Mention Me Privacy Policy

We may hold the following personal data about you:

• Your email address and/or telephone number if you have provided one to us;
• Details of your visits to any refer-a-friend programme you are participating in; and
• A record of any correspondence between you and us.

Please do not include any sensitive information such as government IDs, health data or financial data in your communications with Mention Me or our support agents.

As is true of most websites, we also automatically gather information about your computer such as your IP address, browser type, referring/exit pages and operating system. When you visit our hosted-pages, we also use cookies to identify you when you come back to the site. For more information on the cookies we use, why we use them and more information about cookies generally, please see our Cookie Policy

We receive your personal data:

• directly from you when you when enter it into our Referee registration page after you have clicked on a sharing link; or
• From our Client if you have entered it into their website when using our ‘share by name’ feature.

We need the above data:

• To check that you are not an existing customer of the relevant Client.
• To allow us to recognise and reward you as a Referred Friend when you fulfil the conditions necessary to receive a reward under the refer-a-friend programme you are participating in.
• To send you service emails solely in connection with the refer-a-friend programme – for example to email you rewards as and when you are eligible to receive them. You can opt-out of receiving these emails at any time by clicking on the unsubscribe link at the footer of any email you receive from us or via our data privacy contact form.
• If, and only if, you have opted-in to receive marketing communications from the relevant Client, we will share your email address and/or telephone number with the Client to enable them to send you those communications.
• To respond to customer service requests.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

In the ordinary course, we will only ever share your data with:

• our Client;
• the friend who has referred you (so that we can notify them when they are due a reward for their referral); or
• on a confidential basis, our own carefully selected sub-processors who are directly involved in delivering our refer-a-friend services. Our processors are only engaged with our Client’s consent and are primarily used for the purposes of hosting our platform and assisting with sending referral service emails to referrers and referees.

We never sell or give your personal information to third parties to use for their own purposes.

In exceptional circumstances, we may disclose or transfer your personal information:

• as required by law.
• when we (or our Client) believe in good faith that disclosure is necessary to protect our rights, protect your safety or the rights and safety of other third parties (including other Mention me users), investigate fraud, or respond to a government request.
• to a third-party buyer or seller in the event that Mention Me is involved in a merger, acquisition, or sale of all or a portion of its assets.
• to any other third party with your prior consent to do so.

Information we hold about you is stored and processed principally in the Mention Me platform. The Mention Me platform is hosted in a secure data centre with the European Economic Area (EEA). Your information may be shared with our carefully selected sub-processors who are directly involved with the delivery of our refer-a-friend services.

In the event that the processing of your personal information at any time requires it to be transferred to and/or stored at or accessed from a destination outside the EEA, we will take all steps reasonably necessary to ensure that your data is treated securely, in accordance with this policy and safeguarded in accordance with all applicable legislation.

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

You have the right to object at any time to the processing of your personal information. You can make this objection via our data privacy contact form.

Depending on where you reside, you may have the following legal rights:

• You have the right to access any Personal Data we hold about you. Any request which is manifestly unfounded or excessive may be subject to a reasonable fee to cover our administrative costs in providing you with the necessary details.
• You have the right to ask us to provide you with a copy of the Personal Data we maintain about you, including a machine-readable copy of the Personal Data that you have provided to us.
• You have the right to ensure the Personal Data we hold about you is up to date and accurate.
• If you have given direct consent to us (or indirectly via the Client) to process any of your Personal Data you may withdraw that consent at any time, and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
• You have the right to opt-out of receiving emails from us at any time. You can do this by managing your privacy settings in the link contained in the footer of any email you may receive from us. You can also opt-out via our data privacy contact form. Please note that if you opt-out of receiving Mention Me emails:
  • we will not be able to send you any rewards or offers you may be entitled to; and
  • you will not be automatically opted-out of any other communications you may have opted to receive from the relevant Client. You will need to inform the Client directly if you wish to opt-out of their direct communications.
• You have the right to request that the Personal Data we hold about you be erased and/or request that the processing of that data be restricted, or object to such processing.
• You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place. In the UK, this is the Information Commissioner’s Office (https://ico.org.uk/). We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.

If you would like to exercise any of the rights listed above, you may submit a request to us via our data privacy contact form or by post to 20-22 Wenlock Road, London, N1 7GU.

