PRIVACY POLICY | THE ACE AGENCY

II. PRIVACY POLICY THE ACE AGENCY

THEACE LTD: Processing personal data of (potential) content creators

THE ACE agency. (THE ACE or we/us/our) maintains a large network of leading and authentic digital content creators that we may connect to our customers who have brand portfolios in the beauty, fashion, lifestyle and food industry.

In order to connect you to the marketing portfolios of our customers, we need to process certain personal data of you. You may be an content creator with whom we now work with, or have worked with some time ago, or with whom we would like to work with in the future. In any case, your privacy is highly important to us. In this Privacy Policy we will inform you about the way we process your personal data when you are an content creator, former content creator or potential content creator in our network. When processing your personal data, we make use of our internal THE ACEPlatform, where we store information that we may receive from you, obtain from public sources or receive from third parties upon your consent. It is important that you read and understand this Privacy Policy, so you are able to make informed decisions and genuine choices about the data that we process.

1. To whom does this Privacy Policy apply?

This Privacy Policy is applicable to you when you are an content creator in our network. This is the case if you are or have been involved in digital content creator marketing campaigns with us. Another possibility is that you are in our network because you are an active professional digital content creator with whom we do not yet have a contractual relationship, but we may like to work together with you in the future. In that case you are a potential content creator.

When you are an content creator, we may obtain information about you via your public profile on social media or via your public website(s). Also, we may have received information directly from you or your agent/management in relation to our contractual relationship. We may also obtain information from third parties, such as social media channels or other digital service providers on the effect of your posts. When you are a potential content creator, the information that we process originates from your public social media profiles or your public website(s) or directly from you or your agent/management.

2. Who is the data controller?

THE ACE is the data controller for the processing of your personal data under the applicable data protection laws.

3. What types of personal data do we process?

We may process the following types of personal data from you:

(a) Personal data of (former) content creators. The personal data we process of our content creators includes your name and address data, gender, date of birth, your public profile photo from social networks, e-mail address, phone number, social media accounts and/or website, account name, nickname, information about preferences, information from your agent or manager if applicable, amount of followers, estimated engagement on social media accounts and assumed target groups. Next to that, the personal data we process includes the details of arrangements made between you and THE ACEincluding start and end date of agreements made, bank details, social security number, Chamber of Commerce number, information that you (or your agent/manager) provide us in the course of our relation and impressions on your social media accounts relating to marketing posts (including the amount of views, types of followers, age groups etc.).

(b) Personal data of potential content creators. The personal data we process of the potential content creators in our network includes your name and address data, gender, date of birth, your public profile photo from social networks, e-mail address, phone number, social media accounts and/or website, account name, nickname, information about preferences, information from your agent or manager if applicable, amount of followers, estimated engagement on social media accounts and assumed target groups. If you or your agent/manager has been in contact with us, we may process the data that has been provided to us in this respect.

The aforementioned types of personal data may originate from various sources. We may process personal data that we have found on your public profile on social media or your public website to the extend you have made this information public intentionally and not solely for private purposes. When you are an content creator or former content creator we will process personal data that we have obtained in connection with our cooperation. This data may originate from your agreement with us, from your social media profile(s) or website(s) and from information you (or your agent/manager) provided to us.

4. What are the purposes for the processing of your personal data?

We may process your personal data for various purposes:

When you are a (former) content creator, we may process your personal data for the following purposes:

1. Maintaining the administration of our network of (potential) content creators;

2. Approaching you for new collaborations;

3. Making propositions for our customers;

4. Improving our services towards our customers by market analysis, identification of reach and target groups;

5. Maintaining contact, handling enquiries, complaints and disputes;

6. Compliance with applicable laws and regulations;

7. Contract management;

8. Rolling out marketing campaigns in collaboration with the content creator;

9. Performance of contracts with content creators;

10. Auditing the effect of a marketing campaign, measuring impressions.

When you are a potential content creator, we may process your personal data purpose 1 to 6 of the above.

We will not further process your personal data for other purposes than mentioned in this Privacy Policy.

5. What are the applicable legal grounds for the processing of your personal data?

We may only process your personal data when there is a legal ground. When you are an content creator, we will need to process your personal data for the execution of the agreement that we will have with you. Also, we may ask your consent for certain data processing activities such as auditing the effect of a marketing campaign. We may furthermore process personal data of our content creators and of potential content creators based on our legitimate business interest to the extent such interest is not overridden by your privacy interests or fundamental rights and freedoms. Where required, we may process your personal data to meet with our statutory obligations.

