Who we are?
Modern Agency SAS, which trades as “Lefty”, is a simplified joint stock company incorporated under the laws of France (societe par actions simplifiee) registered at the Trade and Companies registry of Paris under the number 810 844 399, based in France, with its headquarter is located 48 rue Montmartre, 75002 Paris, France (“Lefty”, "we", "us" or "our").
Lefty manages a platform of social media influencers, talents and VIPs (together, “Influencers”) that connects brands to social media content creators. Lefty enables brands to find, manage and pay content creators, and creators to collaborate with brands on creative projects of their choice. Lefty is an independent company, not associated with any social media sites.
This is our Privacy Notice for Influencers. Please read this Privacy Notice to ensure you are aware of how and why we use your personal data and how we comply with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and all other applicable data protection laws (together, “Data Protection Laws”).
What we do?
Lefty collates publicly available information about Influencers and collects information about individuals who may use our platform in their capacity as an Influencer (to the extent such information is obtained from you, “you” or “your”). In connection with Lefty’s services (“Services”), we make this collated personal data available to our clients on our database via Lefty’s Influencer platform (the “Lefty Platform”) which provides the ability for clients to identify, analyse and manage their engagement with Influencers.
In this Privacy Notice “GDPR” means the General Data Protection Regulation (EU) 2016/679 and “Data Protection Laws” means the GDPR and all applicable data protection laws.
Lefty respects your privacy and is committed to protecting your personal data. This Privacy Notice will inform you (i) how we protect your personal data when it is used on the Lefty Platform, (ii) of your privacy rights and (iii) how the Data Protection Laws protect you.
We act as a controller of the personal data which we obtain about you (excluding Client Stored Data, as set out below).
When a client of Lefty uses the Lefty Platform, they are able to enter information relating to Influencers into their account or you may share information relating to yourself with that client through the Lefty Platform. To the extent such information constitutes personal data under the Data Protection Laws, that information as well as that certain publicly available Influencer data for which Lefty is the controller is referred to as “Client Stored Data”. To the extent we process Client Stored Data solely in order to provide the Lefty Platform to a particular client, under the Data Protection Laws, to the extent applicable, we will act as a “processor” on behalf of that client in respect of that Client Stored Data. This Privacy Notice therefore does not apply to the processing of that Client Stored Data – for which the applicable client acts as the “controller” and is therefore responsible for obtaining all necessary consents and providing you with all requisite information as required by applicable law.
What data do we process and how is it obtained?
Personal data is any information about an individual which makes them identifiable. It does not include anonymous data – being where the identity is removed.
We collate, store and use different kinds of online personal data about Influencers which is obtained directly or indirectly from publicly available sources such as social media networks. We may also collect personal data directly from you via the Lefty Platform. Such personal data may include:
your name, age, email address and company/brand;
your account name, social media handles and any other online identifiers;
posts or messages which you have shared publicly on social media; and
any other information you make public.
How is your personal data used?
We only use your personal data to the extent permitted by applicable laws. We use your personal data where it is necessary to pursue our legitimate interests which is to provide our services to our clients. Your interests and underlying rights do not override such interests.
The Lefty Platform may benefit Influencers by facilitating connections with brands to enable such brands to expand such Influencer’s presence in the marketing environment. This in turn allows Influencers to enhance their specialisms and expertise. Influencers can also engage us to be included on the Lefty Platform.
The Lefty Platform therefore provides a mutual benefit to both brands and Influencers by empowering each to build important and strategic relationships for their shared benefit. Further, the Lefty Platform provides wider public benefit by enabling the development of and insight into the wider Influencer marketing environment.
Your personal data may also be used (i) where you have provided consent to the processing (subject to your withdrawal at any time), (ii) where it is necessary for us to comply with a legal obligation, or (iii) where it is necessary to perform a contract.
For what purpose will your personal data be used?
We process your personal data to enable users of our Lefty Platform to identify, analyse and manage their engagement with Influencers. As above, we also use your personal data to enable us to connect you via the Lefty Platform with clients and brands.
The Lefty Platform provides tools for the analysis of Influencer behaviour, preferences and interests as well as determining their relevance, engagement and influence reach. This activity may be determined as “profiling” under Data Protection Laws. To the extent Lefty's processing does constitute “profiling” under Data Protection Laws, you have the right to opt out and object to our processing of your personal data for such profiling purposes – see below. If you have any questions or concerns, please reach out to legal@the-independents.com.