When we act as a Data Controller, if you are located in the EEA, Switzerland or the United Kingdom, we only process your Personal Data where we have a legal basis to do so. The legal bases we rely on include:

• Necessary to perform a contract. We will process your Personal Data where it is necessary to give effect to a contract between you and us, for example when you subscribe to the Services, or otherwise accept our Terms and Conditions.
• Necessary for compliance with a legal obligation to which we are subject. We may process your Personal Data where we are required to do so to comply with our legal obligations, for example to comply with tax and accounting obligations or to comply with a search warrant or court order.
• Necessary for a legitimate interest that we pursue. Where we or a third party have a legitimate interest in processing your Personal Data, we may do so provided that our interest is not overridden by your rights and interests. We may rely on this legal basis to, for example, keep business records, respond to unsolicited communications from you, assert our legal rights and obtain professional advice.
• Consent. We may also process your Personal Data on the basis of consent in some circumstances. For example, we may ask you to consent to our use of cookies and similar technologies or to sign up to direct marketing. You may withdraw your consent at any time by contacting us.

We may Process the following Personal Data about you:

• Your email address;
• Your name;
• Your billing address and postal address;
• Your date of birth;
• The order details and order history of purchases of goods/services you have made with the Client;
• Details of your interactions with our clients (if relevant);
• Details about whether you have referred someone and how you referred them (if you are also a member of a referral programme with that Client);
• Purchase history, product interests, preferences, feedback, and survey responses; and
• Social media and content-sharing platform accounts and links (including but not limited to Facebook, Twitter, Instagram, Snap, YouTube, Vimeo, TikTok and Pinterest), including any access to your accounts that you have made public, including posts, analytics, etc., as well as any content posted and made publicly available on such platforms.

Please do not include any sensitive information such as government IDs, health data or financial data in your communications with Mention Me or our support agents.

If you are entitled to receive commission then our third party processor will ask you to provide payment details, payment method details and other financial and billing information and in addition it will also process payment history.

As is true of most websites, we also automatically gather information about your computer such as your IP address, browser type, referring/exit pages and operating system. When you visit our hosted-pages, we also use cookies to identify you when you come back to the site. For more information on the cookies we use, why we use them and more information about cookies generally, please see our Cookie Policy.

We will process this information as a Data Controller.

The above data is either:

• collected from you by us or our Client, or one of our Client’s partners so that we can operate the service for the Client or our Client’s partners;
• received directly from you if you have entered it into our registration page or if you have provided it to one of our processors; and/or
• Obtained from public information on a social media profile.

We use your data for the following purposes:

• To assess your suitability to be invited to join a Client’s influencer programme and invite you to register to apply to become an influencer or brand ambassador;
• To facilitate the Client’s approval process of prospective influencers;
• To communicate with you in connection with an influencer programme and otherwise assist you with joining a Client’s influencer programme;
• To manage a Client’s influencer programme which shall include fulfilment of commission, rewards or otherwise payments and monitoring your performance against any campaign to ensure compliance with any Client and Mention Me terms and conditions; and
• To prevent and detect fraud.
• To review your social media profile across our client base to allow us to better assess your suitability to be invited to join a Client’s influencer programme; and
• To invite you to register to apply to become an influencer or brand ambassador.

We take measures to delete your Personal Data or keep it in a form that does not permit identifying you when this exceeds the retention period agreed with our Clients, or the information is otherwise no longer necessary for the purposes for which we process it, unless we need to retain certain information as required by law, including to comply with tax requirements, or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse or enforce our Terms and Conditions. When determining the specific retention period, we take into account various criteria, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the relevant statute of limitations.

If you would like details of any retention periods which may apply to you, please contact us via our data privacy contact form.

In the ordinary course, we will only ever share your data with our Clients or, on a confidential basis, with our own carefully selected Processors who are directly involved in delivering the Services, such as hosting our platform and assisting with sending emails to our Client's customers, referees and influencers. These processors may include cloud service providers, AI providers, analytics partners and influencer marketing programs, where applicable. We only allow our processors to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on processors relating to ensure they can only use your Personal Data to provide the Services to us and to you. We may also share Personal Data with external auditors, accreditation and the audit of our accounts.