6. Consent for sharing additional social media data

If you are an content creator, we will ask your consent for sharing specific information in relation to (the reach of) your posts, weblogs and vlogs with us. When you give your consent, you allow social media channels such as Facebook and other parties, like Google Analytics, to provide data relating to the amount of views or clicks and other aggregated information about your followers or website visitors (e.g. age, location, interests, language) in relation to your posts or website content. The information we receive is not attributable to individual followers or website visitors yet may contain your personal data (in any case your account name or website URL). The parties providing such information will remain data controllers in relation to the personal data they will process in this respect. THE ACE will only be the data controller for the further processing of your personal data and we will only process such in accordance with this Privacy Policy.

7. How long will your personal data be retained?

We will not retain your personal data longer than necessary for the purposes for which we have obtained your personal data. In principle we may retain your personal data up to a maximum of two years upon the ending of our business relationship, unless we are required to retain your personal data to live up with a statutory obligation.

8. Who has access to your personal data?

Persons working at or on behalf of THE ACE may have access to your personal data on a need-to-know basis. Next to that, THE ACE may involve third party service providers who will act as a data processor on our behalf. THE ACE selects its service provides with due care and makes all necessary arrangements with these third parties. In any case, THE ACE will enter into a data processing agreement which includes arrangements on data security to protect your personal data against data breaches.

THE ACE may provide certain personal data to its customers in order to provide them with business propositions or in relation to a marketing campaign of a customer that you participate in. When our customers would further process your personal data, they would do so for their own purposes acting as a data controller. The terms and policies of our customers may apply to such data processing activities.

THE ACE may provide your personal data to competent authorities upon their request to the extent legally required or to the extent this would be necessary to defend DIA's rights in legal proceedings or investigations.

9. Are your personal data processed outside the EEA?

Our third party service providers may be located in countries outside the European Economic Area (EEA) which may not offer an adequate level of protection of personal data. In order to protect your personal data and to live up with our statutory obligations we shall enter into a data transfer agreement on the basis of the Standard Contractual Clauses as approved by the European Commission prior to engaging service providers outside the EEA.

10. How is your personal data secured?

We will exercise due care when dealing with your personal data. Amongst other things, this means that we will adopt appropriate technical and organizational measures to secure and protect your personal details against loss and unlawful processing. We protect our systems and applications according to the applicable standards for information security and we also make data processing agreements with our service providers which include obligations to implement adequate security measures.

11. Your rights

You have certain rights relating to the processing of your personal data. You may at any time, with reasonable intervals, exercise your right of inspection of your personal data. Upon your inspection, you may request us to correct or delete your personal data when the data is incorrect or excessive. To the extent your personal data is being processed based on your consent, you may withdraw your consent at any time. In order to exercise your rights please contact us using the contact information set out in this Privacy Policy. We may ask you in response to your request to identify yourself. Like any data subject, you will always have the right to issue a complaint with the competent data protection authority in case of violation of the applicable data protection laws and regulations which affects your privacy. The Data Protection Act 2018 is the UK's implementation of the General Data Protection Regulation (GDPR).

12. Contact

If you have any questions concerning the manner in which we process your personal data, about this Privacy Policy, or you wish to invoke your rights,

you may contact us at hello@theaceagency.co

This Privacy Policy may be modified from time to time. We encourage you to check this Privacy Policy regularly so that you are aware of any changes.

This Privacy Policy was last updated on May 2023.

II. PRIVACY POLICY THE ACE SHOP

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from theaceagency.co (the “Site”).

PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

- “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers , email address, and phone number. We refer to this information as “Order Information”.

When we talk about “Personal Information” in this Privacy Policy, we talk both about Device Information and Order Information.

HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

- Communicate with you;

- Screen our orders for potential risk or fraud; and

- When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Wix to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.wix.com/about/privacy We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

BEHAVIOURAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

- Facebook: https://www.facebook.com/settings/?tab=ads

- Google: https://www.google.com/settings/ads/anonymous

- Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

DO NOT TRACK

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

YOUR RIGHTS

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.

DATA RETENTION

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

MINORS

The Site is not intended for individuals under the age of 16.

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at hello@theaceagency.co or by mail using the details provided below: