarantee the security of any Account Information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
We otherwise store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.
Where it is likely that a breach results in a risk to the rights and freedoms of individuals, we will notify the competent privacy supervisory authority within 72 hours of becoming aware of it. This information can be provided in phases to facilitate fast and efficient reporting.
Where a breach is likely to result in a high risk to the rights and freedoms of individuals, we will notify those concerned directly with the following information:
- the nature of the Personal Information breach including, where possible;
- the categories and approximate number of individuals concerned and the categories and approximate number of Personal Information records concerned;
- the name and contact details of the data protection officer or other contact point where more information can be obtained;
- a description of the likely consequences of the Personal Information breach;
- a description of the measures taken, or proposed to be taken, to deal with the Personal Information breach and, where appropriate, of the measures taken to mitigate any possible adverse effects.
The servers that store your Personal Information have appropriate administrative, technical, and physical controls that are designed to safeguard your Personal Information, including industry-standard encryption technology.
If you have any questions or concerns regarding security using Launchmetrics Spotlight, please send us a detailed message to email@example.com. We will make every effort to answer your concerns.
How Long Do We Conserve Your Information?
We retain your Account Information for as long as your employer’s Account is active and thereafter unless your employer requests deletion of a particular User.
Who can access my Personal Information?
We might be required to disclose Users’ Personal Information in order to comply with the law, a judicial proceeding, court order, subpoena, or other legal process, or where it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or as evidence in litigation in which we are involved.
Moreover, in order to provide you the desired Service, User Personal Information might be shared with:
- Entities affiliated to Fashion Tree S.r.l. as part of the Launchmetrics Group. Please note that all the entities affiliated to the Launchmetrics Group executed reciprocal data processing agreements and standard contractual clauses pursuant to article 46 par. 2 lett. c) of GDPR to lawfully share and process Users' Personal Information.
- Sub-contractors engaged by us providing essential service (e.g. cloud providers, CRM, customer and billing support). Upon request we can provide you with the list of the subcontractors. As a general rule we engage subcontractors who share with us the same or equivalent degree of care when it comes to respect the right to privacy and personal data protection.
Without prejudice to the above, unless upon your specific consent or as otherwise required by Applicable Data Protection Laws, User’s Personal Data shall not be shared with any other organizations.
Notice for California Residents
California Privacy Laws regulate how we handle personal information of California residents, granting certain rights to their residents with respect to their personal information.
Pursuant to CCPA when it provides the Services, Launchmetrics is both a “Business” and a “Service Provider”.
If you are a Launchmetrics customer, under the CCPA you are considered a “Business” and Launchmetrics is the “Service Provider” in most cases. As such, we are responsible for processing the Personal Information our Service captures on your Account and is stored on our servers.
Although we do not sell personal information in exchange for any monetary consideration, the CCPA defines a sale in a way that may include allowing third parties to receive certain combined Personal Information such as, depending on how you use the Services, when we are sharing device information (such as browser type and version, operating system, preference settings, unique device IDs and language and other regional settings) and identifiers (names, job titles, IP address, email address), commercial information (such as record of the Services purchased or demos requested), usage information and Internet activity such as browsing history (clicks, scrolling, browsing times and load times) or app usage, cookie information and customer feedback with website analytics companies and providers of customer relationship management, consulting, email, product feedback services and security and other operations vendors.
You may opt out from the sharing of your Personal Information. While Launchmetrics does not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the relevant law.. We wish to provide you with control over how your Personal Information is collected and shared. If you would like to opt out of Launchmetrics’ use of your Personal Information for such purposes (when considered as a sale), you may do so within the Services and by contacting Launchmetrics at firstname.lastname@example.org.
In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer:
- Identifiers (name or alias, online identifier, IP address, email address and cookies);
- Internet or other electronic network activity information (browsing history and time, search/click history, loads, browser type and version, operating system, preference settings, unique device IDs and language and other regional settings).
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 115 E 23rd Street, Floor 4, Suite 420, New York, NY 10010, USA. The request should attest to the fact that you are a California resident, and provide a current California address.
If you have additional questions about this section or how to exercise your rights under the California Privacy Laws, please contact us at email@example.com. California Privacy Laws allow California consumers to designate an authorized agent to exercise their rights under California Privacy Laws. If we receive a request from an agent, then we have the right to verify that you indeed want to take the action requested by the agent and will do so by contacting you directly.
Notice for Users located in the People’s Republic of China
In particular, the purpose of this section is to inform Users accessing Launchmetrics Spotlight in China (“Chinese Users”) that for the purposes indicated in section “Why We Collect Personal Data and Lawful Basis to Do So”, we might transfer Chinese Users’ Personal Data outside China. Provided that, we will consider to have received Chinese Users explicit consent to the data transfer upon registration of User’s Account.
For the sake of clarity, Chinese Users’ Personal Data might be transferred among the companies belonging to the Launchmetrics Group, to its service provider, for the purposes indicated above and to the members of the Launchmetrics Network. Any Chinese Users wishing to know which entities received their Personal Data, can contact Launchmetrics at firstname.lastname@example.org.
What Happens When There are International Data Transfers?
We are part of a global organization, the Launchmetrics Group, and we engage providers and suppliers around the globe. As such, we may share and transfer information about you to countries in the world where we do business in connection with the uses identified above and in accordance with this Policy.
In light of the above, we commit to comply with any legal requirements provided under any Applicable Data Protection Laws to process and to transfer Personal Information to third countries, in particular with:
- GDPR, and UK GDPR. We are making sure that any of these transfers are supported by the strict legal compliance of our suppliers to the GDPR and to UK GDPR. As applicable we will rely on European Commission Adequacy Decisions, or a UK Adequacy Regulation, or Standard Contractual Clauses (also called Model Clauses) to meet the GDPR/UK GDPR requirements. When necessary, compliance can be achieved if suppliers use an approved certification mechanism.
- Data protection laws in force in the People’s Republic of China and Hong Kong. By accessing and using your User Accounts you hereby grant your consent to transfer your Personal Information outside Chinese jurisdiction.
- Singapore data protection laws. Pursuant to article 10 of the Personal Data Protection Regulation 2021, by accessing and using your User Accounts you hereby grant your consent to transfer your Personal Information outside Singapore jurisdiction. Moreover, please consider that pursuant to articles 10 and 11 of the Personal Data Protection Regulation 2021 we took the appropriate steps to ascertain whether, and to ensure that, the recipient of your Personal Information is bound by legally enforceable obligations, by executing a contract.
Your Rights under the Applicable Data Protection Laws
Pursuant to the Applicable Data Protection Laws, you have a number of rights concerning the Personal Data that We hold about you . You can exercise any of these rights, by using the contact details set out below:
- The right of access. You have the right to obtain access to your Personal Data subject to the data Processing. This will enable you, for example, to check that we are using your Personal Data in accordance with the relevant data protection law. You may access the information we hold about you in this way, using the Contact information section.
- The right to rectification. You are entitled to have your Personal Data corrected if it is inaccurate or incomplete. You can request us to rectify any errors in information that we hold by contacting us (please see section How to contact us? here below).
- The right to erasure. Also known as ‘the right to be forgotten’, it enables you to request the deletion or removal of certain Personal Data that we hold about you by contacting us (please see section How to contact us? here below). Pursuant to applicable laws we may not have all your Personal Data erased.
- The right to restrict processing. You have rights to ‘block’ or ‘suppress’ certain further use of your Personal Data. When processing is restricted, we can still store your Personal Data, but will not use it further.
- The right to data portability. You have the right to obtain your Personal Data in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch (please see section How to contact us? here below).
- The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your Personal Data with the relevant national Data Protection Authority (please find here the list of European Data Protection Authorities https://edpb.europa.eu/about-edpb/board/members_en).
- The right to withdraw consent. If you gave your consent to extensive processing that we do with your Personal Data (i.e. we rely on consent as a legal basis for processing your Personal Data), you have the right to withdraw that consent at any time. You can do this by contacting us (please see section How to contact us? here below). Withdrawing consent will not however make unlawful our use of your information while consent has been apparent.
- The right to object to processing. You have the right to object to certain types of processing. You can for example object to the publication of pictures taken of you within the context of a conference. To exercise this right, please get in contact (please see section How to contact us? here below).
- The right to not be subject to automated individual decision-making. You have the right not to be subject to a decision solely based on automated processing, including profiling. To exercise this right, please get in contact (please see section How to contact us? below).
- The right to equal access. You have the right to not be discriminated against for exercising any of the rights indicated above.
Where you wish to exercise their rights in the context of one or several specific processing operations, please provide their description in the requests. Your requests will be handled within a maximum of 30 (thirty) working days.
How do I Review or Change my Personal Information?
If you would like to review or change your Personal Information, we will deal promptly and appropriately with any inquiries unless we have to keep that information for legitimate business or legal purposes. However, if your requests are deemed to be excessive or complex a small fee may be charged and a time-period extension may apply.
You can contact us at: email@example.com or you can reach out to firstname.lastname@example.org.
How Can I Delete My Account?
Should you ever decide to delete your Account, you may do so by emailing email@example.com or firstname.lastname@example.org. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account.
Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion may remain stored by us for the period of time needed for us to conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
What Happens When There Are Changes to this User Policy?
Although most changes are likely to be minor, we will occasionally update this User Policy to reflect user and customer feedback about Launchmetrics Spotlight changes and clarifications will take effect immediately upon their posting. We encourage you to periodically review this User Policy and associated Notices to be informed of how we are protecting your information and check for any changes. We have the sole discretion to modify this User Policy and the Notices. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services or the homepage of Launchmetrics Spotlight.
How to contact us?
If you have any questions or comments regarding this User Policy or our privacy practices using Launchmetrics Spotlight please send us a detailed message to email@example.com. We will make every effort to resolve your concerns. You may also contact us by postal mail or email at:
Launchmetrics - Privacy
Via Brera 17,
20121, Milan, Italy
English Version Controls