We never sell or give your personal information to third parties to use for their own purposes.

We may also disclose or transfer your Personal Data:

• as required by law. We may disclose your Personal Data to third parties if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies. We also reserve the right to disclose your Personal Data that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Services and any facilities or equipment used to make the Services available, or (v) protect our property or other legal rights, including to enforce our agreements, or the rights, property, or safety of others.
• when we (or our Client) believe in good faith that disclosure is necessary to protect our rights, protect your safety or the rights and safety of other third parties (including other Mention Me users), investigate fraud, or respond to a government request.
• to a third-party buyer or seller in the event that Mention Me is involved in a merger, acquisition, debt financing or sale of all or a portion of its assets, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets..
• to any other third party with your prior consent to do so.

Information we hold about you is stored and processed principally in the Mention Me platform. The Mention Me platform is hosted in a secure data centre within the European Economic Area (EEA). Please see the section ‘Customer Service Support and Use of Third-Party Service Providers’ for information on when your data is transferred outside of the EEA. Your information may be shared with our carefully selected processors who are directly involved with the delivery of the Services but such sub-processors shall only process Personal Data in the EEA and otherwise in countries which have an adequate level of protection from a data protection perspective. In particular, we process your data in France, Ireland and the UK.

In the event that the processing of your Personal Data at any time requires it to be transferred to and/or stored at or accessed from a destination outside the EEA, we will take all steps reasonably necessary to ensure that your data is treated securely, in accordance with this policy and safeguarded in accordance with all applicable legislation. In particular we will rely on (i) an EU Commission, UK or Swiss government adequacy decision, (ii) contractual protections for the transfer of your Personal Data, or (iii) another valid data transfer mechanism. If you are located in Europe, you may contact us as specified below for more information about the safeguards we use to transfer Personal Data outside of Europe.

We have appropriate security measures to prevent Personal Data from being accidentally lost, or used or accessed unlawfully. We limit access to your Personal Data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

You have the right to object at any time to the processing of your personal information. You can make this objection to us via our data privacy contact form.

• You have the right to access any Personal Data we hold about you. Any request which is manifestly unfounded or excessive may be subject to a reasonable fee to cover our administrative costs in providing you with the necessary details.
• You have the right to ask us to provide you with a copy of the Personal Data we maintain about you, including a machine-readable copy of the Personal Data that you have provided to us,
• You have the right to ensure the Personal Data we hold about you is up to date and accurate.
• If you have given direct consent to us (or indirectly via the Client) to process any of your personal information you may withdraw that consent at any time.
• You have the right to opt-out of receiving emails from us at any time. You can do this by managing your privacy settings in the link contained in the footer of any email you may receive from us. You can also opt out via our data privacy contact form. Please note that if you opt-out of receiving Mention Me emails:
  • we will not be able to send you any rewards or offers you may be entitled to; and
  • you will not be automatically opted-out of any other communications you may have opted to receive from the relevant Client. You will need to inform the Client directly if you wish to opt-out of their direct communications.
• You have the right to request that the Personal Data we hold about you be erased and/or request that the processing of that data be restricted.
• You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place. We would, however, appreciate the chance to deal with your concerns before you approach a supervisory authority, so please contact us in the first instance.

If you would like to exercise any of the rights listed above, you may submit a request to us via our data privacy contact form or by post to 20-22 Wenlock Road, London, N1 7GU. You may also submit a request directly to the relevant Client in accordance with the procedures outlined in their privacy policy which will be available on their website.

When we act as a Data Controller, if you are located in the EEA, Switzerland or the United Kingdom, we only process your Personal Data where we have a legal basis to do so. The legal bases we rely on include:

• Necessary to perform a contract. We will process your Personal Data where it is necessary to give effect to a contract between you and us, for example when you subscribe to the Services, or otherwise accept our Terms and Conditions.
• Necessary for compliance with a legal obligation to which we are subject. We may process your Personal Data where we are required to do so to comply with our legal obligations, for example to comply with tax and accounting obligations or to comply with a search warrant or court order.
• Necessary for a legitimate interest that we pursue. Where we or a third party have a legitimate interest in processing your Personal Data, we may do so provided that our interest is not overridden by your rights and interests. We may rely on this legal basis to, for example, keep business records, respond to unsolicited communications from you, assert our legal rights and obtain professional advice.
• Consent. We may also process your Personal Data on the basis of consent in some circumstances. For example, we may ask you to consent to our use of cookies and similar technologies or to sign up to direct marketing. You may withdraw your consent at any time by contacting us.