Opting out
In certain circumstances you may have the right to request that we stop processing your personal data. To seek to exercise any such right, please email contact@lefty.io. Lefty reserves the right to refuse any such request to the extent permitted by applicable law.
Potential disclosures of your personal data
The main ways in which we may share your personal data are as follows:
to our clients using the Lefty Platform;
to our group companies;
to third party service providers providing us with IT and hosting related services; and
to our professional advisers or any other persons to whom we are under a legal, professional or contractual duty to disclose.
Where a disclosure needs to be made to a third party, we will use our reasonable efforts to ensure that such persons respect the security of your personal data and Data Protection Laws. For certain clients and where applicable in their capacity as a “processor” of any data “controlled” by us, we request Data Protection Agreements to ensure they adhere to Data Protection Laws in respect of the Lefty Platform.
International transfer of personal data
Any personal data we collect may be transferred from time to time to throughout the world – to our group personnel or third parties. Further, the Lefty Platform may be accessed anywhere in the world, including countries which may not have equivalent data protection laws.
Where we transfer your personal data outside of the EEA to countries which do not ensure adequate protection of personal data, we seek to use specific contracts approved pursuant to Data Protection Law. This requires such parties to protect your personal data to the standards required in the European Economic Area pursuant to the GDPR. To the extent we seek to rely on another basis for safe transfer of your personal data outside of the EEA, we will keep you updated by way of an update to this Privacy Notice.
Data security
We operate appropriate security measures designed to prevent accidental or unauthorised loss or access to your personal data. Further, we restrict access to your personal data to only those persons who have a business need to know. Persons processing your personal data on our behalf will only process your personal data pursuant to our instructions and are subject to duties of confidentiality.
Data retention
We only retain your personal data for as long as necessary to fulfil the purposes for which it was obtained. For this we consider the amount, nature and sensitivity of the applicable personal data, as well as the potential risk from unauthorised use or disclosure, the purposes for which we process your personal data, whether those purposes can be achieved by other means and any other applicable legal requirements.
Your legal rights
In certain circumstances, you may have specific rights under Data Protection Laws in respect of your personal data, including:
To request access to your personal data – enabling you to obtain a copy of the personal data we hold about you in order to check it is being lawfully processed.
To request correction of your personal data – enabling you to have us correct any incomplete or inaccurate data we hold about you.
To request erasure of your personal data – enabling you to have your personal data deleted where there is no good reason for us continuing to process it and where we are lawfully able to comply with your request.
To object to processing of your personal data – in particular where we rely on a legitimate interest you consider it impacts your fundamental rights and freedoms or constitutes “profiling”.
To request restriction of processing of your personal data – enabling you to ask us to suspend the processing of your personal data in certain scenarios.
If you wish to exercise any of these rights, please email contact@lefty.io. Lefty reserves the right to refuse any such request to the extent permitted by applicable law.
Data requests
You will typically not be required to pay a fee to access your personal data or exercise any of your rights. However, we may be permitted to charge a reasonable fee or refuse to comply with your request to the extent your request is unfounded, repetitive or excessive. We aim to respond to all legitimate requests within one month.
Privacy practices of third parties
This Privacy Notice only considers our collection, processing and use (including disclosure) of your personal data. Our clients and other third parties may have access to your personal data and use it in other ways in accordance with their own privacy practices. We encourage you to familiarize yourself with the privacy statements provided by any platform you use to publish any data.
Please note that our services may use the YouTube API and YouTube’s developer terms require us to notify you that our services use YouTube API Services (i.e. data from YouTube) and to link to the Google Privacy Policy
You can revoke user access on the Google Security Settings Page
Please also see YouTube Terms of Service
Changes to this Privacy Notice
Please note that we continually review this Privacy Notice and it is updated from time to time. Please be sure to check frequently for any updates.
Further assistance
Please contact legal@the-independents.com to the extent you have any questions regarding this Privacy Notice.
You may have the right to make a complaint at any time to the applicable supervisory authority which regulates the processing of personal data in the country in which you are located. However, we would appreciate the opportunity to deal with any concern before you approach such supervisory authority and welcome you to contact us at legal@the-independents.com in the first instance.
Updated: 16 May 2023