We may hold the following personal data about you:

• Your email address;
• Your first and last name;
• The details of any content you have downloaded;
• Details of your visits to our website; and
• A record of any correspondence between you and us.

As is true of most websites, we also automatically gather information about your computer such as your IP address, browser type, referring/exit pages and operating system. When you visit our hosted-pages, we also use cookies to identify you when you come back to the site. For more information on the cookies we use, why we use them and more information about cookies generally, please see our Cookie Policy.

We will receive some or all of the above data directly from you if you have:

• submitted it to us via our website when completing a contact form;
• submitted it to us when downloading content from our website;
• submitted it to us when communicating with us through our website chat feature; or
• submitted it to us when attending one of our hosted events.

We may also receive certain of the above data from one of our 3rd party partners if you have submitted it to them when downloading any of our content that they publish on our behalf.

We may also receive some or all of the above data from our 3rd party partners.

We may use the above data:

• To email you specific content you have requested;
• To keep you up to date with developments at Mention Me and to send you marketing communications we think you may be interested in, unless you have opted-out of receiving such messages. You can opt-out at any time by Unsubscribing from Mention Me, or by clicking the unsubscribe link in the footer of any email you receive from us;
• To respond to any customer service enquiries; and
• To monitor and analyse traffic to our website and website performance.
• To allow us to better understand our website visitors
• To identify potential business leads and enhance our marketing efforts

We hold and process all of the above data as Data Controller either because you have expressly consented for us to do so, or because it is in our legitimate business interests to process it for the purposes specified above.

As Data Controller, we are responsible for keeping your data secure and processing it in accordance with applicable legislation.

We won’t process your data for any longer than is reasonably necessary for us to do so for the purposes specified above. Specifically:

• If you have indicated to us that you are a consumer or a sole trader, we will not send you emails other than those you expressly solicit from us and we will then delete your data;
• If you have not opted-out of marketing communications from us, but you have also not responded to an email after 12 months of being on our marketing list, we will no longer send you emails unless you expressly request us to;
• If you have opted-out of marketing communications we will no longer send you emails and we will retain a copy of your data solely for the purposes of ensuring you are no longer sent marketing communications.

We will only ever share your data, on a confidential basis, with our carefully selected Data Processors who we use in connection with the sales and marketing operations of our business. We will never sell your data to third parties.

In exceptional circumstances, we may disclose your data:

• as required by law.
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the rights and safety of other third parties, investigate fraud, or respond to a government request.
• to a third-party buyer or seller in the event that Mention Me is involved in a merger, acquisition, or sale of all or a portion of its assets.
• to any other third party with your prior consent to do so.

Information we hold about you is stored and processed on Mention Me’s secure servers and may be shared with and stored by our carefully selected Data Processors who we use in connection with sales and marketing operations of our business.

The processing of your data may involve it being transferred to and/or stored at or accessed from a destination outside the European Economic Area (EEA). In such circumstances, we will take all steps reasonably necessary to ensure that your data is treated securely, in accordance with this policy and safeguarded in accordance with all applicable legislation.

You have the right to object at any time to the processing of your personal information. You can make this objection to us via our data privacy contact form.

• You have the right to access any information we hold about you. Any request which is manifestly unfounded or excessive may be subject to a reasonable fee to cover our administrative costs in providing you with the necessary details.
• You have the right to ensure the personal information we hold about you is up to date and accurate.
• If you have given consent to us to process any of your personal information you may withdraw that consent at any time.
• You have the right to opt-out of receiving emails from us at any time. You can opt-out at any time by Unsubscribing from Mention Me, or by clicking the unsubscribe link in the footer of any email you receive from us.
• You have the right to request that the personal information we hold about you be erased and/or request that the processing of that data be restricted.

If you would like to exercise any of the rights listed above, you may submit a request online to us or by post to 20-22 Wenlock Road, London, N1 7GU.